Rough Sleeping Advisory Panel Prevention sub-group feedback

Date: 7 August 2023

Status: group feedback

Authors: Local Government Association and St Basil's

In summer 2023, the Rough Sleeping Advisory Panel, which brings together leading experts from local government and homelessness charities to scrutinise, support and challenge progress on the Government’s Ending Rough Sleeping for Good Strategy, set up three sub-groups to focus on specific themes. 

The themes were prevention, led by the Local Government Association and St Basils; recovery and intervention, led by Housing Justice and Thames Reach; and transparent and joined-up systems, led by the Centre for Homelessness Impact and London Councils. The leaders produced reports based on the conversations and input in each sub-group, which are published below. The reports, therefore, may not always reflect LGA policy.

The sub-group scrutinised and assessed the progress made against the commitments made in the cross-government ‘Ending Rough Sleeping for Good’ strategy and highlighted future and wider delivery challenges. There was also an opportunity for members to elaborate on any points raised via written feedback following the sub-group meeting. The key points made by the representatives from leading organisations committed to tackling homelessness are set out below.

Organisations: Local Government Association, St Basils, YMCA, Coventry City Council, West Midlands Combined Authority, Pathway, Crisis, National Housing Federation, Thames Reach, Greater Manchester Combined Authority, Shelter, Homeless Link, Expert Link, Brooks Newmark, act, St Mungo’s, Depaul, Greater London Authority, Bristol City Council, Housing Justice, Centre for Homelessness Impact, London Councils

Departments: Department for Levelling Up, Housing and Communities, Department for Work and Pensions, Ministry of Defence, Ministry of Justice, Department for Education, Department of Health and Social Care.

In 2018, a Rough Sleeping Prevention Task and Finish Group, consisting of local government, charities and the Ministry of Housing Communities and Local Government, outlined different definitions of prevention in its report:

• Universal prevention - preventing or minimising risk of homelessness and rough sleeping across the wider population at an early stage. 
• Targeted prevention - focus on ‘at risk’ groups and transitions such as young people, BME, prison leavers, or mental health patients. 
• Crisis prevention – preventing homelessness or rough sleeping likely to occur within 56 days in line with the Homelessness Reduction Act. 
• Emergency prevention – support for those at immediate risk of sleeping rough, by provision of ‘Somewhere Safe to Stay’. 
• Recovery prevention – prevention of repeat homelessness and rough sleeping, for example through support with tenancy sustainment and employment support.

It is critical that we view prevention in this broader context, which we have captured through the discussion points and recommendations throughout this paper.

Local Housing Allowance (LHA) Rates

Local housing allowance (LHA) rates govern the maximum amount of Housing Benefit that low-income tenants of private landlords can receive. It has been frozen since April 2020 at a time when rents have significantly increased resulting in rents that cannot be covered by LHA. For example, a council reflected that only 3 per cent of properties are fully covered by LHA in their Combined Authority area. 

The sub-group consistently raised LHA as the key short-term barrier to increasing the affordability and security of housing. While LHA rates should return to ensure eligible tenants have access to the bottom 30 per cent of private rented properties, there was recognition that any increase would be helpful.

Social and Other Types of Housing

The lack of social homes – exacerbated by income and expenditure pressures on council Housing Revenue Accounts (HRA), policy changes and inflationary pressures - has resulted in less affordable housing stock, pushing people into an ever tighter and unaffordable private rental market, as well as unsuitable temporary accommodation. This increases housing pressures and leads to increases in rough sleeping, as seen in the Rough Sleeping Snapshot. The Affordable Homes Programme with its increased emphasis on funding for social rented homes should lead to an increase in social rented homes in the next 3-5 years. Coupled with the inclusion of grant funding for estate regeneration, this is a positive contribution towards reversing reductions in social rented homes. However, they will not alone get to the number needed of around 90,000-100,000 per year that both Shelter and Inside Housing agree are needed. The Government needs to recognise that additional investment is needed to rapidly increase the supply of social rented homes as outline in our six-point plan. Councils have also called for various non-fiscal interventions to increase social homes. 

More specifically, the sub-group also raised the lack of other types of housing. These include the lack of new build genuinely affordable one-bedroom homes, supported housing, Housing First, and care placements (see commitment 4). For example, a homeless charity suggested that greater responsive support should be available to both landlords and tenants to avoid leaving housing managers isolated in managing issues in supporting people with housing needs. The lack of this support means that Registered Providers (RPs) are less likely to house single people with homelessness risks due to the perception of being ‘risky’ tenants. Further grant funding would also mean that RPs are more likely to make stock available.

The Renters Reform Bill

The sub-group recognised that the Renters Reform Bill is an overwhelmingly positive move. However, there are increasing uses of Section 21 ‘no fault evictions’, leading to evictions and increasing homelessness risks, so the legislation needs progressing as soon as possible. There also needs to be full consideration of support to the private rental sector in dealing with changes - such as incentives to landlords to move from non-commissioned exempt accommodation back into single and family homes. It will also be crucial to effectively communicate these changes through an information campaign targeted at landlords and tenants to raise awareness of rights and regulations, ensuring a smooth implementation process. Appropriate transitional arrangements will also minimise the impact of potential supply issues arising from landlords leaving the market.

Funding

There was a recognition of recent improvements in the funding arrangements, such as the Rough Sleeping Initiative (RSI) being a three-year settlement, and the positivity of knowing Homelessness Prevention Grant (HPG) is for two-years. However, despite these improvements, this is still a relatively short period and leads to a ‘cliff-edge’ because of the inability to plan beyond the settlements. Similarly, the HPG is, by necessity, often used to tackle high levels of homelessness amongst families with children and other priority need categories, which can result in cohorts being missed, especially single people. It also fosters a focus on ‘crisis’ prevention due to being used when people present to local authorities, rather than targeting more upstream prevention measures.

The sub-group was clear that multi-year, non-competitive, ‘single pots’ of funding would maximise the use of council resources and allow the targeting of upstream prevention.

Collaboration and joint working

While the Homelessness Reduction Act has led to increased collaboration and partnership working, there was a recognition that it did not go as far as the sector needed. It has not led to the full realisation of collaborative and integrated working, particularly with non-statutory services and with Integrated Care Services (ICSs). DLUHC could use its stewardship, especially considering funding, regulation, legislative and policy levers, to drive greater integration and joint working between local authorities and other services (also see the Duty to Refer section).

Data and evidence 

The data and evidence-base, particularly on rough sleeping, available for institutions and organisations trying to prevent homelessness is inadequate. This includes sharing data between sectors and services, such as the NHS, and data on different demographics, such as non-UK nationals, women and LGBTQ+. There was a strong view that we need to obtain more useful and targeted data – such as the Women’s Rough Sleeping Census - and that all stakeholders need to fully utilise this when developing rough sleeping prevention policy.

There was support for developing the risk assessment tool in response to DLUHC’s question of whether it was a ‘nice to have’ or whether there is other support that should take priority. There was a clear call for the tool to be produced with the sector and for it to be developed to reflect differing circumstances across the country. Representatives of combined authorities offered to provide further support in the development of the tool.

There were also concerns about how and whether the tool supports the wider homelessness sector and whether it is targeted enough at upstream prevention. A representative of a homeless charity reminded the sub-group of the key role the Voluntary and Community Sector (VCS) fulfils in identifying people at risk early. The sub-group supported the role of the VCS in helping to develop the tool. 

Linked to the aforementioned point about data collection, it was also suggested that the tool could be helpful when considering the risk factors for single people given the lower success in preventing and tackling rough sleeping in this group.

Whilst there was recognition of improvements made, the general view of the sub-group was that this is still largely crisis prevention, rather than universal or targeted prevention and often does not provide the associated support required to make the option sustainable.

No-one should leave prison homeless and sleep rough

There was recognition of the improvements in recent years. The Offenders Bill restricting the release of people on a Friday has been positive, ending the race for homelessness support services before they close on a weekend. The Accommodation for Ex-Offenders (AfEO) scheme has also been very positive in supporting homelessness by supporting many of those unable to provide deposits. However, it remains limited by the availability of affordable, LHA-rate homes and supply of accommodation.

Similarly, the roll-out, for example, of Community Accommodation Service Tier 3 (CAS3), has worked well with strong collaboration between the national and regional/local homelessness prevention teams and stakeholders. However, the sub-group still flagged the opportunities for greater collaboration. Move on from CAS 3 accommodation still presents a problem as a result of housing supply issues and the competition for accommodation between public services can add to the challenge. This requires greater collaboration between DWP and DLUHC as well as between Government and local partners to better align policy and support prison leavers. For example, HM Prison and Probation Service (HMPPS) noted that they can potentially support those in priority need if they know far enough in advance from local areas.

It was also raised that the Local Housing Allowance shared accommodation rate (SAR) is problematic for prison leavers and people on probation for whom shared accommodation might be unsuitable because of the risks that they present or the vulnerabilities that they have. There is a need to consider flexibilities that would allow exemptions from SAR in specified circumstances.

Young people leaving care will receive the support they need to secure and maintain suitable accommodation 

A Step By Step report found that care experienced young people are still disproportionately represented in homelessness and rough sleeping services. There were references to positive programmes of support for care leavers with accommodation and support upon entering adulthood. However, there needs to be a more proactive approach to recruiting and retaining the workforce needed to support this area. Sub-group members also raised the need for greater multi-agency and multi-disciplinary working, with references to a need for clarity of responsibilities and the potential for a designated role in local authorities to draw programmes and support offers together.

No-one should be discharged from hospital to the streets.

The sub-group’s most raised point emphasised the opportunities through ICSs, particularly health and social care but also upstream family services, to maximise the impact of money in the system. This could be achieved more successfully by clarifying ICSs’ role, responsibilities and accountabilities with regard to preventing rough sleeping, and through the use of homelessness officers to support the integration of health, housing and social care in ICSs. 

It was also flagged that the effectiveness of hospitals’ ability to effectively use the Duty to Refer (see Duty to Refer further on) and prevent rough sleeping is hampered by acute pressures in health and housing. Forthcoming research led by Pathway called ‘Exploring the Implementation of the Duty to Refer in Hospital Settings’ has indicated this has sometimes led to discharges without appropriate housing in place, which has led to rough sleeping in the worst cases. This has a ‘knock on’ effect for rough sleeping in other priority need cohorts. Healthcare capacity and capability building, coupled with greater join-up and understanding between local housing services and healthcare, is critical in easing these acute pressures and reducing inappropriate accommodation usage and rough sleeping. 

Some contributors also highlighted risks relating to the Discharge to Assess pathway for those leaving hospital. The sub-group were pointed to evidence showing that it is much more effective when accompanied by step down care and specialist teams, reiterating the importance of developing supported housing and step down accommodation.

No-one who has served in the UK Armed Forces should face the need to sleep rough

The Ministry of Defence provides Service Family Accommodation (SFA) for personnel and their families while they are serving in the Armed Forces. It was raised that the area for improvement in the prevention space is greater collaboration, partnerships and signposting across government to identify vulnerable people towards the end of their service in the Armed Forces, or where individuals are no longer eligible for accommodation.

The MOD is looking to develop and improve a holistic, through career approach to transition which begins on the first day of service. Signposting and information will be available to access housing advice, financial support and education, or to develop the skills to gain employment for example.

We will review the impact of the new asylum dispersal system on homelessness and rough sleeping

In asylum, the process of move on from Home Office accommodation after decisions had been served on asylum claims already represented a difficult transition for local housing, homelessness and support systems given the notice period was already less that statutory timelines. This has been exacerbated by recent changes – detailed in the Home Office’s Ceasing Section 95 Support Instruction - shortening the discontinuation of support. 

Reframing immigration advice and integration both before and after decision, maximising notice and ensuring wider support is available needs to be utilised as a preventative service to reduce risks of rough sleeping and the need for costly crisis interventions.

The use of the no recourse to public funds (NRPF) condition for asylum seekers and migrants also creates risks around destitution and homelessness, as stated on the NRPF Network resources. There is little clarity on the support offered for non-UK nationals and those with no recourse to public funds (NRPF) who fall outside councils’ statutory responsibilities to provide support and accommodation. Some people with NRPF have accommodation tied with employment and if they get sick or lose their jobs, they often become homeless with moredata needed to increase understanding of the extent of migrant employment tied to accommodation and the consequent risks of rough sleeping.

The overwhelming input from the sub-group was the inconsistency in policy, operational and funding approaches. There were positive steps that had been taken in relation to homelessness challenges in resettlement, such as the Local Authority Housing Fund supporting the acquisition of accommodation, but this was tempered with it not being aligned with the timeline for Afghan bridging hotel closures which risked increasing homelessness presentations and subsequently rough sleeping. It was also suggested that an increased match funding from government as part of this could support councils acquire homes needed for some larger Afghan families.

The Refugee Transitions Outcomes Fund (RTOF) has provided specialist keyworkers in some local authorities to provide tailored support to refugees with positive outcomes for individuals, improved expertise within local authorities and greater collaboration with VCS partners. However, the specification is narrow, focusing largely on employment when housing is the main barrier. The successor programme - the Refugee Employability Programme – has an even greater focus on employment and will be hampered by homelessness as a key barrier. We need to build on RTOF’s learning so that future programmes are flexible to support homelessness prevention, with recurrent funding like the Homelessness Prevention Grant to plan for the long-term. 

Finally, there is little iterative learning and consistency across the various asylum and resettlement schemes. Even when there are significant financial resources inputted to schemes, there is a lack of recognition of the capacity challenges facing local authorities and delivery partners. The sub-group felt that we need to move from responsive, reactive work on resettlement and build on what can be learnt from previous schemes in co-production with relevant stakeholders.

Rewiring Whitehall

The sub-group reflected on the lack of join-up across departments with different responsibilities. Sub-group members noted that the Rough Sleeping Strategy was a good start, but there is a lack of a wider delivery strategy and associated action plans. The National Housing federation has set out the case for the Government to develop and publish a long-term plan which sets out how it proposes to meet housing need in full, including how it will prevent and reduce rough sleeping. Moreover, councils called for a wider prevention strategy by addressing the drivers and levers of homelessness within central government policy, with associated actions and accountability. Departments involved in local places cannot leave it solely to local authorities.

Voluntary and Community Sector

The sub-group often raised that there is a lack of clarity on the role of the VCS in prevention despite its huge role in early prevention, non-statutory services and support with non-UK nationals and those with NRPF. It is important to recognise and clarify the role of the VCS regarding youth homelessness, employment support and strengthen its voice and contribution.

Housing Related Support

The reduction in housing-related support by over 50 per cent since the ring fence was taken off the Supporting People Fund in 2009 is key to understanding the reduced resourcing of prevention activities. The level of need and the lack of resource to fund housing-related support to prevent homelessness in the first place or re-occurrence is a significant gap and needs addressing.

Duty to Refer

The Duty to Refer has had some success in increasing collaboration but this has been limited. It was raised, for example, that if there was better knowledge of the outcomes once a Duty to Refer was applied then this would save capacity in the system to avoid following up referrals. Greater capacity building in local authorities could help with providing partners with greater information on the outcomes of referrals. It was also acknowledged that greater collaboration could be sought following referrals to better join up services in a similar way to safeguarding referrals. 

Similarly, it was raised that greater capacity and capability building for skills and operational support in hospitals, particularly for clinicians, would support the use of the Duty to Refer in a preventative way. It has often been seen as a last resort at the point of discharge, rather than in anticipation of move-on.

Making a new statutory ‘Duty to Collaborate’, to named public bodies to collaborate to prevent homelessness would place less of a burden on homelessness services alone and widen access to preventative support, while encouraging partnership working across multi-disciplinary teams. This could include a requirement to collect and publish data of those who are at risk of homelessness and the action taken to prevent.