At times in the past week or so I wish I’d never raised the possibility that the shared accommodation rate or SAR could apply to social housing tenants through the backdoor of the under-occupation HB reform also known as the bedroom tax.
Yet I’m glad I did. Despite the hundreds of emails and other correspondence I have received eating into my workload and time; despite condescension from certain quarters attempting to attack my reputation and professionalism; and despite beating myself up at what must be my lack of articulation as some still don’t get the issue, and despite the House of Commons library today reissuing the same SN/SP/5889 standard note from 24 October 2011 detailing the SAR issue but with today’s date –a truly bizarre coincidence(?) the raising awareness of the SAR issue has been worth it.
Thankfully I have metaphorical broad shoulders, else the “Have you ever even spoken to the DWP” comments or the “this is just an example of the ever increasing problem of paranoia created by blogs” ones or the “you just want to create a story where there isn’t one” comments could be damaging professionally. Yet the problem is a real one and the application of the SAR to social tenants post April 2013 could happen through the backdoor of the bedroom tax process. It’s also a problem that can’t be ignored and the housing sector can’t simply rely upon this just being an unintended consequence that DWP officials say orally that we don’t expect this to happen.
What is to stop a council HB officer in May 2013 from determining that a 28 year-old social tenant in a 1 bed flat is underoccupying it? Or any of the new super-qualified HB staff from October 2013 when they begin to administer Universal Credit for a planned 4-year interim period from making such a decision? There’s nothing at all preventing this. Just as one HB department a few years ago deciding that the HB regulations on sheltered housing were to be interpreted in a very narrow way and created the £1000+ per annum disability rent tax issue?
If a 28 year old in the private sector lives in a 1 bed flat he is overoccupying and will only receive the shared accommodation rate or SAR under LHA. While we now the SAR regulations state clearly the SAR won’t apply to social housing tenants, the bedroom tax regulations which will replicate the LHA provisions to social housing in 2013 could see the same outcome being achieved – SAR by the backdoor.
What I find interesting and revealing in the 200+ emails I have received from housing assistants to housing Chief Executives is that the impact of SAR applying to social tenants in 2013 hasn’t been stated and significantly doesn’t need to be stated – we all know it would have a horrendous impact and drastically change the face of all rented housing.
The number of emails and the huge increase in blog views all show the level of the concern right across the sector. Many have stated that I am raising an issue they would want to raise but can’t afford to be seen doing so which just reinforces my view that luckily I can and I should raise such issues.
There is nothing to stop a shared accommodation rate being applied at any time in the future after April 2013 is also a common consensus and the political and economic inequality of the SAR applying to just the private tenant is a major issue. Go back and read the HoC paper from October 2011 republished today to see unambiguously that the rationale behind SAR is to reduce the HB bill. The £214m saving from just the 88,000 single 25-34 year olds in the private sector would triple if the 177,000 social housing tenants were added – a £430m per year saving is not to be sniffed at and especially when the budget stated incredibly vaguely that a further £10bn of savings will be needed from the welfare bill by 2016. That £10bn must also assume that this government achieves welfare savings it seeks from the bedroom tax and other reforms and that the affordable rent model won’t cost any more yet my post last month revealed that AR may end up costing well over a billion pounds a year more.
My strongly held view is that we need to seek DWP confirmation in writing ahead of 2013 that a backdoor version of SAR won’t apply or be introduced through the bedroom tax regulation. That has to be a sensible way to proceed. If it is just an unintended consequence, if it is so easy for DWP to state orally it won’t apply or even if it is just paranoia from a blog we need an unambiguous written answer ahead of 2013 and the introduction of the bedroom tax. That is why I posted the open letter to Grant Shapps on this issue. His remit as Chair of the Homelessness prevention ministerial working group which also includes Lord Freud has a specific aim of looking at unintended policy consequences.
One final point with which some in social housing may take umbrage is the impact upon rented housing if SAR does apply. The unanimous consensus that it would be highly damaging can be seen as social housing doesn’t give a jot that SAR has massive negative impact in the private rented sector to those 34 and under. With the PRS taking up more and more of new lettings and having more and more of an impact on rented housing, the knock-on effect of that affects social housing more and more every day. This increased impact on social housing is exacerbated by the SAR extension to 22 -34 year olds that is already in force and the social rented sector can no longer be as blasé about SAR in the PRS as they have been in the past.