The Community Housing Cymru Group[i] (CHC Group) is the representative body for housing associations and community mutuals in Wales, which are all not-for profit organisations. CHC’s members provide over 158,000 homes and related housing services across Wales. In 2014/15, CHC’s members directly employed 8,800 people and spent over £2bn (directly and indirectly) in the economy, with 79% of this spend retained in Wales. CHC’s members work closely with local government, third sector organisations and the Welsh Government to provide a range of services in communities across Wales.

Cymorth Cymru is the umbrella body for providers of homelessness, housing-related support and social care services in Wales. Cymorth Cymru believes that everyone has the right to live safely and independently, managing their own lives in their own homes. However, for many people, and for many reasons, this is not always possible without support. CymorthCymru’s members provide a wide range of support and assistance to enable people to live as independently as they possibly can, or build a positive future after a housing crisis or stressful period in their lives. Cymorth Cymru acts as the ‘voice of the sector’, influencing the development and implementation of policy that affects members and the people they support.We work inpartnership with over 120 members and other stakeholders to prevent and reduce homelessness and improve the quality of life for people who are marginalised or at risk of housing crisis across Wales.

You recently received the National Housing Federation proposal on future funding of Supported Housing (attached).Community Housing Cymru and Cymorth Cymru[ii]have followed a similar consultation process.We outline below our support for the principles laid out in the National Housing Federation’s document whilst highlighting crucial differences that should be considered for a devolved nation.

It is widely accepted that the three principles below should be considered in any reforms to supported and sheltered housing:

  1. No one with support needs will become homeless or end up in unsuitable accommodation.
  2. The actual housing and support cost of delivering a quality service will be fully met, and will be flexible enough to meet changing levels of demand.
  3. The taxpayer and those living in supported and sheltered housing will have evidence of the quality and value for money of the services being funded.

Consideration should be given to the following when assessing a new funding system:

  • A focus on long-term security for landlords and providers, allowing them to continue to invest in new and existing supported housing services.
  • Remove the threat of the Local Housing Allowance (LHA) cap to give both landlords and providers confidence to continue to developnew, and innovate existing,supported housing schemes while the funding system is reformed.
  • Work closely with the supported housing sector in Wales when developing a new funding model.
  • Departments across the UK and Welsh Government work together and support the new funding model in order to provide a secure future for supported housing, reflecting the benefits it provides across the respective policy priorities of both governments.
  • That sufficient time is given to manage the transition to any new system, and that in the meantime the current funding arrangements – without the LHA cap - continue until the transition is completed.

How a new approach could work in Wales

We support the NHF view that a secure and sustainable future funding mechanism for supported housing will be one in which:

  • Actual rents and eligible service charges are funded via Universal Credit and Pension Credit or State Pension, and an enhanced budget for support is made available to Welsh Government

As part of this approach we believe that:

  • Responsibility for the decisions on how to implement an appropriate level of quality assurance and value for money in Wales should sit with Welsh Government.
  • In order to safeguard local funding streams, such as the Supporting People Programme, and allow for more effective planning and budgeting, assurances should be given over the level of funding Welsh Government will receive, including a flexible demand-led resource.

The approach we have outlined is intended to apply to all supported and sheltered housing in Wales with a clear and consistent approach to maintaining accurate records of the number of units and applicable costs to each. The number of supported housing units in Wales is 36,928[iii], for the year 2014-15, and our membership responses indicate that these sustainable tenancies will be at risk when the LHA Maxima is enforced in April 2017 unless a new model of funding is announced.

Within a secure and sustainable future funding model, we believe that actual rents and eligible services charges for supported and sheltered housing should be funded via Universal Credit or Pension Credit/State Pension for those of pensionable age.

The key elements of this approach would be:

  • Actual rents and eligible service charges funded via the benefits system through either Universal Credit or Pension Credit/State Pension depending on the claimant’s age.
  • A new definition and set of criteria should be developed to clarify which housing should be eligible for enhanced payments. As a minimum, this should include housing currently defined as ‘specified’.
  • All providers seeking enhanced benefit payments above those available in general needs housing should follow the Welsh Government guidelines and registration.
  • There would not be any caps on funding available through the benefit system, but a system of ‘flags’ would identify potentially excessive costs for closer scrutiny by a specialist supported housing team and rents officer within Universal Credit.
  • Eligible service charges within Universal Credit are more restrictive than the current approach. Any ‘people-focused’ housing management costs, if no longer eligible for benefits funding, should be met via funding for support services made available by HM Treasury to Welsh Government.
  • The default setting for payment of the housing element of Universal Credit claimants living in supported housing should be for it to paid direct to the landlord.
  • The threat of the LHA Maxima must be removed from the supported and sheltered sector.

We propose that the support element of supported housing, such as the Supporting People Programme, remains in place but any additional support costs traditionally paid through the benefit system but prohibited by Universal Credit, such as Intensive Housing Management, should be devolved to Welsh Government.

How will outcomes be addressed within this system?

Welsh Government would be responsible for consulting with landlords and providers in Wales on appropriate outcome indicators that the sector can support, building on the work of the Supporting People Outcome Data group and the Data Linkage work that will evidence its impact.Given the increasingly strong performance of local authorities, landlords, providers and the strategic role of Regional Collaborative Committees,we are confident that housing related support will continue to enable people to live independently in Wales.

Paul Langley

Community Housing Cymru

2 Ocean Way, Cardiff CF24 5TG

@paul_CHC

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