Strategic Statement 2024 for Supported Exempt Accommodation

This statement sets out the council’s view on the current supported exempt accommodation market in the city as well as looking to illustrate what we know about our existing provision, our immediate and future needs and how we will assess the need for supported accommodation in the city. It sets out Coventry’s approach to ensuring that there is sufficient, safe, and appropriate accommodation, that meets the needs of the client groups it is designed for whilst ensuing value for money.

Introduction

Specified accommodation is a term used to describe supported housing where help with housing costs is provided through Housing Benefit (HB). Claimants who live in specified accommodation (where eligible for help) have their HB excluded from the benefit cap calculation.

Specified accommodation is made up of four categories:

• Exempt accommodation
• Managed properties
• Refuges
• LA hostels

Supported Exempt Accommodation (SEA) is accommodation offered by housing associations, registered charities, voluntary organisations and LA's that offers care support or supervision over and above that provided by a regular landlord.

SEA can include group homes, hostels, refuges, sheltered housing, supported living complexes, extra care housing and adapted housing for the disabled. Housing Benefit (HB) recognises the often-higher costs of providing such accommodation and providers can apply for an exemption to the local housing allowance rate where a resident receives care, support, or supervision for the purpose of enabling them to live or adjust to living independently within the community.

Traditionally, supported housing has been primarily provided by the social housing sector managed and delivered by Registered Providers (RPs), local authorities and third sector community, voluntary or charitable providers, i.e., not-for-profit organisations. Over the last decade, however, following a broadened definition of social housing and numerous changes in relation to governance arrangements of social housing, the numbers, and types of providers in the sector providing supported housing have also grown. The broadened definition of social housing in 2016, governed by the Regulator of Social Housing (RSH), allowed RSH to award Registered Provider status to private sector ‘for profit’ organisations. These organisations now also make up part of the supported housing provision and represent a growing number of private sector organisations and landlords with RP status operating within the supported housing sector.

Supported housing is typically defined as housing designed to meet specific needs and in which there is some level of support provided as part of the accommodation offer. Within this there are broadly two categories of accommodation; Specialist Supported Housing and supported housing that meets a shorter-term need, often referred to as Transitional Supported Housing. Sheltered housing for older people is the notable anomaly.

Specified accommodation categories

The landlord must be a Voluntary Organisation, a Registered Charity, CIC (Community Interest Company) or Registered Provider (Housing Association).

• The landlord must have a legal interest in the property concerned (ownership or lease).
• The residents must need ‘care, support or supervision.’
• The ‘support’ to meet these needs must be provided by the landlord or on its behalf.

To be classified as a ‘Managed property’:

• The landlord must be a Voluntary Organisation, a Registered Charity or Registered Provider (Housing Association).
• The landlord must have a legal interest in the property concerned (ownership or lease).
• The resident must need ‘Care, Support or Supervision.’
• A third party provides the ‘Care, Support or Supervision.’

To be classified as a Domestic Abuse refuge:

• The landlord can be the same providers as above but can also be the Local Authority.
• The accommodation must be used wholly or mainly for non-permanent accommodation for people who have left their homes because of domestic abuse.
• There is no requirement that the resident receives care, support, or supervision.

To be classified as a Hostel:

• Hostel cannot be self-contained.
• Care, Support or Supervision must be provided (not necessarily by the landlord).

Purpose of this statement

This document sets out the council’s view on the current supported exempt accommodation market in the city as well as looking to illustrate what we know about our existing provision, our immediate and future needs and how we will assess the need for supported accommodation in the city. It sets out Coventry’s approach to ensuring that there is sufficient, safe, and appropriate accommodation, that meets the needs of the client groups it is designed for whilst ensuring value for money.

It also aims to illustrate what is known about people in need of supported housing in the city. This includes information about current estimated populations of key client groups in supported housing. It will also consider the next steps of reviewing supported housing including the wider local support pathways and how these can improve and ensure need is met in the future.

Why we need a Supported Housing Statement and Statement of need

Supported housing provides crucial help to some of the most vulnerable people in our community. It can have a positive impact on an individual’s quality of life: from their physical and mental health to their engagement with the community and maintain their independence. For some people, supported housing may be a long-term option as support needs are unlikely to change throughout the course of a lifetime. For others, supported housing may be a step along the way to fully independent living, for example for those recovering after a period of mental ill-health, or can form a vital part of a planned route into mainstream housing.. Through helping people to increase or maintain their independence, supported housing can also be a cost-effective way of supporting people, by reducing their future need for more intensive support, such as residential care or more expensive statutory services.

Safe, warm, secure housing is central to a person’s health and well-being, to their ability to enjoy and contribute to community life, and the ability to participate in work, education, and training. Being unable to access appropriate housing can contribute towards isolation, a loss of independence and in some cases can lead to a need for residential care, to hospital admissions or to homelessness. In every community there are some people who require more tailored housing, with a degree of support attached, whether this is on a temporary or permanent basis. They may be vulnerable due to old age or ill health, have a long-standing illness or disability, or lack the skills to manage a tenancy, and need more support to maintain their independence. For some people, supported housing may be their last step on the housing ladder, as they grow older and look for a home which will be able to meet their changing needs. For others, supported housing may be a step along the way to fully independent living, for example for those recovering after a period of mental ill-health, or can form a vital part of a planned route into mainstream housing as part of the homelessness route. Through helping people to increase or maintain their independence, supported housing can also be a cost-effective way of supporting people, by reducing their future need for support from statutory services.

There is a recognised need for supported housing and there are many good providers who work both in, and outside of commissioning frameworks. Unfortunately, there are also a number of not so good providers some even falling into the category and being described as rogue landlords where they are operating purely on a profit-based model often offering very little in terms of enhanced housing management, support, or guidance to their residents.

In 2022 the Committee for Levelling Up, Housing and Communities found in its investigation into the sector that the experiences of some residents in supported housing were ‘beyond disgraceful’ and a National Audit Office report into the sector in 2022 stated that ‘gaps in regulation enable some providers to offer poor-quality housing with support that does not meet the needs of residents.’

The Supported Housing Regulatory Oversite Act (The Act)

The Supported Housing Regulatory Oversite Act (The Act) which came into force on the 29th August 2023 was passed as a response to the issues with the quality of some of the accommodation, providers and the care and support provided in exempt accommodation. Some providers were seen to place profits over the actual provision of care and support which is an essential part of supported exempt accommodation.

The Act will allow Government to create new National Supported Housing Standards which will set out minimum standards for supported exempt accommodation and will aim to address the type or condition of accommodation, as well as the care or support provided whilst ensuring provision is value for money. There is no set date for these standards to be introduced and it is not currently known what the standards will specify. Alongside an introduction of minimum expected standards, The Act will introduce new licensing regulations specifically in relation to exempt supported accommodation. It also sets out how a new Supported Housing Advisory Panel will work and makes changes to the rules on intentional homelessness when a person leaves accommodation which does not meet national standards. The act will also require local authorities in England to review supported housing in their areas and develop Specific Supported Housing Strategies.

Coventry

Coventry is a diverse and cohesive city with a relatively young population, with a median age of 35 years compared to the UK average of 40 years. In recent years, the city has experienced an 8.9% growth in its population, from 316,915 in 2011 to 345,300 residents in 2021 (census data). This is a higher increase than the rate in the West Midlands (6.2%) or England (6.6%).

In 2021, just over one-fifth (22%) of the city’s population are children and young people aged under 18, 65% are of working-age (18-64), and the remaining 13% are aged 65 and over. The city’s population has grown particularly amongst younger adults, alongside the growth and success of the city’s two universities in attracting students locally and internationally; as well as better-paid jobs in certain sectors of the local economy.

Over the past decade, the city has become increasingly ethnically diverse, with just under half of its school-aged population from an ethnic minority background in 2021; up from around one-third at the 2011 census.

The percentage of Coventry neighbourhoods that are amongst the 10% most deprived in England reduced from 18.5% to 14.4% between 2015 and 2019. Based on this measure, Coventry ranked 64th nationally in 2019 (with 1st being the most deprived), an improvement in ranking from 46th in 2015. These pockets of deprivation limit people’s opportunities to succeed in life; and transforming life chances requires addressing the social inequalities that are established right from the earliest years. The latest available data, for 2020/21, suggest that 23% of Coventry children aged 0-15 live in relatively low-income families compared to 19% nationally.

The median house price in Coventry for the year ending September 2022 was £214,500, lower than the West Midlands regional average of £225,000 and the England average of £275,000. Over the last five years Coventry house prices have increased by 6% a year on average, similar to the level of increase elsewhere, and therefore Coventry is still more affordable than the other parts of the West Midlands metropolitan area in regard to property purchases. There has been an increase in private renting and a reduction in home ownership amongst Coventry residents over the last 10 years.

Household overcrowding is more prevalent in Coventry (7.7% of all households) than national (6.4%) and regional averages (5.4%). However, overcrowding has reduced since 2011 when it was at 9.5% of households.

Source: Coventry JSNA City wide profile 2023

There is a considerable proportion of Houses in Multiple Occupancy (HMOs) in the inner city wards.

This has contributed to an increase in the number of supported accommodation schemes being set up within the local authority in recent years.

Over the last decade there has been a significant increase in the number of purpose build student blocks being developed in the city centre and surrounding area. This has resulted in a number of former student HMOs being surplus to requirements, particularly those which aren’t en-suite.

This has resulted in a number of former student HMOs on the market as investment opportunities with some of these being used for supported accommodation. The majority of HMOS, and therefore exempt support accommodation units are situated in pockets within the city alongside existing commissioned and temporary accommodation provision. This results in high numbers of complex individuals in small geographical areas thus placing pressure on local police and community safety resources.

Currently, there are more than 3255 supported housing bed spaces and 49 supported housing suppliers running active schemes in the city (this includes 1437 bed spaces for those over 55 and in sheltered / extra care type accommodation).

Supported Housing type: Demographic and make up.

There are 5 main cohorts (sheltered housing for older people accommodation for victims of domestic abuse, recovery housing for people with substance misuse challenges, homelessness accommodation and accommodation for people with learning difficulty and mental health) that exempt supported accommodation is provided for in the city as well as a significant amount of sheltered, housing with care and extra care provision in the city, (for the purpose of this statement we will not include sheltered and extra care). Not all people in each category will require supported accommodation, but the below figures give an indication of the potential need within the city across the client groups as well as providing general information in terms of rough sleeping and homelessness that will impact the demand for supported accommodation.

Substance misuse

Coventry has an average number of citizens who are dependent on substances, and an above average number of citizens who’s alcohol consumption is considered harmful. The local authority commissions a drug and alcohol support service with the opportunity for residential rehab being part of the offer. The local authority does not commission any specific recovery accommodation.

During 2021/22

There was an estimated of 5416 people in Coventry who were alcohol-dependent (https://www.gov.uk/government/publications/alcohol-dependence-prevalence-in-england)

Note: but this reflects dependency, not “at risk of alcohol-related health problems” and approximately 700-800 people who are dependent access treatment each year.

There is an estimated 2,500-heroin and crack users in Coventry (the estimate has recently been increased from 1,800). Approximately 1200 drug users will access treatment each year.

Note: this is the current estimate of people who are using / misusing heroin (or other illegal opiates) and / or crack cocaine. It does not include any other substances; it also does not include those who are using / misuse prescription only opiates, etc.

In 2021/22, there were 858 presentations (new starts) to structured treatment. Of these 28 (3%) were NFA, and 118 (14%) had a housing problem at assessment. This does not include those who accessed non-structured treatment.

Source: Office for Health inequalities and disparity

Domestic abuse

Estimating the number of people affected by domestic abuse is difficult due to the hidden nature of the problem and difficulties for individuals in recognising domestic abuse. The local authority commissions a number of services for victims of domestic abuse including accommodation.

During 2022/23 the total number of reports to the police in relation to DA in the city were:

• DA non crime: 3,671
• Da crime: 6,890
• Total: 10,561

Learning disability

The total population living in Coventry classed as having some form of learning disability / learning need is 7,428 however of this group it is expected that only 4% will need to live in supported accommodation.

• Total population aged 18-64 predicted to have a learning disability 2023 - 6,345 (by 2025 – 6,482)
• Total population aged 65 and over predicted to have a learning disability 2023 – 1,083 (by 2025 – 1,111)
• Total population aged 18-64 predicted to have a moderate or severe learning disability 2023 – 1,448 (by 2025 1484)
• Total population aged 65 and over predicted to have a moderate or severe learning disability 2023 144 (by 2025 – 147)
• Total population aged 18-64 predicted to have Down's syndrome 2023 160 (by 2025 – 163)
• Total population aged 18-64 predicted to have autistic spectrum disorders 2023 2,650 (by 2025 – 2,715)
• Total population aged 65 and over predicted to have autistic spectrum disorders 2023 486 (by 2025 – 502)

Mental health

There are approximately 46,221 people in Coventry living with a common mental disorder such as depression. Although it should be noted that the majority of people in this group are unlikely to require supported housing and will live independently in the community.

Projected numbers of people aged 18-64 in Coventry with specific mental health needs.

People aged 18-64 2020.

• With a common mental disorder 46,221
• With a borderline personality disorder 5,872
• With antisocial personality disorder 8,404
• With a psychotic disorder 1,726
• With two or more psychiatric disorders 17,728
• who are survivors of childhood sexual abuse 27,945
• With early onset dementia 76
• Who will die by suicide 17

Note: dependant on drugs figure covers all drugs not just opiates and crack.

Source: Mental Health Market needs assessment 2021/26

Cited: PANSI data 2020. Note that there will be overlap between these groups.

Young people

As of 2022/23 there were 713 looked after children in Coventry.

There were 33 children who received a caution or court sentence in 2022/23’.

Similarly, this number is a small proportion of children open to YJS and the Service saw 125 allocations in the year 22/23.

In 2022/23 1392 applicants who were between the ages of 18 – 25 years old approached the council in housing need of which 640 were assessed as homeless or threatened with homelessness, duty., 22.5% were assessed as being threatened with homelessness and were owed a prevention duty and 77.5% were assessed as already homeless and were owed a relief duty.

Homelessness and Rough sleeping

There are 150 commissioned bed spaces available across the city for homeless people with support needs who are over 25 and 60 for those under 25. Stays in supported housing for homeless people can vary, but the best outcomes were typically achieved by residents who stayed between 3 and 6 months. Any less usually indicated a negative move on e.g., eviction.

There are a small number of people for whom traditional supported housing models (hostels and HMO’s do not work) and for those the evidence shows that more dispersed models of support, such as Housing First maybe more appropriate. There is currently a Housing First scheme in Coventry, run by the council, which has supported 80 individuals throughout the project into permanent self-contained accommodation. There are also 25 designated units provided by 2 RPs in the city and a further dedicated 16 self-contained rooms in a hostel for use by those with a history of rough sleeping.

During 2022/23 – approximately 5798 households approached the council for housing advice. Approximately 833 of these were at risk of homelessness (prevention) and approximately 1955 of these were actually homeless (relief). Of those who were homeless and needed accommodation, 1240 were accepted as homeless and therefore owed the main homelessness duty.

Of the 1240, 378 were single people.

63 households presented as homeless due to Domestic abuse.

Migration and non-UK nationals

As at the October 2023, Coventry has 396 HMOs in use by SERCO with approximately 1280 of those housed being single males who are currently going through the asylum process. There are also 3 asylum hotels in Coventry with around 550 people in it. Approximately 85-90% of them are single male.

The recent changes in the timescales for those who are granted positive decisions means we are seeing an increasing number of single men presenting to homelessness services for support. Between July 2023 and October 2023, 417 people received Leave to Remain status and 340 of them are single male.

Current provision (where enhanced housing benefit is paid)

Cost

As at 1st week of November 2023 the total rent paid per week for exempt supported accommodation (commissioned and non-commissioned) is £521,383.08.

With the totals by client group as follows:

• Other £59,906
• Sheltered £164,639
• DA: £26,753
• Recovery housing: £11,535
• Homeless: £185,625
• LD/MH: £72,922

The average amount of rent paid by claimants of Housing Benefit across all client groups in supported accommodation is £212.72.

Registered provider schemes- the average amount of rent paid per week was £197.51.

Non-registered provider schemes, the average amount of rent paid per week is £240.92.

Homelessness and Complex need (singles)

As of 1st October 2023, there were 18 providers providing accommodation for those who are homeless and/ or at risk of homelessness or who have complex needs. The local authority commission 150 beds for those over 25 who have complex needs or are ex-offenders, with 10 beds being specifically for women. The local authority also commissions 60 beds for those under 25. Nacro commission a further 10 beds specifically for ex-offenders.

The overall cost of the commissioned support provision for singles is circa 600k per annum with the overall housing benefit across the cohort being for both commissioned and non commisoned beds is circa £185k per week.

There is currently on average 12 weeks waiting list for a bed space in both the commissioned and non-commissioned provision with move on happening after an average of 3 years.

Recovery and Dry houses

As of 1st October 2023, there were 3 providers operating specifically as dry/ recovery houses in the city – none of these are commissioned and receive no funding via the local authority other than via housing benefit.

The overall housing benefit across the cohort being £11,535 per week.

Waiting lists for these projects are not known.

Domestic abuse

As of 1st October 2023, the Council commisions1 provider through the– “Domestic Abuse Safe Accommodation contract” which includes the pilot for the Complex Needs Unit for those fleeing DA.

There are 4 non commisoned providers who provide accommodation for those experiencing DA with 2 of the providers also offering provision for those fleeing sexual exploration/homeless. 2 of the providers though not commissioned to provide accommodation are commissioned to provide community-based support in the accommodation and receive funding for family support workers to meet the requirements of the DA Act 2021.

The overall housing benefit across the cohort being £26,753.50 per week.

Migration and Non-UK nationals

There is no commissioned provision for this cohort. Three providers operate in the city offering accommodation to people who have been newly granted leave to remain/ status. The overall housing benefit across the cohort being £59,000 per week.

Mental health and learning difficulties

As of October 2023, there was 1 commissioned provider in the city providing 34 bed spaces for people with MH problems. In addition, there was 1 provider providing accommodation with a mix of funded packages, of support and floating support. Six providers provide accommodation without any direct relationship with the local authority.

There is one commissioned provider in the city providing 41 bed spaces for people with learning difficulties. In addition, there were thirteen providers providing accommodation with a mix of funded packages, of support.

As of October 2023, there was 4 commissioned providers in the city providing 548 bed spaces for Elderly people. In addition, there was 8 provider providing accommodation with a mix of funded packages, of support and floating support. The overall housing benefit across the cohort being £72,922.56 per week.

Improving provision: Supported Housing improvement programme (SHIP)

Following a successful bid for funding via the Supported Housing Improvement Programme (SHIP) with the Department of Levelling Up, Housing and Communities (DLUHC), we have, as part of the pilot programme started to develop our approach to management, governance, and oversight of supported exempt accommodation in readiness for the implementation of the Supported housing regulatory oversight Act 2023:

We have:

• Employed an additional multi-disciplinary team of officers to conduct inspections on properties in terms of the quality of the asset, to ensure that those living there are receiving appropriate support whilst ensuring value for money.
• Collaborated with current providers to create a Guide for Standards of quality – a tool which can be used by new and existing providers to ensure the quality of support and accommodation.
• We have created a front door / gateway process for providers of exempt supported accommodation to provide information, advice, and guidance for those wishing to operate in the city. https://www.coventry.gov.uk/sea
• We have developed routes and mechanisms to capture Anti-Social Behaviour issues and complaints through a single access point.

Regarding the development of the Guide to the standards of quality expected in SEA, these have been created collaboratively with current providers and in line with current best practise and are reflective of the pending requirements as laid out in the Supported housing regulatory oversight Act 2023.

The Guide to standards has been developed for current providers of SEA or those looking to move into this market and is a statement of the checks and balances we will conduct and our expectations regarding how they operate in the city. It also illustrates what we will be assessing and inspecting against when we conduct our programme of visits.

The underpinning message of the Guide is to acknowledge what “good” looks like and use this to improve the standard of accommodation to benefit both the residents and the providers.

As part of the SHIP pilot, we are conducting a baseline inspection on all exempt supported accommodation both in terms of assessing the quality and compliance of the asset, but also in terms of the quality of support alongside VFM. The inspections findings will then allow us to RAG rate providers and where needed support providers to improve the quality of provision.

What does our information tell us?

Key aspects of the current picture of supported housing based on the information available are:

Current HB costs for those in non-registered provider settings such as the majority of those in settings run by limited companies and charities/voluntary group claim more HB than those in registered provider settings with over a circa £50 difference in cost on average .

Registered provider schemes- the average amount of rent paid per week £197.51

Non-registered provider schemes, the average amount of rent paid per week £240.92.

There are a number of providers and schemes for those at risk of homelessness, with ill mental health, substance misuse issues and a history of criminality however these types of accommodation (unless part of the commissioned provision) all provide low level support ( not 24 hour ) . There are more limited options for those with a recovery housing need, people with neurodiversity and substance misuse and those with complex needs. Provision for more complex individuals is a gap in the city and often means those most in need are not able to access accommodation or lose it due to their perceived complexity.

The proportion of registered social landlords/housing associations in Coventry is significantly lower than the latest reported national average this means most exempt supported accommodation in the city attracts a subsidy loss which is significant.

Our data and information collection on exempt supported accommodation is limited, we are therefore committed to an expansion of data collection activities to further understand supported housing in Coventry as part of our wider Homelessness needs analysis. We will use the information to further inform our requirements in terms of future demand, this will be done using information and data included in other key documents such as the JSNA, Health and Well-being strategy.

It is clear that our historic approach to the provision and oversight of exempt supported accommodation that is not commisoned by ourselves has been provider led as opposed to needs led, as providers who meet the criteria are able to set up and operate without having to evidence a requirement or need for the provision. There is ambiguity in terms of pathways and often due to the demand on mainstream housing referrals are made into accommodation on an “only option” as opposed to a “right option” basis.

Where we have known issues with a provider the local authority does cease referrals. However, the local authority has little control over who other services refer to and a limited understanding of referral routes, assessment processes and risk. This can result in groups of incompatible, complex people being housed in a single location. There can be significant impacts on local residents in areas as a result of this clustering of provision resulting in community cohesion issues and added pressure on local policing and community safety teams.

We know where tenancies are ended or fail in exempt supported accommodation additional pressure is added to our commissioned services, front line housing service as well as our rough sleeping outreach team.

In the 2022/2023 financial year, the council dealt with 476 cases related to evictions from supported accommodation. Of these, 14% were attributed to households no longer eligible for supported housing, 17% were due to rent arrears, 37% resulted from other breaches of tenancy or license unrelated to rent, and 32% were due to various other reasons.

Having had regard for the aforementioned data and information and having reviewed the role of pathways and quality and through the work being carried out as part of SHIP, our long term aim is to be able to offer providers advanced information of supply, demand, and gaps. These can be used to inform service provision based on robust information in terms of need and ensure that provision is safe, of good quality and offers VFM.

Future need and Next steps

Our overarching vision is to ensure the right supported housing options are available at the right time and the right place for those that need them. Through this, we will help to increase or maintain independence, and to help to prevent future reliance on statutory services.

As part of the wider Housing needs analysis being carried out in 2024 and the development of our new Homelessness and Rough sleeping strategy, we will explore in detail what the housing need in the city is and use the information to influence and guide the development of our future Supported Housing.

We will conduct further analysis and engagement around accommodation-based support for all cohorts and use the findings within our wider Homelessness and rough sleeping strategy and any other associated documents.

In complicated economic times it is vital that resources are targeted to have the greatest impact. Therefore, it is important that we are able to prioritise the competing needs of different groups in order to determine where to direct investment in supported housing. At present Coventry does not have a system for prioritising need, and to do this will require planning across all council services, as well as other partner agencies – we will:

• Make use of existing evidence and knowledge (JSNA, SHMA, health and well-being strategy) to identify areas of unmet need.
• Raise the profile of supported housing as part of a prevention agenda through the Homelessness Partnership Forum and the Health and Wellbeing Board.
• Develop greater links between housing, public health, and social care commissioning in planning for and delivering supported housing.
• Create clear pathways for all types of supported accommodation that are reflective of need as opposed to availability.
• Understand the cost effectiveness of services through a better understanding of downstream savings achieved and ensure VFM across supported housing provision.