LGA response to the Government’s consultation on allocation methods for New Burdens funding: New Duty on Local Authorities to Provide Domestic Abuse Support in Safe Accommodation in England Friday 13 November 2020

Councils recognise they have an important role to play in tackling domestic abuse, alongside partners in health, education, housing, the police and wider services. The Government’s commitment to ensure adequate funding will be provided to place vital accommodation-based domestic abuse services on a long-term, sustainable footing is therefore a positive step.


Summary

2.1 Councils recognise they have an important role to play in tackling domestic abuse, alongside partners in health, education, housing, the police and wider services. The Government’s commitment to ensure adequate funding will be provided to place vital accommodation-based domestic abuse services on a long-term, sustainable footing is therefore a positive step.
2.2 A new statutory duty to deliver domestic abuse accommodation support and services will not be effective without adequate and sufficient Government funding. The new funding needs to fully account for any increases in demand for domestic abuse services. Additional funding is also required to provide wider community-based support.
2.3 Currently, there is a variety of different funding streams for domestic abuse specialist services. Often these are one-off, short term grants that do not allow for long-term planning or consistency in service. In order to transform the response to domestic abuse, a joined-up approach needs to be implemented to unlock a broad range of support packages available to support victims of domestic abuse and intervene with perpetrators to change and prevent their behaviour.
2.4 We are concerned that the proposed new duty is too narrowly focused on just a single part of the response to domestic abuse. This may force councils and their partners to narrowly focus on accommodation- based services at the expense of a more holistic approach to domestic abuse services and could potentially hamper innovative approaches to domestic abuse service design.
2.5 We also note that the duty applies only to local authorities, yet councils cannot tackle this crime on their own. This requires a range of public services, including the police to work together. The Government needs to consider how other agencies and bodies will be required to contribute towards tackling domestic abuse locally, so the responsibility does not just fall on councils. For example, how the health service will contribute towards tackling domestic abuse, and how the local domestic abuse policy will become embedded in day-to-day services.
2.6 There will only be a one-year funding settlement for local authorities this year, which makes it incredibly difficult for them to plan how to provide the local services our communities rely on and which have proved so vital during the pandemic, including public health, adult social care, children’s services, homelessness support, and help for those in financial hardship.
2.7 Councils will face a £4 billion funding gap next year just to keep services running at today’s levels and need urgent certainty about how to set budgets and to plan any measures they may be forced to take to cut spending.

3 Detailed response to key questions:

3.1 We welcome the opportunity to contribute to the Government’s consultation on the allocation of new burdens funding, for the new statutory duty on local authorities to provide domestic abuse support in safe accommodation in England.
3.2 The LGA has outlined its response to some of the consultation questions below. However, it is difficult to comment further on the funding methodology for the new statutory duty in the Domestic Abuse Bill, until it is clear what the final amount of funding will be, which is dependent upon the Government’s Spending Review. We would welcome the opportunity to comment further on these consultation questions, once the outcome of the Spending Review has been announced.
3.3 Proposed allocation method for support costs: The proposal is for funding to be allocated based on population figures in the Tier 1 authority. To do this, we will calculate the % of the population (age 16+ Years) under each Tier 1 and apply this to the element of funding covering support costs.

3.4 Question 1: Do you agree with the proposed approach for allocation of support costs (population based formula x labour costs adjustment)? [yes/ no/ comments]

3.5 LGA response: Councils have reported that there may be practical challenges in undertaking an effective local needs assessment in the absence of a national overview of unmet demand. A related challenge is that often domestic abuse victims are from out of area, which is very difficult to map and plan for.
3.6 We are concerned that these factors will mean it proves difficult to accurately estimate the financial implications of the new duty. The Government should commit to reviewing the new burdens assessment following the introduction of
the new model, to ensure that sufficient funding to support the duty has been provided to councils.
3.7 It would be helpful if data from National Domestic Abuse Helplines could held to inform a local needs assessments, to help gather a comprehensive picture of the level of unmet demand. Some additional guidance on how to meet the need for specialist services on a national basis, would be welcome.
3.8 Future funding allocations will need to consider the level of out-of-area support required. The local needs assessment won’t have taken place before the statutory duty comes into force 1 April 2021, so funding levels will need to be adjusted accordingly. Transitional funding to support current domestic abuse support and services beyond the end of the financial year will be needed, to keep services running whilst the new Local Domestic Abuse Partnership Board arrangements are being set up.
3.9 We await the statutory guidance on how “support costs” will be defined and what services these will entail. It will be difficult to estimate whether the allocation of funding will be sufficient to meet these support costs until the statutory guidance has been published and the funding has been announced in this year’s Spending Review.
3.10 We would welcome any reassurance that local domestic abuse provision will continue to be funded at its current levels, and additional funding will be available to support the new duty.
3.11 Any new burdens assessment for the cost of support must consult commissioners as well as providers, to ensure it develops a comprehensive picture across all models of support rather than any given model of provision. The victim’s voice should be central to any commissioning decisions made about support and accommodation provision.
3.12 The funding allocation needs to be holistic and flexible, taking into account the range of factors that affect the prevalence of domestic abuse. Some consideration should be given to the levels of deprivation and poverty, and how this affects the prevalence of domestic abuse.
 

4 Question 2: Are there other factors that should be included in the formula? [yes/ no] - If answered Yes, please provide evidence in support of the argument.

4.1 LGA response: Wider housing pressures need to be taken into account. New duties arising from this consultation will also need to reflect fundamental pressures in the housing system, including the lack of affordable housing and temporary accommodation in a number of areas. These issues are fundamental to being able to provide accommodation-based services, and the Government must look at how it can support councils to increase housing supply.
4.2 The Government must also bring local housing allowance rates back up to cover at least the lowest 30 per cent of market rents, to improve housing affordability and enable successful move-on from accommodation-based services.
4.3 There is the assumption that housing costs will in many cases be met through welfare benefits and that MHCLG will therefore only be funding the associated support services for victims and their children. In terms of commissioning services, the housing and support elements of these services are not separated out in this way.
4.4 The feedback to the new burdens and costs questionnaire must inform the funding arrangements for this new model since without adequate funding, local authorities will be unable to provide effective support to domestic abuse victims and their children.
4.5 It is also important to highlight the wider early help and prevention service needs which help to address the wider causes of domestic abuse. It is vital a range of advice and support services are delivered to help tackle domestic abuse.

5 Question 3: Do you agree that funding element of support costs should be allocated to Tier 1 authorities only? [yes/ no/ comment]

5.1 LGA response: If funding for support costs allocated to Tier 1 areas, it will take some time for funding agreements to be reached between Tier 1 and Tier 2 authorities. Many areas will look to their needs assessment to help secure the necessary funding agreements, which means funding may not be available to Tier 2 local authorities by 1 April 2021.
5.2 There needs to be some reassurance from Government provided to local authorities, who are currently funding domestic abuse accommodation services, about whether current service level provision will continue, and can be extended, past the 1 April 2021. Many local authorities are having to make commissioning decisions prior to the Spending Review in November 2020, and they cannot provide any certainty to domestic abuse providers about their future in the next financial year.
5.3 Some additional funding to help with this transition after the financial year will be required, if services are expected to continue in the interim whilst the local domestic abuse partnership board is being set up.

6 Questions 4: Do you agree with the proposed approach for allocation of the administrative new burden for Tier 1 authorities (equal split +labour costs adjustment)? [yes/ no/ comments]

6.1 LGA response: The new statutory duty applies only to local authorities, yet councils cannot tackle this crime on their own. This requires a range of public services, including the police to work together. The Government needs to consider how other agencies and bodies will be required to contribute towards tackling domestic abuse locally, so the responsibility does not just fall on councils. For example, how the health service will contribute towards tackling domestic 
abuse, and how the local domestic abuse policy will become embedded in day-to-say services.
6.2 It is difficult to comment further on the funding methodology for the new statutory duty, until it is clear what the level of funding will be, which is dependent upon the Government’s Spending Review announcement. We would welcome the opportunity to comment further on these consultation questions, once the outcome of the Spending Review has been announced.
 

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