Response from Stratford-on-Avon District Council
1. Consultation on housing costs for sheltered and extra care accommodation
2. Consultation on housing costs for short-term supported accommodation
Agreed by the Leader of the Council – Councillor Chris Saint, 19 January 2018
Contact Renata Mosz
District Housing Enabler
Stratford-on-Avon District Council
Elizabeth House
Church Street
Stratford-upon-Avon
Warwickshire
CV37 6HX
Tel 01789 260842
Section 2: Consultation on housing costs for sheltered and extra care accommodation
Question 1: We would welcome your views on the following:
a) Sheltered Housing definition: what are the features and characteristics of sheltered housing and what would be the practical implications of defining it in those terms?
Defining older person’s accommodation in terms of sheltered and extra care is too simplistic. New models of provision are constantly emerging which cross the boundaries between these two forms of provision.
The description of sheltered accommodation as set out in paragraph 7 is useful up to a point i.e. as a general description or possibly as a lowest common denominator.
It is difficult to define sheltered housing as it ranges from sheltered housing to very sheltered housing. Other terms are also in common usage to describe such provision. There are a wide range of models as regards design and levels of support (and care) across this sector which are not true extra care schemes. For example, some very sheltered schemes have evolved to include a proportion of extra care homes and / or homes converted to provide intermediate (6 week step-up or step-down beds) for people who would otherwise be occupying hospital beds.
It should also be noted that sheltered housing is not just for people with low level needs but that it can accommodate people with higher level needs.
The Housing LIN should be able to assist with definitions but see also the response to Q1c below.
b) Extra Care definition: what are the features and characteristics of extra care housing and what would be the practical implications of defining it in those terms?
Extra care is easier to define than sheltered housing. The Council’s adopted Core Strategy (2016) defines extra care housing as comprising self-contained homes with design features and support and care services available to enable self-care and independent living. Each household has its own front door. It is for people whose disabilities, frailty or health needs make ordinary housing unsuitable but who do not need or want to move to long term care (residential or nursing homes).
All the Council’s legal agreements (s106s) securing such schemes also contain a clause requiring the availability of 24 hour care on site for all residents.
A number of people choose to move to extra care housing (and sheltered housing) whilst they are in good health and they have nil or limited care needs. Such people want to future proof their housing and move whilst they are still in good health and not when there is a health crisis. It is important that any funding model does not discourage people from making such moves.
Finally, although extra care housing for younger people will presumably be covered by the funding model for people who require long term support, there is a need for Government to cross reference the policies for extra care housing for different groups of people
c) Is there an alternative approach to defining this stock, for instance, housing that is usually designated for older people? What would be the practical implications of defining sheltered and extra care supported housing in those terms?
Extra care housing provides higher levels of care and support than sheltered housing. Consequently, rents / service charge / care charges for extra care housing are higher than for sheltered housing. Therefore, it would not be helpful to amalgamate sheltered and extra care housing as regards funding.
The best option would be to designate sheltered housing as all other older people’s housing and allow for a menu of options as regards service provision and cost – see the response to Q1a above. The alternative is to try and further break down what is currently included in sheltered housing but this would be problematic for the reasons outlined in Q1.
Question 2: Housing costs for sheltered and extra care housing will continue to be funded through the welfare system. To meet the Government’s objectives of ensuring greater oversight and value for money, we are introducing a ‘Sheltered Rent’ to cover rent inclusive of eligible service charges.
How should the detailed elements of this approach be designed to maximise your ability to commit to future supply?’
See responses to Q1 and Q4.
Question 3: We are keen to make appropriate allowance for eligible service charges within Sheltered Rent that fairly reflects the costs of this provision, whilst protecting the taxpayer. What are the key principles and factors that drive the setting of service charges (both eligible and ineligible)? What drives variations?
See the responses to Q1 and to Q4 (and, in particular, the menu of options). The variations are driven by service provision.
Question 4: The Select Committee and a number of other sector representatives have suggested that we use a banded approach to reflect variety of provision across the sector. We are interested in understanding more about this. How do you think this might work for sheltered and extra care housing?
A banded approach is the only way to accurately reflect the many different existing and future service models.
Value for money in schemes is not solely about overall costs and the rent payable. Therefore, it is important that the bands are not too rigid and that there is flexibility in the system to allow for innovation i.e. the bands must not inhibit (or dictate) best practice as regards design or service provision. There is a real danger that providers may go for the highest rent and the lowest service provision within any particular band. It is important that any such approach allows for variations. In addition to the bands, it is essential that there is a mechanism to take account of higher costs and to pilot new ways of working i.e. a menu of options. For example, areas with higher land costs may necessitate higher rents (but within an agreed maximum).
There should also be a commitment at the outset to review the bands (costs and types of provision) at least annually.
Question 5: For providers, on what basis do you review eligible service charges? What drives changes?
- More than once a year
- Annually
- Every two years
- Every 3-5 years
- Every 5 years or more
- When a new tenant moves out of the property
- Other (please state).
Not applicable – the Council is not a direct service provider.
Question 6: Of your service charges, what percentage is paid by:
- Welfare payments - through eligible service charge
- Local authorities - for example, through supporting people
- The tenant
- Any other reflections
Not directly applicable – the Council is not a direct service provider.
However, it should be noted that the supporting people budget held by Warwickshire County Council used to fund the provision of alarms in local housing association sheltered and very sheltered schemes. This funding was withdrawn. Tenants are supposed to fund the alarms themselves but some cannot afford to do so. The result is that rather than speaking to the alarm call centre that would assess the situation, tenants now dial 999 and ambulances have to attend. Savings to the supported housing budget have resulted in costs to the health service.
Question 7: Attached to the policy statement is a draft National Statement of Expectation (see Section 4). We would welcome your views on the Statement and suggestions for detailed guidance.
The Statement is welcome but lacks detail. The three aims outlined at the top of page 52 are all good but it is essential that any funding arrangements are sufficient and responsive enough to enable providers to build new schemes and or re-model (may be partially) existing schemes. In order for this to happen, providers will need assurance that revenue funding i.e. rents, support care costs can be guaranteed for the long term.
Question 8: The National Statement of Expectation encourages greater partnership working at local level regarding supported housing, including sheltered and extra care housing. What partnership arrangements do you have for sheltered and extra care housing at the local level?
Partnership working is always welcome because outcomes are better for commissioners and residents. However, it is important that no one partner is allowed to veto schemes that meet identified local needs. Having a range of providers is beneficial for everyone.
Stratford-on-Avon District Council currently works with a number of different housing association providers to provide extra care housing. To date, two extra schemes have been built in the District and a further two schemes are under construction. None of these schemes was commissioned by Warwickshire County Council. However, the County uses the schemes to avoid placing people in inappropriate residential care homes and nursing homes. This both saves money, but equally importantly helps people to continue living independently in the community in their own homes.
A fifth extra care scheme in the District, which has been directly commissioned by the County Council, will be considered by the District Council’s planning committee shortly.
To facilitate joint working, both housing association providers and Warwickshire County Council’s extra care housing lead attend joint partnership development meetings.
Question 9: Government has moved the implementation of the reform on sheltered and extra care accommodation to April 2020. How will you prepare for implementation in 2020, and what can the Government do to facilitate this?
The most important thing that the Government can do is to clarify its proposals and ensure that they are realistic and deliverable. From a new development perspective, schemes have been cancelled or put on hold because of the continuing uncertainty about revenue funding.
Question 10: Deferred implementation will allow for additional preparatory measures. What suggestions do you have for testing Sheltered Rent?
None as the District Council has no housing stock. However, we will liaise with our housing associations partners to check what is happening in their schemes.
Question 11: How do support services predominantly in sheltered and extra care accommodation get commissioned in your organisation or local area?
- By local authority (upper tier)
- By local authority (lower tier)
- Through the local NHS
- Other (e.g. nationally). Please name.
See responses to Q8.
Question 12: We believe the sector can play an important role in driving forward improvements in outcomes and value for money, for instance through joint commissioning and sharing of best practice. What role can the sector play in driving these improvements forward?
An independent body such as the Housing LIN should be commissioned to identify and share best practice across England at least annually but possibly every six months. Its mandate should include the identification of emerging issues and recommendations to Government.
Question 13: If you have any further comments on any aspect of our proposals for sheltered and extra care accommodation, please state them here.
It is very welcome that the Government recognizes the necessity of securing long-term revenue funding via the welfare system for extra care and sheltered schemes. If the details can be agreed to everyone’s satisfaction, this should provide peace of mind for existing residents and enable providers to deliver urgently needed new schemes.
Section 3: Consultation on housing costs for short-term supported accommodation
Question 1: Do you agree with this definition? [Yes/No] Please comment
No.
The definition is fine with the exception of the maximum two year residency period. Owing to housing affordability issues, some people may have to wait longer than two years to find suitable affordable general needs accommodation. It is pointless to work with people for two years to prepare them for living independently and then to make them homeless. There will also be a few people who require more than two years support.
Two years maximum is a good aspiration for the majority of people but it should not be an absolute deadline. The definition could easily be improved by deleting the last three words i.e. whichever occurs first. The definition would then read
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.
Question 2: What detailed design features would help to provide the necessary assurance that costs will be met?
This will depend on the particular scheme for each client group. For example, the design features for refuges will be completely different to those required for young people.
Question 3:
a) Local authorities – do you already have a Supported Housing plan (or plan for it specifically within any wider strategies)? [Yes/No]
Yes.
A high level plan identifying priorities for supported housing and extra care housing in Stratford-on-Avon District is included within the Stratford-on-Avon District Housing Strategy. The Strategy includes the Homelessness Review and Strategy, and the Private Sector Housing Strategy.
It is unknown whether the County Council has a strategic supported housing plan although it does have commissioning priorities.
b) Providers and others with an interest – does the authority (ies) you work with involve you in drawing up such plans? [Yes/No]
Not applicable. The Council is not a provider.
c) All - how would the Supported Housing plan fit with other plans or strategies (homelessness, domestic abuse, drugs strategies, Local Strategic Needs Assessments)?
This would depend on how it is drawn up, who is involved in drawing it up, who decides on commissioning opportunities, and what funding is available and for how long.
See also responses to Q4 and Q5.
Question 4:
a) Local authorities – do you already carry out detailed needs assessment by individual client group? [Yes/No]
Yes, but generally only for some client groups where it is evident that there is a serious problem and there is no or limited provision.