Housing (and IH) does not get the LHA maxima policy

For a full month I have been ‘banging on’ about the LHA maxima policy and how it WILL close homeless hostels and DV refuges as well as sheltered housing.

In speaking with scores of people the first reaction is this can’t be true Joe, no government in their right minds would implement a policy that they know closes housing for vulnerable older persons or those fleeing violence and abuse.  Yet that is what this policy will do as well as housing with support and/or care for every other vulnerable client group.

Friday’s Inside Housing has this on their front cover and major story and attempted to state the impact yet their efforts still chronically understated what it means and chronically underestimated the level of HB cuts and chronically under considered the impacts.

Here is the Inside Housing article below from behind the firewall.

lhamaximaIHpiece

What follows is not meant as an attack on Inside Housing per se or any journalists there individually.  IH is the leading housing trade journal and if they understate and undersell the issue – which they do significantly – then the response and challenge from ‘housing’ will reflect that in its level and in timing.

Timing – The article says “…government was formulating plans to cap social rents at the Local Housing Allowance (LHA) level for all new tenants from April 2018.

No! No! No! – The LHA maxima cap applies to all new tenants from April 2016 not April 2018.  The HB cut the LHA maxima gives will not be applied until April 2018 – a two-year deferment – but it applies to all new tenants from April 2016.

That subtle point is of critical significance as it means for every homeless hostel and DV refuge that it will hit EVERY tenant there on day one – Monday 4th April – as every resident will have taken up their tenancy / licence AFTER April 2016 as these are short stay services and so every one of them will have the LHA maxima applied.

  • That makes hostel and refuge financially non-viable and very specifically its major revenue funding (HB) non-viable.  
  • That further means that no capital funding will ever go into them as they have no viable revenue funding.  
  • This also means that no form of supported housing, supported living or sheltered housing will ever be built again from TODAY because any new build service coming on stream after April 2016 will see ALL of its tenants hit by the LHA maxima cut from April 2018
  • In lay terms they will close, they will not be built and they will never reopen due to the LHA maxima cuts application to revenue funding.

nomorehsglhamaxima

The policy hitting in 2016 but deferred until 2018 is also a major issue in all homes for life in supported and sheltered housing too and here is why using sheltered housing to explain the average length of stay factor which is critical in order to understand the impact and let’s look at a simple illustration.

Sheltered housing has a churn, a percentage of residents who leave each year and a 50 bedded sheltered scheme with a 10% churn will see 5 tenants leave each year and 5 new ones replace them.  The 5 new sheltered tenants from 2016/17 and the 5 new tenants from 2017/18 making 10% in all will be hit on day one in April 2018.

In previous posts I have revealed actual rent figures from Merseyside of non-resident warden sheltered housing averaging £140 in HB eligible rent for the 1 bed properties there yet the 1 bed LHA rate is £90 per week and that is all that will be paid.

So in figures on Monday 4 April 2018 this 50 bed sheltered scheme will see:

  • 40 lots of £140 HB paid to existing pre 2016 tenants and 10 lots of £90 HB paid – a reduction per week of £500 and £26,000 per year to the entire scheme making that scheme non-financially viable. This £10 per week average rent cut (£500 pw cut and 50 tenants in scheme) on the £140 rent level is a 7.14% rent cut.  Social landlords are up in arms over a 1% imposed rent cut in general needs rents yet this is seven times that in sheltered housing
  • In April 2019 this becomes 35 lots of £140 and 15 lots of £90 as there will be 5 more new tenants in 2018/19 and this is a £750 per week reduction and a £39,000 HB shortfall. – A £15 per tenant per week rent cut or a 10.71% rent cut!
  • In April 2020 this becomes 30 lots of £140 and 20 lots of £90 HB paid giving a £1000 per week reduction in HB and £52,000 per year. – A £20 per week rent cut on £140 is a 14.29% rent cut
  • That is a cumulative cut of £115,000 this parliament which equates to a rent cut per tenant of £44.23 per week on the £140 rent level or a cumulative rent cut of 31.6%.

The above assumes 100% of sheltered tenants in receipt of it and is also is based on a 10% churn and is a simplistic illustration.

I was reading the Older Persons Housing Strategy for Sefton (1 of 5 Merseyside Councils) and it said (a) that average sheltered housing churn was 16% in Sefton and way above my 10% example used; and (b) recommended that the council get as much new extra care sheltered provision as possible.

This 16% churn with a more realistic 75% of sheltered tenants in receipt of HB is a 12% overall average cut, which is 20% above the figures in my illustration above which therefore is a cautiously low illustration

This Older Persons Housing Strategy has been agreed and is going to cabinet on 4th February to be ratified.  Yet any new extra care sheltered approved will not see its first tenants until after April 2016 as the provision has to be built.  This means in April 2018 when the LHA maxima cut begins that every resident there will be hit by the cut – all 100%.

A typical extra care HB eligible rent in the region is £158 per week and the viability of all such extra care schemes (and two are already in the pipeline) will have been based on receipt of this £158 per week level in housing benefit, even if only 50% of tenants were expected to receive it.  One of these schemes is a 90 bed unit and that is 90 lots of £68 per week less income – a weekly HB shortfall of up to £6,120 and up to a yearly HB shortfall of £318,240 at 100% receiving HB.

YES that in-development new 90 bed extra care scheme in MBC Sefton is non-financially viable even before it is built!  I also hear another extra care scheme is in the pipeline in Sefton and that too becomes non financially viable as does ANY extra care scheme in the future with the LHA maxima policy.

That is what the LHA maxima policy means and that also explains why Inside Housing and the housing sector has so understated and underestimated what the LHA maxima policy means. It also explains why the LHA maxima in making revenue funding non-financially viable means that no extra care provision (or hostel or refuge or supported living model provision) will ever be built again!

It also explains why I get so bloody angry and ranty in my blogs over this and why I always berate the NHF and others over their inactivity over this issue and goad them to challenge this policy publicly.

If Joe Public knew the LHA maxima policy means no more older persons housing and no more DV refuges then perhaps the policy would be as quickly abandoned as it was when first raised in July 2011 by the government.

How do we challenge?

The prospects for challenge are limited and limited ONLY to political challenge and utilising public opinion for two reasons.

Firstly, the LHA maxima is a housing benefit therefore welfare benefit policy and comes under the DWP and not under the CLG where housing sits.  IDS and the DWP and we must assume the Treasury want the saving and Greg Clark and Brandon Lewis do not as it buggers up their housing plans.

The likelihood is IDS and Osborne will prevail and the policy with no exemptions and with the DHP budgets taking the strain was confirmed in parliamentary written answers back in December to John Healey, Emily Thornberry and others.

Linked, the love-in between the NHF and central government over the voluntary RTB deal is between NHF and CLG and so ‘housing’ has no pulling power on this issue as it is not a housing policy but a welfare benefit policy.

Secondly, the LHA maxima policy will be introduced by SI and therefore have had no discussion or scrutiny; it will need to be introduced by end of February to give the mandatory 4 weeks notice of taking effect; AND once in, the only hope of challenging this is a ‘prayer!’

That is another reason why the IH piece saying April 2018 is critically misleading in saying this is a 2018 issue and 27 months away when it is an issue to be responded to and successfully challenged in 27 days and any longer is too late!

Let me take you back to MBC Sefton’s Older Persons Housing Strategy I mentioned above and we can begin, but only begin, to look at the impacts of the LHA maxima – and note well and I restate this was written and presented and agreed BEFORE the LHA maxima policy was announced.

The strategy is good and recommends more sheltered housing as I stated and that will also help with hospital discharges and so many other issues and nicely dovetails with CCG strategies and a whole host of other health and wellbeing and adult social care ones.

YET the LHA maxima cap means there will be less and less sheltered housing and no new sheltered housing so that is going to lead to less hospital discharges and higher bed-blocking costs to the NHS and so we see the LHA maxima policy means all health and social care and older persons strategies as well as the new Care Act provisions that have and are to be put in place in need of a total re-write!!

The same bed-blocking issues will apply to those tenants who live in the supported living model (SLM) and that’s mental health, learning, physical and sensory disabled tenants and many more specialised vulnerable tenants such as those with acquired brain injuries and any other vulnerability and care or support need in the SLM.  That also means the new adults with learning disability framework to come in from April is also up the khyber too – and all down to the LHA maxima policy.

This means (outside of tenants) the biggest losers and biggest headaches and biggest transfer of costs go to local government – and that means local councils even if they are Conservative controlled ones.  The LHA maxima policy is therefore apolitical and not a party political issue and it is a huge transfer of cost from central to local government.

Costs – and IH underestimate

The IH article says the estimate losses are between £56 and £126 and says no more about the source of those figures.  Those ranges are way off and as I said weeks ago using official current figures from Liverpool homeless hostel rents are as high as £382 with the 1 bed LHA maxima being £90 and so we are looking at a £290 or so per week shortfall which is more than double Inside Housing’s range, and in a low rent area.

The unsourced IH figures will come presumably from housing providers yet very few housing associations are the main support provider in homelessness or domestic violence and abuse refuges or in many other forms of supported housing,  the support deliverers are often managing agents , which can have rent levels way in excess of £300 per week.

The national average 1 bed LHA rate even including the perversely high London LHA rates is £111 per week and so the upper band of weekly HB cut will be well over £200 per week and will be double the IH unsourced estimate and again, presumably, because IH only sourced figures from social landlords and not from support providers (plus ca change!)

More importantly, I have used £50 to £68 per week figures above in actual examples and demonstrated that this lower band figure means both inevitable closure and such services never reopening because the LHA maxima prevents financially viable revenue funding.

DHP as shortfall stopgap?

The IH article completely omits this part of the Government’s strategy yet it was again admitted in parliamentary written answers – and notably from DWP with regard to discussion above re challenge – in December which further included an announcement of an additional £70 million of DHP over the two years 2018/19 and 2019/20 to meet these LHA maxima cuts.

As I have also demonstrated previously the LHA maxima cut just to single homeless services in Liverpool is in excess of £3 million per year and to sheltered around a £1.2 million per year cut and then however much all other supported housing is cut.  Liverpool’s current £1.7 m DHP allocation may increase to £2 million by 2018 yet will still have to pay out against a £6.78 million per year bedroom tax HB cut and all other current purposes as well as an additional £12 million per year HB cut from the reduced overall benefit cap from this April.

The same benefit cap reducing will increase homelessness dramatically too as it hits over 30 times as many households as it does now and therefore dramatically demand for homeless provision and especially homeless families provision.  Yet such provision becomes non financially viable and the left hand clearly has no clue what the right is doing and local government is left with substantial additional costs.  The LHA maxima is a further transfer of cost (and blame) from central to local government on top of the benefit cap reduction by £500 per calendar month (£26k down to £20k pa)

The DHP to make up the shortfall of the LHA maxima HB cuts simply cannot work.

Further comment

Firstly a quick rebuttal to some social media comments and one said the LHA maxima issue has been overstated as it only concerns HB income and fails to include other supported housing income.  That has some validity in theory but in practice it has none and again to explain we can wear the shoes of the local council.

If the provision is housing and support funded such as HB and SP then the level of the HB cuts make the service non-financially viable immediately if hostel or refuge and very quickly for longer term provision such as sheltered.

If the provision is the SLM model or extra care sheltered model is has 3 funding streams and a typical example in a low rent area such as Merseyside is:

  1. HB eligible income £140 – paid by central government
  2. HB ineligible income £12 – paid by tenant
  3. Support funding £12 – paid by LA
  4. Care funding £286 – paid by LA

This is a total of £450 per week and the only alternate provision is the registered care model which costs £750 per week and all borne by the local council.

After LHA maxima hits the HB eligible income falls to £90 and a £50 per week cut which leaves the service non financially viable.  Provider informs council who then has two options – (a) increase the care package by £50 so paying £336 in care funding, or (b) let the service fold and then have to pay £750 per week for registered care.

Yet even that assumes that the registered care model is available which it is not and the same Autumn Statement that saw Osborne announce the LHA maxima also saw Osborne allow a 2% precept on council tax for local councils to pay (some) of the increasing costs in the adult social care crisis.

Together this means councils will have to find the money (same principle as additional DHP) and further cost and blame shift from central to local government.

Is it inevitable that local councils will have to ration their funding to meet the additional HP demands and then does it become likely that local councils will only fund the supported housing services which would give them higher costs if they did not?  In short, LAs may meet some of the shortfalls for older persons and disabled persons that they currently provide care funding and have mandatory duties towards BUT not fund supported housing services where they do not have mandatory duties which would be all sheltered (excluding extra care) and no funding for hostels or DV refuges?

These same non mandatory duty provisions will also quickly  lose support funding too as this is discretionary and secondly the LA will need it back to mitigate its own higher costs of supplementing housing with care services.

Also housing should note well as I have again said before that DHP funding at local councils will switch markedly from bedroom tax DHP to benefit cap DHP and then LHA maxima cap DHP meaning social landlords who now have some tenants bedroom tax arrears mitigated by DHP soon will not have any as DHP ceases to be given for bedroom tax purposes. – Another reason IH is chronically underestimating the impact of the LHA maxima policy.

When services close, which is not just inevitable but a racing certainty, they cannot reopen due to the revenue funding aspect of the LHA maxima so just as night follows day, alternate provisions will rapidly increase in cost due to far greater demand.

Summary

Taking the IH article as reflective of the knowledge of the LHA maxima policy impact gives huge cause for concern.

The timing is immediate even yesterday and not sometime before April 2018 and social landlords with any form of supported, sheltered and SLM provision need to clear their desks and act now and decisively.

The income risk is far greater than IH report in its estimated bands yet even at the lowest bands this means inevitable closure of existing services AND rules out any future provision because there is inadequate revenue funding*

Social landlords and the majority being HA’s need to build bridges with LA’s and work with them to prevent the LHA maxima policy from being introduced – the same LA’s that the NHF shafted in the RTB voluntary deal and the same LA’s who resent housing associations for this.

The numbers affected has been chronically underestimated and even the earlier Placeshapers report on this gave a 400,000 figure for sheltered housing affected and up to 130,000 in supported housing on an informed best guess basis.  Both those figures are very low indeed and separately I will detail why these will be no lower than 500,000 for sheltered and no lower than 190,000 for supported or 25% more sheltered tenant affected and around 50% more supported affected.

______________________________________

The LHA maxima cut will apply as I have illustrated above and make closure inevitable EXCEPT in those areas with freakishly perverse high LHA levels which by and large means London. This is an important exception as it does help explain why it has taken so long for housing to wake up to the cataclysmic impacts of the LHA maxima policy.  It’s the same old London, London, Bloody London only focus of the housing sector playing a part in the if it doesn’t affect London then it won’t impact elsewhere therefore nothing is done about it….. but hey I’ve ranted about that so many times the reader will be sick and tired of such argument by now, despite the above further proving how much it impacts across all housing policy and social landlord (in)actions in response.

______________________________________________

Sheltered Housing & LHA maxima explained – In Merseyside which is NOT a high rent area a typical HB eligible rent level is £140 per week which HB now covers.  Yet from 2018 the 1 bed LHA rate will apply and below is the 1 bed LHA rate across the country.

The rightmost column – reading down from £1,090.31 in Ashford Kent – shows how much per year the pensioner will need to find out of their state pension or savings just to pay the rent or be evicted for arrears (all based on a low £140 HB eligible charge for a 1 bed sheltered flat)

lhamaxshelt1lhamaximashelte2lhamaximashelt3lhamaxshelt4lhamaximashelt5lhamaxshelt6lhamaxshelt7

Of course if the HB eligible rent is higher than £140 and for example quite common to see £160 per week in extra care even in low rent ‘oop’ North then you can add a further £1000 per year to the shortfall.

Note well how the LHA maxima does not impact in high rent areas such as London and you can see why I use the London, London, Bloody London posit as being just another example of non public challenge to this policy because it doesn’t affect London and the usual housing great an good can’t see past the capital – including the commentariat such as Inside Housing and others.

Anyone still think I am over-egging the LHA maxima and its impacts? !

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21 thoughts on “Housing (and IH) does not get the LHA maxima policy

  1. Good evening Joe

    How can I help make as many people as possible aware of this issue? What can we do?

    Thanks and keep up the good work

    Nic Newman

    Sent from my iPhone

  2. Hi Joe … will keep you posted on this planed 50 unit in Northampton
    Cabinet Member Report for Regeneration, Enterprise & Planning Northampton Borough Council Monday 25 January 2016
    Lake View site – the site has now been acquired and will be used for sheltered housing accommodation.
    An application for the demolition of the existing buildings has recently been submitted.

    Councillor Tim Hadland Cabinet Member for Regeneration, Enterprise & Planning
    https://northamptondefendcouncilhousing.wordpress.com/2016/01/16/who-do-you-think-you-are-kidding-mr-hadland/

  3. Its interesting the eligibility of the rule change in 2016, but the deferment of the financial change till 2018.

    I wonder if the reason for this is that given how many providers work the Cons have worked out that it will take a couple of years for the actual impacts to take hold (for old people supported housing only, DV and homeless are such a small consort that the government knows no one cares about “a few scroungers” – classic divide and conquer, news will target this as only affecting the homeless and ignore the DV element. DV and homeless will close 2 years before the election, more than enough time to spin)… money will start to decline from 2018 onwards, but an assumption is made that enough will limp on till 2020 (with initially a slow attrition of staff to “save money”; some DHP; reserves slowly diminished; some cross subsidy from HA’s that have “normal” rental as well as supported; and some predatory buy outs, with a view to conversion to rental or sale), that by the time they actually collapse and shutter the next election will have passed.

    The impacts wont be felt till the cons have won 2020, hidden away just long enough… and by then to late as the impact will be fully felt in 2020/2021, so 5 years later people will have forgotten and it will be yesterdays chip paper come 2025 – probably with a sop of “more money” but this time to “private state providers” with massive profit margins inbuilt.

    The bedroom tax was a classic of this form of long term deception, long enough that the evictions didn’t really start for 2-3 years except where previous rental arrears were made worse. The “spokesperson” saying “not bedroom tax” (alone). Now its 3 years later the “independent” report has, dispute its massively deceptive conclusions and detail, basically said its failed in all its “publicised” targets and reasons for existing. Its real reasons for existing however have all been fulfilled, punishing the poor for being poor and destroying social housing as a viable concern; with the added advantage that it showed just how incompetent the HA industry, and David Orr specifically, has been at showing up the covernments policies – they didn’t fight the bedroom tax, so they are never going to fight the changes coming.

    As I was typing this, and reading the article… another thought hit. When these facilities close (including old peoples supported/sheltered housing) the local councils will get the blame, especially with the new devolution deals… government will say “nothing to do with us, we gave power to the devolved areas, its up to them if they don’t fund them (by topping up DHP’s)” while cutting central funding each and every year. Could they really be joining up their thinking?

    1. There is also another thought… when these “companies” fold, the government will also blame the “state providers” (HA’s) and council run homes… obviously only real privatisation, to the usual suspects (G4$, crapiter, et. al.), as “private state providers” will solve the problems… huge transference of assets for free, a captive market, trebles all around – kerching!

    2. I really should stop typing comments before actually reading and, more importantly, comprehending everything that is in the original article instead of scan reading… Joe makes similar points to my own, only far more eloquently and coherently than my comments.

  4. I’ve just submitted a briefing to the leadership team at the HA I work for. I included this example: We have just opened a multi million pound Extra Care scheme… all singing, all dancing, providing excellent facilities for vulnerable people, commissioned by the LA and supported by grant funding because this accommodation is sorely needed. But for anyone moving in after April, the situation looks like this:

    Affordable Rent Service charge Total Eligible LHA amount Shortfall Annual Shortfall
    1 bedroom 89.00 91.00 180.00 83.78 96.22 5003.04
    2 bedroom 107.00 91.00 198.00 97.81 100.19 5209.88

    That’s over half the total cost of their accommodation. How can a sorry little increase in DHP mitigate that shortfall? As we know, it cant. If this shortfall was the same for all our sheltered/supported/extra care schemes, we’d be looking at a loss of guaranteed income around £10m per year. That’s not including all the general needs blocks with service charges which will no longer be covered by HB.

    This policy on it’s own could cost us more than the 1% rent reduction, but put the two together and it’s ‘Welcome to Shit Creek… there are no paddles so please keep your arms and legs inside the boat.’

    1. Your HA along with hundreds of others have been going down the Extra Care route for years and it can take years to develop and get the capital funding and everything else in place. All of that will count for nought in 2018/19 as the ‘all singing, all dancing’ schemes ill be forced to close as the % of new tenants (lets say 10%) in 2016/17 and 2017/18 will have their HB cut to the LHA maxima and each one in your illustration is £5k per year.

      The issue is that the entire scheme becomes non viable and so the cut to the 20% of new tenants means the other 80% of tenants – at a much needed and in demand service – will have to leave and your HAs reputation will be shot and your HA will be left with a wonderful facility that is redundant and becomes a folly!

      The vulnerable tenant is shafted, the HA is shafted in reputation and financially and the local council, local MP, local populace and so on will think your HA is a heartless bastard which will impact on all other areas of your HA’s work too.

      All of this has come about because of an ideological dictat from Govt that has had no scrutiny as it is not part of any legislation or any impact assessment (so Govt is pissing into the wind!) and the NHF has said absolutely bugger all about because it doesn’t affect their favourite members based in London!

      Your HA and hundreds of others (outside London) will all be in that same boat and the entire HA sector will have had its reputation shot to pieces – by which time the G15 privateers who pull the NHF strings will all be fully fledged private landlords and of course no give a shit

      In summary, your HA and all other HAs in the NHF has to tell the NHF to go f*ck itself and resign from the NHF – a name in which National surely contradicts the Trades Descriptions Act.

      1. In summary, your HA and the rest have to act and focus on the solution an not on the problem(s) and that means challenging the policy, challenging the apathetic NHF, raising awareness NOW of what this means and not waiting until a few months before 2018 as housing always does – Housing needs to find and grow a set of balls and be contacting all older persons lobbies and anyone and everyone else which is something it has little history of doing.

        Funny how a squalid private bedsit in central London sees the landlord getting £260 per week off the state but an all singling all dancing holistic service incorporating quality housing, quality support and quality health and social care oop North is only allowed £84 per week….

      2. I’m at a bit of a loss as to how I can influence this to make sure we’re nailing our colours to the wall as an organisation and saying to the government that they CANNOT do this. And feeling pretty frustrated about it to boot.
        Suggestions?

  5. Excellent post Joe and I agree 100% with your assessment of the facts and figures. Interestingly I have yet to meet the RP with its head in the sand over this. All I have spoken to are incredibly concerned about the impact on these vital services and appear in agreement with your analysis you were very quick out of the blocks on some 5-6 weeks ago.

    They absolutely will not push the button on new supported housing developments (I have spoken directly to providers holding off letting the contract on 4 extra care developments providing well over 500 homes). They have all said the average funding gap on rent for them is £60-70 per week. SP funding is being cut on 2 of the projects as well so they are likely dead in the water.

    I have also spoken to one large RP who has said they have no option but to close a number of their supported housing projects if this goes through as it would take them under to try and subsidise them.

    This is horrific stuff which was buried within the CSR yet the impact is possibly one of the worst we will have seen under this Government.

    I do keep hearing chatter that the push for exemptions is still going on.

  6. Kevin – I did not say individual HA’s are putting heads in sand, I said the NHF is silent on the issue and they are and that is a huge issue, though HA’s don’t dare criticise or challenge the NHF even when the case is overwhelming.

    I know many supported housing providers – some small HA’s some not – who will fold and fold immediately if this policy goes through which it can and will before the end of February in order to effect the April 2016 start date. They have no umbrella body of note and as managing agents for many HAs are looking to them to lobby and make a bloody fuss over this, yet the NHF is mute.

    Whispers we all hear yet NHF are in bed with CLG and this is a DWP matter where they have no sway and frankly give the impression they couldn’t be arsed fighting this issue.

    This wasn’t buried in the CSR it was clear and housing chose to presume this would not apply to supported or sheltered – an entirely different issue. When DWP written answers confirmed it applies from early December many HAs missed it and since that time NHF has put out two articles on the issue yet failed to mention what it means and have massively downplayed issue.

    The policy means an ever dwindling stock of supported and sheltered housing as no new build is viable as it does not have the revenue funding to make it so – That is a huge huge issue that HA’s are still failing to say publicly and still failing to raise awareness of and are seemingly content not to raise awareness in case Government finds the huge rent differential between council run sheltered and HA run sheltered that can be as much as 100% in the same LA.

    Govt will say if one social landlord can provide sheltered at £90 per week then why are HAs charging £140 per week to the public purse! – And that is also why the NHF is keeping quiet and not making a fuss as it exposes that (superficial in part yet also valid in part) issue but superficial premises have never stopped this government before have they?!

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