Local authority interventions to improve quality in supported housing

Question 1

1.  Supported housing, quality concerns and the supported housing pilots

Accepted Answer

1. This chapter includes:

what supported housing is and its key functions
quality and value for money concerns in supported housing
the supported housing pilots that tested local authority interventions to improve quality and value for money
what this resource is, how it was developed, and how it might be useful for local authorities

What is supported housing?

2. Supported housing is accommodation packaged with support or care to enable some of the most vulnerable people to live as independently as possible in the community. The cohorts these service support include:

older people
people with a learning disability
people with a physical disability
autistic people
individuals and families at risk of or who have experienced homelessness
people recovering from drug or alcohol dependence
people with experience of the criminal justice system
young people with a support need (such as care leavers or teenage parents)
people with mental ill health
people fleeing domestic abuse and their children

3. These are not always distinct groups and many individuals may have multiple needs.

4. Supported housing providers should deliver good quality accommodation and support provision, working to maintain or increase the levels of independent living for their residents, according to their needs.

Quality and value for money concerns in supported housing

5. There have been increasing reports of poor quality supported housing, often concentrated in non-commissioned short-term (or ‘transitional’) accommodation. Reports include issues with the quality of both accommodation and support and, in some cases, residents not receiving any support at all. As a result, there are concerns about the detrimental impact this can have on resident wellbeing and outcomes, the neighbourhoods surrounding these schemes, and the pressure this can place on public services.

6. For residents on a low income, help with housing costs (e.g., rent and eligible service charges) can be funded through Housing Benefit if certain eligibility criteria are met. For residents living in properties which meet the criteria for ‘exempt accommodation’^{[footnote 1]} Housing Benefit is not restricted by welfare reforms such as the Benefit Cap which may apply to residents in other types of social or private housing. Therefore, where supported housing is of poor quality, it comes at high cost to the public purse and represents poor value for taxpayers’ money.

Supported housing pilots

7. To address these concerns, in October 2020 the Department for Levelling Up, Housing and Communities (DLUHC) launched year-long pilots in 5 local authorities to test ways to improve quality, value for money, and oversight of supported housing. The Department for Work and Pensions (DWP) supported the pilots.

8. Birmingham, Blackburn with Darwen, Blackpool, Bristol, and Hull Councils received a total of £5.4m to carry out a range of activities to address the challenges associated with poor quality supported housing.

9. All areas focused on the short-term part of the market, which is where concerns have been concentrated. The accommodation is typically intended to be used for up to 2 years (although this can vary) often to support residents with multiple complex needs, and/or following a life crisis such as homelessness, domestic abuse, substance misuse, or mental ill-health. The support aims to build the skills and confidence needed for the individual to move on to general needs or other appropriate long-term housing.

10. The pilot’s core activities included:

Strategic planning – the pilot authorities developed plans to better understand local need and supply. This enabled them to make informed decisions about new provision and encourage providers to deliver supported housing that met local need.
Inspections and enforcement of accommodation standards – the pilot authorities inspected supported housing to check and monitor the quality and safety of accommodation. Where hazards were identified, providers would be required to resolve the issues within specified timeframes.
Reviewing the support provided to residents – the pilot authorities reviewed the support provided by conducting person-centred interviews with residents. Where support was insufficient or could be better tailored to the individual, they created improvement plans or worked collaboratively with the providers to improve the support provided.
Enhanced scrutiny of Housing Benefit claims – the pilot authorities increased their scrutiny of Housing Benefit claims and providers who were charging or intending to charge rent that would be covered through residents’ Housing Benefit. This ensured that the rents and services charges being claimed were justified and that the provider and scheme met eligibility criteria.

11. The pilot authorities supplemented these activities with initiatives that addressed the challenges of their local context.

12. All participating local authorities took a joined-up approach between council departments and with external services including police, specialist charities and providers of excellent quality supported housing. This approach helped to deliver these activities in a joined up way and improved the quality of supported housing.

13. The pilots reinforced the government’s National Statement of Expectations (NSE) for supported housing, which was published in October 2020 and sets out the government’s vision for the planning, commissioning and delivery of accommodation in supported housing.

14. The pilots completed in September 2021 and have been independently evaluated by Kantar Public. The full report includes many positive results.

Who might use this resource?

15. This resource outlines the interventions that the pilot authorities found effective for improving quality and value for money in supported housing. It has been developed by DLUHC in close consultation with DWP and the pilot authorities.

16. As these interventions have been tested by a group of local authorities over a year, this resource will be of use to local authorities that want to:

drive up the quality of support and accommodation
improve value for money
effectively manage the supply of supported housing in line with local need
improve oversight of supported housing

17. Many of the successful interventions benefited from a multiagency approach. Therefore, this guide will also be useful for organisations with an interest in supported housing who currently work, or would like to work, in partnership with their local authority.

Question 2

2.  Establishing a council multidisciplinary team

Accepted Answer

18. This chapter includes:

who to include in a multidisciplinary team
the benefits of a multidisciplinary approach, particularly where the team has support from the council’s senior leaders
how a multidisciplinary team can collaborate with external partners

Establishing a multidisciplinary team

19. Bringing together the relevant teams and skillsets in a multidisciplinary council team can deliver benefits to the delivery of the interventions in this resource.

20. It is beneficial to include representatives from teams such as:

Revenues and Benefits
Adult Social Care
Domestic Abuse
Safeguarding
Housing Options
Homelessness and Rough Sleeping
Legal
Environmental Health
Health and Safety
Planning
Support Commissioners
Information Governance

21. The benefits of a multidisciplinary team when carrying out interventions to improve quality and value for money are:

bringing together knowledge from a range of services that have responsibility for the accommodation, support and welfare of residents, enabling a holistic approach to addressing issues
a clear and positive message to providers and residents that relevant teams in the authority are working together
a more consistent, efficient approach to prospective providers and new schemes
better local authority oversight of new providers and schemes before Housing Benefit claims are processed

22. It is important that relevant stakeholders are aware of the team’s responsibilities and objectives. This should include:

internal council departments – if a provider tries to contact the authority via any other route than the multidisciplinary team (for example, seeking agreement of costs from the Revenues and Benefits team), these teams will be aware that the provider should be redirected.
external agencies – agencies such as probation and police can provide intelligence to the team on providers considering setting up and instances of anti-social behaviour resulting from existing provision.
the public and service users – if residents are aware of the team’s work, they can contact them more easily.

23. The pilot local authorities reported buy-in from the council’s senior leaders and political leadership to be particularly influential for the multidisciplinary teams’ success.

24. Clear senior support within the council, through a sponsor or a more formalised governance structure, such as a supported housing board, can:

establish a clear council-wide position on new and existing supported housing
improve team confidence in making decisions about new providers and provision
create an escalation process for managing issues of poor quality provision, especially when there are cross-cutting concerns or implications
demonstrate that the council is committed to acting against poor quality supported housing, which can help to:
- deter providers whose schemes represent poor quality and value for money
- reassure residents and neighbourhoods that the council is committed to addressing concerns

25. This resource will refer to activities as being completed by a council multidisciplinary team, as this is the approach that all the pilot authorities found effective.

Working across organisational boundaries and collaboratively with a provider to apply a multi-agency approach to support a vulnerable resident in Blackburn

Blackburn with Darwen Council established close working relationships with providers of good quality supported accommodation through the pilot. This enabled regular communication between the council and these providers, which resulted in better support for residents through a multi-agency approach.

One case saw the council assist a provider in supporting a resident, Hannah*, with mental ill-health who was struggling with hoarding behaviours. The concerns had become so significant that they were causing health hazards to Hannah and other residents in the scheme. Hannah was not engaging with support to clear or tidy the room, and this led to the scheme contacting the Council’s Housing Needs Team in relation to her likely imminent eviction.

In response, a council Housing Officer visited the scheme. The council and the provider sought a resolution that supported both Hannah and the other residents in the property, and evictions should only be a last resort when people have multiple and complex needs. In addition, they noted that exposing Hannah to street homelessness would likely exacerbate her health concerns. The Housing Officer requested appropriate assistance from colleagues, including House in Multiple Occupation (HMO) compliance officers, to make the resident’s room safe. The scheme and council staff both adopted a person-centred approach to supporting Hannah through the clearing and cleaning of the room, as this was a challenging process for her. Taking a person-centred approach meant talking to Hannah, explaining the issues and concerns, and listening to her perspective. Together, the scheme and council staff worked with Hannah to form a plan of action that she had input into and felt comfortable with.

Hannah was able to retain her accommodation and she agreed to a daily room check by the provider to help her to better maintain her room, her hygiene, and keep on top of her hoarding behaviours. The council’s Housing Officer spoke to Hannah in more detail about her mental ill-health and they made a referral to re-establish her engagement with the Community Mental Health Team.

Working collaboratively with external partners

26. The pilot authorities found working with external agencies key to joining up on supported housing matters and effective data sharing. These include:

providers of high-quality provision
homelessness charities
drug and alcohol services
police
probation
referral agencies

27. The benefits of working with these organisations include:

preventing referrals into poor quality provision by working together to support residents into appropriate provision
providing improved multiagency interventions where residents are receiving poor or insufficient levels of support
improving and streamlining the journey for supported housing residents who have contact with different organisations and agencies
developing an effective overarching local strategy on the supply and quality of supported housing in the area
increasing the council’s access to training by specialist agencies

Working with external agencies to address local concerns and improve neighbourhood conditions in Birmingham

Prior to the pilots, Birmingham City Council had no dedicated department responsible for investigating reports of anti-social behaviour (ASB). Reports of ASB passed between various departments and work was either duplicated or fell through the cracks as each team believed others would deal with the incident.

Through the pilots, the council sought to identify ASB related to supported accommodation which allowed them to examine whether providers could be doing more to prevent the behaviour.

They developed strong working relationships with West Midlands Police, which allowed swift information and intelligence sharing around ASB. This allowed the council and the police to take positive action more quickly and decisively where complaints were received. The council were able to determine which supported housing schemes to focus their efforts on and effectively combat ASB in local communities. The council completed 193 investigations into ASB issues related to supported accommodation, all of which resulted in a form of positive action - whether providing advice to providers or the rare need for a more extreme intervention such as a closure order or decommissioning of a property.

The pilot has given Birmingham’s local residents, councillors and MPs a supported housing team which acts as a single point of contact for concerns around ASB. Local communities now feel that the council is taking their concerns seriously as ASB investigators knock on neighbours’ doors to inform them of the council’s attendance in the area and what action is being taken.

Question 3

3.  Undertaking strategic planning to understand local need and supply

Accepted Answer

28. This chapter includes:

the benefits of strategic planning
how the pilot authorities developed their plans

29. The pilots focused on developing strategic plans for short-term supported housing, which is reflected in this resource.

The benefits of strategic planning

30. The benefits of developing and maintaining a strategic plan for supported housing include:

increased cross-council understanding of local need and supply, including where any gaps in good quality provision exist
enhanced ability to plan to meet projected future need in a sustainable way
sending a strong signal to providers of potential new schemes about the type of provision needed in the area, encouraging them to meet this need
improved joined up working with other local authorities, providers, and relevant agencies
a shared understanding of the council’s objectives for the supply of supported housing

Develop a strategic plan

31. Strategic planning includes:

assessing current need and existing local supply
projecting future demand
projecting future supply
identifying any gaps between future supply and demand and planning to meet these gaps

32. In developing a strategic plan, it is helpful to collect data on existing supported housing stock and local demand. Utilise any existing local strategies that provide data on local need and combine these with newly collated data to avoid duplication.

33. Work collaboratively across council teams including:

Commissioners of supported housing and care and support services
Homelessness and rough sleeping
Children’s Services for young people leaving care
Adult Social Care teams

34. It can be beneficial to work with external specialist agencies and charities with a local presence. This could include organisations that specialise in:

drug and alcohol misuse
domestic abuse
children’s services
mental health
probation

35. To understand local need that is, and is not, being met by existing supported housing provision, you might collate:

the total number of people living in the area
the number of people currently living in supported housing
the number of people on supported housing waiting lists
an estimate of the number of people not currently receiving adequate support in their accommodation which local organisations and charities may hold relevant information on
projected future demand

36. Identify and log known data on existing supported housing:

the number of units and schemes of supported housing
the number of commissioned and non-commissioned services
the cohorts the provision caters for
the support being provided at the accommodation
any areas with a high concentration of supported housing

37. Estimate what new provision is in the initial stages of being set up by considering:

planning applications for supported housing
notifications of new schemes setting up
any recent growth of supported housing in the area
any discussions taking place on meeting local need, including where commissioned funding is not available

Question 4

4.  Conducting a standardised assessment of new providers and schemes

Accepted Answer

38. This chapter will explain the:

stages of a standardised assessment that were carried out by the pilot authorities
benefits of a standardised assessment process for new schemes and/or providers
benefits for local authorities of improving oversight of new providers and/or schemes

Standardised assessment process

39. The pilot authorities found increasing their oversight of providers of proposed or new schemes in a consistent way to be valuable. The benefits of working with providers on a scheme from the start include:

developing a positive working relationship with the provider to ensure a commitment to delivering good accommodation and quality support services is in place early on
checking whether the scheme, once future claims are made from a resident, is unlikely to meet the criteria for specified accommodation (e.g., including exempt accommodation), as set out in Housing Benefit regulations, before a Housing Benefit claim is made
meeting local need more effectively by advising providers on local demand and priorities

40. Standardising the assessment process can help the multidisciplinary team:

provide a clear and consistent service to new providers and existing providers setting up new schemes
provide a single response to all providers who may have different contacts within the council
gather all the information they need to assess new providers and schemes
benchmark and make comparisons between providers

41. The assessment should have a clear structure through which providers/schemes can proceed. The stages, as conducted by the pilot authorities, are:

send a template for a provider to complete with their supported housing scheme proposal
review the proposal
conduct due diligence checks of the provider, organisational structures and professionalism of those involved in the scheme’s running
complete an accommodation inspection
conduct a review of the proposed support
communicate the findings to the provider

42. The assessment can be adjusted based on the stage the new schemes is at. For example, if an accommodation inspection cannot be conducted, a provider’s proposal for the provision will need to be considered and further reviews may take place once the scheme is set up.

43. Providers proposing good quality accommodation and support should be able to pass quickly through the stages, particularly if the scheme meets local need. Some local authorities, where they know the provider has a proven track record for delivering good quality supported accommodation in the area, may decide to keep reviews light touch.

Local authority powers that can be applied when assessing new providers and schemes

44. Local authorities have the power to:

A form for providers of new schemes to complete

45. Upon request, send the provider of a new scheme a form to complete, with a clear deadline to return it. You may choose to be clear that you will only process forms that include all the requested information.

46. A form to send to providers creates consistency for the team processing them and for providers completing them. Including space for free text can prevent the process being a ‘tick-box exercise’ to help assessors from the multidisciplinary team identify levels of commitment and experience.

47. The form can request information on the provider’s organisation and their supported accommodation proposal including:

the name of the provider and others involved in the organisation, e.g., landlord, support provider, managing agent
the responsibilities of all organisations involved
whether the provider is registered with the Regulator for Social Housing (RSH)
the cohort(s) the scheme is for
the area the scheme is opening in and why that area was chosen
where applicable, information on other supported housing schemes the provider has a responsibility for – within the same authority and outside

48. Support provision and accommodation should either be explained or proposed:

description of the site including photographs, why the site was chosen and how it will be maintained
cohorts the provision is for
example support plans and proposal for support delivery
the support delivered on site, how it will be funded and the support that can be signposted to
a breakdown of housing costs, including a breakdown of estimated service charges
template occupancy agreement used at the scheme
previous experience of the provider and/or staff
staffing structures
training for support workers and DBS (Disclosure and Barring Service) checks
size of caseloads
example documentation such as risk assessments
details of existing multiagency networks and relationships the provider is involved with

Reviewing the form

49. Whether the scheme is vacant or occupied, the multidisciplinary team can complete a desktop review of a returned form and any additional documentation, considering the following questions:

Does the scheme meet local need and is it in a suitable location?
Does the provider demonstrate the experience necessary to deliver supported housing to a high standard?
What is the provider’s experience in providing these types of services?
Does the provider have the right housing management policies in place to be a responsible landlord?
Does the provider have sufficient safeguarding policies in place that are appropriate for the cohort they propose to support?
Is the support at a scheme, or the proposed support, sufficient and designed to be tailored to residents’ needs to produce positive outcomes?
Do pictures of the accommodation look safe and suitable for the needs of the residents?

50. If you assess that a scheme proposal would benefit from improvements, or the information provided is lacking detail, it is recommended that you contact the provider with recommendations or further requests.

Due diligence checks of the provider’s organisational structures and professionalism of those involved in the scheme’s running

51. Due diligence checks can help a local authority to ensure that a provider complies with all requirements on supported housing, including that they are a not-for-profit organisation.

52. Considerations should include:

who is involved in the organisation, e.g., owners, partners, support providers, managing agents, social landlords, charities, trustees
which organisation or people are responsible for which scheme services e.g., accommodation, support, or funding
what the reporting structure of those in the organisation looks like
whether the provider is registered with a regulator, e.g., the Regulator of Social Housing (RSH), the Care Quality Commission (CQC), the Charity Commission, Ofsted (Office for Standards in Education, Children’s Services and Skills), or the Office of the Regulator of Community Interest Companies, and what level of scrutiny the provider would receive through this
who residents pay rent and service charges to and what the rent structure looks like
if there are lease arrangements and what the terms of the leases are
whether the rental costs and service charges are justified and meet regulatory requirements (if providers are registered with the Regulator of Social Housing)
any links between involved parties that could present a conflict of interest
whether all parties are conducting professional activities with the goal of providing quality support and housing to residents

53. To answer these questions, consider requesting the following from providers:

proof of funding for support costs to ensure that providers have a separate funding stream for support
information on staff structures, job descriptions, hours worked and salaries (rotas may provide a good example of the level of staff cover on shifts)
the Service Level Agreement between the landlord and support and/ or care provider to determine what responsibility each party has for the provision of care, support and supervision, to determine the accommodation’s status
the lease agreement particularly where a core rent comprises a charge for a lease to a Superior Landlord
assurances on how any conflicts of interest of those within the organisation are appropriately managed
invoices and receipts to verify who is responsible for paying all outgoing costs

54. Assessments can be complemented by extra research into the provider through:

online searches
checking whether they are registered with Companies House or the Charity Commission
enquiries to other local authorities in which the provider delivers supported housing
phone calls or meetings with the provider

55. Providing Revenues and Benefits teams with the research and evidence collected at this stage will support them in making informed decisions once Housing Benefit claims are made.

Accommodation inspections

56. If the new scheme is open and/or accessible, visit the property to complete an accommodation inspection (see chapter ‘Completing accommodation inspections’).

57. If the scheme has only minor or no hazards, it is helpful to feedback these positive findings to the provider.

58. Where significant or major hazards are identified, the provider can be required to address these within appropriate timeframes.

Reviewing support

59. If Housing Benefit claims have not yet been made, you can assess a scheme level proposal for delivering support to residents. A provider can be asked to provide this proposal along with their completed form.

60. If residents are living at the new scheme and Housing Benefit claims have been submitted to Revenues and Benefits teams, you can conduct reviews of resident support (see chapter ‘Reviewing resident support’).

Communicating findings effectively to providers

61. Once assessments have been completed deliver your findings clearly to providers.

62. Where improvements are required, a comprehensive letter will demonstrate that the local authority has conducted necessary research and has evidenced why further improvements or information is needed. Letters should be clear and concise and can be structured as:

Introduction – the stage in the assessment process that has identified concerns with a new scheme
Background – what you know about the provider and scheme
Explanation of the assessment – the regulations and definitions that the assessment is measuring against
Concerns or questions about the provider and/or scheme, and what further information would be needed to meet requirements
Requests for contact information e.g., for councils in other areas in which the provider operates
Next steps and timeframes for:
- the provider to acknowledge the questions and/or recommendations
- Improvements to be made for the application to remain open
Contact details for the council team

63. It may be useful for the multidisciplinary team to call or meet with the provider to communicate the findings verbally.

64. Providers of good and excellent provision should also be positively acknowledged when delivering assessment findings.

Joined up working with Revenues and Benefits teams

65. Joined up working between the multidisciplinary team and the Revenues and Benefits team, is key to ensuring the assessment process is streamlined.

Revenues and Benefits teams should inform the multidisciplinary team when they receive claims from residents at new schemes. If the multidisciplinary team are not already aware of the scheme, the provider can be redirected to the assessment process before Revenues and Benefits makes any decision on claims.
The multidisciplinary team should inform Revenues and Benefits teams when they are assessing a provider and scheme and make them aware when claims are likely to be made.

66. Revenues and Benefits teams will assess and decide an individual claim on its own merit. Providing the findings on a provider and scheme to Revenues and Benefits teams can support them in assessing whether criteria in Housing Benefit regulations are being met.

Joined up working with Revenues and Benefits teams to improve support for residents in Blackpool

From the early days of the pilots, Blackpool Council sought to join up internal teams for the purposes of supported housing matters. They quickly established that collaborative working between Revenues and Benefits teams and teams with experience of cohorts with support needs, could provide training opportunities and make interventions to improve quality more effective.

The Commissioning Team undertook work describing the support needs of client groups commonly housed in supported housing. They shared this with Revenues and Benefits colleagues so they could better understand the different levels and types of support that someone with mental ill-health or a learning disability, for example, might need to access.

This increased Housing Benefit Officers’ expertise in supported housing, understanding what evidence they should expect from a provider to demonstrate minimal support is being delivered to the claimant. Overall, this process helped Housing Benefit Officers make more informed decisions about claims.

Many in Blackpool Council’s pilot team believe that collaboration has been the most valuable and positive aspect of the pilot.

Assessments completed

67. If the provider has worked effectively with the local authority and has demonstrated their ability to deliver a quality service, then the scheme is more likely to receive local authority backing. You may wish to:

prioritise referrals into these schemes and encourage other referral agencies to do the same
inform commissioning teams to ensure providers that are delivering noticeable positive outcomes for residents are considered when resources are available

68. If the team is not confident that the accommodation and support are of sufficient quality, but the provider proceeds with setting up a scheme, you could discourage referrals into the scheme and encourage other referral agencies to do the same.

Question 5

5.  Reviewing resident support

Accepted Answer

69. The chapter includes:

what a resident support review is
how to plan and deliver a resident support review programme
how to conduct a person-centred interview with residents
how to assess the quality of support and convey findings to providers

Resident support reviews

70. Local authorities can assess the support in place for residents who are living in supported housing and in receipt of Housing Benefit.

71. A review determines:

whether an individual needs support
what support is required
the extent to which the support provided meets the needs of the individual

72. If a review finds that the provider could do more to meet the individual’s needs, or that no support is provided at all, provide the landlord with recommendations for improvement and follow up to check that progress has been made.

73. Conducting resident support reviews allows the authority to:

listen to resident voices and ensure improvements to support are reflecting resident experiences and the change they want to see
identify residents who are at risk in their provision who may not have felt able to report it and support them in having the risk addressed
build a Council presence within supported housing where residents feel more supported and encouraged to communicate with the authority if they have concerns about their scheme or provider

74. The pilot authorities implemented a resident support review programme across multiple supported housing schemes where residents were in receipt of Housing Benefit.

75. Undertaking a proactive programme of reviews gave authorities greater oversight of the quality of supported housing and was often the first step in improving outcomes for residents.

Delivering a resident support review programme

Establishing a review team

76. Establish a team that is responsible for reviewing the support delivered in supported housing. This should reflect the principles of multidisciplinary working (see chapter ‘Establishing a council multidisciplinary team’).

77. Develop partnerships with specialist agencies and charities to include those with experience of supported housing in teams that are conducting interviews with residents. Doing so can:

help to build residents’ trust that the process will support them
encourage residents to speak openly and have their voice heard
ensure assessments of the quality of support reflects experiences of those who have lived in supported housing services

78. It is important that all those conducting support reviews complete necessary security checks and, for those without sufficient previous experience, receive appropriate training. This includes core competencies relating to:

safeguarding
equalities
knowledge of housing related support
building safety
building professional relationships in a housing and homelessness/ rough sleeping context
managing aggressive and difficult behaviours
professional boundaries

79. Training should ensure that those in the team:

understand the principles of a person-centred approach
have a clear expectation of what tailored support looks like and what it can achieve
understand how best to work with vulnerable people and have good interpersonal skills, being able to build rapport with a diversity of people
can assess if an environment is safe for both the reviewer and the resident
can identify potential risks to residents
can identify a hazard that compromises safety in a residential building
understand the necessary personal data (including sensitive data) that they may need access to, to deliver effective reviews

80. Collaborate and build partnerships with providers of excellent support services to further support the training of a newly established review team.

81. Where appropriate, specialist training should be delivered to the multidisciplinary team by experts within specific fields, for example, domestic abuse organisations and children’s or adult social care services.

Planning and targeting a schedule of reviews

82. When planning the schedule of a review programme, you may focus on providers and schemes where there are indicators of a poor quality service. Or you may conduct sample checks across all local supply to improve oversight of the wider local market (see chapter ‘Planning and targeting interventions effectively’).

Reviewing support at scheme level

83. Reviewing the support at scheme level can indicate whether the required structures, policies and processes are in place to deliver effective support to residents.

84. Make use of any information already on file for the provider and/or scheme and ensure any request for information is appropriate and relevant to the review taking place.

85. Similar to conducting a standardised assessment of providers, you may find it useful to request:

the name of the provider and others involved in the organisation, e.g., landlord, support provider, managing agent
the responsibilities of all organisations involved
the area and address of the provider’s scheme(s)
the cohort(s) the scheme houses
evidence of a separate funding stream for support
resident satisfaction forms completed anonymously
description of the site (ideally with photographs), why the site was chosen, and how it is maintained
the model occupancy agreement
a description of the support provided at the scheme and how the provider ensures it is delivered effectively:
- mission statements
- example support plans
- explanation of what support can be delivered on site and what support can be/is signposted to
- previous experience of the provider and/or staff
- staffing structures
- training for support workers and evidence of DBS checks
- size of caseloads
- relevant policies, such as safeguarding
- example documentation, such as risk and needs assessments, the standard referral process and occupancy agreement
- if applicable, the quality and/or accreditation standards worked towards

86. Resident’s safety and data protection protocols must always be respected.

Conduct thorough risk assessments before conducting reviews
Consider adjusting the review process, and how data is requested, collected, and handled, to reflect certain circumstances. For example, ensure specific data handling policies on the location of safe houses or refuge accommodation for those fleeing domestic abuse are followed
Ensure that a resident’s data is shared only when necessary, such as to manage a risk and ensure their safety and wellbeing, and data sharing policies and procedures are followed appropriately

87. When visiting the scheme to conduct a scheme level review, it is beneficial to:

talk to staff about the policies and procedures at the scheme, and whether they feel equipped to provide adequate support and deliver positive outcomes for residents
conduct a light-touch and informal accommodation inspection. Any obvious hazards identified can be logged and followed up through a more detailed accommodation inspection

88. Implementing confidential complaints and feedback systems can provide you honest information on resident and staff experiences.

Reviewing referral processes

89. When reviewing support at scheme level it is important to assess how providers accept and decline referrals into their schemes. This includes looking at the referral pathway itself and the documentation used to collect information on residents’ needs.

90. A good referral process will include an assessment of the resident’s needs based on sufficient information provided by a referrer. A quality needs assessment and referral process:

improves referral and assessment consistency for all staff at a scheme and for referral agencies
ensures residents will receive sufficient support in appropriate accommodation
ensures prospective residents are a suitable addition to the mixture of residents already living at the property

91. Speak with staff to understand what their standard referral process is and assess this alongside a sample of a provider’s referral documentation.

92. Resident experience of the referral process is important. If you intend to conduct person-centred interviews with residents later, it is valuable to ask them about:

their experiences of the process
the level of information they were provided with
what choice they had in where they were offered

93. A poor quality assessment process may lead to poor quality or unsuitable support provision. Where a reviewer has identified inadequate or poor quality need assessments and/or referral processes, present this to the provider and suggest recommendations for improvement.

Reviewing support at an individual level

94. Reviewing the level and quality of support at an individual level by conducting person-centred interviews and considering individual support documentation, can help the reviewer to understand the resident’s experiences and to drive improvements.

95. To conduct individual level support reviews:

consider how many residents to conduct reviews with at each scheme
contact residents directly to arrange a review of their support and ask the provider to assist with this if needed
ensure that all parties understand what to expect from the review

96. Make sure the process is set out clearly for providers and residents, including:

the format and purpose of the review
dates and times for the appointments
where the review will be held (an appropriate private space)
providing the option for a male or female reviewer where appropriate
timings for next steps following the visit

97. Request permission from the resident to review the support they are receiving and consider using permission forms for residents to sign when requesting support documentation. Written consent is not a requirement of reviewing support documentation if the resident is in receipt of Housing Benefit. However, being transparent about the benefits of the review process and the council’s intentions can improve resident cooperation with the support review.

98. Ask the provider to share documents they have on file for a resident that are relevant for reviewing the support. This may include:

a signed and current license agreement or tenancy agreement
a sample of assessment forms – needs assessment, risk assessment, initial assessment or multiple, as appropriate
information about the resident’s referral into the organisation
an outcome-based support plan
evidence of the provider’s regular reviews of the support plan

99. The documents should be assessed for whether they are appropriate for the support being provided. It may be that the support on site or meeting the resident’s needs does not require all the above documentation.

100. The absence of any relevant documents or information can be considered when undertaking the review assessment. It may be appropriate to recommend that the provider starts obtaining or completing these documents.

Person-centred interviews with residents

101. The purpose of conducting a person-centred interview as part of a support review, is to understand the resident’s experiences of their provider and the support they receive, in their own words.

102. The findings from the interview can be compared with assessments of support plans and scheme level reviews, to provide a full picture of the support being provided and whether it is tailored and sufficient.

103. Conducting a resident support review in person can help the reviewer to:

build positive relationships with the resident, increasing confidence in the local authority
assess body language, giving a clearer sense of how the resident feels and acts in this space
hold open and honest conversations, as the review team may not always be confident that phone interviews are being held privately

104. Before conducting an in-person review, consider the safety of both the resident and the reviewer.

conduct sufficient and relevant risk assessments
assess whether reviews are best conducted by an individual reviewer or multiple. If it is an individual, a lone-working risk assessment should be carried out
consider whether the resident would benefit from support in the interview, for example, a family member, peer advocate, support worker or translator
ensure that in-person support reviews with very vulnerable cohorts, such as those with multiple complex needs or survivors of domestic abuse, are conducted, or supported, by someone with experience of working with those cohorts

105. When conducting an interview with residents, reviewers should aim to:

understand the resident’s support needs
whether the provider is delivering sufficient support that is tailored to the resident
consider and respond to any risk(s) posed to the resident, including agreeing a plan to address risks and take immediate action if there are safeguarding concerns

106. The reviewer should:

reassure the resident that the conversation is confidential
aim to build a rapport with residents to encourage open conversation while understanding this may not happen immediately
be sensitive to the vulnerability of some residents, as some residents may feel uncomfortable or unwilling to answer some questions, and reviewers should be able to adapt and respond appropriately
speak to residents privately and individually to understand their experiences of their support in their own words

107. It is important to be aware that some residents may find it challenging to speak openly about their experience of their accommodation and support (see chapter ‘Potential risks and challenges’).

Where access is refused

108. It is the resident’s choice whether to engage with the local authority and cooperate with an interview. If a resident declines the opportunity, you may decide to conduct a desktop review of the provider instead.

109. Local authorities do have powers that can help them assess the quality of support and provision.

Under regulation 86 of the Housing Benefit Regulations 2006, local authorities can request information in relation to a Housing Benefit claim. This includes requests to verify support provision.
Where the authority is already completing a property inspection under the Housing Act 2004, having provided Notice of Entry, officers may wish to arrive to conduct support reviews as the accommodation inspection is scheduled to be ending. The right of entry to complete the property inspection does not extend to the support review, but the combination of these actions may facilitate access and reduces disruption for residents and support providers.

Assessing the findings

110. Once all planned reviews at a scheme have been conducted, make an overall assessment and set out key findings. An assessment of the documentation, resident interviews and conversations with scheme staff can:

conclude whether the support in place is tailored to residents’ needs as much as possible (this should consider both what the resident has said they require and what the provider and referrer (where relevant) have set out as the resident’s support requirements)
clarify whether the provider has accurately depicted the support they are delivering
determine whether residents are treated with compassion, dignity, and respect, all with the goal of moving towards greater independent living

111. Provide recommendations to the scheme where improvements could be made to the quality and/or suitability of support.

112. Logging the results by scheme, with space to log future visits, can provide useful oversight of the quality of local provision and any changes.

Follow up

113. Following up with the provider ensures they acknowledge and understand the assessment findings and are beginning to take steps to improve where needed.

114. You can act upon the reviews by:

collating the review findings from the scheme and identify consistent positive support practices and where improvements can be made
contacting the scheme with overall findings and make recommendations based on these
sending a brief and accessible letter to the resident to inform them of the local authority’s recommendations to the provider

115. Where residents have low expectations of their accommodation and support provision, this is an opportunity to lay out what they should expect from their provider and accommodation. A phone call may be more appropriate to relay the findings to some residents.

116. Providers of good and excellent provision should also be positively acknowledged through this follow-up process.

117. When providing feedback, particularly when it includes recommendations for improvement, also provide:

dates by when the provider is asked to a) acknowledge the recommendations and b) complete and evidence actions and next steps
contact details to give the provider the opportunity to discuss the feedback further and any potential support that could be given to the provider where they may be inexperienced

118. On or around the final deadline to implement recommendations, revisiting the scheme to view and record the improvements may be helpful.

119. Responding positively to recommendations can be beneficial to providers as they can:

raise their profile positively with the local authority and referral agencies. This can benefit the provider if they are considering setting up other provision where local authority support would make this more efficient.
work collaboratively with the authority to delivering tailored support for the cohorts and locations where it is most needed

Conducting a review of resident support and suggesting improvements to ensure person-centred support is delivered at a scheme in Blackpool

Blackpool Council conducted reviews of support provided to residents in their local supported housing to identify where support was not sufficient or suitably tailored to residents. The council supported providers in making improvements to better support residents in achieving their goals and greater independent living.

Accommodation for young people was included in some of the council’s support reviews, to ensure the quality of support to this vulnerable group of service users was sufficient. The council invited Young Ambassadors to conduct the support reviews with them and provide their expertise, as they have been through the care system in Blackpool and have an excellent understanding of what people leaving care may need from their support and accommodation.

In one scheme, the council (with support from Young Ambassadors), assessed it as providing good quality support, in safe and suitable accommodation, but identified that staff needed to include more input from residents in their individual weekly support plans. The Young Ambassadors’ experience of living in supported housing highlighted the importance of residents having a choice and a voice in their steps to greater independent living.

Blackpool Council, along with the Young Ambassadors, provided examples to the provider of what improved support plan entries could look like if the young people themselves provided input. Where a support worker had completed a resident’s support plan to say, “Tuesday you are going to the dentist”, it was advised that encouraging residents to input their own entries along with a goal or ambition would help residents to focus on their tasks for the week and celebrate their achievements. If written by the resident, with support from staff, the entry may read, “This week I will make an appointment with the dentist and I will try to overcome my worries and make the visit on my own.” Residents are more likely to be invested in their own progress, goals and achievements when they have made and fully considered their aims.

After the council liaised with the manager at the scheme and agreed this new format for the support plans, the young people reported enjoying setting their own goals and are becoming more confident in achieving them and progressing their lives.

Question 6

6.  Completing accommodation inspections

Accepted Answer

120. This chapter includes:

the powers local authorities can use to enforce accommodation standards
the steps of an accommodation inspection

Local authority enforcement powers

121. Under the Housing Health and Safety Rating System (the HHSRS), Housing Act 2004, local authorities can inspect accommodation standards in supported housing and require improvements.

122. It is beneficial to maintain regular communication with the local Fire and Rescue Service for schemes with communal areas. Under The Regulatory Reform (Fire Safety Act) Order 2005, the council and local Fire and Rescue Service have a shared responsibility for oversight of fire safety in communal areas, such as those in a House in Multiple Occupation (HMOs) and larger supported housing schemes, including hostels.

123. You may want to implement a joined-up approach to accommodation inspections with the local Fire and Rescue Service.

Accommodation inspection

124. To complete an accommodation inspection:

provide a Notice of Entry to providers before attending
explain the reasons for the inspection
request information about which people or organisations involved in the service have a compliance responsibility, including requesting the relevant contact information
where hazards are identified, categorise them according to their potential risk to safety (category 1 hazards are the most significant)
contact the person or organisation responsible for reducing or removing the hazard. Local authorities have a statutory duty to take enforcement action if they identify the most serious ‘category 1’ hazards, assessed using the Housing Health and Safety Rating System (HHSRS)
provide a timeframe within which each hazard needs to be addressed. Landlords must comply with this enforcement action and are committing an offence if they do not
log hazards on a database to effectively monitor improvements

125. It is beneficial to use Environmental Health Officers or Housing Enforcement Officers to complete these inspections, as they have the relevant experience to identify and enforce against building hazards.

126. A site visit can ensure:

the property is free of significant hazards
the accommodation is, or would be, a safe and pleasant home
the provider is accurately depicting the accommodation to the local authority as well as current and future residents

127. Undertaking a proactive inspection programme gives greater oversight of the quality of accommodation in supported housing.

128. To ensure the provider is completing the actions, it can be helpful to attend the scheme to monitor improvements. Where the hazards are less significant, you may decide that a provider can send photographic evidence of the completed actions.

Working with external agencies to improve accommodation standards for the benefit of residents in Blackpool

From the early days of the pilots, Blackpool Council sought to implement a locally joined up approach to supported housing. They quickly established where collaborative working between council departments and external agencies could help the pilot interventions have the most impact.

Blackpool partnered with the Lancashire Fire and Rescue Service (LFRS) to maximise the effectiveness of their accommodation inspection programme. Once LFRS understood how the objectives of the pilots complemented their own work to improve the safety of accommodation through inspections, they saw the value of working collaboratively with the pilot team. This collaboration meant the Council’s Housing Enforcement Team and the LFRS Community Safety Team could carry out joint accommodation inspections and share intelligence between teams. For example, when Housing Enforcement Officers identified fire safety concerns, they escalated these to LFRS, who arranged a follow-up visit to the property. Maximising enforcement capabilities ensured providers were held accountable for unsafe accommodation.

Many in Blackpool Council’s pilot team believe that collaboration has been the most valuable and positive aspect of the pilot.

Question 7

7.  Planning and targeting interventions effectively

Accepted Answer

129. This chapter includes:

what data on providers and schemes is useful to collect before planning and targeting interventions
how to identify indicators of poor quality to target interventions
how to identify an appropriate sector-wide sample of schemes to gain broad oversight of quality

Planning a schedule of interventions across schemes

130. There are many approaches you can consider when reviewing schemes in your area. The approach an authority chooses to take will vary based on the local market, scale of concerns and resources available to the authority.

131. Some of the pilot authorities focussed on providers and schemes where there were indicators of a poor quality service. Others conducted sample checks across all their local supply to improve their oversight of the wider local market.

132. To plan either approach, it is useful to collate and organise data on local supported housing, including:

commissioned and non-commissioned
scheme names, addresses and postcodes
provider details, e.g., name, areas in which they operate locally and/or nationally
cohort that the schemes house, e.g., people experiencing crises/homelessness, mental ill-health, or those with a learning and/or physical disability
number of units in each scheme.

133. Collecting this data can improve oversight of the local market and assist an authority when prioritising reviews of schemes.

Assessing schemes based on indicators of poor quality

134. Identifying local schemes and providers where there are common indicators of poor quality supported housing can allow an authority to prioritise interventions based on the level of risk.

135. Assessing supported housing schemes against the following indicators may flag the need for intervention:

non-commissioned support services
number and nature of complaints received by local authority services or external agencies, including the police
concerns from neighbours
where there is a concentration of supported housing
evidence of concerns about a provider in other local authorities
turnover of residents, identified through analysis of Housing Benefit data
a high number of units within a scheme
private rented landlords with leasing arrangements in place

136. Although the presence of risk indicators can highlight the need for further investigation into the quality of a scheme, it is important that any reviews or inspections are conducted from without pre-judging its findings.

Sample checks across all supply

137. Alternatively, you may choose to review a sample of schemes that represent services across the supported housing sector reflecting a:

range of cohorts
variety of scheme sizes
range of quality based on views from commissioners of good providers, indicators of risk and schemes with no obvious reports or indicators of quality

138. This approach:

increases knowledge and oversight of all local supported housing
identifies concerns in provision where the risks are not apparent
identifies good quality provision to prioritise referrals into those schemes
develops relationships with good quality service providers to share and drive good practice

Question 8

8.  Potential risks and challenges

Accepted Answer

139. This chapter outlines:

the risks and challenges that the pilot authorities encountered when conducting their interventions
ways to mitigate against these risks

Reassuring residents and providing security

140. Residents may not feel comfortable speaking openly about their provider if they are concerned about the impact it might have on their tenancy. You can provide reassurance to residents by:

building relationships with them through an increased council presence in schemes with concerns
helping to raise residents’ expectations of support and accommodation
educating residents about their rights
implementing confidential complaints and feedback systems

141. There are real risks associated with the security of residents’ tenancies when scrutinising the quality of providers and schemes, including threats of eviction or scheme closures. It is important that these risks do not deter local authorities who want to ensure that supported housing residents are receiving sufficient support for their needs in safe accommodation.

142. Being well prepared to refer residents to new accommodation, quickly and/or at scale can mitigate these risks. Joined-up working is key. You can:

build relationships with providers of good-quality supported housing to maintain oversight of voids and shorter waiting lists for accommodation
build relationships with specialist referring and support agencies, such as homelessness charities and drug and alcohol services, to ensure there are systems in place for emergency referrals
develop strong working relationships between Housing and Revenues and Benefits teams to communicate which Housing Benefit claims should to be prioritised for processing

Challenges by providers

143. Housing Benefit case law requires that the care, support or supervision provided in specified accommodation (except for the ‘refuges’ category), is ‘more than minimal’, to meet part of the eligibility criteria for Housing Benefit.

144. If a local authority challenges a provider on the levels of support they are delivering, or are proposing to deliver, this may be disputed by the provider. This may take the form of a provider setting up a scheme without local authority backing.

145. Where a Housing Benefit claim has been rejected or if the claimant does not agree with the amount awarded, this may be disputed by the claimant through an appeal against the decision and their housing provider may support them in this process.

146. To ensure you are prepared for the possibility of a legal challenge, it is important to keep well documented evidence of your intervention findings to justify and underpin the authority’s decisions.

Accommodation which is provided by a non-metropolitan county council, a housing association, a registered charity or a voluntary organisation (Paragraph 4, Schedule 3 of the Housing Benefit Regulations 2006), who also provide the claimant with more than minimal levels of care, support or supervision. ↩

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Applies to England

1. Supported housing, quality concerns and the supported housing pilots