Research to inform a fundamental review of social housing allocations policy

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Joel Lang
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1 Research to inform a fundamental review of social housing allocations policy Chartered Institute of Housing in Northern Ireland March 2014 The Chartered Institute of Housing (CIH) is the professional body for people involved in housing and communities. We are a registered charity and not-for-profit organisation with a diverse and growing membership of over 22,000 people - both in the public and private sectors - living and working in over 20 countries on five continents. CIH is the only professional organisation representing all those working in housing. Our purpose is to maximise the contribution that housing professionals make to the wellbeing of communities. General comments CIH welcomes the opportunity to comment on the Department for Social Development s commissioned research to inform a fundamental review of social housing allocations policy. We recognise that the purpose of the report is to advise on the best way of allocating what has become a scarce public resource. Whilst CIH has views that are outlined below, and we recognise that housing supply lies outside the scope of this review, we believe it is nonetheless imperative to highlight the importance of increased housing supply in the context of social housing allocations. The report identifies that 22,675 of the applicants on the social housing waiting list were in housing stress on 1 January 2013, and 9,878 applicants were found to be statutorily homeless. Despite this, only 11,701 homes were allocated across the social housing sector in 2012, and only 5,771 of those were to statutorily homeless households, meaning approximately 42% of statutorily homeless households were not housed. Only a region-wide programme of social home building in areas of demand can negate a shortfall of this magnitude, and address interconnected policy objectives including affordability in other tenures.

2 The nature of access to social housing On the supply side, CIH advocates a tenure-neutral approach to housing in the long-term and therefore equalising choice of tenure. Social housing should be neither a residual tenure nor one of last-choice. In the context of increased supply then, a larger number of households will consider social housing to be sufficiently accessible. Hence, retaining universal access to social housing is vital even in the context of a needs-based approach of prioritising its applicants. On the demand side, tenants should have access to free and independent advice on a tenure neutral basis in the form of a Housing Options Service, which sets out the full range of housing options, and is personalised to be based on the circumstances of the household. Personalisation is key, as advice tailored to concealed households who are neither in housing stress nor in an overcrowded household will naturally vary from advice given or services referred to vulnerable and homeless individuals and households. Another important role of the service is managing the expectations of applicants the reality is that as long as demand outstrips supply some applicants will not be housed. We note that the Northern Ireland Housing Executive (NIHE) need not discharge its duty to homeless applicants by housing them in the social rented sector, although this has been their custom and practice. In the context of the numbers of statutorily homeless households remaining un-housed in the social rented sector, the Housing Options Service therefore would have a key role to play in enabling access to the Private Rented Sector (PRS). A thinkpiece collaboratively produced by CIH, DSD and SmartMove states there is a clear strategic and economic case for investing in private rented sector access schemes to help make better use of the sector to meet the housing needs of low-income, vulnerable and homeless individuals and households. 1 A 2012 report commissioned by the Housing Rights Service concurs the PRS can be used effectively to meet the needs of even the most vulnerable homeless, and create sustainable, long term tenancies. Of course, a significant degree of support is required if the vulnerable homeless are to sustain tenancies which would be provided by a multi-disciplinary mobile team, while affordability remains a key obstacle. 2 The 1 CIH NI, DSD, SmartMove NI. Making the Most of Northern Ireland's Private Rented Sector to Meet Housing Need. Belfast : CIH NI, DSD, SmartMove NI, 2011 p Policis, Centre for Housing Policy. Meeting the housing needs of vulnerable homeless people in the private rented sector in Northern Ireland. Belfast : Housing Rights Service, 2012 pp. 8-9.

3 relationship between landlords, the NIHE, local government and the Housing Options Service will be a critical factor in the success of such a service. Assessment and allocation A benefit of banded allocations systems is determining priority for households who have similar levels of need, by looking at how long a household has been waiting for an allocation. Simple banding schemes with straightforward principles are quick and easy to administer, and clear and transparent. The more complex and numerous the criteria of any assessment scheme are, the more complex the scheme will be. The risks include: the scheme becoming expensive and time-consuming to operate; requiring a value judgment to be made, making the process less transparent and open to argument; and requiring more frequent monitoring and review of applicants details to ensure they are correctly banded. For instance, changes to individual circumstances over time mean applicants are more likely to move between different bands if banding has a narrow criteria. Traditionally the mechanism for determining priority between applicants across the UK tended to be points based whereby, much the same as the system in use here currently, indicators of need were given a points value and an applicant s priority was determined by the quantity of points accumulated. A study in 2007 by the then Scottish Executive Improving Access and Maximising Choice: the Applicant's Perspective on Allocations Schemes 3 found that applicants did not often understand the points based system and were unsure what the points meant in terms of priority and also who was afforded the highest priority. It also found a common complaint was that the system of awarding priority was not sufficiently transparent and respondents had no real understanding of which types of applicants were considered to have priority. Even those individuals who had high priority were often unclear as to how many points/what priority rating they had and how close they were to being allocated a property. Respondents also mentioned that staff were not particularly helpful in explaining the priority systems (p. 21). 3

4 The Scottish Government now encourage a banding system used by most landlords as a more appropriate system to rank applications. The banding system reflects different levels of need for example high and medium and low and will be simpler for the applicants to understand. Under a banding system those who fall into more than one of the reasonable preference categories are given greater priority. Within the banding system landlords are encouraged to have a mechanism for determining priority for housing among applicants who have similar levels of need. This is often decided by looking at how long the applicant has been waiting for an allocation. The global principles of an allocations scheme should be: 1. Fairness and perceptions of fairness emerge consistently as an extremely important issue for applicants everywhere and affect views of the entire allocation process. Whatever approach is adopted has to be seen to be fair by the users of the system. 2. Transparency is important: applicants and staff need to understand how and why decisions are made and can buy into the process. 3. Simplicity of operation: the process needs not to be bureaucratic and impossible to understand. 4. In the long term, it needs to address wider social and community interests: in England now local authorities are encouraged to consider how they can use the allocation process to meet local and community needs or wider social action: e.g. getting people into work, linking tenancies to work development programs and this is because a lot of disenchantment with the allocations process has been around the idea that to get accommodation, you need to chase points: perverse incentives. A banding system shouldn t reinforce perverse incentives and should address wider social and economic, community issues. In the short term, given the chronic undersupply of social homes in Northern Ireland, addressing wider social and community interests at the expense of needs based allocations is not ideal and CIH notes that the research states this in recommendation three. There are other ways in the interim to meet wider social and community interests, such as a proportion of new estates being allocated as private co-ownership housing targeted at first home buyers though again this reverts to the scope of supply.

5 5. Doesn t discriminate: in addition to avoiding religious discrimination in the allocation of social homes, be careful about schemes which prioritise local connection in case they indirectly discriminate against new arrivals to an area. Fairness is bound up with equality. 6. Choice: the high demand for properties often leads respondents to feel that they have very little choice in which property they would eventually be allocated. Often people waiting feel that they have very little choice, and so will need to accept whatever is offered. Given the length of time some applicants wait, they feel they cannot take the risk of rejecting any property offered. Systems which can support some form of choice are therefore important, but this in reality can be difficult to achieve. 7. Customer satisfaction: whatever approach is adopted, the satisfaction of customers will be important for tenancy sustainment prospects but also organisation performance. The Scottish study however was interesting on this because it found the key satisfaction issues were property condition, suitability and location particularly proximity to family or the perception of the property being in a decent area. The existence of choice within an allocation system did not seem to have a strong relationship with satisfaction largely because respondents did not perceive there to be any real choice, even in areas with choice based lettings in operation. 8. Prioritising (fast-tracking) high needs within bands: if a banding system is used, priority cards can also be used in line with the banding approach to prioritise applicants in urgent housing need such as victims of domestic violence or hate crime. Choice based lettings (CBL) is a way of meeting both choice as a global principle of allocation, and parity of tenure. Where households have choice of location limited by financial means in the PRS and owner-occupied tenures, CBL offers choice of location limited by housing need as determined by the position on the waiting list, there otherwise being no choice in direct lettings of social homes beyond refusals. CBL can encourage participation in the allocations process and is demonstrated to reduce refusals and voids, which is to be welcomed. Measures would need to be introduced to support households for whom barriers to participation in CBL are presented, including vulnerable households and households without internet access. CIH is also supportive of recommendation ten there should be a facility to make direct lettings in

6 prescribed exceptional circumstances. Direct lettings may need to be made to high priority applicants (e.g. if a statutory homeless applicant has not been bidding in a CBL scheme). Summary and concluding comments A review of social housing allocations policy provides an opportunity to introduce, with the Housing Options Service, comprehensive advice on a tenure neutral basis that can better meet the needs and expectations of social housing applicants, which CIH has been formally calling for since Within an allocations policy that retains universal access and needs-based priority, a benefit of a simple, clear and transparent banded system with straightforward principles is determining priority for households who have similar levels of need, by looking at how long a household has been waiting for an allocation. A CBL system can reduce rejections and voids, and offer choice and greater participation in the social rented sector, though some households will require support measures varying from assistance in accessing the system to direct lettings in exceptional circumstances. In a broader context, the only way to enact an effective policy retaining universal access and needsbased priority is by meeting housing demand with supply. For more information please contact Justin Cartwright Policy and Public Affairs Officer Chartered Institute of Housing in Northern Ireland P: M: E: justin.cartwright@cih.org

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