National Statement of Expectations

Introduction

The National Statement of Expectations for Supported Housing (NSE) was finally published on 20 October 2020, five years after the 2015 Comprehensive Spending Review suggested regulatory and oversight changes were needed, although in 2018 the government announced that housing costs for supported housing would continue to be funded by Housing Benefit.

The NSE has been developed in collaboration between the Ministry of Housing, Communities and Local Government (MHCLG) and the Department for Work and Pensions (DWP) with input from local councils and the supported housing sector.

We are confident you will have read it and understand the content; what good supported living looks like, ensuring the accommodation is safe and of good quality, collaborative working to ensure local demand is met and that providers offer value for money.  The latter is the focus of our attention here as we feel that this is a potential risk to the sector.

The guidance states that “Supported housing accommodates some of the most vulnerable people in our society; it is, therefore, essential that it is safe, of good quality, meets residents’ needs and fits with the local community. It must also provide value for money for the resident, commissioner, and taxpayer.

The quality ultimately determines outcomes – higher quality means individuals are more likely to experience better outcomes, whether that means successfully living independently, navigating and staying out of crisis or managing their health effectively. This not only results in a better quality of life for residents but can also support more effective use of resources elsewhere for public services and local councils”.

Working collaboratively is crucial. We would encourage providers to engage with their local council to demonstrate the safety, quality and value of their service.

Risks

While the guidance is suggestive of better outcomes for residents being afforded high quality and safe accommodation it also encourages local authorities to ensure that costs are reasonable, transparent, comparable and represent good value for money.  This, superficially, is understandable, and we absolutely agree that supported housing should be value for money, however, it should be value rather than cost that is examined when applying this approach.  Our fear is that local authorities may feel obliged to place downward pressure on management, maintenance and service costs to levels which compromise the long-term sustainability of much required supported housing services.

It seems that controlling the enhanced housing management costs is particularly highlighted and we would agree that it is important that care should be taken in this regard.  Again, though, we fear that restrictions may be placed on genuine providers who are generating genuine value to the tenants and government.

Although not directly related to the NSE you should also be aware that the Department of Work and Pensions (DWP) Housing Benefit circular (A10/2020), was updated and issued on 10 February 2021.  The purpose of the guidance was to inform that the DWP was aware that some local authorities were not referring some rents in supported housing to the Rent Officer (RO) because they deemed them to be reasonable.  Staff were remined that where the landlord is not a registered provider of social housing then the rent should be referred to the RO, irrespective of whether they deemed it to be reasonable.  This indicates that there may be some local authroities that have not been doing this, and those that have not are likely to experience some subsidy loss thus applying pressure on their own finances.

Coupled with local authorities being advised to take steps to ensure that the supported living accommodation is providing value for money, as part of the NSE, it seems that there is a real risk of rent and service chages coming under increased scrutiny.

Mitigation

We have 20 years of experience in helping providers of supported housing to review their charges and service delivery to give them and local authorities assurances that charges are both transparent and robust.

Considering the potential additional scrutiny that the NSE leans towards we would suggest that this is an ideal time, if not vital, for organisations to review service delivery models and existing rent and service charges.  By doing so risks can be mitigated.

By way of example, one of the latest cases we have worked on highlighted that some charges needed to be optimised and the others were, in fact, being overcharged.  After our review we were able to advise on how costs and resources could be pooled and how a greater allocation of income could be directed to business support.

The exercise insured that the organisation is in a much better position and prepared for any detailed scrutiny of charges.

For independent and experienced help in reviewing your rent and service charges and service delivery model please email us at info@supportsolutions.co.uk