Official Report 309KB pdf
Item 2 is on homelessness in Scotland. Today, we will hear evidence from representatives of the Scottish Housing Regulator as part of the committee’s follow-up to our homelessness commitment inquiry, which we undertook in 2011-12. The Scottish Housing Regulator’s recent report on housing options ties in closely with the areas that the committee hopes to explore in the coming months.
I welcome Michael Cameron, chief executive, and Christine MacLeod, director of regulation, governance and performance, of the Scottish Housing Regulator. Would either or both of you like to make some opening remarks?
I thank the committee for the invitation to speak to our recent report “Housing Options in Scotland: A Thematic Inquiry” and to give evidence to the committee.
We want to highlight that our board selected housing options as the subject for the regulator’s first thematic inquiry not only because our statutory objective includes protecting the interests of people who are homeless or who might become homeless but because the sustained achievement of the 2012 target has been an important focus of our regulation of landlords for some years. We also recognised that the housing options approach had been promoted as a key way for landlords to deliver on the target. A range of views have been expressed about how effective the housing options approach is.
Our board also took into account this committee’s recommendation that the SHR work with colleagues in the Scottish Government to ensure that services that are delivered by a housing options approach are consistent across Scotland and that local authorities are meeting their legislative duties. The thematic inquiry was designed also to address the committee’s recommendation.
It is important to say that the housing options approach is widely recognised as a good policy response to homelessness, but there had not been an in-depth evaluation of its effects. Through the thematic inquiry, we aimed to assess the success of the new housing options approach, its impact on statutory homelessness and what outcomes are achieved for people who seek help from local authorities. It is about getting a national picture of whether the housing options approach is an effective way to prevent homelessness.
It might be worth stating that there has been a very positive response from stakeholders to our recommendations in the thematic inquiry report. On 9 May we published our findings with recommendations, which are focused on the Scottish Government and councils. The intention is that the report will act as a catalyst for improvement. Stakeholders’ immediate reaction to it has been positive. We have been encouraged by the fact that the key stakeholders, which are the Scottish Government, the Association of Local Authority Chief Housing Officers and the Convention of Scottish Local Authorities, on behalf of local authorities, have already committed to using the report to improve the delivery of housing options in Scotland. They have accepted our recommendations and are already making progress in implementing them.
Thank you. Will you give a brief overview of why you undertook the study and the methodology that you used in carrying it out?
We were conscious that housing options had been taken up by many local authorities as an approach to the prevention of homelessness. We knew that, although views had been expressed and some studies had been done on the housing options approach, there had not been an in-depth national evaluation of its effectiveness, so we wanted to look at that in particular.
As regards our methodology for the thematic inquiry, we gathered evidence from a wide range of sources. We looked at and analysed national performance and statistical information. We reviewed what other research and studies had said about the housing options approach. We looked in depth and on site at the delivery of housing options and we looked at six case study local authorities, so we saw what actually happened. That included reviewing 280 housing options cases and shadowing 60 local authority interviews of people who were seeking assistance.
The tenant assessors who work with us carried out a mystery shopping exercise—they phoned local authorities as if they were looking for assistance. We surveyed the 26 local authorities that were not involved in the case studies, which gave us that national profile and national picture. We also used and built on the findings from inquiries that were carried out in recent years in individual local authorities around homelessness and we discussed with a range of stakeholders what their views were. All of that fed into the evidence base that we used for the thematic inquiry report.
It is perhaps worth saying that we used the findings from the six case studies at an aggregate level to inform our assessment of the success of the housing options approach nationally—we did not report on each council’s performance.
Your report notes that local authorities are at varied stages in their development of the housing options approach. How wide a variation exists between local authorities? Obviously, the report is a snapshot—we also took a snapshot when we did our homelessness inquiry. Most local authorities seem to be improving, but homelessness levels have gone up in the Scottish Borders, East Renfrewshire and Moray. However, Moray was one of the places that we studied and it was one of the beacons.
We certainly found variation across the local authorities. The housing options approach is relatively new. There is no national set of guidelines to direct and support local authorities on how to deliver housing options within the homelessness prevention service. We certainly found that local authorities are developing individual approaches. The way in which the housing options approach is integrated within homelessness prevention services is also dependent on how each local authority delivers those services.
Certainly, most local authorities are enthusiastic about the potential for the housing options approach to make a difference to the possible outcomes for homeless people. The local authorities see it as a positive way to give people good advice and genuine choices.
We found that, because the approach is relatively new, the consistency that tends to develop over time is not yet there. We found that some local authorities are more advanced in their development of the housing options approach and others have yet to implement it fully. Although some local authorities have been coming together to share good practice and lessons from their experiences, we saw that there is clearly a lot of potential to do even more if there was a national framework and national guidance to support local authorities.
I have a couple of questions on housing options in practice. What have been the main changes that local authorities have made to their services in moving towards a housing options approach to tackling homelessness?
Local authorities have used a variety of ways to deliver housing options in practice. We saw evidence of some really good links and referral arrangements with other council services and other agencies. Some local authorities made good use of mediation services to achieve appropriate outcomes for people.
We found that most local authorities changed their officers’ roles and responsibilities with the introduction of housing options, to ensure a greater focus on prevention work. We found that homelessness officers generally received training on housing options service delivery, but that was not always the case for initial reception staff, who are sometimes the first people that someone approaching the council might see.
Housing options practitioners are making use of the Scottish Government-funded housing option hubs, which bring practitioners together to share good practice and develop new ideas for delivering housing options. Local authorities are making use of those hubs to develop new approaches and to share approaches that they have found to work in their areas. There are a range of methods and approaches.
It is good to hear about that range of methods and how they have been used to tackle homelessness.
The regulator’s report states:
“The lack of a clear and consistently-applied recording of outcomes in Housing Options has been a major barrier to evaluating the success of the approach both locally and nationally.”
Can you give us any details on where the inadequacy is in the reporting of the outcomes, on how that affected your ability to carry out the study and on where improvements could be made so that the list of measures that you mentioned can be properly monitored and we can see which of them have been most effective?
Absolutely. The lack of a national set of statistics on the outcomes that are achieved through housing options placed a limitation on the type of analysis that we could carry out. There was indeed a
“lack of clear, consistently applied recording of outcomes in Housing Options”.
As we said, that was
“a major barrier”
to us in evaluating the success or effectiveness
“of the approach both locally and nationally.”
We found that local authorities were implementing their own approaches to recording their local outcomes. There was variation in how that was being done and no consistency, even across local methods of recording outcomes. The local authority representatives to whom we spoke recognised that they needed to improve their monitoring of outcomes. They also recognised that there was a vacuum as regards a national monitoring framework to which they could contribute.
Since we were on site and looked into the matter, the Scottish Government has introduced mandatory data collection and monitoring of housing options outcomes, effective from 1 April. That is a really important and timely development that will support a proper evaluation of the effectiveness of housing options.
I want to follow on from the questions on options reporting and guidance. Your report identifies a tension between local authority duties to homeless persons and housing options, and the Scottish Government has produced guidance that makes it clear that local authorities should complete a homeless assessment for any person who is homeless or threatened with homelessness at the time of the options interview. Did you find out why that advice is not always followed?
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When we were on site, we found that there is awareness of the high-level guidance that was provided back in 2009 through a joint publication by the Scottish Government and COSLA, but that was a high-level statement with little further detail on how the development of housing options should accommodate the requirements of the homelessness legislation. The Scottish Government actively promoted local development of approaches to ensure that there was innovation and that those approaches were relevant to the local context. That means that, although officers on the ground are aware of the high-level objective, they are not always clear about what it means when somebody approaches them, or about whether they should pursue a housing options approach or take them down the route of a homelessness application. That confusion leads to variation in practice.
Around half of all local authorities have said that there is a need for more guidance, and Shelter has asserted that the absence of national guidance on housing options has resulted in a gap in some areas. Do you think that putting guidance on a mandatory footing would close that gap?
Yes. We think that it is important that there is clear guidance and an effective monitoring framework. As Christine MacLeod has said, we now have half of that in place with the introduction of the mandatory monitoring framework by the Scottish Government on 1 April. Given the variation that we found, both within local authorities and across local authorities, we believe that there is a need for clearer guidance. We are also mindful that the code of guidance on homelessness, which is the broader set of guidance available to local authorities to assist them in the delivery of their homelessness duties, has not been updated meaningfully since 2005. There is a real opportunity to put in place clear guidance that will assist local authorities to deliver effective housing options that enable them to appropriately discharge their statutory duties on homelessness.
If a review was done and the 2005 guidance was updated, would that make a big difference?
It would be for the Scottish Government, in discussion with COSLA and ALACHO, to decide whether that was the best vehicle to get appropriate guidance for housing options. It seems sensible that an eye should be given to the broader homelessness guidance when introducing specific guidance on housing options and how that relates to the statutory homelessness duties.
Can you comment on the specific impact that the removal of the distinction between priority and non-priority need homeless applicants has had on local authority practice in relation to potentially homeless people?
The inquiry that we undertook was aimed specifically at identifying the impact of housing options on prevention of homelessness, which was seen as an important way to address the delivery of the 2012 target for removing non-priority for homeless people. The Scottish Government’s position on the published statistics is that that has been an important factor in achieving the target.
We found that, on a number of occasions, individuals who were dealt with through the housing options approach had fairly clear prima facie evidence of homelessness, but a homelessness assessment was not carried out. Those people might well have achieved an appropriate outcome that dealt with their housing need, but the lack of such assessments is the reason why we identified in the report a level of underreporting of homelessness as a consequence of local authorities dealing with people through the housing options route.
Thank you. That covers all my questions.
I want to look at some practical examples, if that is okay. First, are you able to give us examples of good practice in the housing options approach that led to positive outcomes for people?
Our report highlights some examples of the good, positive practice that we found. We saw good early intervention work to prevent homelessness, particularly in cases involving people with private sector tenancies and those who own their homes. For example, local authorities have been able to offer advice and make referrals to other agencies, including the local authority’s own benefits service, and to mortgage-to-rent schemes for owners in financial difficulties.
Our report highlights the positive practice example of Falkirk Council, whose debt and welfare advice team works with owner-occupiers who are in mortgage arrears and have been threatened with eviction, and which uses the Scottish Government’s mortgage-to-rent scheme to convert mortgages to rents. Such actions have prevented evictions and homelessness.
Through housing options, people have been able to get settled accommodation outcomes that they are satisfied with, whether that is a local authority house, a registered social landlord house that is let through the mainstream housing list or a house in the private sector. For many, that was a positive outcome. In short, we saw good examples of the housing options approach having the right sort of effect and appropriate outcomes.
You must also have come across some less positive outcomes. Can you give us any examples of instances where outcomes could have been improved?
Some people did not get solutions to their housing problems or the kind of positive outcome that they might have achieved if they had received a homelessness assessment. Had local authorities carried out an assessment of homelessness and housing options as recommended in the 2009 Scottish Government and COSLA guidance, it would have resolved the weaknesses in many of the cases that we reviewed.
What role do registered social landlords play in the housing options approach, and how can they achieve good outcomes for people?
In this thematic report, we focus on the role of local authorities in housing options and homelessness prevention. We have some statistics on the contribution that RSLs make; we know, for example, that they contribute 37 per cent of social sector housing outcomes for homeless applicants. In the most recent figures, which are for the final quarter of 2013, that equated to approximately 1,500 tenancies, as compared with 2,500 local authority tenancies.
As a result of preparing the report, you have recommended that the Scottish Government produce further guidance on housing options. What key issues should be covered in that guidance?
The principal issue that we have recommended such guidance should cover is the provision of advice to local authorities on how they can deliver housing options services and meet their statutory homelessness duties. It is all about removing the lack of clarity on how those two elements can operate effectively side by side. In our report, we set out a range of recommendations that we believe can be tackled through the provision of clear guidance, but that is the critical one. More than half of the local authorities stated to us that they felt that there was a need for much greater clarity in that respect.
Thank you.
I will follow up on that point. You said that it was mainly councils and council housing that play a part rather than registered social landlords, but Glasgow City Council, for example, does not have its own housing—it is all held by registered social landlords. Is there a particular problem in that case? I recall an article a few months ago that said that Glasgow was not meeting its obligations on homelessness. I do not believe everything that I read in the papers, but is that perhaps the case?
With regard to Glasgow specifically, we have been engaging with the city council on its acknowledged difficulties in delivering appropriate temporary and other accommodation for homeless and potentially homeless people. The council has committed to making the improvements that need to be made, and it has put in place interim measures to deal with those difficulties while it implements a longer-term, sustainable set of improvements to its homeless service to ensure that they are addressed.
Does the council have accommodation or does it still rely on social landlords?
It has a mix. It has arrangements in place with registered social landlords and other landlords in the city, and it has access to other accommodation that it makes use of for temporary accommodation purposes.
Okay. We move on to temporary accommodation. Gordon MacDonald will go first on that.
Your report highlights that there has been a general decrease in the use of temporary accommodation from the peak in 2010-11 of 11,264 households. I understand that the figures for the final quarter of 2013 suggest that the number has fallen to 9,963.
People are provided with temporary accommodation for a range of reasons. Can you identify the underlying reasons for the 11 per cent reduction during that period?
We certainly observed that downward trend in the use of temporary accommodation by local authorities. However—this may answer your question—we did not always see effective strategic planning by local authorities with regard to the level of temporary accommodation that was required. We found that some local authorities had reduced the provision of their own properties for temporary accommodation, but we did not necessarily see any links between that reduction and the planning requirements with regard to the need for temporary accommodation. It was not always clear how decisions that related to the demand for temporary accommodation were fed through to reduce the actual level of such accommodation.
Some local authorities are reducing the availability and choice of temporary accommodation, which may make it more difficult to meet people’s needs in the future. There are also differences between local authorities in the provision of temporary accommodation for people whom they have assessed as homeless and those whom they have taken through the housing options route.
Does that mean that there is no evidence to suggest that assessments are being done more quickly or that settled accommodation is being found more quickly? Does it mean that there are fewer intentionally homeless people? Are you saying that councils may not be providing enough temporary accommodation?
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We are saying that there was not clear evidence of strong, effective planning for the provision of temporary accommodation based on a clear understanding and assessment of the levels of need and demand.
It is probably worth saying that the reduction in the use of temporary accommodation mirrors, to a degree, the reduction in the number of applications that local authorities are dealing with. We could conclude that there is a certain logic in that element of mirroring. It is undoubtedly the case that, if local authorities are effective at preventing homelessness, they will reduce the need and demand for temporary accommodation. However, the report identifies that there is some evidence that some of that reduction may be because people are being diverted from the homelessness application route to the housing options route, so temporary accommodation is not being made available where it would perhaps have been required.
But ultimately, regardless of which route people go down, they are being found accommodation.
Not everyone is being found accommodation. As my colleague said earlier, some of the outcomes that were achieved through the housing options route were probably less favourable than the outcomes would have been had the person been dealt with through the homelessness statutory framework. It is correct to say that the outcomes were not always what they should have been for every individual who was dealt with through the housing options route.
Are there any findings in your report that could improve the use of temporary accommodation?
As my colleague has said, the inquiry focused very much on the operation of the housing options approach. We touched on temporary accommodation in so far as it related to the approach and its provision, but we have not made direct recommendations on temporary accommodation.
We engage with individual local authorities through the shared risk assessment process that we undertake with our scrutiny partners such as Audit Scotland. When we identify a requirement for improvements around temporary accommodation through that process, we pick that up in the direct engagement with the local authority.
Are you taking any steps to monitor the quality of the temporary accommodation that local authorities provide?
We look at the figures as part of the shared risk assessment when we look annually at local authorities’ performance in relation to their duties and responsibilities. We also make use of the Scottish Government statistical returns from local authorities, which include figures on temporary accommodation.
Following on from my colleague’s questions about temporary accommodation, I note that the foundation of your important function as the Scottish Housing Regulator is, of course, the Scottish social housing charter. One of the outcomes in the charter is that
“Local councils perform their duties on homelessness so that: homeless people get prompt and easy access to help and advice;
and
“are provided with suitable, good-quality temporary or emergency accommodation when this is needed”.
How do you measure whether the accommodation that local authorities are providing is of good quality? You will be aware of evidence from Shelter Scotland that, despite the significant decrease in the number of families being placed in temporary bed-and-breakfast accommodation since the legislation was introduced in 2004, a small number of families—and particularly pregnant women and children—are still being placed in accommodation that is not wind and watertight. How do you measure the quality of accommodation in order to meet the outcome that is specified in your charter?
We have just concluded the collection of the first round of performance information on the social housing charter. Landlords were required to provide us with that by the end of May. We will now analyse that information, and we aim to report back to tenants and the wider public by the end of August. It will be the first time that we will have had a comprehensive data set on landlords’ performance against the charter. We will then use that information, along with a range of other information and intelligence that we gather through the shared risk assessment, to identify which local authorities we may need to engage with further so as to understand better how they are performing.
The only really effective approach to assessing the quality of temporary accommodation is direct inspection. We would undertake that where we have identified a risk that a local authority is failing to deliver that quality—taking account of a range of different information that comes our way, so that we understand where the risk is. The range of activity that will flow out of our shared risk assessment process may well include engaging with a number of local authorities around the quality of the temporary accommodation that they are providing.
Have you had any discussions with Shelter Scotland on the specific issue of temporary accommodation?
We have fairly regular conversations with Shelter both at a strategic level and when we are engaging directly with particular local authorities. We view Shelter as an important stakeholder and a useful source of intelligence, given its work on the ground through a range of projects and its housing advice centres. We have had a range of conversations with Shelter on those sorts of topics.
I was concerned to read about what appeared on the face of it to be an inappropriate diversion of people away from the provision of homelessness services to the housing options approach. My understanding was that, under the regulations, local authorities have a housing support duty that requires them to assess, where appropriate, the housing support needs of homeless applicants for whom they have a duty to secure settled accommodation. Why was that not kicking in when people were to all intents and purposes homeless, as you pointed out?
It is important to understand the different assessment routes that local authorities are considering. The duty around support needs is relatively new—it was introduced in the summer of 2013. We saw some good examples of local authorities ensuring that the support needs of individuals who approached them were fully assessed and that appropriate responses were put in place. The difficulty arose where local authorities were making decisions about whether an individual was to be dealt with as a homeless person or through the housing options route. Where it was done through the housing options route, it was not always clear that the requirements around the assessment of support needs would kick in.
That goes back to a point that we made earlier and our recommendation around clear guidance to ensure that local authorities understand—and are assisted in providing—the appropriate assessments at the appropriate point for each individual who approaches them.
Was that a consistent finding across the country? Were some local authorities doing the appropriate thing and others not? Is that what you are saying? Was that because of a lack of clarity in the guidance?
It was not a consistent finding. We found that a number of councils were doing effective joint assessments around homelessness, housing options and support needs, and all those assessments were happening at the same point. In our report, we highlight a council that ensured that the support needs assessment was happening for all individuals in every case, so it is certainly not a consistent issue.
Again, that brings us back to the point about clarity and ensuring that there is consistency across all local authorities.
So it is that best practice that we are aiming for across the country, in every local authority area.
We certainly highlight that as positive practice in our report.
On page 13 of your report, you highlight that
“there are no nationally-available ... statistics on the outcomes people achieve through Housing Options.”
You go on to state:
“The lack of clear and consistently-applied recording of outcomes in Housing Options has been a major barrier to evaluating the success of the approach both locally and nationally.”
How important is it that we are now moving towards mandatory data collection? What difference do you think that will make?
I think that it will give policy makers and stakeholders real evidence of how the housing options policy is being delivered in practice and allow it to be evaluated based on statistical information. The data collection involves collecting details of who has applied, household characteristics, reasons for application, prevention activity and, very importantly, outcome. That will provide a set of important evidence about housing options and a national evaluation of its implementation.
At the moment, there is inconsistency between the approaches of different local authorities. Do you see that improving?
The monitoring framework and what the Scottish Government and others will potentially develop by way of national guidance are the two things that clearly come out of our thematic inquiry as being the things that are needed. One of those is in place and it will start to deliver the statistical information, and we have a commitment from the Scottish Government and local council bodies on developing the national guidance. Those two things will make a real difference to how well local authorities consistently deliver housing options in an effective way.
The mandatory requirement has been introduced from April this year. Is there guidance to accompany that yet?
There is guidance on what statistics need to be provided for the new monitoring framework so that they are collected, provided and submitted consistently. The guidance on how housing options should be delivered on the front line by staff in different local authorities is still to be developed, but we have positive commitments from Scottish Government and local authority bodies to do that. We are aware of early progress having been made to develop that guidance.
The distinction and the clarification are useful and helpful—thank you.
How do you, as the regulator, see your monitoring work tying in with the new requirements, particularly in relation to the charter and the indicators that relate specifically to homelessness and housing advice?
We are in the first year of the charter. As of 1 June, the information for last year has been submitted to us and we are in the process of analysing it. We also rely on statistics that the Scottish Government collects from local authorities, which we will use to review local authority performance against the charter outcomes. That will feed in to what my colleague mentioned—the shared risk assessment process for each local authority. That will give us our regulatory priorities to focus on in relation to individual local authorities in the coming year.
You state that, in undertaking the inquiry, you had
“feedback from discussions with a range of stakeholders.”
Were some of those stakeholders people who had pitched up at their local councils saying that they were homeless, who said that their problem had been dealt with through the housing options route, as opposed to how they might traditionally have expected it to be dealt with?
The stakeholders we refer to in the report are stakeholder representative bodies such as Shelter. As part of our case studies, we observed interviews at local authorities at which homeless people or people who were saying that they were potentially homeless were spoken to by people from the council. We had that direct evidence from people who were approaching councils and going through the housing options or homelessness assessment route.
We have no further questions. Thank you very much for being with us this morning. It has been very helpful.
We will now move into private session, as previously agreed.
10:46 Meeting continued in private until 11:18.