- Defines what “Exempt Accommodation” is and clarifies the present confusion over what is and what is not Exempt Accommodation
- Identifies the need for change to the Exempt Accommodation rules and proposes a new framework for investing in preventative services to support independence in relation to accommodation where vulnerability is an issue
- Provides up to the minute information on the DWP’s current thinking on both the future of Exempt Accommodation and its relationship to the Welfare Reform Act
- Discusses how Tenancy Sustainment services to vulnerable people in general needs accommodation can be funded and delivered
- Acknowledges the need for a clear definition of “vulnerability” and the need for a common methodology to demonstrate the social and financial return on investment (SFROI) of services for vulnerable people
In September 2012 the UK Government announced that tenants of Exempt Accommodation would have the housing component of their Universal Credit administered outside of Universal Credit in a manner consistent with the existing Exempt Accommodation rules.
In other words, vulnerable tenants would be entitled to enhanced levels of Housing Benefit as a consequence of their additional housing needs provided that they live in Exempt Accommodation. Subsequently, the DWP also stated that such people would be exempt from bedroom tax, benefit cap and direct payment of rent. These developments were very much in line with what Support Solutions had been predicting would happen since 2011.
“Exempt Accommodation” is
- Where the Landlord is a Non-Metropolitan County Council, charity, voluntary organisation or housing association
- And has a legal interest (ownership or lease) of accommodation
- And that accommodation houses people who require “care, support & supervision”
- And that the additional services provided to those people are provided by the landlord, or by an agency on the landlord’s behalf
Since that time there has been a deal of confusion on the part of Local Authorities and providers about what Exempt Accommodation is and the situation was not helped by the provision of inconsistent advice from within the sector. This lack of clarity has resulted in a greater appetite on the part of some Housing Benefit Teams to challenge some claims for enhanced Housing Benefit made on the basis of the Exempt Accommodation rules. As a consequence, many supported/sheltered housing schemes managed by Agencies on behalf of Registered Providers have been deemed non-exempt. The same has applied to many sheltered housing schemes, irrespective of the management arrangements, on the grounds that they don’t provide sufficient “care support provision” to qualify as Exempt Accommodation.
Both arguments should be easily disprovable. Agency managed schemes are often deemed non-exempt on the grounds that the Agency is commissioned to provide support to the tenants by a third party, e.g. a Supporting People team, so therefore the Agent provides the service on behalf of the third party and not the landlord, so therefore it’s not Exempt Accommodation. However, irrespective of any arrangement the Agency has to provide support, the landlord is claiming (and paying to the Agency) enhanced housing management charges for the Agency to provide Additional Housing Management Services/Intensive Housing Management, not support, on the landlord’s behalf. This Additional Housing Management Services/Intensive Housing Management constitutes “care support and supervision” because it involves the provision of “more than routine property management functions”. This was established by Judge Turnbull in the most recent case law precedent regarding the definition of “Exempt Accommodation”. It places a greater burden upon the landlord, or its agent, due to the nature of the accommodation and the tenant group within that accommodation. Furthermore, this Additional Housing Management Services/Intensive Housing Management must make a genuine difference to the ability of the tenant to remain independent in their accommodation.
The same applies to Sheltered Housing. Providing a housing management communication system such as Housing Proactive, which is Housing Benefit eligible, or even an alarm (which isn’t) equates to “more than normal property management functions” and makes a genuine difference to the ability to the tenant to live independently in the accommodation. There is no reason why this shouldn’t apply to general needs social lettings where the tenant is vulnerable. There is no minimum amount of care support and supervision required to qualify as Exempt Accommodation, although there must be a need for care, support or supervision to be provided.
The outcomes of this system, when it is allowed to work unhindered by technical misinterpretations, is that Investment in Prevention through Additional Housing Management Services for vulnerable people in social lettings are funded very cost effectively; at least in part by Housing Benefit and the Exempt Accommodation rules. The major positive outcomes are that vulnerable social tenants receive the sort of Investment in Prevention through Additional Housing Management Services that enable them to become or remain independent in their accommodation at a much lower cost than would be payable for the emergency interventions that would otherwise be necessary for some without it. Prevention is not only better than emergency intervention; it’s also a lot cheaper. That fact should be obvious to all.
The Need For Change
We do feel, however, that the Exempt Accommodation rules do need reviewing because much has changed since their introduction in 1996. Primarily as a consequence of the work that Support Solutions has undertaken the Exempt Accommodation rules, which were introduced to cap the levels of rent payable to private landlords, are now at least as important a means of funding independence in relation to accommodation as Supporting People, the future for which is uncertain to say the least. We have worked with providers, commissioners and Housing Benefit teams to implement the regulations in a way that is transparent and fair. A way that acknowledges the financial and strategic interests of the Local Authorities and the operation of the subsidy rules through which the Local Authority reclaims the enhanced Housing Benefit it has paid out for Investment in Prevention through Additional Housing Management Services under the Exempt Accommodation rules. We do understand their shortcomings in reflecting current arrangements, for example, they include Non-Metropolitan County Councils as Exempt Accommodation landlords but not Unitary Authorities, which have often taken on the roles and functions of County Councils. So this would require either a tribunal case to rule on whether a Unitary is effectively a County Council and therefore complies with the definition. Or it would require us to suggest that the Local Authority leases its properties to a Registered Provider in order to comply with the Exempt Accommodation qualification criteria as a Local Authority landlord.
The whole misunderstood debate around whether or not agency managed schemes are Exempt Accommodation is another example, of the need for change, albeit a by-product of a failure to understand the regulations rather than a failure of the regulations themselves, although we acknowledge that the definitions could be simplified.
What we must do then is to reinvent Exempt Accommodation, the system through which preventative Investment in Prevention through Additional Housing Management Services is provided.
One of the major benefits of being an Exempt Accommodation tenant at the moment is the fact that such tenants are protected from some of the implications of the Welfare Reform Act, for example, the Spare Room Subsidy (Bedroom Tax) although that may change (see below), the Benefit Cap and exemption from direct payment arrangements in most cases.
Any replacement for, or reinvention of, the Exempt Accommodation rules should retain these protections to vulnerable people, bearing in mind that for many “vulnerability” will not be a permanent situation.
Any replacement of Exempt Accommodation must enhance its strengths and remove its weaknesses. Perhaps we should call this new system Investment in Prevention through Additional Housing Management Services (Investment in Prevention for short) and base it on the principles of prevention and a proven Social/Financial Return on Investment. It should be based on a methodology developed with providers, statutory sector stakeholders and Government.
Firstly, we need clarity as to who would be entitled to receive Investment in Prevention through Additional Housing Management Services payments. There should be consistent treatment of all Investment in Prevention providers; irrespective of the legal identity as long as they can provide an acceptable Financial and Social Return on Investment and that they meet proper quality standards that are based on a simplified Quality Assessment Framework standard or similar quality assurance tool. Of course some providers will already have accreditations to provide more complex services than Additional Housing Management Services and these can be passported for compliance purposes.
One of the weaknesses of the Exempt Accommodation rules is that they apply differently to different providers and different tenants. Registered Providers (Housing Associations) are favoured because Local Authorities reclaim from the DWP, via their subsidy claim, all of the enhanced Housing Benefit they pay. Most Local Authorities do not have a problem paying Registered Providers enhanced Housing Benefit under the Exempt Accommodation rules. The same cannot be said in relation to non-Registered Provider Exempt Accommodation providers, such as charities and voluntary agencies. Even though they are absolutely entitled to enhanced Housing Benefit for Additional Housing Management Services Local Authorities are often loath to pay them and for understandable reasons. The Local Authority can only claim 60% of the difference between the Valuation Service Rent determination and the actual level of enhanced Housing Benefit awarded.
This prompted Medway Council to complain to Lord Freud (Minister for Welfare Reform) about the Exempt Accommodation system as non-Registered Provider Exempt Accommodation claims left them with a £1.6 million hole in their accounts. This is a by-product of an inconsistent system. If Medway had been able to claim for subsidy we doubt they would have complained. Medway had good cause to identify this inconsistency in the Exempt Accommodation rules. So there is an uneven playing field between Registered Provider and non-Registered Provider Exempt Accommodation providers, despite the fact that they provide the same sorts of services to the same sorts of people. This inconsistency should not form part of any new system.
Private sector providers are even more restricted in what they can claim where they are also the landlord. This is quite right in relation to their landlord role but the point is that the status of a vulnerable person’s landlord, if they have one, should be irrelevant. Why should a private tenant (or owner occupier) be entitled to a reduced level of services and resources based on the legal status of their landlord or the fact that they don’t have a landlord? In fact, why should it have anything to do with the landlord at all? What should matter is that whoever provides Investment in Prevention through Additional Housing Management Services should be accredited for quality and be able to show a proven social and financial return, according to an agreed methodology, on the work they do with vulnerable people.
So in addition to levelling the playing field between Registered Provider and non-Registered Provider non-profits we also need to do so in respect of treating all vulnerable people consistently. This should be both in relation to enhanced levels of Housing Benefit (whilst Investment in Prevention is paid via that route) and in relation to Welfare Reform Act exemptions.
Under the Exempt Accommodation rules tenants of Registered Providers and non-Registered non-profit Providers are theoretically entitled to enhanced Housing Benefit on the same basis, albeit that non Registered Providers are often subject to greater scrutiny and lower payment for Additional Housing Management Services than their Registered Provider counterparts. This is due to the Local Authorities exposure to subsidy loss. If, however, you are a private tenant or owner-occupier you are entitled to precisely nothing by way of Investment in Prevention through Additional Housing Management Services due to the legal status of your landlord, the rent restrictions that apply to private landlords or the fact that you have no landlord. This remains the case irrespective of who the Additional Housing Management Services provider is. It is patently absurd that vulnerable people in the private sector should be discriminated against in this way. Acknowledging this gives us huge scope to develop preventative services irrespective of the form of tenure/status of the landlord. The intention of so doing is to provide a much wider range of cost-benefit proven preventative services that enable people to remain independent in their own accommodation and take a lot of pressure off statutory services.
Routing Investment in Prevention through the DWP’s cash-limited budget won’t work in the medium to long term. You can’t increase a social or financial return by reducing your investment. Money for Investment in Prevention should be disbursed by National Governments to accredited Providers that can show a positive social and financial return on investment.
In case that sounds a bit like “pie in the sky”, given the cost before value approach applied to public expenditure, we might want to look at one of the possible implications of enhanced devolution within the UK (or of Scottish independence if that’s what happens). It is quite likely that “welfare” will be a devolved function in Wales, Northern Ireland and Scotland, even without Scottish independence. There is a greater appetite within devolved Governments, than in the UK Government, to invest in prevention and to focus on value not cost. It will take just one devolved (or independent) administration to put its money where its mouth is and make this structural change which the UK Government seems to find so difficult: invest in prevention in order to save much more money through reduced emergency interventions and simultaneously impact positively on the lives of vulnerable people and the communities in which they live. Devolved Governments are closer to the people who elect them and seem to be able to respond more quickly to their needs. Pity then, that there is no English Government.
Current DWP Thinking.
You may have heard that the DWP has recently made some announcements that will potentially increase the scope of exemptions from certain Welfare Reform Act provisions to include supported housing that “doesn’t meet the precise definition of Exempt Accommodation”, including agency-managed schemes (although we believe that the very many of them actually do meet this definition, or could very easily do so). These announcements have been described by some as changes to the Exempt Accommodation rules, which they are not. The Exempt Accommodation rules remain unchanged.
The intention will be to create an additional definition of “Supported Housing” within the Welfare Reform Act Regulations to include both Exempt Accommodation and supported housing that doesn’t meet the precise definition of Exempt Accommodation. However, as we have set out above, technical misunderstandings of the detail of what constitutes Exempt Accommodation have already, and wrongly, excluded some agency managed schemes and sheltered accommodation. It seems that the DWP/UK Government and some sector advisors have accepted incorrect and limiting definitions of Exempt Accommodation (e.g. excluding agency managed schemes and sheltered housing from that definition). We remain concerned to ensure that legitimate Exempt Accommodation providers receive the levels of enhanced Housing Benefit to which they are entitled under the Exempt Accommodation rules, which also results in Local Authorities reclaiming via their annual subsidy claim the enhanced Housing Benefit they pay out.
What the Government has said is that it will exempt more people from the Benefit Cap and direct payment of rent if they live in supported/sheltered housing which is agency managed and therefore (sometimes wrongly) deemed not to be Exempt Accommodation and will therefore otherwise be subject to Universal Credit and restricted service charges. Despite previous statements from some sector advisers to the contrary, such schemes will not be exempted from the Spare Room Subsidy (Bedroom Tax). However, the protection from some of the provisions of the Welfare Reform Act does not mean that tenants will necessarily be entitled to enhanced levels of Housing Benefit because, allegedly, they’re not in Exempt Accommodation. It is important that these tenants have the same entitlement to enhanced levels of Housing Benefit for Investment in prevention through Additional Housing Management Services where such services are not otherwise funded. We strongly encourage providers and commissioners who find themselves in this position to contact us. Support Solutions specialises in establishing legitimate Exempt Accommodation scenarios; we don’t charge if we don’t succeed in doing so and in increasing housing revenue.
We think that it is increasingly important for providers to establish Exempt Accommodation status as we believe that one of the possible outcomes of current DWP thinking, albeit not yet, is a finite budget to fund Investment in Prevention through Additional Housing Management Services in Exempt Accommodation and possibly also a finite list of eligible service charge activities. However, we also need to bear in mind that there is a strategic move by statutory authorities to move away from expensive and often more institutional forms of provision, such as registered care homes. The alternative would be community-based housing options, much of which would be Exempt Accommodation under the current arrangements and therefore entitled to enhanced levels of Housing Benefit. This being so, the amounts of revenue for Exempt Accommodation are not likely to be capped yet.
Our view is that money for prevention should not be held by the DWP, should not be cash-limited and should be disbursed on the basis of a proven positive social and financial return. In addition to agency managed schemes and other supported housing that “doesn’t meet the precise definition of Exempt Accommodation, the Government has also decided that where vulnerable social tenants are in receipt of “public subsidy”, for example, personal budgets for the provision of care and/or support they will also fall in to the expanded definition.
The DWP has recently been in discussion with a number of the sector’s advisory bodies regarding an expansion of the scope of exemptions from the Welfare Reform Act to include those services that don’t meet “the precise definition” of Exempt Accommodation. The exemptions in question would be from the Benefit Cap & direct payment of rent to the tenant, but crucially not the Spare Room Subsidy (Bedroom Tax), which up to this point has only applied to tenants of Exempt Accommodation. In concert with the advisory bodies the DWP proposes to replace reference to Exempt Accommodation within the Welfare Reform Act regulations with a new definition: “Supported Housing”. Please click here to download a copy of the email from the DWP to the advisory bodies it is in discussion with. Within this email “Supported Housing” is defined as accommodation that is specifically designed or designated for providing support and within which the support provided is funded through a public body. This has been described by sector advisors as a great success for their behind the scenes work with the DWP. We assume this refers to the widening of the scope of exemptions to the Welfare Reform Act regulations, although they have since stepped back from a previous assertion that such exemptions would, critically, include exemption from the Spare Room Subsidy (Bedroom Tax).
However, it is of concern to us that we appear to have arrived at this position without the knowledge of the sector as a whole, the more so because the definition of “Supported Housing” is ambiguous. Support Solutions hopes that “designed or designated” means both purpose-built supported and sheltered housing, other multiply-occupied buildings that house vulnerable people and general needs social lettings within which a vulnerable tenant has been identified. Given Lord Freud’s statement that there should be no increase in DWP expenditure we rather fear that it may mean “designed” more than “designated”, although we’d be pleased if it means both as this keeps open the door to the possibility of funding tenancy sustainment services, albeit only in social lettings.
Furthermore, what is meant by the statement that “the support provided to the resident should be funded through a public body”? Does this mean a commissioned service, for example, statutory sector funding for “support”? Or does it mean, for example, that local authorities can commission services for a nominal value and that Registered Providers, which are public bodies after all as per Weaver vs. L&Q, can continue to subsidise services, as they have done for years, and thus fulfil the “funded by a public body” criterion whilst retaining an entitlement to enhanced levels of Housing Benefit through the Exempt Accommodation rules?
And that leads us to another question: if references to “Exempt Accommodation” in the Welfare Reform Act Regulations are to be replaced by the definition “Supported Housing”, what does that mean for the future of Exempt Accommodation? It seems to us that this proposed definition will include both Exempt Accommodation and schemes that don’t meet the precise definition of Exempt Accommodation. It appears that what will occur is that this new definition will be established within the Welfare Reform Act Regulations and will replace Exempt Accommodation as a phrase within those Regulations. Exempt accommodation will continue to exist, however; as a consequence those claimants who qualify for Exempt Accommodation for Housing Benefit purposes may then not qualify for exemption from the Spare Room Subsidy (Bedroom Tax) because of the limited scope of “Supported Housing” within the Welfare Reform Act Regulations. An example of these types of claimants would be those who live in supported accommodation that does not receive any public funding to pay for the care, support or supervision. Far from being a successful negotiating outcome this would be a serious step backwards from the position announced in September 2012 by Iain Duncan-Smith & Lord Freud to the effect that Exempt Accommodation tenants would be exempt from Spare Room Subsidy (Bedroom Tax), Benefit Cap & Direct Payments.
The DWP gives the appearance of having given ground whilst actually doing the opposite. It has agreed to limited additional Welfare Reform Act exemptions to supported housing that “doesn’t meet the precise definition of Exempt Accommodation” (although most of it probably does) whilst also removing exemption from the Bedroom Tax from Exempt Accommodation by including the latter in the proposed definition of “Supported Housing”. We very much hope that the DWP doesn’t now use what appear to be concessions on its part, which aren’t really concessions at all, to insist on a more restrictive interpretation of “Supported Housing”: i.e. as a commissioned service delivered in purpose-built accommodation.
We believe that there is nothing in the Exempt Accommodation rules as they stand to prevent the legitimate claiming of enhanced Housing Benefit for Investment in Prevention through Additional Housing Management Services to vulnerable tenants in general needs social lettings. We think it would be an excellent use of public money as a preventative investment where tenancy sustainment, which is needed in the short term, for example as an alternative to eviction where vulnerability is an issue. It would be equally valuable to be able to provide longer term tenancy sustainment services to vulnerable tenants in general needs social lettings under the Exempt Accommodation rules. For example, where a tenant is frail/elderly, or has learning disabilities or long term mental health needs the provision of Investment in Prevention through Additional Housing Management Services could make the difference between inexpensive independence in general needs on the one hand and expensive (and probably unnecessary) dependency in support or sheltered housing on the other.
Support Solutions is very interested to talk to providers who would like to develop tenancy sustainment services for vulnerable tenants in general needs funded through enhanced Housing Benefit. For the longer term however we need to look at the tenancy sustainment issue from the perspective of a reinvention of Exempt Accommodation in favour of a wider system of preventative investment. We believe that Investment in Prevention through Additional Housing Management Services for vulnerable people in general needs and in private accommodation should be a function of any replacement system for Exempt Accommodation. This should be the case irrespective of the status of the person’s landlord or ownership status, unlike the current Exempt Accommodation arrangements. In many cases the landlord won’t be the Investment in Prevention provider but whoever is the provider will need to pass muster on the quality and Financial and Social Return on Investment conditions, which would need to be an outcomes-based methodology.
For the future we’d like to see a situation where investment in prevention isn’t a function of the UK Government’s DWP or any other Government department operating to a cash-limited pot. Investment in prevention should be based on a provable social and financial return: it should reduce public expenditure, not increase it. A failure to invest in prevention is a guarantee of the need to spend excessively on emergency interventions, which is bad for everyone.
Support Solutions has been calling for an enhanced definition of vulnerability since we responded to the DWP’s July 2011 consultation on the future of Housing Benefit in supported and sheltered housing.
For the purposes of Investment in Prevention through Additional Housing Management Services, vulnerability should be seen in terms of the implications of that vulnerability for the ability of the person to live independently in their own accommodation. The purpose of Investment in Prevention through Additional Housing Management Services is to maximise independence in relation to accommodation for reasons of both independence and cost. It may well be the case that such people have additional support and social care needs which would need to be separately funded. The purpose of Investment in Prevention through Additional Housing Management Services and the money that funds it is to ensure that vulnerable people are provided with services that enable them to live as independently in ordinary accommodation as possible within the parameters of choice, need and safety.
A full definition of vulnerability needs to be developed for this purpose, which is beyond the scope of this Briefing but essential nonetheless. We will be exploring this further at our National Housing Support & Social Care Conference at the ICC in Birmingham on 13th February 2014, to be addressed by David Brindle, and via our on-line and social media presence. It is essential that vulnerability is properly defined.
Social and Financial Return on Investment
Another issue that requires development is a methodology to calculate the Financial and Social Return on Investment of Investment in Prevention through Additional Housing Management Services. Such approaches are complex because people are complex and statutory sector infrastructure such as the NHS, Local Authority social care, homelessness, criminal justice and others will have different needs that require different outcomes from Investment in Prevention through Additional Housing Management Services, for example, the NHS might want to see reduced levels of hospital admissions (voluntary and compulsory), reduced pressure on GP surgeries, reduced length of stay in hospital, reduced pressure on community health services etc. Homelessness departments would want to see fewer statutory homelessness interventions; landlords want fewer voids and associated costs, lower arrears, less anti-social behaviour and so on.
Again, at our conference on February 13th we want to focus on discussing a meaningful basis for calculating/quantifying both the financial and social benefit of Investment in Prevention through Additional Housing Management Services based on the notion of the maximisation of independence and the minimisation of financial cost by way of interventions that would not have had to happen if cost effective interventions such as Investment in Prevention through Additional Housing Management Services had been in place. Actually, this is exactly what the Exempt Accommodation rules do, albeit that their scope is limited by the way they are currently constructed. Support Solutions believes that the time is right to understand these rules better and to change them so they are fit for the future. These rules have worked very well, despite their limitations, the level of misunderstanding about their application and the fact that Support Solutions has made it a primary concern to ensure they fund Investment in Prevention through Additional Housing Management Services properly. This is an example of a focus on value not cost. It remains more important than ever that providers who have not yet gone down this route do so.
If we are to reinvent Exempt Accommodation we need to focus on the needs of the tenant, not the nature of the landlord. We need to focus on the integrity, commitment and cost of the Additional Housing Management Services providers through compliance with a simplified Quality Assessment Framework based or other quality standard and we need to focus on a methodology for Financial and Social Return on Investment that is non-bureaucratic, capable of flexibility and is convincing to the DWP, the UK Government as a whole and devolved Governments within the UK.
At a strategic level the DWP has said that any new system to develop or replace Exempt Accommodation should not involve any increase in departmental expenditure. This is an example of a failure to focus on value not cost and a failure to acknowledge that one Government department’s expenditure cut is another department’s cost increase. In this case, if the DWP reduces what is currently Exempt Accommodation expenditure for preventative services there will be an immediate and far more significant increase in expenditure elsewhere in the NHS, criminal justice, social care and homelessness budgets. Whether money comes from the DWP or any other Government department; it’s all public money. It is really very short sighted for Government to focus on departmental expenditure targets without considering the overall impact of all public expenditure.
We should focus on value not cost. If a reduction in expenditure on prevention causes a far greater increase in expenditure on crisis intervention, which it evidentially does (CAP Gemini and Frontier Economics), then the capping of expenditure on prevention is a logical absurdity and we remain in the ludicrous position of focusing on cost, not value, and we end up spending far more money than we should on interventions that would otherwise be unnecessary and human pain and suffering which is absolutely avoidable.
The UK Government’s view that “welfare” expenditure should be reduced should be tempered by the need to target such expenditure so that it leads to social benefit by way of independence for vulnerable people, and financial benefit by way of reduced pressure on statutory services and a significant reduction in public expenditure. Funding for prevention should be given to accredited providers, not landlords, albeit that many such providers may also be landlords; Registered Providers being the obvious example. These providers should be able to deliver Investment in Prevention through Additional Housing Management Services to any vulnerable person, irrespective of their occupancy status, though means-testing would be necessary.
- Support Solutions is of the view that many services that have been deemed not to meet the precise definition of Exempt Accommodation are Exempt Accommodation, specifically many agency-managed schemes and many schemes that are claimed not to provide sufficient “care, support & supervision”.
- We believe that Tenancy Sustainment services can and should be provided to vulnerable people in general needs social lettings through the Exempt Accommodation rules.
- We think that the Exempt Accommodation rules should ultimately be replaced by a wider system of “Investment in Prevention” wherein entitlement to such services should not be dependent on the legal identity of the landlord and should also be open to owner-occupiers on a means-tested basis.
- “Investment in Prevention” should not be funded through the cash-limited budget of the DWP and money should be paid to accredited providers on the basis of a common Social & Financial Return on Investment methodology and with a focus on value before cost.
- Constitutional change within the UK may enable devolved Governments (or an independent Scotland) to facilitate this.
- The current/recent negotiations between the DWP and sector advisers appear to us to be problematic in that the sector has not been sufficiently involved in them. They have resulted in what appear to be pyrrhic concessions at the possible expense of Exempt Accommodation tenants now being subject to the Spare Room Subsidy (Bedroom Tax), from which they were previously exempted. This would be a particular issue for Tenancy Sustainment services for vulnerable tenants in general needs accommodation. We would be happy for our fears on this to be allayed.
- We need an agreed definition of “vulnerability” and a common Social & Financial Return on Investment methodology.
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