This blog details WHY all supported and sheltered housing will close and HOW this Conservative Government has confirmed that every refuge, hostel, supported living and sheltered housing provision will close.
It is a long and detailed blog in the form of an open letter to Government, all MP’s, all local councils, housing providers, housing related charities and the general public. I make no apologies as to its length so please read on.
In the Autumn Statement the Chancellor George Osborne said that all social rented properties are to have their level of housing benefit capped at what is paid to private landlords. To those uninformed of what these means that may seen equitable and fair and we can rest assured that past practice will see Government using this allegedly equitable reason for the policy.
Yet to those who know what it means: –
- it will see the closure of sheltered housing, the closure of every domestic violence refuge, the closure of emergency and direct access accommodation such as homeless hostels.
- it further means the closure of every supported living facility which includes accommodation and care or support to those with support needs such as metal health, learning disabilities, physical disabilities, those who are deaf or blind and deafblind, those with autism or acquired brain injury and every other conceivable support need.
- it will also mean charities that support these ‘vulnerable’ client groups will close and it means local councils will incur billions in additional costs per year in social service care plans and in massively increased homeless cases.
That means that local council budgets will increase massively and totaling BILLIONS not millions more per year and that means council tax for all residents will have to increase massively, which it is not allowed to happen, so it means swingeing cuts by local councils and closures of libraries, leisure centres, parks and gardens and the end of meals on wheels and probably bins being collected once per month rather than once per week.
All of those statements are without hyperbole or exaggeration and all derive from the seemingly fair and equitable change of limiting housing benefit to the LHA maxima – which the DWP has confirmed:
The provision of housing for all supported housing residents and sheltered housing residents’ gives stability to allow care and support services to be delivered to vulnerable people and it also extremely cost-effective as I discus later: Yet this change which on the surface seems equitable will mean that the supported and sheltered housing services will close and hundreds of thousands of people with support and care needs will not get that care and support.
This seemingly innocuous change means the principle behind the Community Care Act and also the National Assistance Act is dead as is all current plans for care and support in the community such as Individual and Personalised Budgets and any form of choice for vulnerable persons as it the new Learning Disabilities framework due to be launched in April 2016 – Dead before its even released! This change also means that more women will die as a result of violence and abuse (why do we belittle it by prefacing with ‘domestic?’) and means rough sleeper policies such as No Second Night Out will die too as there will simply be no provision for rough sleepers to go to.
I am doing my utmost not to sensationalise this outrage and the anger I feel towards this policy as I have spent over 20 years working in supported housing and know with certainty that this will happen unless this policy is changed.
I am also seething over this policies total lack of any scrutiny as it was first mentioned in the Autumn Statement and is not part of the Welfare and Work Bill or the Housing and Planning Bills going through parliament as it post dates both, and it has not been added in to any of these as an amendment; it will be introduced by secondary legislation in the form of a Statutory Instrument and therefore have no parliamentary or democratic scrutiny before it becomes policy!
Put the practical implications and consequences together with this total lack of scrutiny and without any impact assessment and you see why this policy change is outrageous.
Page 125 of 152 pages of the Blue Book which details what the Chancellor said in his Autumn Statement is this:
3.47 Capping Housing Benefit in the social rented sector – The government will apply the relevant Local Housing Allowance rates as maxima for Housing Benefit paid in the social rented sector, including the Shared Accommodation Rate for single claimants aged under 35 without dependent children. The cap will apply from 1 April 2018 but only to tenancies signed after 1 April 2016. (26)
At first many only saw this as a change to the Shared Accommodation Rate or SAR and/or assumed that supported and sheltered housing provision would be exempt from this.
Yet that is not the case as a series of DWP Written Answers (included at end) were given on 14 December which say supported and sheltered housing provision WILL be subject to the LHA maxima and not exempted from this policy. Those same DWP written answers also confirmed the Government’s policy is for any of the housing benefit cuts the policy means in supported or sheltered housing are to be met with a request for a Discretionary Housing Payment (DHP) yet that is wholly disingenuous even if it wasn’t disturbing enough by being discretionary in the first place.
What does the policy of the LHA maxima mean?
(a) Single homeless hostels – The average single homeless hostel has 31 residents according to Homeless Link figures and the vast majority of them only accommodate those under 35. While I have no accurate figure for average rent levels I know from services I have developed, worked in, managed and got funding for that a very low housing benefit level there is £160 per week. Yet the national average LHA maxima for shared accommodation is just £67.35 per week and as low as £45 per week in some areas.
As such and at the low £160pw average the housing benefit will reduce by £100 per week for all 31 average residents making a cut of £3,100 per week and a yearly cut to the average single homeless hostel of £162k or so per year meaning it will inevitably have to close.
Nationally the same Homeless link figures say there are 36,540 single homeless bedspaces in England and at £100 per week of HB cut this is a £190 million per year cut – and that is using very conservative figures that are likely to be higher.
The total amount of DHP that all English councils receive is around £100 million per year (£125 million for England, Scotland & Wales in 2015/16) and so just the HB cut to single homeless hostels in England of £190 million would require DHP budgets to double.
Then add in the HB reductions for all domestic violence refuges which number around 300 refuges in England and then all supported housing for those with autism, acquired brain injury, blind, care leavers, deaf, ex-offenders, alcohol and drug detox and rehab and all learning disability services, all mental health services and all vulnerable support and care units and the idea that shortfalls can be met by DHP budgets is a fabricated nonsense.
Then add in the HB cut to sheltered housing units and the HB cut is going to run into billions per year. The same DHP budgets held by local councils that are already overstretched in paying for bedroom tax, LHA cap and SAR cap and benefit cap HB shortfalls simply cannot stretch even with the Government promise of £35m per year more in 2018/19 and 2019/20 – a figure given in the DWP Written Answers this week and included at the end.
(b) Sheltered housing – I detailed here that 1 bed sheltered housing properties in low rent Liverpool receive a typical average of £138 per week in housing benefit yet the LHA maxima for a 1 bed is £90.90 per week in Liverpool. A weekly cut of around £50 per week or £2600 or so per year. So if Liverpool has say 8,000 sheltered housing units and 75% of tenants there get housing benefit this will see 6,0000 properties each requiring a DHP of £2,600 per year each.
That would be a figure of £15.6 million per year.
YET this only applies to new properties from 2016 and only applied from 2018.
Yet IF 5% of sheltered properties change hands each year, which is not unreasonable, we see this means 280 new tenancies per year need the DHP of £2600. That is £728,000 per year. Yet in the first year of 2018 this would apply to 280 new tenants in 2016, a further 280 in 2017 and a further 280 tenants in 2018 making 840 tenants in all each needing a £2,600 per year DHP and that is £2.184 million alone in 2018 and more than the total DHP budget in Liverpool so whither DHP for bedroom tax, benefit cap or LHA cap or indeed for rent deposits or any other uses!
(c) Liverpool City Council – the same council faced with the £2.184 million DHP demand for sheltered housing would also be faced with huge increases in care costs in all supported housing services that have care funding.
For example let’s say it costs £500 per week for a vulnerable person in supported living and that £200 of this is met by HB and £300 is paid from LCC care budgets. Once that £200 HB reduces to £60 per week then for LCC to continue its legal duty to that vulnerable person it will have to find the £140 per week of housing benefit which has been cut ELSE it will have to find a full registered are provision for the resident and costing £900 per week.
That of course applies to every local council who have care packages with service users living in the supported living model of care which as the number above show means councils now pay £300 but will have to pay £440 per week or if that service goes will need to pay £900 per week!
Some will be horrified at the figures I use there which are illustrative but nonetheless typical. Yet those same figures create the rationale and strong economic case for housing benefit paying more than the LHA maxima. The additional £140 per week saves the public purse £400 per week (£900 less £500) and that is the eminently sensible reason why more housing benefit is paid to supported housing provision in the first place and why it has been national policy since 1987.
Staying with Liverpool City Council an article in The Guardian last month on the savage cuts it has faced from central Government funding revealed it has cut care packages down from 15,000 cases to 9,000 cases per year.
We can use that figure of 9,000 care packages and if we assume the average care placement in supported living is 5 years it means 1,800 care packages each year will face the £140 per week example cut in HB. That will give a DHP need each year for £7,300 per case and for 1,800 yearly cases a £13.14 million demand and increase to be borne by the council – so even if the average care placement is 10 years the cost halves to an additional £6.57 million per year to Liverpool City Council…whither the DHP budget then!
You begin to see why my comment over bins being collected once a month and libraries and parks and leisure centres closing is NOT hyperbole in any way.
This wholly unscrutinised policy change of the LHA maxima is madness and hugely damaging to the entire fabric of British society. we rightly care for those in need and as explained above the current policy that the LHA maxima seeks to change is the most cost-efficient way of looking after those who are vulnerable.
While I have abstained from political comment thus far, this LHA maxima policy is purely ideological and nothing more.
It is staggering that even those who should know of this policy change and its implications do not.
Only today I read an article from a housing association chief executive who said apart from the 1% rent cut and right to buy the Autumn Statement held no fears for social landlords. He couldn’t be more wrong as I can tell that same CEO, that in just one of the local councils of the 22 in which he operates, the LHA maxima will see his housing association and his housing association sheltered tenants lose over £100,000 in this parliament from this policy and put all his sheltered housing services at threat! I suggest strongly you go back and revise your view of the Autumn Statement Mr CEO!
It is time that housing people as well as MPs and local councils and the general public all woke up to what the LHA maxima policy means as the issues are frightening in their scale and in their cost.
UNLESS we all lobby to get supported and sheltered housing exempt from it and shout the horrendous consequences I have outlined above in brief from the highest rooftops then the death of sheltered and supported and by consequence all of social housing will happen.
This policy simply has to change.
Here are some of the DWP written answers from December 14 that DO mean the Government is not going to exempt supported and sheltered housing from this policy and intend the ridiculous notion of DHP replacing these cuts. When you read them for yourself bear in mind that there are no older person’s exemptions in LHA rules.
The DHP issue…
Does Government know what impact the LHA maxima will have?…No!
Again the Government admits it doesn’t know what it is dealing with…
In which DWP say how can we possibly know the impact…
DWP further admitting it hasn’t got a clue as to impact…
DWP saying if people hit by this then its their own fault….
Oh the DWP finally admits that vulnerable people hit will have to seek a DHP…
And just for avoidance of doubt here’s the added DHP from 2018 to deal with this multi BILLION pound added cost….
And here’s DWP saying (a) we don’t have a clue as to impact and (b) go claim a fecking DHP…!
So will ‘disabled’ be exempt from LHA maxima?…No clearly not! (no existing disability exempt criteria in LHA regs)
Disability you say? Ah the universal DHP panacea again…
What about added costs of disability and all forms of supported and sheltered housing that is paid with HB through service charges that don’t exist in the LHA regulations?
No you can’t claim them as this reform will PREVENT social sector tenants from receiving MORE THAN IF RENTING PRIVATELY….So there we have it – ALL supported and ALL sheltered housing is well and truly dead because the service charges it levies to pay for its provision and which are only found in the HB regulations for social housing services such as sheltered and supported housing will NOT be paid over and above the LHA maxima!
If you want an overview of what ‘service charges’ means in practice take a look at my post here that this LHA maxima policy – the same one above that the DWP admits it has no clue as to what the impacts will be yet is introducing it regardless – take a look at why all DV refuges will close because of this here!
Definition of specified accommodation below:
Source for this Government definition is here (pdf)