Conservative housing benefit changes mean that every refuge for domestic violence and abuse will close as they will not be financially sustainable.

That is a frightening statement yet one without any hyperbole and one of fact and the same applies to all ‘supported housing’ services such as homeless hostels and group homes for those with learning disabilities, mental health, physical and sensory disablements and any other support need or vulnerability.

This is a hugely emotive subject area and one I have worked in and advised on for 20 years yet here I try to explain this complex issue as simply as I can and without superfluous comment and I will use the example of the refuge to explain.

The HB change

The Autumn Statement of Osborne just over a week ago announced that housing benefit is to be capped in social housing (which includes supported housing such as a DV refuge etc) to the rate paid in the private sector which is called Local Housing Allowance.

The problem

Housing Benefit regulations have some very niche ‘laws’ which mean that the far higher costs of providing a refuge can be paid for through housing benefit.  Yet the crude cap this Government wishes to put in place leads to a massive reduction in the housing benefit level a refuge can claim and means all refuges will have to close.

To really simplify the issue, a woman when fleeing domestic violence and abuse does not flee with the kitchen sink strapped to her back and so requires furnished accommodation and refuges also need to be open 24 hours a day to receive a woman fleeing, with or without children.

A refuge is therefore furnished, is open and staffed outside of normal working hours and is a temporary and emergency provision – all of these necessities incur much higher cost than general needs rented housing and the HB regulations that have been in place since 1987 reflect this and allow for these higher costs.

Indeed there are some extremely specific HB regulations just for refuges which allow for the costs of providing children’s playground equipment even including the soft matting underneath a swing that we see in our public parks – and rightly so.

Yet now this Conservative government wants to stop this and instead is saying that local councils should pay for this out of their discretionary housing payments (DHP) budgets which (a) as the name says is discretionary and (b) they are used for bedroom tax, benefit cap, LHA cap, and so many other purposes and already massively over subscribed.  The refuge provider therefore cannot rely upon their receipt and given the amounts involved leave no option but to close refuge provision.

I shall leave any comment on what using DHPs for refuges and other supported housing provision means for the likelihood of the bedroom tax tenant and benefit capped tenant getting a DHP which this plan will obviously mean a massively reduced chance of receiving and so no more.

Instead here is a simplistic overview of how HB currently funds a 10 bed DV refuge which you will quickly see gets inordinately complex.

We can break down the expenditure areas into 3 categories of (a) ‘ordinary’ housing management costs, and (b) additional or intensive housing management costs, and (c) furnished provision.

A) Ordinary housing management costs are simply what is covered in an ordinary rent in a non supported rented environment such as your average council flat and requires no explanation.

B) Additional or intensive housing management costs reflects at the simplest level that a refuge is a temporary housing facility and the residents may be there say two months.  That means 6 residents per room per year whereas the average council flat has a resident for 12 years and so we see there is 72 changes of tenant in a refuge than there is in the average council flat (6 per year for 12 years) and so 72 times more basic administration.

Then as the primary purpose of a refuge is safety there is additional housing staffing needed which could be support staff or a security guard or concierge who are able to ensure the building is secure and also admit a women fleeing violence and abuse at 2am for instance.

Staffing at a refuge also means more experienced staff who need to check that safeguarding procedures are in place and adhered to and because this 10 bed refuge could have 10 women and 30 children – and I could say so much more on what constitutes intensive housing management.  However, HB regulation also covers these necessary intensive housing management costs and so the cost of providing a refuge service is much higher.

C) Furnishings – Beds, wardrobes chests of drawers, and so on for bedroom furniture which could mean 4 beds and two cots in a room all of which have to be very rugged given the number of people using them and all bedroom soft furnishings, bedding, curtains have to be fire retardant and also highly serviceable for the excessive wear and tear and include rubberised sheets for bedwetting purposes and so on and so on.

Then in communal areas we see a necessity for communal kitchens (white goods, crockery, cutlery, pans, bottle and can openers, other utensils, and of course fire blankets and extinguishers and so on) – then communal laundry which needs commercial grade washing machines and dryers given used by 10 women and 30 children’s laundry needs – then communal lounge(s) which need armchairs, settees, a TV and so on, as well as fire retardant curtains etc, etc) – and then communal areas which need emergency lighting systems, fire extinguishers, signage, right down to a salt bin in outside communal areas…and so on and so on and so forth.  Communal toilet facilities necessitate sanitary disposal (hoppers) and so on and so forth too.

Then there is communal areas both inside and outside for creche / child’s play areas and again all provision is needed right down to soft matting under children’s playground equipment….

Housing Benefit regulations pay for all of this necessary equipment as well as the maintenance of that equipment and the much higher maintenance and wear and tear and repair costs from having 10 women and 30 children sharing a large house.  Note too that because children are in a refuge then what may be a 28 day for a repair in a block of non supported flats such as a staircase spindle post broken gives a need for a repair done the same day in a refuge as a child could fall through that gap.

Some idea of numbers and costs

In a low rent area such as the North of England the housing cost of providing a 10 bed refuge can easily top £320 per week and by comparison an individual flat in a 10 bed ordinary block of flats could be £80 per week.  A 1 bed private flat may be £100 per week and this receives £100 per week in LHA which is what this hare-brained Government policy wishes to limit the DV refuge to in this valid yet generic example.

A shortfall of £220 per week for 10 flats / rooms is a £2,200 per week reduction in housing benefit and a near £115,000 per year reduction in housing benefit to a 10 bed DV refuge!

The issue is a stark one as the figures reveal and there is no doubt or hyperbole in saying that every DV refuge will close as a result.

One wonders what and how much the Home Secretary Theresa May knows of these consequences as she constantly – and rightly – has a sub-department of her Home Office portfolio called Violence Against Women & Girls (VAWG)

teresamaytorture

Further comment

The refuge example also applies to all supported housing environments from homeless hostels to shared and individual supported provision for any support need or vulnerability.  The refuge is (hopefully) easier to explain in terms of the necessary high costs as above and for example the added costs necessary for children which only apply to refuges and not to homeless or mental health or learning disability supported housing provision (mums and babes units excepted as well as homeless families units.)

Most importantly, a refuge provision and what that needs to entail is easier to explain as those not familiar with supported housing provision can readily recognise the need and necessity for fire retardant soft furnishings and urgent repair costs and so on.

The reason I started blogging almost 5 years ago was because the Conservative led coalition proposed the very same issue in limiting housing benefit in supported housing to the Local Housing Allowance rate paid to private landlords and private landlords do not DO supported housing such as hostels or refuges.

That policy change – to limit supported housing to LHA – came about because the Conservatives failed to consider supported housing at all in Universal Credit plans and quite simply forgot about it and did not include it  – and, as is their want, they issued a knee-jerk consultation paper on limiting HB to LHA levels! Check this Inside Housing article from October 2011 and you will see that the Government did indeed forget all about refuges and other supported housing environments and over 200,000 vulnerable tenants there or even my very specific and actual examples of refuges that I developed and got funding for which meant these Conservative proposals would see 24% – 65% cuts in refuge funding!

This led to still ongoing behind closed doors talks with supported housing umbrella groups and Lord Freud and despite that, this limiting of LHA to social housing which includes refuges and all other supported housing resurfaced 9 days ago in the Autumn Statement from Chancellor Osborne.

But then again, this limiting of HB completely forgot about supported housing such as refuges (surprise bloody surprise!!) and when it was raised after the surprise announcement in the Autumn Statement I immediately said this would close every refuge and said within that post that I expected the Conservative Government to exempt supported housing (often now called specified housing) from this measure.

HOWEVER… it is extremely disturbing that Government thinking is apparently that supported housing such as refuges will NOT be exempt and instead Government expects that DHP budgets will make up the housing benefit losses and reports from Homeless link here, a frankly outrageous and disingenuous one from the NHF here  (see below too) and others that specifically mention the DHP issue such as from Mencap here as well as my own numerous calls and correspondence with contacts – some of which I cannot state for obvious reasons – ALL suggest that the Conservatives will NOT exempt refuges from this measure and puts everyone of them at acute financial risk of closure.

Let’s return to the 10 bed refuge example above and ask yourself if any local council will be able to find £220k per year from its existing DHP budgets!  If you look at the official figures (pdf) you will see how much each local council gets in DHP and you will see that many local councils do not even receive £220,000 per year in DHP which is supposed to be used for bedroom tax, benefit cap, LHA cap, SAR cap, other welfare reforms, and just about anything and everything else according to this Conservative Government.  DHP is the universal panacea for all austerity according to them!

Finally, what is deeply, deeply disturbing is the National Housing Federation’s response to this in a blog by its Chief Executive David Orr yesterday which called the Government decision to limit housing benefit in refuges et al to the LHA rate.  He called this a SURPRISE yet the same NHF 4 years ago were one of the organisations that said limiting refuge HB to the LHA rates was a mistake and so NHF and David Orr are disturbingly disingenuous to call this a surprise and that can only, for me, mean one thing.

The NHF and David Orr are prepared to NOT challenge this issue and not prepared to challenge this particular Conservative Government on this issue because they are in bed with them over the farcical voluntary right to buy extension to housing association tenants.  A policy of don’t criticise this Government else the voluntary RTBe deal is in doubt.

It seems that the NHF and David Orr are entirely prepared to let all DV refuges go to the wall as long as housing associations can keep the charade of the RTBe deal that they proposed to Government.  That is deeply worrying indeed and the same David Orr will know that this Government put out a tender last year won by IPSOS / MORI which included references to limiting supported housing rents to LHA and included the use of DHP to make up this shortfall which as I have explained simply cannot happen.

Here is part of that Government specification from its Terms of Reference:

lhaspecipsosmori

Yet David Orr calls this DHP paying the shortfall and limiting of LHA idea yesterday a SURPRISE and further disingenuously says this must somehow be an oversight by the very same Conservative Government he and the NHF have chosen to get into bed with!!!

Deceitful, disingenuous, distasteful, disturbing, disgraceful, despicable David Orr!

UPDATE – IN RESPONSE TO WOEFUL TWITTER COMMENTS FROM THE OMNISCIENT usual suspects!!

This can’t be true Joe, the Government is putting more money into this and see this piece from earlier in the year see this piece from earlier in the year which says Government is putting £3.2million into Refuge.

  1. Refuge is the name of a national charity and by and large they do NOT operate refuges and they operate domestic violence services but not accommodation (ie refuges)
  2. £3.2 million in a one-off payment is welcome YET the limiting of housing benefit to refuges sees the example outlined above produce a £22,000 per year funding cut for 1 refuge.
  3. There are 300+ refuges in the UK so 300 lots of £220k pa cuts becomes a £6.6 million per year cut
  4. So £3.2m given to domestic violence services for Refuge (over what period?) is counteracted by a £6.6 m cut in funding for all refuges

This produces a net cut of millions per year funding reduction and all DV refuges will close.

Also note that the additional funding for Refuge (the organisation) is earmarked and ringfenced for specific issues and NOT to mitigate the massive HB cuts I outline above.

6 thoughts on “Conservatives to close ALL DV Refuges

  1. We will need to see what sort of detail is in the regulations when they appear nearer the time, but one possibility is that the applicable LHA rate will be the one for the claimant’s own household and not for the accommodation. This has advantages and disadvantages:

    – on the plus side, if a woman occupying a refuge has children the LHA rate would be two or more bedrooms
    – but the provider will find it very difficult to plan budgets when rent income depends on the random variable of how many children each new service user brings with them

    It also isn’t entirely clear how this announcement applies to the overlap between regulated social housing and true “exempt accommodation” which is a subset of supported accommodation to which more generous HB rules apply in both the regulated social sector and the charitable voluntary sector. Exempt accommodation is currently entering another phase of its endless consultation-review-kick-into-long-grass cycle that ha been going on for at least a decade – whatever the outcome is this time, will it apply to exempt accommodation in the regulated social sector leaving the LHA announcement applying only to schemes that sit outside the exempt accommodation subset? Who knows, but this is complicated enough to make me think that cutting HB/UC for supported housing will not be as easy or as catastrophic as it seems at first glance

  2. A considered view as always Peter and as we both know this all stems from the mistake and incompetence of Government in not looking at how policy change in UC and other reforms affects all forms of supported housing.

    Yet take your argument that a women with 4 children would qualify for the 3 or 4 bed rate of LHA in a refuge and one I accept. She will still be allocated the 1 room in the refuge which leads to all sorts of issues.

    – the refuge will receive a higher HB income for that room and a lower one for the childless woman fleeing and from detailed actual figures from refuges I advise more than 30% of women in refuges are single
    – that LHA rate per housing need incentivises a refuge only accepting a women with children (and just stating that obvious fact will cause ructions for obvious reasons!)

    I could discuss that one issue alone with its huge number of consequences as well as many other subtleties and nuances for other supported housing provision as given this LHA linkage will only apply to new tenancies it penalises those units with the lowest average length of stay such as DA and EA environments.

    The purpose of the above was to highlight the huge issues, most of which are beyond Government thinking, and raise awareness of them. The flippant announcement of HB being limited to LHA in the Autumn Statement and ‘sold’ on the basis of apparent ‘fairness’ typifies this Government’s idiocy and ideological prerogative – or issuing policy without thinking of the consequences in short.

    If I had raised this about homeless hostels or sex-offender units or detox or rehab – who all share the same risks as refuges in their typical length of stay – then this post would have been ignored and the refuge example (a deserving client group q.v. the aforementioned “undeserving” provision) was used deliberately to highlight the issue of announcing policy without any forethought! And as usual we have no impact assessment being issued on this seismic change that threatens ALL supported housing.

    One day we may have considered policy with regard to housing and HB in all its forms, a subject I will go and ponder over a drink with my unicorn…

  3. Hi Joe

    I wrote to you before as I have linked one of your articles to a petition I have started as you explained it so well, better than I ever could. I’m so grateful for your informative blog and if possible could you raise awareness about the petition? It would reach so many more and we will have a chance to stop the Tories from doing this! https://petition.parliament.uk/petitions/113864

    Kind regards

    Lisa Kirkham

    > On 11 December 2015 at 13:48 “SPeye Joe (Welfarewrites)” > wrote: > > joehalewood posted: “Conservative housing benefit changes mean that every > refuge for domestic violence and abuse will close as they will not be > financially sustainable. That is a frightening statement yet one without any > hyperbole and one of fact and the same applies to al” >

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