Consultation on housing costs for short-term supported accommodation – COSLA response.

As the representative body for Scottish local authorities, COSLA welcomes the opportunity to respond to the consultation on Funding for Short Term Supported Accommodation.

Local authorities in Scotland already play a key role in commissioning and funding of supported accommodation and COSLA regards it as vital that funding arrangements in the future ensure that all current funding through the social security system is maintained and that allowance is made for future need.

COSLA believes that local knowledge and expertise is vital to ensure effective commissioning practice in future and considers that, in Scotland, funding being devolved to the Scottish Government should be further devolved to local authorities to enhance local integrated planning for future need.

In our response, COSLA does not propose to deal with all the questions posed in the consultation as many of them are directed at proposed arrangements for England. Rather, we will focus on what needs to be considered with particular reference to Scotland in the UK Government’s proposals.

Definition of Short Term supported accommodation

We recognise that the Government has now decided to retain funding for the majority of supported accommodation within the social security system but feels the short-term nature of some services make them more suitable to grant funding. At this time, COSLA would not have any revisions to put forward on the definition proposed for identifying this type of accommodation i.e.

‘Accommodation with support, accessed following a point of crisis or as part of a transition to living independently, and provided for a period of up to two years or until transition to suitable long-term stable accommodation is found, whichever occurs first.’

However, we note that this is not intended to include temporary accommodation which will continue to be funded through the social security system. Yet it is meant to include short term homelessness services where support is provided. Within Scotland, there is real potential for confusion, because of the way temporary accommodation is defined in statute and operated in practice and we would urge further guidance on this point, both to avoid confusion and to ensure that all services where funding is intended to be devolved in new arrangements is accounted for in any sizing of current funding.

There are also arrangements in place where it would be desirable for individuals to remain in current accommodation in the longer term to enhance stability and networks of support and COSLA would not want to see funding arrangements preclude outcome focussed solutions for individuals e.g. satellite tenancies to core and cluster arrangements. This is an area where more thought and guidance is required.

Quantum of Funding to be devolved

It is vital that the process for determining the level of funding to be devolved is both transparent and robust - fully capturing all relevant spend currently made through the social security system. We understand that the government intends to seek information from local authorities on current levels of spending on relevant accommodation through enhanced information requirements in Housing Benefit (SHBE) information returned to the Department for Work and Pensions (DWP). COSLA must be involved in this process so that we can ensure a full response from our member authorities and facilitate advice and comment from our members on the best way to ensure that all relevant spend is included. Clear guidance on what should and should not be included in this exercise will be needed.

In addition, the government needs to develop, in consultation with local authorities and devolved governments, what provision it intends to make for future need. The policy paper speaks of ‘lower projected demand for future need’ for this type of short term provision. No evidence is advanced for this - COSLA is not convinced that demand will not increase for this kind of short term and emergency accommodation in many areas in coming years. Close consultation with the local authority sector and other stakeholders in making adequate provision for future needs is required – an evidence base to support any changes will be crucial.

COSLA notes that there is concern among some stakeholders about the long-term security of funding for short term accommodation by moving to a grant funded approach. It is vital therefore that both that the quantum of funding following reflects all funding for this type of supported accommodation through the social security system and includes a robust mechanism to allow for future need.

Strategic Planning and meeting local needs.

COSLA won’t comment upon proposed arrangements for strategic planning and meeting local needs in England but would note that there are already such arrangements in place in Scotland which continue to develop.

Local authorities in Scotland already are responsible for producing Local Housing Strategies and Strategic Housing Investment Plans for their areas and are partners with Health Boards in Integrated Joint Boards (IJBs) responsible for health and social care services in the 32 local authority areas. As part of their planning, these IJBs are required to produce, with partners, Strategic Commissioning Plans which include Housing Contribution Statements. These arrangements continue to develop with needs planning, outcome and performance monitoring.

In the Homelessness field in Scotland, there are also in place arrangements such as the Homelessness Prevention Strategy Group, jointly chaired between Scottish Government and COSLA – this provides a strategic forum for encouraging action between agencies and drives forward actions in this area, including discussions around the best use of funds to support councils’ responsibilities and existing efforts to tackle homelessness locally. These will continue to adapt to new challenges including the changes in homelessness presentations and rough sleeping.

COSLA considers that, in Scotland, future planning for supported accommodation should form part of these developing planning arrangements.

Contact: Michael McClements

Policy Manager

0141 577 0911 January 2018

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