Moving Supported Housing Forward: the unfinished business of “Funding Supported Housing”
This Briefing intends to update you on the UK Government’s very brief Interim Response to the “Funding Supported Housing” Consultation submissions made by many of you reading this.
It looks at the NHF’s recent discussion paper on the future of “Long-Term Supported Housing” and looks to reframe some of the assumptions therein.
It identifies better definitions of Supported Housing as alternatives to 2 of those proposed by the UK Government.
It comments on how Supported Housing might be funded by a “Supported Housing Rent” under Universal Credit when Housing Benefit is abolished, presumably in 2022.
It comments on the need for a new regulatory framework for Supported Housing and its relationship to the generation of value by Supported Housing providers.
The scope of this Briefing applies to England only in the context of the recent UK Government consultations on the future funding of Supported Housing. However the models we propose may also be applicable in devolved administrations.
Interim Response to Consultation
On 3rd April 2018 the UK Government published an interim response to the “Funding Supported Housing” consultations on Short-Term Supported Housing and Sheltered and Extra Care Housing. You can see this here. The UK Government has promised a full response during the summer. Some 738 consultation responses were received; 304 responses in respect to Sheltered and Extra Care Housing and 434 responses to the consultation on so-called Short-Term Supported Housing.
In respect of Sheltered and Extra Care Housing the UK Government identified that responses focused on certain key themes:
- We should not be too prescriptive in how Sheltered and Extra Care Housing is defined;
- Sheltered and Extra Care Housing providers should be entitled to full cost recovery of the housing and accommodation based additional needs costs that they genuinely incur
- That the true costs of meeting these additional needs, and the impact of change, should be tested/piloted.
In respect to so-called Short-Term Supported Housing the UK Government identified that peoples’ responses are focused on a number of key themes.
- The definition “Short-Term Supported Housing” is inappropriate;
- The ring fence for the funding of this form of accommodation should be retained permanently;
- That the UK Government should entirely revise the model.
These very general themes are very much in keeping with the thinking we’ve developed with the published Briefings and public Events we’ve held late last year and early this year. But what is critical is the detail of the UK Government’s response, which we’re told we can expect this summer.
Developments in the Future Funding of “Long-Term Supported Housing”
The context behind the issue to address so-called “Long-Term Supported Housing” is its virtual omission from the UK Government’s second consultation on the Future Funding of Supported Housing. Within that document of 54 pages a mere 5 paragraphs were devoted to “Long-Term Supported Housing”. We did learn however, that it would continue to be funded from within the Universal Credit system.
The NHF has produced a discussion paper on the future funding of “Long-Term Supported Housing”, which you can see here. We also comment critically on that and propose a distinctly different structural and values-based approach to that proposed by the NHF.
In the same way we challenged the appropriateness of the term “Short-Term Supported Housing” we believe the term “Long-Term Supported Housing” is inappropriate and should be replaced with the term “Intensive Supported Housing”. This is partly to do with our view that identifying different types of supported housing by timeframe is more a reflection of cost control and budget management than of the meeting of need.
Support Solutions identified “Immediate Access Accommodation” as a replacement term for so-called Short-Term Supported Housing, as identified in the UK Government’s 2nd set of consultation proposals on the future funding of Supported Housing. The Government acknowledges in its Interim Response that people have concerns about the definition.
The term “Immediate Access Accommodation” has gained traction as a consequence of our published Briefings and recent events that we delivered in late 2017 and early 2018, and was fed back to the UK Government through a variety of channels.
Within “Intensive Supported Housing” peoples’ needs can be of any duration but the point is that they’re intensive. This might be as a consequence of an addiction or as a consequence of a severe learning disability to give just two very different examples of many.
We do wonder whether the UK Government was lost for ideas in relation to how Intensive Supported Housing/Long-Term Supported Housing should be defined within its Consultation proposals. It shouldn’t have been. Back in 2016 it revised the definition in the (Social Housing Rents (Exceptions and Miscellaneous Provisions) Regulations 2016) of “Specialised Supported Housing”, which is broadly defined as follows:
“Specialised Supported housing means Supported Housing-
(a) Which is designed, structurally altered, refurbished or designated for occupation by, and made available to, residents who require specialised services or support in order to enable them to live, or to adjust to living, independently within the community,
(b) Which offers a high level of support, which approximates to the services or support which would be provided in a care home, for residents for whom the only acceptable alternative would be a care home,
(c) Which is provided by a private registered provider under an agreement or arrangement with-
(i) a local authority, or
(ii) the health service within the meaning of the National Health Service Act 2006(11),
(d) in respect of which the rent charged or to be charged complies with the agreement or arrangement mentioned in paragraph (c), and
(e) in respect of which either- (i) there was no public assistance, or
(ii) if there was public assistance, it was by means of a loan secured by means of a charge or a mortgage against a property.”
This has created a lot of private investment in Intensive Supported Housing (in its “Specialised Supported Housing” form) especially from pension funds.
If the UK Government adjusted the “Specialised Supported Housing” definition to allow for both public and private capital and renamed it “Intensive Supported Housing” they’d have better conceptualised what they’d improperly termed “Long-Term Supported Housing”. It’s not about a timeframe, it’s about the intensity of need, and there is much to be done to ensure that this type of Supported Housing is understood by the NHS and Social Care commissioners for what it is and can be: as alternatives to hospital and registered care and more than that.
Definitions of Different Types of Supported Housing
We don’t believe that timescale or client group should define Supported Housing; it should be defined by the nature of the needs it meets. We do think that 2 of the 3 definitions of different types of Supported Housing identified in the “Funding Supported Housing” Consultations need to be changed.
Immediate Access Accommodation: this is the term we developed to replace some of what the UK Government defined as “Short-Term Supported Housing”. The NHF subsequently suggested that “Immediate Access Accommodation” should be for a period of up to 12 weeks. The UK Government proposed that it should fall outside the funding scope of Universal Credit. It should be funded by a permanently ring fenced fund held by local authorities. Its costs are not eligible to be met through Universal Credit.
Intermediate Supported Housing: which, by definition, applies to people who don’t need Immediate Access Accommodation, although they may have come from it, and don’t need Intensive Supported Housing, although they may have come from it. The duration of someone’s stay in Intermediate Supported Housing would depend on the duration and extent of their need within a system geared towards the maximisation of managed interdependence.
Intensive Supported Housing: as defined above with the additional observation that it should also be operated within a system geared towards the maximisation of managed interdependence.
Sheltered and Extra Care Housing as defined by the UK Government’s 2nd set of Consultation Proposals and as may be amended by the Consultation responses.
Funding Housing & Housing-Based Additional Needs Costs Through Universal Credit
One of the necessary outcomes of any Consultation on the future funding of Supported Housing must be the identification of the mechanisms through which it is funded under Universal Credit. In other words, how do we fund “Supported Housing Rent”. Here we have an opportunity to simplify the system in a variety of ways.
Whoever the landlord is, be it social, private, statutory, voluntary charitable; would it not be better for there to be a simple system whereby the costs of the building are met through a banded system to take account of different cost variables? (See the “Lord Best letter“). The additional housing needs components can also be banded according to level of assessed need (low, medium or high).
This system has the advantage is of reflecting variable levels of additional need and building/property costs whilst at the same time applying established maxima to each band.
Within a Universal Credit claim Supported Housing Rent components would be therefore be awarded based on a banded regional basis to reflect the variable costs of the development and management of property in every and any given region of England. The housing based additional needs component of the housing costs could be paid on three levels: low medium and high. These are simple principles that allow for variable costs in both buildings and the needs of the people who live in them. The same approach can be replicated for Sheltered Rent where some Sheltered & Extra Care Housing residents still qualify for Universal Credit.
The housing costs of Universal Credit-eligible Supported Housing should continue to be met under Universal Credit but should be separately calculated from the rest of the claimant’s Universal Credit entitlements, exactly as is the case for Exempt Accommodation and Housing Benefit at the moment.
However, Housing Benefit won’t exist post-2022. This gives us the opportunity to identify what should be eligible for Supported Housing Rent within Universal Credit. Some components of a Supported Housing/Sheltered Rent that are deemed “ineligible” to be met through Housing Benefit may not be deemed to be “ineligible” under the new Sheltered/Supported Housing Rent, which should have 2 components:
- The regionally banded buildings component
- The housing-based additional needs component set at level 1, 2 or 3 depending on the extent of need
There should be sufficient levels of (banded) revenue to meet the variable housing and housing-based additional needs costs of Supported Housing services. Full cost recovery is the key principle here; both of the property costs and of the housing-based additional needs costs, which should be low, medium or high.
Exactly the same structure could be applied to the rents of Intensive Supported Housing and Intermediate Supported Housing. It may well be the case that the housing based additional needs component is higher in Intensive Supported Housing than in Intermediate Supported Housing but it should be identically structured.
In the case of Sheltered and Extra Care Housing, some residents will qualify for Universal Credit as a consequence of being below retirement age, including where one part of a couple falls below pensionable age. In this case the Universal Credit housing component is paid as Sheltered Rent. This is a term introduced by the UK Government in their second set of Consultation Proposals. It is intended that the Sheltered Rent be regulated by Homes England, although just less than 30% of Sheltered and Extra Care Housing is not owned or operated by housing associations registered with Homes England.
Immediate Access Accommodation, as distinct from Supported/Sheltered Housing, is to be funded according to the UK Government by a ring fenced local fund that will meet its entire cost. If there is to be a ring fenced fund at local level it should be permanently ring fenced. In the case of shire counties we believe it should be the second tier authorities (District and Borough councils) that hold the ring-fenced fund, not the County councils, as it is typically the role of second tier authorities to manage homelessness through which many referrals to Immediate Access Accommodation would come. An enhanced local authority role in regulation and of referrals to Immediate Access Accommodation, including some people with no local connection, is important.
Supported/Sheltered Housing services would have to generate high value including significant cost benefit. The providers of these supported housing services should be assessed and registered as having met the necessary regulatory framework (see below). We are not suggesting a random increase in resources for the accommodation costs of Supported Housing, rather that services that generate value are fully funded. They always cost less than they save anyway.
Enhanced Universal Credit housing payment (“Supported Housing Rent”) should be potentially payable to all types of providers, irrespective of whether they are social, statutory, voluntary, charitable or private. The point is that they have to generate value: outcomes for people, cost benefit to the public purse and wider community benefit. They have to comply with regulatory standards. We really should dispense with the absurd and discriminatory notion that peoples’ entitlements to enhanced revenue (in this case Supported Housing Rent) as a consequence of their additional needs should be dependent on the legal identity of their landlord, which is the case now with enhanced Housing Benefit that funds Intensive Housing Management.
Regulation of & Generation of Value in Supported Housing
It is definitely necessary for Supported Housing to be regulated, this is not only because some Supported Housing meets very high levels of additional need although that fact makes it ever more important.
Some Supported Housing is already regulated, for example, by the Charity Commission or Homes England (The Scottish Housing Regulator and Welsh Assembly Government in Scotland and Wales respectively). But the scope and extent of that regulation is not particular to Supported Housing. In any event, no regulatory body can claim anything like a monopoly of regulatory influence in Supported Housing. There does need to be a common regulatory framework for Supported Housing in England, administered by the infrastructure that should commission and oversee Supported Housing.
What is the sense in having different forms of regulation (and rent control) applied by different regulators? For example, Homes England is proposed to regulate “Sheltered Rent”, even though 30% of Sheltered and Extra Care Housing falls outside its wider regulatory remit.
Supported Housing (as previously defined: Intermediate Supported Housing, Intensive Supported Housing, Sheltered and Extra Care Housing but excluding Immediate Access Accommodation), should be registered with and regulated by integrated commissioning authorities with pooled budgets organised regionally within England over time.
But while we await and promote that structural change we should encourage the development of a regulatory framework and values base for Supported Housing based on the principles of value generation, not cost control. A regulatory framework and value generation model for commissioning and funding Supported Housing should be devised by the University sector, which has no bias in relation to the costs and outcomes of such a system. It should be piloted and adjusted as necessary and then passed to integrated commissioning infrastructure when it’s in place. So it would ultimately be Commissioners who would be responsible for ensuring regulatory compliance and the generation of value by Supported Housing providers using a common national (for England) regulatory standard and value generation methodology.
Times of change bring us opportunities. The first opportunity is to shape the nature of that change. Supported Housing cannot afford to exist at a remove from the NHS and wider commissioning interests. Supported Housing is a big part of the solution to the problems faced by statutory sector commissioners but a failure to reinvent it in parallel with the reinvention of integrated commissioning in England would mean a continuation of uncertainty and dysfunction. Those who look at integrated commissioning and say, “it’ll never happen” are the authors of a self-fulfilling prophecy. The need for change is undeniable; it’s the nature of that change we have to be clear about.
We think that the UK Government’s definitions of Supported Housing (excluding perhaps Sheltered & Extra Care Housing) need to be revised as we have suggested above.
As well as a need for structural change in Supported Housing and how we conceive it there is a need for a change in the values base we use to make judgments about it. The idea of “cost control” being at the forefront of how we see or judge Supported Housing is a way of putting the meeting of need below the management of a budget. Cost-benefit on the other hand is one important factor we should use in assessing whether a Supported Housing scheme generates value. Two other factors we should simultaneously and equally consider are what are the outcomes for people who live in that Supported Housing scheme and for the wider community in which it is located?
A simple banded Supported Housing Rent structure with a buildings component and an additional housing needs component can easily be made to work within Universal Credit. Supported Housing providers of whatever legal identity would only be eligible to claim it if they comply with a nationally agreed regulatory framework in England and they can demonstrate the generation of value.
Michael Patterson April 2018
© Please acknowledge the author as Michael Patterson of Support Solutions UK when the contents of this Briefing are reproduced in whole or in part (Creative Commons licence applies).
 This reflects our belief that no one is “independent”. All of us, with or without additional needs, exist in a state of managed interdependence. Providers that generate value manage that interdependence well, amongst other things.
 “Value Generation” has 3 components: outcomes for people; cost-benefit to the public purse & wider community benefit.