There is an unintended problem with the HB reform to the shared accommodation rate (SAR) and (women) fleeing domestic violence and abuse (DVA). The problem concerns move-on from a refuge to the private rented sector (PRS) as the HB change means the SAR will apply to all under-35s whereas previously it applied to under-25s.
DVA provision tends to be a 3-stage process of (a) pre-refuge outreach support; (b) refuge provision itself, and (c) a new tenancy ie move-on. Alternatively it can comprise just the refuge (b) and move-on (c), but always includes move on.
Any women without children who are moved on will be met with the SAR change unless they have been receiving support in a refuge for 3 months or more (with the caveat that the refuge is a hostel in HB terms and is not self-contained – see below at A) and this has the impact of ensuring women stay at a refuge for at least 3 months. This is an exemption from the SAR though it is unclear whether outreach support in the pre-refuge stage would be taken into consideration. (Many women are in touch with such support prior to taking the traumatic decision to move into a refuge.)
Some key variables and trends have been evident from refuges we advise nationally:
- The first is an increasing number of childless women accessing refuge (some as high as 35% of all residents) and so the increase to under-35s will potentially affect more women with this reform.
- The second is the increasing need to use the PRS for move-on due to social housing shortages and so this change will affect far more childless women fleeing DVA.
- The third is that SP outcome targets have consistently been seeking reduced times spent in refuge, or greater ‘throughput’ there. The SAR reform thus works against this aim of reducing the refuge length of stay.
Point 2 above, the increasing need to use the PRS for move-on, is a generic issue for all supported housing accommodation-based services (ABS) such as homeless hostels. It is also well known and uncontested that 1 bed social housing is in particularly short supply for general needs tenants as well as supported housing ones and additionally we see another HB reform, the under-occupier issue, reveal through NHF figures that there are 180,000 tenants under-occupying 2-bed accommodation yet only 68,000 yearly lets of 1 bed accommodation. In short there is a chronic national shortage of 1 bed social housing and DVA providers have sought greater help from the PRS for move on out of necessity and that need to use the PRS is increasing and will increase further.
Having read almost all SP strategy documents from the 150 top-tier councils that administer the programme, the vast majority of the support needs analyses they include have ‘move-on’ as a top 3 priority. Move-on is a national problem from all accommodation-based supported housing services and includes single homeless hostels as well as refuges.
At an operational and strategic level for DVA refuges (and single hostels) if you can’t move-on residents then you can’t admit new residents as the refuge or hostel is bed-blocked. An age-old problem that is made more acute by SP commissioning decisions and SP outcomes for greater throughput, many now see greater throughput / shorter length of stay as contractual obligations on the provider and this will increase with the trend toward payment by results (PBR) which the great and the good of the CLG wish to see applied to refuge and hostel with only 80% of funding paid and 20% withheld dependent on reaching ‘outcomes’ such as increased throughput.
Hence the impact of the SAR widening the age criteria to the under-35s will strongly work against such variables, trends and the entire supported housing accommodation based sector of refuges and hostels.
What will HAVE TO emerge is that DVA providers will need to be much more circumspect on whom they admit to refuges and childless women will have a much more reduced chance of accessing refuge provision when they are fleeing domestic violence and abuse. Of course DVA providers won’t want to do this but they will have to as they have no choice: They are contractually obligated to throughput figures as part of their SP contracts and SP teams are highly unlikely to reduce throughput outcome targets which leaves DVA providers with no choice except to admit less childless women seeking refuge.
There are necessary differences between move-on needs for refuge as oppose d to homeless hostel residents. Those fleeing DVA are unlikely to feel safe in shared accommodation provision such as a house in multiple occupation (HMO) or similar shared provision with a single main door accessing 3, 4 or more bedsits for example (which is increasingly used for former single homeless hostel residents.) A HMO of this type accommodating 4 or 5 women who have fled DV is a huge security risk as it only takes 1 perpetrator to make all feel and be very insecure.
Even if such provision is available and was suitable, former refuge residents will be competing with all under-35s for this and even moving on 3 single women into 1 HMO of this type highly problematic as there is no support funding for this additional stage.
Many social landlords own refuge buildings and like to imagine they support DVA provision. Yet how many have amended their allocation plans to include the much greater need for a social housing move-on solution for the childless under-35s that reside in refuges? Not many if any. Yet they need to and need to prioritise the greater need for such accommodation that the SAR HB reform dictates.
It is no longer good enough for social landlords to smile for publicity photographs extolling their virtues for leasing a refuge on a peppercorn yearly rent to DVA organisations. They need to look more at the move-on problems these HB reforms create. If they don’t DVA refuges will be even more bed-blocked, will be less able to meet SP outcomes on throughput and risk losing SP funding. If one part of the model, in this case move-on, doesn’t work the whole model including refuge doesn’t and is threatened.
Do the social landlords that have DVA providers as their managing agents know what proportion of refuge residents are childless and under-35? If not, why not – and now more than ever you need to know.
What this pernicious HB reform will dictate is a fundamental change in DVA (and single homeless) support provision. Joe Public may well acquiesce to the coalitions rationale for the SAR change, this being the under-35s should have to cut their cloth and only be paid enough in benefit to live in shared housing. Yet Joe Public would surely not accept this superficial rationale if they knew it meant excluding single women escaping domestic violence and abuse, which is exactly what it does.
There was no discussion of this in this governments impact assessment on the change to the SAR. That cannot be of design just of their incompetence and lack of knowledge of the operation of supported housing. Why WAFE (Womens Aid Federation of England) have been deathly quiet on this issue is another matter altogether making refuges wonder why the hell they pay their WAFE subscriptions for? Where have all the pro-women MPs and Lords been on this issue – nowhere? Where has the female Home Secretary and her office that repeats parrot-fashion at every turn that 2 women die each week from DVA been on this? Nowhere and silent. Where have the Police Liaison Officers been on this as it will massively impact on their budgets and time? Where have the NHS A&E staff and lobby been on this with the similar transfer of cost this places on their budgets through increased DVA incidents?
It can only be they all saw the SAR change as just affecting young single homeless persons and lets cut to the chase they’re not high on anyones agenda are they? They are homeless because of being workshy or lifestyle choices – the undeserving vulnerable if you will. Yet all of these MPs, Lords, CLG, Home Office, womens organisations, Police, NHS, probation, IDVAs and others who claim to be ‘stakeholders’ and knowledgeable about DVA issues have been quiet as a mouse and in doing so have labelled childless women fleeing domestic violence and abuse as the same ‘underserving vulnerable’ as those workshy single homeless miscreants!
A) Over recent years the tendency has been to move away from shared or communal facilities to make all rooms fully self-contained. Many purporse built ne refuges are self-contained such as the much lauded one opened in Blackburn in 2011. Yet in being self-contained they no longer fit the definition of a ‘hostel’ and this has serious consequences for its funding and sustainability. Not only will it not be exempt as discussed above, it will also encounter rent funding problems with the HB regulation definition of a ‘hostel.’
I have discussed the closure of DV refuges in many previous posts on here particularly in relation to the DWP consultation on 2011 on rent in exempt and supported accommodation. These DWP plans – that we are now informed are shelved – would lead to cuts of between 24 and 65% based on refuges I have advised. Whether the DWP revisit such plans is not known as they have not and dont intend to publish a consultation response!!
UPDATE 18 FEBRUARY 2012 – The DWP have lost an Upper Tribunal case on a HB matter and they are instead planning to change HB regulations. In simple terms the judges voted against our view on what HB regulations say so we will change the wording of them to suit our view and reduce funding. It concerns the definition of ‘sheltered housing’ yet does affect refuges. If refuges are self-contained they are no longer ‘hostels’ and as they are not ‘sheltered housing’ (using its ordinary lay definition) then HB exempt regulations set up to ensure HB funding covers most of refuge costs are fundamentally weakened leaving DV refuges at a higher risk of financiaal sustainbility. This is a more obtuse albeit valid point than those above on SAR change. Yet (a) the DWP and government havent seen this aspect just as they havent seen the unintended (we must presume) consequences of the SAR reform on DV refuges; and (b) again – we are WAFE or other DV lobby groups on this – the silence is truly deafening!!!