Chapter 11: Assessments and personalised plans
Guidance on the initial assessments required to determine the duties owed to a person applying for homelessness assistance; personalised housing plans and the reasonable steps to be taken to prevent or relieve homelessness.
11.1 This chapter provides guidance on the (section 189A of the 1996 Act) assessments that housing authorities must carry out to determine the duties owed to a person applying for assistance, and the needs and circumstances of those applicants who are eligible for assistance and homeless or threatened with homelessness. It includes guidance on personalised plans and the reasonable steps applicants and housing authorities may take to prevent or relieve homelessness.
Overview: assessments and personalised plans
11.2 The section 189A duties to assess an applicant’s case and develop a personalised plan provide a framework for housing authorities and applicants to work together to identify appropriate actions to prevent or relieve the applicant’s homelessness. In performing these duties, the Secretary of State considers that housing authorities should adopt a positive and collaborative approach toward applicants, taking account of their particular needs and making all reasonable efforts to engage their cooperation. Personalised plans are more frequently referred to as ‘personalised housing plans’, and so this term is adopted throughout this guidance.
11.3 Every person applying for assistance from a housing authority stating that they are or are going to be homeless will require an initial interview. If there is reason to believe that they may be homeless or threatened with homelessness within 56 days the housing authority must carry out an assessment to determine if this is the case, and whether they are eligible for assistance. If the applicant is not eligible for assistance or if the authority is satisfied that they are not homeless or threatened with homelessness within 56 days, they must be given a written section 184 notification of the decision reached. For further guidance on eligibility see Chapter 7 and for further guidance on notifications see Chapter 18.
11.4 In some circumstances it will be possible to determine that an applicant is not threatened with homelessness at first approach, but in most cases further enquires will need to be carried out to find out more about their housing circumstances before being satisfied that they are not threatened with homelessness within 56 days. If the applicant believes they are threatened with homelessness and there is reason to believe that this is the case then further investigations will be required.
11.5 Guidance on whether a person is homeless or threatened with homelessness is provided in Chapter 6. It should be noted that applicants who have been served a valid section 21 notice to end an assured shorthold tenancy of their only available home, which expires within 56 days, are threatened with homelessness.
11.6 Housing authorities are encouraged to take a flexible approach toward applications for assistance where there is an evidenced risk of homelessness, which might not necessarily result in homelessness within 56 days. Rather than advise the applicant to return when homelessness is more imminent, the housing authority may wish to accept a prevention duty and begin to take reasonable steps to prevent homelessness. However, where there is no risk of homelessness in the foreseeable future the housing authority should offer advice and assistance to the applicant as appropriate.
Assessment of circumstances and needs (section 189A(2))
11.7 Applicants who are eligible and homeless or threatened with homelessness must have an assessment of their case, which includes assessing:
(a) the circumstances that have caused them to be homeless or threatened with homelessness;
(b) their housing needs, and what accommodation would be suitable for them, their household and anybody who might reasonably be expected to live with them; and,
(c) the support that would be necessary for them, and anybody who will be living with them, to have and sustain suitable accommodation.
11.8 When assessing the circumstances leading to a threat of homelessness housing authorities will need applicants to provide all relevant information to inform their assessment. This will usually include enquiring into their accommodation history at least as far back as their last settled address, and the events that led to them being threatened with or becoming homeless.
11.9 Applicants should be encouraged to share information without fear that this will reduce their chances of receiving support, and questions should be asked in a sensitive way and with an awareness that the applicant may be reluctant to disclose personal details if they lack confidence that their circumstances will be understood and considered sympathetically. Housing authorities should ensure staff have sufficient skills and training to conduct assessments of applicants who may find it difficult to disclose their circumstances, including people at risk of domestic abuse, violence or hate crime.
11.10 When assessing the housing needs of an applicant housing authorities will need to consider the individual members of the household, and all relevant needs. This should include an assessment of the size and type of accommodation required, any requirements to meet the needs of a person who is disabled or has specific medical needs, and the location of housing that is required. The applicant’s wishes and preferences should also be considered and recorded within the assessment; whether or not the housing authority believes there is a reasonable prospect of accommodation being available that will meet those wishes and preferences.
11.11 An assessment of the applicant’s and household member’s support needs should be holistic and comprehensive, and not limited to those needs which are most apparent or have been notified to the housing authority by a referral agency. Housing authorities will wish to adopt assessment tools that enable staff to tease out particular aspects of need, without appearing to take a ‘checklist’ approach using a list of possible needs. Some applicants may be reluctant to disclose their needs and will need sensitive encouragement to do so, with an assurance that the purpose of the assessment is to identify how the housing authority can best assist them to prevent or relieve homelessness.
11.12 Some applicants will identify care and support needs that cannot be met by the housing authority; or which require health or social care services to be provided alongside help to secure accommodation. Housing authorities should be mindful of duties under the Care Act 2014 including those relating to assessment and adult safeguarding; and the use of Care Act powers to meet urgent care and support needs where an assessment has not been completed.
Arrangements for carrying out assessments
11.13 Housing authorities should provide assessment services that are flexible to the needs of applicants. The Secretary of State considers an individual and interactive process will be required to fully and effectively assess circumstances and needs. Whilst advice and information services could be provided via an online process, housing authorities could not rely solely on such means to complete assessments into individual circumstances and needs for people who are homeless or threatened with homelessness within 56 days.
11.14 In most circumstances assessments will require at least one face to face interview. However, where that is not possible or does not meet the applicant’s needs, assessments could be completed on the telephone or internet or with the assistance of a partner agency. For example, an applicant who is in prison, hospital or in other circumstances where they cannot attend an interview, could have an assessment completed through a video link or with the help of a partner agency able to complete an assessment form, provide information and assist with communication where needed.
11.15 Some applicants may find it more convenient to complete an assessment through telephone or internet interviews, but there should be an opportunity for the assessment to be completed through a face to face meeting where the applicant’s needs indicate this is necessary, or if the applicant requests it.
11.16 Assessments should be specific to the applicant and the results of the assessment must be notified in writing to them.
Responding to referrals for assistance
11.17 Housing authorities will receive referrals of customers from other service providers, both statutory and non-statutory, including public authorities with a statutory duty to refer people who are homeless or threatened with homelessness. Some referring agencies will be better equipped than others to establish the threat of homelessness, or to conduct assessments of needs, and housing authorities will need to supplement the information provided within a referral with their own assessment and enquiries. For further guidance on duty to refer see Chapter 4.
11.18 Housing authorities should work alongside applicants to identify practical and reasonable steps for the housing authority and the applicant to take to help the applicant retain or secure suitable accommodation. These steps should be tailored to the household, and follow from the findings of the assessment, and must be provided to the applicant in writing as their personalised housing plan.
11.19 Housing authorities will wish to develop resources and tools that can be used regularly to address common issues, whilst also ensuring genuine personalisation in response to the wide range of circumstances and needs experienced by applicants. The Secretary of State expects this to result in significant variation in the staff time and other resources invested with each applicant in accordance with the nature and complexity of the issues they face.
11.20 Personalised housing plans should be realistic, taking account of local housing markets and the availability of relevant support services, as well as the applicant’s individual needs and wishes. For example, a plan which limited the search for accommodation to a small geographic area where the applicant would like to live would be unlikely to be reasonable if there was little prospect of finding housing there that they could afford. The plan might instead enable the applicant to review accommodation prices in their preferred areas as well as extending their home search to more affordable areas and property types. In their interactions with applicants, housing authorities are encouraged to provide sufficient information and advice to encourage informed and realistic choices to be identified and agreed for inclusion in the plan.
11.21 Through their assessments, housing authorities might identify support needs that cannot be easily met from existing service provision. Improvements in assessments and data capture will enable authorities to build up better information to assess needs and inform commissioning arrangements for the future. The Secretary of State recognises that ‘reasonable steps’ will vary between housing authority areas, and will be affected by housing markets and availability of services to support vulnerable people. However, every authority should engage in efforts to identify and measure needs and prioritise funding for the provision of services, as well as the development of partnerships, appropriately.
11.22 It would not be reasonable to agree steps for an applicant that were reliant on them engaging with a service provision that is not currently available in the district or which is unlikely to be offered to them. If the applicant is already receiving services from an agency that might contribute to preventing or relieving homelessness, the housing authority may wish to seek the applicant’s consent to involving them in developing and agreeing reasonable steps, and in delivering the personalised housing plan.
11.23 The Secretary of State expects the type of reasonable steps a housing authority might take to prevent or relieve homeless to include but not be limited to the following, irrespective of whether the applicant may have a priority need or be homeless intentionally:
(a) attempting mediation/conciliation where an applicant is threatened with parent/family exclusion;
(b) assessing whether applicants with rent arrears might be entitled to Discretionary Housing Payment;
(c) providing support to applicants, whether financial or otherwise, to access private rented accommodation;
(d) assisting people at risk of violence and abuse wishing to stay safely in their home through provision of ‘sanctuary’ or other measures;
(e) helping to secure or securing an immediate safe place to stay for people who are sleeping rough or at high risk of sleeping rough.
Process and timing
11.24 Housing authorities are required to notify applicants of the assessments they have made, and also provide written personalised housing plans. In practice, these 2 notifications might be combined to provide a clearer response to applicants.
11.25 The duty to issue written notifications should not prevent a housing authority from taking immediate action to assist an applicant where necessary. An officer may, for example, contact a young applicant’s parents or carers, perhaps through a same day home visit, if they have been asked to leave, or make immediate contact with a landlord where there is an imminent threat of eviction. In these cases prevention work would begin in parallel with the assessment and planning process, having regard to initial assessment findings and with the agreement of the applicant.
11.26 Where initial prevention or relief work is undertaken in parallel with the assessment and planning process it follows that in some cases successful prevention or relief will have been largely achieved before the assessment and personalised housing plan have been completed and the applicant has been informed in writing. Where this is the case, the record of actions taken might be included in the section 189A assessment, whilst any further steps needed to sustain the accommodation arrangements are included in the personalised housing plan.
11.27 Wherever possible and appropriate, housing authorities should prioritise efforts to prevent homelessness so that households can remain in their accommodation or, helped to secure a new home rather than becoming homeless. This might include, for example, achieving agreement for a young family to remain in the parental home pending an offer of Part 6 accommodation; or agreeing steps through which the housing authority and applicant might resolve outstanding benefit difficulties to clear or reduce rent arrears.
11.28 Housing authorities must take reasonable steps to prevent homelessness whether or not the applicant has a local connection with their area. If the applicant is actually homeless the authority may refer them to another authority where they have a local connection, and must provide copies of the assessment, and any revisions to it that have been notified to the applicant, as part of the referral arrangement. If the housing authority has agreed a personalised housing plan with the applicant they should also forward the plan to the notified authority if it has relevance, and with the applicant’s consent. For further guidance on local connection see Chapter 10.
Reaching agreement and reviewing the plan (section 189A(4) to (11))
11.29 Housing authorities should make every effort to secure the agreement of applicants to their personalised housing plans. Identifying and attempting to address personal wishes and preferences will help achieve that agreement, and improve the likelihood that the plan will be successful in preventing or relieving homelessness.
11.30 If the housing authority is unable to reach an agreement with the applicant about the reasonable steps to be included in their personalised housing plan, they must record why they could not agree; and provide the written plan to the applicant indicating what steps they consider it reasonable for the applicant and the housing authority to take.
11.31 The personalised housing plan may include steps that the housing authority considers advisable for the applicant to take (‘recommended steps’), but which the applicant is not required to take if they choose not to do so (section 189A(7)), as well as steps which they are required to take (‘mandatory steps’). The relevant duty (prevention or relief) cannot be ended for failure to co-operate with recommended steps. The use of recommended steps might enable the authority to provide or refer the applicant to a broader range of advice and support, for example to address wider needs or to help increase their housing options in the future through employment support. Mandatory steps should be limited to those which the housing authority considers are required in order to prevent or relieve homelessness. The plan must set out clearly which steps are mandatory and which are recommended.
11.32 Assessments and personalised housing plans must be kept under review throughout the prevention and relief stages, and any amendments notified to the applicant. Housing authorities will wish to establish timescales for reviewing plans, and these are likely to vary according to individual needs and circumstances. Some applicants will need more intensive housing authority involvement to achieve a successful outcome than others, and the timescales for regular contact and reviews should reflect this. Personalised housing plans agreed during the prevention stage will need to be reviewed if an applicant subsequently becomes homelessness, enabling housing authorities and applicants to focus on steps required to help secure accommodation.
11.33 If the housing authority become aware that the information the applicant has provided for their assessment is inaccurate or if there is new information or a relevant change in the applicant’s circumstances and needs there will be a need to initiate a review of the assessment and plan. The housing authority should also arrange a review if they believe the applicant is not cooperating with the personalised housing plan for whatever reason.
11.34 If the housing authority considers that their assessment of the applicant’s circumstances and needs have changed, or that the agreement reached as to reasonable steps is no longer appropriate they must notify the applicant in writing. The housing authority must notify the applicant if it considers any of the agreed steps are no longer appropriate, and there will be no consequence of failure to take any of the ‘removed’ steps after written notification is given.
11.35 For practical purposes a review of the plan might be conducted by telephone, email or video-link, especially if the applicant is unable to or declining to attend office based appointments.
11.36 Applicants have a right under section 202 to request a review of the reasonable steps the housing authority is to take under sections 189B(2) and 195(2) which includes having regard to their personalised housing plan within the prevention and relief stages. Housing authorities should encourage applicants to raise any concerns they have about their plan and work to resolve disagreements to minimise the occasions on which the applicant will feel the need to request a review.