Choice Based Lettings Scheme - EIA
Choice Based Lettings – Equality Impact Assessment (May 2007)
Stage One: Set Up EIA Team
INRA Assessment Team
· Zulfiqar Mulak , Head of Housing Needs
· Remi Osadiya, Head of Housing Support Services
· John Isted – Lettings Manager
· Armand Forster – RSL and Sub Regional Officer
Stage Two: Aims and Objectives of the Policy, Function or Service
The aim of the CBL Scheme is to:
· Give social housing tenants/applicants more choice and control over where they live.
· Build communities that are stable, viable and inclusive.
· Allow applicants choice of home to be matched as closely as possible to supply, while continuing to let social housing on a needs based system of priorities.
· Ensure transparency.
Intended Beneficiaries
· Vulnerable and hard to reach groups including those with literacy and language issues.
· LBH tenants.
· Applicants on the waiting list (including private & housing association tenants).
· Homeless families.
How does it fit into other things we are doing?
· It is a key housing policy aim of the Government.
· The Homelessness Act 2002 includes a provision to introduce choice based lettings (CBL) to overcome concern about unfair, bureaucratic allocations.
· All housing authorities are expected to introduce CBL by 2010 and Government wishes to have a nationwide CBL scheme in place by 2009.
· Statutory returns to CLG seek data on CBL and Audit Commission ratings would be affected if Hackney did not implement a form of CBL.
· Meets governmental and customer expectations to introduce greater choice.
· Introduces greater transparency into the lettings function, providing service users with more information as to their prospects of securing social housing.
· Seeks to secure the promotion of equality and diversity by provision of services in community languages.
· Enables the Council to involve its housing association partners more effectively and encourage progress in respect of common registers and lettings policies.
· Assists the Council’s work with sub-regional partners promoting mobility and advertising opportunities available to service users in other parts of the region.
· Provides a platform to promote the Council’s Affordable Homes strategy and the provision of intermediate housing.
· Creates a database of customer bidding and preferences that can be interrogated to ensure that the service is reaching those who are disadvantaged or vulnerable, as well as informing the Council’s Decent Homes strategy and planning policies for social housing.
Stage Three: The Initial Assessment
YES. Choice Based Lettings schemes rely on customers taking pro-active responsibility for their prospects of being rehoused. This is in complete contrast to the existing situation in which the Council identifies potentially suitable properties for all our customers.
The study of some of the first established CBL schemes in this country, “Piloting Choice Based Lettings: An Evaluation” (May 2004), commissioned by the CLG (ODPM at the time), recognised the potential for vulnerable customers to be disadvantaged by CBL schemes. In this context, housing applicants were deemed to be potentially vulnerable on a number of grounds such as disability, age or by reason of illiteracy or lack of use of English. These clients may potentially be disadvantaged when the onus is on them to take responsibility for identifying and bidding for suitable homes.
There are no specific concerns that CBL will have a differential impact on customers on the grounds of gender or sexuality.
YES. In order to obtain social housing under CBL, customers must know which properties are available, as well as be able to bid for homes that they want. If vulnerable clients are not assisted, directly or indirectly, in the bidding process then the differential impact of bidding patterns is likely to be adverse.
NO. Those likely to be adversely affected would disproportionately represent many of the groups that the Council’s equality policies specifically seek to assist.
YES. The Council realistically must introduce a CBL scheme and although research has shown that such schemes deliver significant benefits for the majority of customers there is a real danger that vulnerable groups will be adversely affected.
However the Council can determine the type of CBL scheme that it will establish, including the IT and services that support the system, as well as the policies which underpin it. It can also learn from the experiences of councils that have already implemented CBL and choose from a range of products that are available to support potentially vulnerable clients.
Q.5: Should there now be a more detailed INRA of the policy, project, function or service?
YES. Lettings of social housing units can significantly affect the life chances of all Hackney residents. This is particularly the case for vulnerable residents who will often have limited alternative options for securing suitable decent housing.
An interim EIA relating to CBL was submitted in the summer of 2006, prior to the introduction of CBL. This outlined the work that the Council had undertaken in formulating its CBL policy and the actions taken that sought to minimise any potential adverse impact on vulnerable and hard to reach customers. It was concluded that we would only be able to properly judge the effectiveness of these actions when the CBL scheme had been in operation for some time. It was further proposed that the detailed EIA should incorporate the work of the EIA on refusals of lettings offers (ROLO).
Arising from the evidence obtained from the consultation, officers sought to procure the CBL system seen as most effective in assisting vulnerable customers participating in CBL. To this end, Cabinet agreed in March 2006 that the Council should join the East London Lettings Company which has the advantages of touch screen kiosks, “talking head” technology and a 24 hour telephone service available in 16 community languages.
We sought, as far as possible, to predict and counter potential adverse impacts caused by the introduction of CBL. Now this EIA considers whether the steps taken have had the desired effect.
The CBL scheme went live on 22 September 2006. Detailed monitoring of bidding patterns and outcomes for all customers commenced immediately from the go-live date, with particular attention being given to potentially vulnerable customers. A six months review of the system which involved an analysis of the bidding activities and the lettings outcome has also been completed.
Stage Four: Scope of the Detailed EIA
This detailed EIA will consider the statistical evidence of the first six months of operation of CBL, alongside information gathered from service users and internal and external partners to determine the extent to which CBL has met the Council’s objective of equal access to services. It will specifically address the outcomes of lettings and compare with the outcomes recorded prior to the introduction of CBL. It will also interrogate bidding patterns to identify any groups of customers, whether by ethnicity, age or disability, under represented among active bidders.
A customer survey will be carried out to verify the findings of the EIA and provide feedback from service users. The aim of the EIA will be to determine any adverse impacts and to recommend amendments to policies and procedures which may reduce such adverse impacts.
Stage Five: Consider the Data and Research
Lettings and offers of social housing by the Council are all recorded and retained on Saffron, the Council’s Integrated Housing Management System (IHMS). This is an ideal format for analysing lettings data as there is a reporting tool as an integral feature of the system. Data can be interrogated within specific time frames and can express outcomes in respect of gender, ethnicity, age or known disability/medical factor.
Each year the reporting tool is used to inform Members of the annual outcome of lettings, broken down into ethnic groupings. The outcomes have been widely seen as equitable over the past three years, with no significant adverse impact on particular ethnic groups. The example from 2005/06 is attached at Appendix 1. We have repeated this exercise for 2006/07 (Appendix 1) to determine whether the introduction of CBL has significantly affected outcomes. Additionally work has been undertaken in respect of age and disability.
The introduction of CBL, and the associated IT, has provided an additional reporting tool. This is because the IT procured for the provision of CBL has its own database recording each individual bid, and ranked shortlist. This may be interrogated to identify bidding patterns for various ethnic or age groups.
In order to inform a detailed EIA, both forms of data are required. Quantitative data will be obtained from both the IHMS and CBL IT systems to enable a judgement to be made as to the impact, adverse or otherwise, of the introduction of CBL on potentially vulnerable customers.
Qualitative evidence has been considered from customer feedback (complaints, suggestions and customer survey) as well as from internal and external partners engaged either directly or indirectly in the lettings process. These particularly include RSLs, Hackney Homes, Community Services and voluntary organisations.
The Council has access to all the quantitative data it is likely to require. However, as outlined above, qualitative data will be obtained from internal and external partners. Regular academic research is undertaken in respect of CBL and this, as well as data from partner authorities in the East London Lettings Company may be of use, particularly when benchmarking Hackney’s performance.
Stage Six: Consult
As significant a project as CBL could not feasibly have been considered without a detailed and full consultation/engagement process. This was ongoing since October 2005 under the guidance of the Member Working Party and the Stakeholder Board.
The consultation did not concentrate on whether or not to introduce CBL, as this is a governmental imperative and had already been agreed in principle by Cabinet in March 2005. Rather the officers involved sought views from partners and customers as to how best to introduce CBL with a particular emphasis on meeting with, and addressing the needs of, potentially vulnerable and hard to reach groups.
The first stage of the consultation process is summarised in Appendix 2. The pre-implementation work aimed at informing customers is also summarised in Appendix 3.
The consultation work is largely now completed. Other than customer surveys and regular liaison meetings with Hackney Homes, RSL partners and voluntary organisations no further work is anticipated and consultation fatigue is not therefore likely to be an issue.
The details of the consultation process appended to this EIA sets out how we consulted all racial groups with an awareness of the diversity within racial groups. Our outreach workers continue to maintain these links.
Stage Seven: Assess the Likely Impact on Equality
Significant research has been undertaken to analyse both bidding patterns and outcomes of lettings. This has concentrated on ethnicity and age which were identified in the interim EIA as the equality areas most likely to be compromised by the introduction of CBL. The key findings of the research are;
· CBL has been used extensively by all ethnic groups and the bid levels have been healthy. The proportion of bids made through the multi-lingual specialized CBL kiosks has risen as familiarity with the system has grown.
· Older applicants are far less likely to bid for than younger applicants. It is likely to be partly due to the fact that older persons are more generally over-represented in lower priority bands. It is anticipated that the participation of older clients will increase now that sheltered housing is being advertised through CBL scheme starting from April 2007and the support arrangement in place enhanced.
· Communities with a significant number of people whose first language is not English such as the Turkish speaking communities have engaged (as Appendix four shows), demonstrating that the support mechanisms in place with community agencies have been effective.
· As anticipated gender has not been a significant factor with women over-represented among bidders.
· Adapted and wheelchair standard properties have been accessed by disabled customers through CBL.
· The pattern of lettings has been fundamentally unchanged from that witnessed before the implementation of CBL.
Full details of the research undertaken are illustrated in charts in Appendix 4.
Stage 8: Consider alternatives
The initial six months of operation of CBL has been generally viewed as a success. This view is widely shared by housing needs staff, RSL and ALMO colleagues who have been regularly consulted, and voluntary organisations. Members of the Council have also praised the scheme and complaints about the lettings process from customers have fallen to a negligible level.
A key concern prior to implementation was that the Council continue to let properties fairly to all ethnic communities within the borough. The CBL software and hardware purchased to run the scheme was intended, with its use of 16 community languages and British Sign Language, to encourage participation from all sections of the community. The outcome has been that there is no evidence that any ethnic community has been disadvantaged by CBL. The pattern of lettings has been fundamentally unchanged from that witnessed before the implementation of CBL. As such no changes to the CBL system are considered necessary at present.
The one equality concern arising from the first 6 months operation of CBL has been the under-representation of older customers among the active bidders. This has been the experience of other boroughs that have introduced CBL and was anticipated in last year’s interim EIA.
There are some explanations for the shortfall in bids from older clients. The majority of bids (around 75%) are made via the internet and older customers are less likely to have access to, or experience of using, the internet. Our policy is to advertise as many properties as possible. The only significant exception to this rule is that a significant number of direct offers have been made to under occupiers, among whom the elderly are over-represented.
Again, until May no sheltered units were advertised under CBL as supporting people services in respect of sheltered accommodation were being restructured. In the first week in which sheltered properties were advertised the proportion of elderly bidders rose slightly over the previous week from 3.1% to 3.5%. As part of the restructuring an outreach/support officer service has recently been funded by supporting people monies specifically to assist elderly people wishing to transfer, or gain access to social housing. Also auto-bidding, which aims to support vulnerable clients, has only recently become available. External agencies have been trained in the use of auto bidding and the elderly are the group of clients for whom auto bidding is most being used.