Funding for Supported Housing
"Funding for Supported Housing": Responding to the Consultation
This is a Briefing, not our formal response to the Consultation, although the key features of our response are visible throughout.
During the pre and post-Christmas period 2016/17 Support Solutions ran a series of 13 Briefing Events across England on "The Future Funding of Supported Housing: Responding to the Consultation". The events were very well attended and we had to rebook a number of them to meet demand.
The Consultation "Funding for Supported Housing" arose from the UK Government's announcement on 15th September 2016 of a new funding model for supported housing and the application of the Local Housing Allowance (LHA) Cap to supported housing. We predicted much of the following in our March 2016 Briefing:
- The LHA Cap will apply to the core rent and Universal Credit eligible service charge components of supported housing rents
- The Intensive Housing Management component of Housing Benefit will be quantified and devolved to "local level" from 2019/20. It amounts to £2.12bn pa.
- The devolved money should be used as the basis for a new funding model (we called it a Prevention Fund)
- A 1% annual rent reduction will apply to the core ret component of English social rents up to and including 2019/20, including supported housing (but excluding almshouses, refuges and "Specialised Supported Housing").
- The "shared accommodation rate" of LHA will not apply to people living in supported housing
- There will be no change to existing funding streams, for example, Supporting People. The devolution of the £2.12bn will be made in the context of "wider commissioning interests".
- The devolved fund will be ring-fenced and set on the basis of "current projections of future need"
- There might need to be a separate funding model for "short-term services"
So the UK Government is restricting its Universal Credit contribution to the housing costs of supported and sheltered housing to LHA levels and the rent/Universal Credit will not fund additional needs. It estimates the cost to Housing Benefit of LHA levels of core rent and Universal Credit eligible service charge for supported housing to be £2bn pa UK-wide. The component it intends to devolve (the "additional needs" or enhanced Housing Benefit part) amounts to £2.12bn and predominantly funds Intensive Housing Management. These figures come from the Evidence Review on the scale, scope and costs of supported housing that the UK Government commissioned to inform this Consultation.
The purpose of the Consultation is to identify a new funding mechanism for the additional costs of "supported housing" over and above LHA Cap levels.
The new funding mechanism will come into effect in April 2019 according to the Consultation. The enhanced Housing Benefit "pot" of £2.12bn will be devolved to "local level" and ring-fenced. The UK Government has also said that this ring-fenced money must be used in conjunction with other "local commissioners" and specifically mentions the NHS.
We believe that the lifting of the ring-fence by the UK Government should depend on an acceptable level of structural reform and regional commissioning integration in England. The fear is that stretched local authorities will be tempted to use the money to offset overhead costs or the costs of otherwise underfunded or unfunded statutory duties.
The Consultation concerns England only except for a single question on the funding of "short-term" services, which also applies to Scotland and Wales. Scotland in particular, and Wales too but to a lesser extent, have the power to put their own houses in order because they have their own governments, but will have an obvious interest in the basis upon which the £2.12bn is allocated. England does not have a national government and the response to the Consultation must look at how the English NHS and local authorities (in particular) are likely to be restructured by the UK Government.
In fact the wider context within which this Consultation sits is massively important and if we fail to see the wider context in our response to the Consultation we may miss the best and only opportunity we'll ever have to restructure the funding and commissioning of services for people with additional needs.
This Consultation is not just about the future funding of "supported housing"; it's about so much more than that.
At our Briefing Events we put forward a model to define the role of "supported housing" as a response to the UK Government's Consultation and in relation to the wider agenda around the integration of health and social care. We call this model "Community Sustainment". It provides a comprehensive response to the need for an entirely new model for the funding and commissioning of services for people with additional needs, and it does so with a firm eye on the future.
We will look at the Consultation questions (of which there are 12) in this Briefing, but we need to set out the wider context first. It should inform our responses to the questions. Our collective responses must be clear and consistent if we are to expect a coherent policy response from the UK Government.
So what is the wider context then?
Back in 2008 we had the global finance crash; governments with publicly funded services such as the NHS and "welfare state" introduced "Austerity". It is with us today, gnawing away at the fundamental structures that have been in place in the UK since WW2.
The UK Government doesn't have the money to pay for public services and welfare in the way that it historically has. It has already put in place significant reductions in public revenue, most notably for "supported housing" via the Welfare Reform Act with all of its related mechanisms such as the Spare Room Subsidy/Bedroom Tax, Benefit Cap and direct payment of Universal Credit, the 1% rent reduction on the core rents of social tenancies up to and including 2019/20, the application of the Local Housing Allowance (LHA) Cap to social tenancy core rent and Universal Credit eligible service charges, including supported and sheltered housing.
The UK Government wants to spend less public money on what we currently call "supported housing". It also wants more supported housing, and better outcomes from it.
As far as public capital funding to develop new "supported housing" is concerned we believe the UK Government will effectively abolish it (public capital funding) going forward. So how do we square the circle by producing better outcomes for people and more "supported housing" on the basis of less public investment? And why do I keep framing the words "supported housing" in inverted commas?
Well the paradigm is shifting; everything is changing. We haven't actually seen "Austerity" yet.
The UK Government intends to radically overhaul statutory sector infrastructure: we believe that it intends to divest English local authorities of direct services, both statutory and non-statutory. Non-statutory providers will provide these services with a much wider, deeper role than just "supported housing". Providers that provide everything from Intensive Housing Management (a term used in the Consultation document) up to and including some healthcare and everything in between.
Local authorities will be merged into regionally organised bodies in England comprised of the relevant parts of the NHS, Social Care, Criminal Justice, Supporting People and Public Health the funding for which will be pooled.
A regionally organised unified commissioning body will commission services from "supported housing" and other providers, except that they won't be just supported housing providers; they'll be Community Sustainment providers. And commissioning won't be undertaken on the basis of the management of cost, it'll be done on the basis of the generation of value (more about that later), which is a Community Sustainment principle. Community Sustainment, remember, is everything from Intensive Housing Management up to and including some healthcare and everything in between.
The Greater Manchester Combined Authority is an example of combined regional administration (including commissioning) in England. Think of it as a Pilot. The Scottish Government has already enacted the Public Bodies (Scotland) Act 2014, which merges Health and Social Work (referred to as "social care" in England) functions at local authority level within 32 Partnership Boards across Scotland. They will need to go a step further and pool budgets too, or they'll defeat the point of structural change.
Community Sustainment and the need for change
Segmented commissioning is only one of the fault lines in the infrastructure for providing services to people with additional needs. The other great fact of dysfunction in this arrangement is a focus on the management of cost.
Segmented, cost-based commissioning is expensive and is no longer fit for purpose. The UK Government believes that there is a lot of money going into the overhead costs of the statutory sector and that much of it would be freed up by the merging of infrastructure, the hiving off of statutory and non-statutory local services into the non-statutory sector (Community Sustainers), in the case of the NHS, the sale of estate such as large general hospitals sitting on prime development land.
Providers on the ground feel that the current system is designed to limit access to funding and services, not the other way round. Commissioners feel they have little choice but to "manage the budget". There are always exceptions of course, but things are getting worse, not better.
R Buckminster Fuller said: "You never change things by fighting the existing reality. To change something, build a new model that makes the existing model obsolete". We don't have a choice about the necessity for change but we must define its form and direction and we need to build a new model.
The UK Government wants to see a community-based healthcare system with fewer people going through it. They will depend, in England, on Community Sustainment providers (what we currently call "supported housing" and more) to provide everything for people with additional needs from Intensive Housing Management up to and including some healthcare.
Any new system such as Community Sustainment has to acknowledge that we are in the midst of paradigm shift. Paradigm shift is when the old ways of doing things don't work any more, for whatever reason, and new ways of doing things are required. The new paradigm is what we must focus on when considering our response to this Consultation. We have the opportunity, and the necessity, to create a new model; it requires new values.
If segmented commissioning and the management of budgets are the fault lines in the current commissioning paradigm then unified commissioning and the generation of value must replace them in the new commissioning paradigm.
Supported housing/Community Sustainment organisations are much about prevention and enablement. In this context the generation of value means three things:
- Outcomes for people with additional needs
- Cost-benefit to the public purse
- Wider community benefit
The 1st and 3rd bullet points should not be expressed as numbers. To do this is to submit to a paradigm that measures things entirely by how much they cost. On the other hand, the 2nd bullet point should always be expressed as numbers, because it's public money.
Supported housing/Community Sustainment providers have long been aware, not only of the fact that the benefits of prevention are financial (Google "cost benefit of prevention") but also personal and community-wide. "Supported housing" already does "Community Sustainment" but only to the extent that the current segmented commissioning/management of cost paradigm allows. We must view the Consultation and the Joint DWP/DCLG Committee Inquiry into the Consultation as the first steps in getting the new paradigm right. We need an entirely new approach with a new set of values.
I mentioned the Joint DWP/DCLG Committee Inquiry. Support Solutions was fortunate to have Margaret McKinnon, the civil servant who heads up this Inquiry, present at one of our events. It is important that the Sector is able to respond to the Joint Inquiry (closing date 3rd February) and the Consultation (closing date 13th February). Margaret was very helpful in encouraging the sector to respond and she reiterated the importance of the Sector sending clear and consistent messages to the UK Government.
Of course £2.12bn will not meet anything like the additional costs of supported housing, never mind the preventative investment required for Community Sustainment. Remember the long-term intention is for Community Sustainment, as we describe it, is for it to deliver on everything from Intensive Housing Management up to and including some healthcare. "Supported housing" is only part of Community Sustainment but "supported housing" providers will be expected to evolve into Community Sustainment providers. That's where the needs and opportunities lie.
When the ring-fence is lifted we expect England's share of the £2.12bn to be pooled with the residual £1.5bn of Supporting People funding as a second step in funding of Community Sustainment. By that time there may also be money being freed up from merged commissioning infrastructure and the transfer of local authority services into the Community Sustainment sector. The Evidence Review identifies a "conservative estimate" of £2.05bn of "other" NHS and social care funding within the supported housing sector.
Recently Norman Lamb, the Liberal Democrat Health spokesman, suggested a "Social Levy" to offset the shortfall in funding for "social care" (in other words everything from Intensive Housing Management up to and including some healthcare). This is a tax that could bring in potentially huge amounts of money to give the Community Sustainment fund the breadth and depth it'll need to deliver the necessary outcomes.
However, any tax on citizens needs to be justified to those who pay it. If people are being asked to pay more tax to support a system they already pay tax for, and is failing, they're entitled to know where the costs in the system are. The UK Government would probably see this as a necessary context for reform anyway. We hear claims that some statutory services have overhead costs of 50%. The fact that such claims are apparently impossible to substantiate or deny at the moment does make it all the more important that local authorities (and the NHS) are able to demonstrate value themselves.
The UK Government would find it politically inconvenient to state any intention to structurally reform the NHS; however, it is very likely on the agenda as a non-manifesto post re-election commitment assuming successful re-election in or around 2020. The sale of NHS estates in England particularly the large general hospitals sitting on prime land would release a lot of money. Some of which would be required for the transformation of the NHS and some of it would be required for Community Sustainment, the preventative agenda that needs to take significant pressure from the NHS.
Specialised Supported Housing
There are other relevant, but on the face of it unrelated developments. One is the redefinition of "supported housing" in England. This includes "Specialised Supported Housing" the definition of which has been tweaked by the UK Government to help further the increased development of supported housing supply as stated in the Consultation. The UK Government is looking to increase the amount of supported housing and stop providing public capital to fund it. Specialised Supported Housing is intended to replace expensive (and in the view of the UK Government) inflexibly overregulated residential care and reduce healthcare admissions and provide high-needs environments into which people can be appropriately discharged from hospital. Specialised Supported Housing is exempt from the 1% rent reduction (which is actually a 14-16% reduction when you factor in inflation up to and including 2019/20). Specialised Supported Housing is defined by the following 3 criteria:
- It should be developed without recourse to any public capital (although statutory sector agencies can make loans to develop them secured as a charge on the properties)
- The people who live in Specialised Supported Housing would otherwise require more institutional accommodation such as registered care or hospital
- Specialised Supported Housing should be developed in line with local health and social care strategic priorities.
The UK Government is looking for environments in which higher levels of need can be accommodated for less money. In short Specialised Supported Housing needs to accommodate everything from Intensive Housing Management up to and including some healthcare, and engage staff qualified to perform these roles, as an essential component of the Community Sustainment agenda.
The UK Government expects to see a strong relationship between the development of Specialised Supported Housing and the structural reform of the statutory sector in this context. Any provider and/or developer who can fund and/or develop Specialised Supported Housing as a means of reducing admissions to healthcare and to reduce the length of time people with additional needs stay in the healthcare system will likely have a very busy development programme and/or a lot of Community Sustainment capacity. The costs of Specialised Supported Housing compared to inpatient care would be fractional, the outcomes better.
Specialised Supported Housing, by definition, has no public capital funding in it. The UK Government isn't intending to invest further public capital, not as a matter of routine anyway. So where's the funding for Specialised Supported Housing going to come from? The answer is private capital, predominantly from Pension Funds, which have enough capital to entirely reinvent "supported housing" development and existing stock.
Pension Funds and their representatives are actively seeking investment opportunities within the "supported housing" sector. The question is not whether supported housing developments, including both Specialised Supported Housing and "conventional" supported housing, will be privately financed but when, by whom, at what percentage return on investment and over what period?
Pension Funds have a social obligation bond placed on their investment strategies; they are the capital funders of the future. We, the "supported housing"/Community Sustainment Sector must get to know them and learn to work with them, and they with us. Increasingly experienced social housing, NHS and local authority thinkers and doers are filling the senior management roles within the agencies that represent Pension Funds.
Download our "Community Sustainment Timeline" (1st Iteration)
The Consultation Questions
Having set out in (necessary) detail the wider context behind the Consultation: "Funding for Supported Housing" we now need to focus on what the Consultation actually asks.
The Community Sustainment future I have set out in this Briefing is "written" between the lines of this Consultation. It is not set out in detail, as that would involve making commitments that might render the UK Government, or any political party, unelectable. It is, however, vital to respond to the Consultation in the wider context. If we fail to do so we miss the best and only opportunity we'll get to redefine how services for people with additional needs are commissioned, funded, delivered and "measured".
The current system is dysfunctional, expensive and not as proactive as it should be. It has to change: constant reminders on the news agenda tell us about the underfunding of "social care" (everything from Intensive Housing Management up to and including some healthcare). The current segmented commissioning infrastructure and the preoccupation with the management of cost has to be replaced by unified commissioning at regional level, a focus on the generation of value and a single pooled investment fund (not a budget) for Community Sustainment.
We also need to reframe some of the Consultation questions and to challenge some of the assumptions behind them.
I Fair access to funding, the detailed design of the ring-fence and whether other protections are needed for particular client groups to ensure appropriate access to funding, including for those without existing statutory duties.
Q1, The local top-up will be devolved to local authorities. Who should hold the funding; and in two-tier areas, should the upper tier hold the funding?
The devolved funding will be ring-fenced, which is important. Who actually holds it is less important than the basis upon which it is held. That basis is that from 2019/20 there should be no change in the use of this money and no lifting of the ring-fence until there has been sufficient progress on the health and social care integration agenda, the shaping and scoping of the new Community Sustainment "mixed social market" on an increasingly regional basis, and an audit of the overhead costs of statutory sector commissioning infrastructure.
The devolved funding should on no account be split between different statutory agencies or different parts of the same statutory agency. It should be held and used (for its current purposes) "in trust" pending the structural and cultural changes that will occur in the coming years up to and beyond 2019/20. It should not be used to support the costs of a failing system.
Q2, How should the funding model be designed to maximise the opportunities for local agencies to collaborate, encourage planning and commissioning across service boundaries, and ensure that different local commissioning bodies can have fair access to funding?
The design of the funding model has to acknowledge as its key principle value generation, which is:
- Outcomes for people with additional needs
- Cost-benefit to the public purse
- Wider community benefit
This needs to be supported by new, independently developed and verified (national) frameworks of expectation, accreditation, value generation and measurement. These are referred to later in the Consultation.
"Planning and commissioning across service boundaries" would be more effective if there were no "service boundaries" within the parameters of Community Sustainment (everything from Intensive Housing Management up to and including some healthcare). There should not be "different local commissioning bodies" for too much longer either, there should be increasingly regionally organised and unified commissioning with no distinction between the NHS (in the context of Community Sustainment), Social Care, Supporting People, Criminal Justice and Public Health.
The funding model should anticipate the pooling of the devolved funding post 2019/20 together with other existing funding and the receipts from the structural reform of the statutory sector.
Q3, How can we ensure that local allocation of funding by local authorities matches local need for supported housing across all client groups?
We believe the UK Government is correct to see the devolved funding as needing to be pooled rather than "breaking down funding between different client groups". Funding for prevention should accommodate the totality of a person's need. It should not be necessary for a provider to have to go to different commissioners to meet the needs of a single person. Subject to structural reform of the statutory sector in the future supported housing/Community Sustainment providers should be able to provide everything from Intensive Housing Management up to and including some healthcare from a single pooled budget.
It is essential to ensure that the needs of ALL people with additional needs are met, especially those who traditionally fall through gaps in service provision and those who have especially challenging needs. If we focus on the generation of value (outcomes for people, cost-benefit to the public purse and wider community benefit) as the key principle for the new funding mechanism then the greatest need receives greatest priority because meeting the greatest need generates the greatest value.
Q4. Do you think other funding protections for vulnerable groups, beyond the ring-fence, are needed to provide fair access to all client groups, including those without existing statutory duties (including, for example, the case for any new statutory duties or any other sort of statutory provision)?
We don't think that "statutory duty" is a useful definition going forward. We think that expecting local authorities to accept additional statutory duties when they routinely fail to fulfill existing ones is problematic. It has become a relative term based on resources; the eligibility bar for a statutory service is being increasingly raised in relation to perceived funding cuts. It's not about the meeting of need so much as the management of money. Lord Porter, Chair of the LGA has already dismissed the idea of additional statutory duties for local authorities. We believe that the restructuring of the statutory sector and the development of Community Sustainment model as an alternative to statutory provision would enable higher levels of need to be met whilst generating much more value.
We believe that local authorities and their statutory partners should continue to focus on the health, social care and wider integration agenda from 2019/20, whilst the ring fence on funding remains. They should collectively work with supported housing/Community Sustainment providers to scope out strategic priorities for everything from Intensive Housing Management up to and including some healthcare in the context of an increasingly unified and regionalised commissioning infrastructure. The Greater Manchester Combined Authority can be a useful Pilot to this end assuming it uses Community Sustainment principles.
All value generation, accreditation, outcomes measurement and other processes for Community Sustainment must be externally developed and verified.
II Clarifying expectations for local roles and responsibilities, including what planning, commissioning and partnership arrangements might be necessary locally.
Q5. What expectations should there be for local roles and responsibilities? What planning, commissioning and partnership and monitoring arrangements might be necessary, both nationally and locally?
There is a health and social care integration agenda underway in England as well as a move to increasingly regionalised administration. In looking at "planning, commissioning and partnership arrangements" we should bear in mind this wider agenda and move in its direction. The Scottish Government has enacted the Public Bodies (Scotland) Act 2014 that unifies health and social work commissioning at local level. The agenda in England needs to be regional with wider commissioning interests and a pooled budget.
"Supported housing" has historically been a victim of its own description when trying to take its place with commissioners, especially the NHS. It's so much more than "supported housing", it routinely does more than it's funded to do and could do so much more if it was funded to do so. Whether it's called "supported housing" (which is a limiting description) or Community Sustainment it should be central to the local/regional planning of the new funding model.
The "commissioning interests" that should be involved in planning with the supported housing/Community Sustainment sector are the relevant parts of the NHS, local authority Social Care and Supporting People, Criminal Justice and Public Health because the logical future direction is for their budgets to be pooled for Community Sustainment purposes.
Monitoring arrangements should be nationally consistent across England. "Monitoring" is a wide term and should include frameworks and processes for accreditation of (Community Sustainment) providers. The methodology for the generation of value, outcomes measurement and other monitoring systems should be externally developed and verified, preferably by appropriately experienced Universities according to a set of agreed structures and values such as those that underpin Community Sustainment.
As an aside, we think that the methodology for informing the allocations of the devolved funding at local level should also be externally developed and verified.
National consistency with some scope for regional variation is essential if we are to tackle the postcode lottery that exists in England. Unfortunately the LHA Cap reinforces the postcode lottery given the variable and inconsistent LHA levels from one local authority to another. This will have an impact on the devolved funding at local level, which has to pick up the additional costs of supported housing over and above LHA levels.
Q6. For local authority respondents, what administrative impact and specific tasks might this new role involve for your local authority?
We are not a local authority so will not be responding to this question in our Consultation response.
We think this question may be designed to give the UK Government a flavour of how local authorities are thinking about the integration agenda with the NHS. We think the UK Government will give local authorities the opportunity to progress the integration agenda. We think (and we expect) that the ring-fence on devolved funding will be kept in place until sufficient integration/restructuring has occurred. In the event that local authorities opt to maintain the status quo, or make insufficient progress in the direction of change, the UK Government may enforce change.
III Confirming what further arrangements there should be to provide oversight and assurance for Government and taxpayers around ensuring value for money and quality outcomes focused services.
Q7. We welcome your views on what features the new model should include to provide greater oversight and assurance to tax payers that supported housing services are providing value for money, are of good quality and are delivering outcomes for individuals and tenants?
These reforms in the words of the UK Government are "the first step" in ensuring that "services are as good as they can be". There is a much deeper, wider journey to follow.
The current system for funding "social care" (everything from Intensive Housing Management up to and including some healthcare) is dysfunctional at best and on the brink of collapse at worst. It is part of the "underfunding of social care", not the solution to it. It has to change.
The new funding model gives us an opportunity for transformation and it requires new values. The first of which should be the generation of value. Value generation can only be achieved when commissioning is unified and not conducted on the basis of the management of cost.
Within the context of investment in prevention and enablement, which is what "supported housing" (or Community Sustainment, in its enhanced form) does. Value generation manages cost anyway. Fewer people require access to healthcare for example.
As previously mentioned, the processes and systems associated with the generation of value such as accreditation, the value generation framework/methodology, the measurement of outcomes must be externally developed and verified and be nationally consistent across England.
IV Exploring the appropriate balance between local flexibility and provider certainty, including what other assurance can be provided beyond the ring-fence, for developers and investors to ensure a pipeline of new supply.
Q8. We are interested in your views on how to strike a balance between local flexibility and provider/developer certainty and simplicity. What features should the funding model have to provide greater certainty to providers and in particular, developers of new supply?
Certainty to both providers and developers of new supply can be achieved through certainty about revenue.
The UK Government needs to be clear about the fact that the future funding model has to meet the additional costs of private capital development and much more besides. As well as restructuring the statutory sector the UK Government's strategic ambitions include the introduction of private (Pension Fund) capital to replace public capital to develop new supported housing, in particular Specialised Supported Housing. £2.12bn pa across the UK won't be sufficient for this, hence our focus on progressive pooling of revenue into Community Sustainment and the accompanying restructuring of the statutory sector.
Again consistent national, or at the very least, regional strategies should be developed in order to inform supported housing development programmes and costs (and their impact on the future funding model) of privately funded supported housing, much of which will be Specialised Supported Housing in its various possible forms. Neither developers nor Community Sustainment providers should have to jump through different hoops in different places to achieve the same general outcomes.
Q9. Should there be a national statement of expectations or commissioning framework within which local areas tailor their funding? How should this work with existing commissioning arrangements, for example, across health and social care, and how would we ensure it was followed?
We are strongly of the view that externally verified frameworks and statements of expectation should be national in scope and should have scope for regional variation. We believe that unified NHS, Social Care, Supporting People, Criminal Justice and Public Health commissioning should occur at regional level in England and that 2019/20 should be seen as a preliminary step on the journey to merge infrastructure and to pool budgets regionally over a 10 year period from 2020.
It is important that no change is made to existing funding arrangements until the new mechanisms and structures have sufficiently developed. This includes the retention of the ring-fence until the devolved funding can be pooled with other prevention funding on the basis of statutory sector restructuring.
Q10. The Government wants a smooth transition to the new funding arrangement on 1st April 2019. What transitional arrangements might be helpful in supporting the transition to the new regime?
There should be no change to funding arrangements for 2-3 years post 2019/20 and that should be dependent on the progress of statutory sector restructuring. There must be no possibility that this funding can be used to support the costs of the existing system.
This funding, together with other funding streams and the restructuring of the statutory sector, should be used to facilitate the evolution of "supported housing" into Community Sustainment.
Q11. Do you have any other views about how the local top-up model can be designed to ensure it works for tenants, commissioners, providers and developers?
The way that "social care" is funded and commissioned needs to be totally reinvented, not just overhauled. This is about more than just a "local top-up model".
We need to see the devolution of the £2.12bn (UK wide) as being the first step in the design and implementation of a new system, which we call Community Sustainment, which is comprised of principles and approaches that the "supported housing" sector has always had the potential for. It's about non-statutory Community Sustainment providers providing preventative, enabling services to people with additional needs across the range of need including everything from Intensive Housing Management up to and including some healthcare, including end of life care. It's not just about housing and "tenants" any more. "Supported Housing" should become "Community Sustainment".
In parallel the commissioning of health, Social Care, Supporting People, Criminal Justice and Public Health should be undertaken within increasingly regionalised commissioning bodies. The Greater Manchester Commissioning Authority is an example of a potential Pilot for this approach.
The devolved funding will need to be merged with existing NHS, Social Care, Supporting People, Criminal Justice and Public Health funding and the ring-fence should not be lifted on the devolved funding until it is being pooled with other revenue as a consequence of statutory sector restructuring and there is consequently no motivation or need to offset the costs of the current system.
The Social Levy proposed by Norman Lamb MP, implemented rather differently from the way he proposes, could be a significant pump-priming boost to the Community Sustainment agenda. It could only be levied as a tax when taxpayers are clear where the costs are within the current system that presides over the "underfunding of social care". The perception is that too much is spent on the costs of the system and too little on the delivery of services. That perception should be tested by an externally developed and verified audit of the costs of the statutory sector.
In parallel with structural reorganisation of the statutory sector there needs to be the independent development and verification of new national accreditation, value-generation, outcomes measurement processes based on unified commissioning instead of segmented commissioning, a focus on the generation of value instead of the management of cost. These systems and processes should allow Community Sustainment providers to provide a continuum of services without top-heavy micro management of "outcomes".
There should be no change to the funding of "supported housing" until it becomes Community Sustainment. In the meantime, pretty much everything else about the system should change.
The UK Government needs to be mindful that the additional costs of "supported housing" over and above the LHA rate will be significantly more than £2.12bn even before the Community Sustainment agenda can begin. It has to include the revenue costs of private capital to develop the Specialised Supported Housing that the UK Government wants, unless the NHS pays it of course, which in many cases it will if it gets better outcomes for less money. There has to be some equalisation of the impact of variable LHA rates across different areas, especially where they bear insufficient relationship to local/regional socio-economic factors. If this isn't done there will be an additional impact on the devolved funding mechanism.
V Developing options for workable funding model(s) for short-term accommodation, including hostels and refuges.
Q12. We welcome your views on how emergency and short-term accommodation should be defined and how funding should be provided outside Universal Credit. How should funding be provided for tenants in these situations?
This is the only part of this Consultation that relates to Scotland and Wales as well as England. it is difficult to see why the UK Government hasn't just indicated that it will devolve a fair proportion of the £2.12bn between the 3 nations concerned based on an externally verified calculation methodology. After all, Scotland will have its own welfare budget very soon and needs to consider its own health and social care agenda. Both the Scottish and Welsh Governments will presumably look at this issue from the perspective of a national (i.e. non-UK) perspective.
We think that people in supported housing, wherever they are in the UK and whilst "welfare" remains a reserved UK Government power, should have their Universal Credit paid to their landlord or Community Sustainment provider as the default position. When both parties agree that a different arrangement should persist then that should be possible too.
However, we think the use of the term "short-term" services is anachronistic and we note that the Consultation invites our views on how such services should be defined. Putting a time limit such as "short-term" on funding for additional need is about the management of a budget more than the meeting of need. The same can be said of "eligibility criteria" which are a byproduct of segmented commissioning and negative competition between different budget holders to NOT fund services.
In Community Sustainment terms there are no "short-term" or "long-term" services, no separate funding or commissioning infrastructure, no cost-based commissioning. There is a single, regionally unified Investment Fund for Community Sustainment comprised of NHS, Social Care, Supporting People, Criminal Justice and Public Health funding, money freed up over time by statutory sector restructuring, capital receipts from the sale of some NHS estate and might also include a form of Norman Lamb's Social Levy.
Download our "Community Sustainment Timeline" (1st Iteration)
How to Fund Housing Support and Social Care Sevices Extremely informative, excellent speaker. Alison Halstead - Riverside ECHG