APPG for Housing in the North: Impact of welfare reform Summary of Evidence received to date. Background The APPG for Housing in the North launched an Inquiry into the impact of welfare reform. The Northern Housing Consortium (NHC) hosted the inquiry and put out a call for evidence in April 2012. The original frame for the inquiry was focused on the following 5 questions Can we demonstrate any economic impact on localities? What, if any, are the particular housing market impacts? Has welfare reform produced behavioural change as Government hoped for? What new services or products, if any, are being developed to support welfare reform? What impact, if any, has welfare reform had on partnerships – existing or revealing the need for new partnerships. Process Organisations (housing providers, Local Authorities, private rented landlords, charities and the third sector) had been invited to provide evidence of their experience/views under the headings set out above. However, it was evident from April 2012 that organisations were at different stages of preparing for/responding to the changes initiated through the Welfare reform Act and therefore not all respondents were able to answer all questions – or as has been the case, evidence has been supplied in an iterative format rather than one complete document. As welfare reform is still unfolding and organisations are reacting to developments as they occur (for example learning from the direct payment demonstration sites), we recommend that the Inquiry is kept “open” and key experiences and learning are shared amongst the housing sector and shared with Parliamentarians as appropriate. It is clear from the engagement and evidence received to date that housing organisations and LA’s across the North respect and agree with the underlying principles of welfare reform –namely to simplify an overly complicated system and that supporting people into work should be a key priority for both the welfare system and housing organisation. However, concern, where voiced, has been on perhaps unintended consequences arising out of the delivery of these aspirations. Engagement and Evidence Throughout the Inquiry, the NHC has received evidence from and has engaged with over 50 organisations. Not all organisations are in a position to provide information against the 5 initial headings but we have not sought to exclude their input as we recognise the importance of collecting as much information as possible whether that is an initial assessment of projected impact or a more detailed assessment of a particular aspect of welfare reform. Focus Whilst the Inquiry framework did not specify any particular aspect of welfare reform, the nature of organisations responding meant that evidence is primarily focused on “housing related” changes – namely, changes in social housing size criteria and the introduction of Universal Credit and direct payments. However, it is clear that wider reforms will also impact on households and neighbourhoods and this may mean we need to return to wider assessment of cumulative impact of welfare reform. Similarly, in preparing for welfare reform, organisations have been able to work with groups known to be affected by changes – those now classed as under occupying for example. The evidence to date gives an indication of the resource requirements, support needed to secure “behaviour change” etc. We do not yet have significant evidence around those individuals and families who due to a change in circumstances are affected “overnight” – we may need to revisit evidence at a later date to assess how well these individuals/families are supported. Local Support As part of the changes to welfare reform, there are some support aspects that have been devolved to Local Authorities –namely, Discretionary Housing Payments (DHPs) delivering a local support service in lieu of the “Social Fund” and of course localisation of council tax support. Not all LA’s have yet published their proposed approaches to DHPs and Social Fund, therefore it is difficult at this stage to assess how these support services will respond to demand. It may be useful to revisit evidence on these matters post April 2013. Recommendations: That the Inquiry is kept open, that learning is shared across the housing sector and that parliamentarians are kept informed That we undertake a cumulative impact assessment of all aspects of welfare reform and we ask Government to agree to similar impact assessment process. That we revisit evidence around local support services once these are fully developed and can be subject to assessment re demand/need and delivery. Evidence to date Economic Impact on Localities Local Authorities have sought to undertake economic impact assessments in respect of welfare reform. These assessments have sought to use national impact assessments applied to local circumstances – the degree to which these have been scenario checked will differ from location to location – therefore we counsel against comparing apples with pears. However, evidence to the Inquiry includes: Durham County Council estimating potential impact of £151million removed from the economy by 2013/14. With welfare reform so heavily intertwined with economic vibrancy they remain concerned that unemployment levels in Durham remain significantly above the national average. Sunderland City Council predict potential impact of £54million removed from local economy Manchester City Council commissioned Centre for Local Economic Strategies (CLES) to determine likely economic impact – their findings suggest potential reduction of £45million per annum to the local economy. Barnsley Council estimate a reduction of £32million per annum from economy – the equivalent of 3100 jobs. Responses Local Authorities are recognising the need to do all they can to support economic growth, working closely with LEPs and Chambers of Commerce as well as utilising other methods such as City Deals. In recent months we have noticed an increased level of engagement with Chambers of Commerce seeking to understand the potential impact on local businesses of these reforms – for example both Sunderland and Sheffield Chambers of Commerce recently held events including seeking a housing perspective. Local Authorities and housing providers are also looking at different spatial or population cohorts likely to be affected by changes - for example can you identify communities with high levels of incapacity benefit (IB) or DLA claimants which may require significant support. One neighbourhood in Rochdale reports IB levels of over 20% national average is closer to 3% Easington in Durham has identified 10% of population is claiming IB Estimating the total economic impact of welfare reform remains difficult at this stage due to the range of scenarios needing to be applied. However, organisations have been more able to supply evidence on the economic impact of specific elements of welfare reform. Housing Market/Housing Welfare Changes and their Impact Unsurprisingly the most complete evidence received to date relates to the impact of proposed changes to social housing size criteria. However, other evidence received includes – learning from demonstration sites on direct payments, changes to Local Housing Allowance (LHA) and changes to shared accommodation requirements. We will share highlighted evidence of each of these. Social Housing Size Criteria/Bedroom Tax The DWP impact assessment acknowledges the spatial impact of these changes with over 40% of working age households in the North affected. Parliamentarians will be increasingly familiar with the local impact and the difficulties faced by individuals and landlords; however it is worth rehearsing some of the key evidence lines again. Scale of Impact 4 housing providers in the Liverpool City Region (representing 30% of social stock) have identified £7million of Housing Benefit (HB) likely to be removed Gateshead Council estimate likely need to collect extra c£2million per annum as a result of under-occupation charges alone Riverside Housing estimate need to collect £4.8million in rent arising out of these changes (c3% of total rent roll) Gentoo calculate £1.8million of extra rent to be collected as a result of under occupation Your Housing Group (NW) advise £3.9million HB to be withdrawn The particular challenge faced by organisations is the mismatch between properties available and demographic need – a fact illustrated by the 4 Liverpool City Region housing providers. North Tyneside Homes report a similar profile mismatch and have estimated that to move everyone into the new “right” sized property, based on current turnover rates, would take over 10 years. The Cambridge Centre for Housing and Planning Research undertook research in Feb 2012 to seek to identify likely responses to HB changes arising out of underoccupation, it predicted that 32% of those affected will wish to transfer to smaller accommodation, 26% will find the money from another source and 42% will simply not pay. NHC members have been applying this model to their own stock profile with results that suggest in places, the potential saving DWP have identified is offset against other draws on the public purse in the form of, higher rents in the private rented sector, bad debt and arrears, potential evictions, potential call on LA services for homelessness applications etc. Some examples are given below: Wigan and Leigh Housing – Moving to the private rented sector Under occupying by 1 bed I 2 bed 3 bed Current household size 4 bed 3 bed 2 bed 6 bed 5 bed 4 bed 3 bed 4 bed Predicted % downsize to LA 30% 4% 6% 0% 0% 30% 4% 30% Predicted % downsize to PRS 2% 28% 26% 100%1 100%2 2% 28% 2% Cost to DWP Impact on DWP budget -£3189.47 +£393,960.62 +£171,921.21 +£ 2,408.45 +£773.45 -£4,556.39 +£22,396.76 -£4205.18 +£579,509.45 Wigan and Leigh – Eviction and Homelessness Costs From the Cambridge study it is estimated that 42% of households will simply not pay the charge and may ultimately get evicted. The estimated saving to DWP from this group is £1,343,429 per annum. However based on the average figure for eviction 1 2 As there is only 1 case this is assumed to move to PRS therefore figure is 100%. As above costs of £6,852 this would cost the organisation £13.1m. Costs that would be met locally from the revenue account (HRA) and therefore reducing income available to repay debt, maintain stock, provide services and build new homes. This is in addition to the increased pressure on the General Fund of meeting homeless costs at a time of reducing budgets and rising homeless presentations based on CLG figures of £5,300 for each homeless acceptance then this would be over £10m in Wigan alone.” Further case studies illustrating the financial comparison between under-occupying and moving adaptations or under-occupying and dealing with ASB have been provided to the Inquiry. Under Occupation Responses Housing providers have been preparing themselves and their customers for these changes as soon as the Welfare Reform Bill was published. Evidence to the Inquiry suggests that considerable effort and resources have been put in place to understand the scale of impact, ensure data sharing was effective and then mobilise communication campaigns. Whilst concerns around data sharing always arise, respondents to the Inquiry have indicated generally good relationships with partners. Symphony Housing Group works with over 40 HB departments and reported LAs as forthcoming with information – the only caveat being “The effectiveness and willingness to engage with us has been affected by their software” Organisations have sought to ensure their customers were informed about the forthcoming changes in a variety of ways including: Northwards Housing Group going to Parents evenings at local schools to raise awareness Halton Housing Group , First Ark, Yorkshire Coast Housing, City West Housing amongst other have produced videos explaining the changes Plus Dane Housing Group have adopted a “beer, prayer and hair” approach – drawing upon the findings of RSA Connected Communities project which suggests people get information from “familiar strangers” in their community, not always “officials”. Leaflets, posters and other campaigns have been of use, but organisations consistently report that face to face advice and support is most effective – this may have implications for the introduction of Universal Credit. Some landlords have looked at reclassification of stock size – effectively changing from a 3 bed to a 2 bed. Their ability to manage this reclassification will be dependent on business plan capacity, numbers affected and ultimately acceptance by any rent referral. Knowsley Housing Trust has recently announced they will be doing this for some of their stock. The use of Discretionary Housing Payments (DHP) to alleviate impact of under occupation charges has been recommended by the government. NHC analysis suggests not all LA’s have a confirmed policy on how they will prioritise under occupation requests against other requests and furthermore how they will distinguish between cases falling into the under occupation category. However, DHP are only payable for a time limited period. Evidence submitted to the Inquiry suggests that demand for DHPs will significantly outweigh level of funds available: Liverpool City Region landlords suggest that for those tenants with a significant adaptation, the estimated HB loss will be £3.57m per annum – or 12% of UK DHP pot available. Liverpool City Region population represents 2.2% of UK total Learning from the Direct Payment Demonstration sites Whilst the focus has been on under occupation, housing organisations have also been preparing for the advent of direct payments under Universal Credit. Currently, the government position is that most tenants will have their UC paid direct to them (including element for rent), those exempt from this position include those in specified supported housing schemes and those in temporary accommodation. The government’s view is that by moving to a position whereby the majority of tenants receive their Universal Credit direct and on a monthly basis it creates a situation which is more akin to that of being in work and receiving a monthly salary. The 6 demonstration sites across the country are testing different elements of the process – particularly the trigger points for switchback (the level of arrears that a tenant hits at which point payment switches back to the landlord). Wakefield and District Housing are one of the demonstration sites and have reported Over 1,000 tenants have received direct payments through the project. Arrears have increased to over £180,000 on the project. This equates to 11% of the debit compared to 2.7% for the whole stock. Payments reverted back to WDH – 174 tenants payments have reverted back to WDH. Over 90% of these have been due to a 15% underpayment trigger. Very few instances have been due to eight weeks arrears accruing. Most tenants pay most of the rent most of the time but are susceptible when they have a crisis in their lives. Housing providers will have substantially higher costs in terms of arrears and administration costs. Housing providers will have less information on which to plan to help and assist We are aware of at least one organisation which is doing its own version of the demonstration site –encouraging their tenants to switch to HB direct now in advance of changes arising out of Universal Credit. A key concern for housing providers in preparing for both Universal Credit and Under Occupation is how the level of bad debt, increased administration costs will affect their capacity to build new homes in the future. WDH analysis suggests lost capacity of £100,000 per week or the inability to build 2,200 homes over a 30 year business plan Homelessness and the Private Rented Sector The Inquiry is keen to receive evidence from all parts of the housing sector and is pleased that the private rented sector have engaged through written evidence and by hosting roundtables and that homelessness organisations have supplied evidence. We are aware that the NE homelessness taskforce is undertaking further specific research on potential impact on homelessness services and clients and we will provide the APPG with an update on this research as it progresses. One NE social landlord reported concerns voiced by private sector landlords that they would not take under 35s, even if in employment, in case their status changed Evidence from the National Landlords Association, representing private sector landlords, also registered concerns regarding direct payments and also felt it was wrong that the demonstration pilots had not included anything focusing on the private rented sector. Behavioural Change The Welfare Reform Act intends to demonstrate to general public and benefit claimants that it pays to be in work – this is both through the design of Universal Credit which seeks to remove cliff edges apparent in current welfare system – and through “nudging” claimants to make “better” decisions about work and welfare. The Inquiry was keen to receive evidence as to whether behaviour change was being achieved. To date, evidence on this topic is hard to determine, particularly as the vast majority of changes have not yet come into being. Respondents identified the primary focus of behaviour change related to under occupation; Your Housing Group reported “Since delivery of our Financial Wellbeing leaflet and questionnaire to residents and since enhancing our Homeswapper mutual exchange subscription to include Rightsize, the Group has seen a growth in the numbers of residents accessing the Homeswapper Service. We are already, in advance of actual implementation of the welfare reform changes ,seeing increased demand for our money advice and tenancy support services “ The NHC supports ContactNet – a network for housing based contact centres and they have agreed to monitor telephone traffic once the changes have taken place to provide evidence on the type of inquiry customers are contacting them about and the ease by which such queries are solved. Riverside Group research suggests that 29% of customers affected by under occupation would seek to work longer hours/take up employment. However, no organisations reported (at the time) increased levels of queries regarding employment opportunities etc. Evidence from the Cyrenians cited a case study which highlighted the potential negative behaviour choices that could arise out of welfare reform Case Study This individual was in receipt of JSA from January to February 18th 2011. When he was due to begin work, health problems (heartrelated) prevented him from starting. He received a sick note from his GP, informed the Department of Work and Pensions, made a claim for ESA and handed in his sick note to his employers. Two weeks later he had heard no response and so contacted ESA. They asked him to attend a medical at Arden house and sent ESA forms which he completed with help of support staff. However, two weeks later he still had not heard from DWP and when he rang them they stated that they had not received the forms. They sent more forms, which again he completed and returned. After eight weeks from first declaring health problems he was still not receiving any money at all, so becoming desperate, he decided to apply for JSA. At this point, he was informed that he would have to wait until he had attended his medical. During this time he has resorted to shop lifting for food. This individual had already experienced very poor physical health, and during this period suffered weight loss, fatigue and an asthma attack. In addition his mental health has been affected. He has experienced anxiety, has become easily irritated and has displayed sudden bouts of anger. He also reports loss of confidence in professionals and the state system; feeling that it is now pointless doing any training courses and can’t see an end to his predicament. New Products and Services All respondents to the Inquiry indicated that as a result of welfare reform they were undertaking fundamental reviews of how they engaged and supported their customers. Many landlords have significantly extended their financial inclusion teams – quite often doubling or trebling in size. Organisations have taken a holistic approach to supporting their customers – not just focusing on welfare reform but on outgoings. The NHC and Derwentside Homes have come together under the banner of “The Smarterbuys Store” to provide access to household goods at affordable rates of finance and promoting Credit Union savings. “The Smarterbuys Store” is aimed at providing an alternative to high street weekly payment stores and hopefully removes the need for customers to access pay day lenders. This initiative is being rolled out to 25 landlords. Landlords in the NW including Bolton at Home, Northwards Housing, Halton Housing Trust, New Charter Housing Trust, Irwell Valley, Kirklees Neighbourhood Housing, Knowsley Housing Trust, Calico, Wulvern and Liverpool Housing Trust have been working with ABCUL (Association for British Credit Unions) to develop a “jam jar” account. One of the barriers to operation of such schemes is the transaction costs associated with card payments. The sector as a whole is working hard to lobby card providers to reduce transaction costs. Gentoo/Sunderland City Council are developing a single on line financial assessment tool by the Local Authority which will enable much easier assessment and initial budgeting for likely welfare reform impacts Organisations are looking at how they can act as “matchmakers” for new shared housing projects As welfare reform is linked to digital access, many organisations are reviewing how they use digital services and how they can streamline their operations – for example providing staff with tablets to enable online activity on home visits and real-time data updating Gentoo also report tenant-led activity on social media platforms including the creation of a Facebook page for mutual exchanges Partnerships One of the aims of the Inquiry was to determine whether partnerships were fit for purpose in responding to the changes brought in by welfare reform and if not, what needs to be done to improve them. The Inquiry also sought information on respondents’ views as to what new partnerships may be needed. Local Authorities, Job Centre Plus and Credit Unions were the most cited partnerships that were fundamental to welfare reform being implemented smoothly from the evidence to date. Data sharing issues and concerns were raised by respondents – although this was generally before the change in regulations regarding data sharing. It appears that although at first many organisations focused, rightly, on their own business requirements, we are increasingly seeing desire to share information and collaborate. Collaboration The NHC operates an online Yammer Group on welfare reform, allowing members to ask questions, share information or documentation, peer support etc. It now has over 170 members. 7 organisations including Liverpool Housing Trust, Leeds Federated, Leeds and Yorkshire, Halton Housing Trust, Kirklees NH, Stockport Housing, North Star Housing have come together to undertake standardised interviews with customers exploring financial circumstances, decision making and spending behaviour. It is hoped that this wider sharing will provide a solid evidence base and will assist in potential service development activity across the group. Many respondents reported concerns about the capacity of the advice sector to cope with anticipated increases in demand – coming at a time when grant funding for such services was under increasing strain, if not withdrawal. A clear area requiring further research was the partnership between housing and health. Many respondents commented on the link between debt and mental health or drug/alcohol misuse. The need for health and wellbeing boards to fully understand the potential impact of welfare reform was made by several respondents. Conclusions The evidence to date shows housing organisations are working hard to prepare their customers for the changes coming with welfare reform. At the same time, organisations themselves will need to adapt their risk management framework, business plans and organisational delivery approaches. Some of the fundamental questions for the sector (as expressed by one respondent) include: Will the sector have to live with fewer resources as social housing providers, and thus need to drive significant savings if we are to continue to build more homes and deliver added value services? Will we become firmer in the management of our tenancies, with a greater emphasis on enforcement than support? Will our relationship with customers change? Will we be forced to retrench, providing core services only, to the detriment of neighbourhoods and communities? Over time, will we need to develop new products and services – whether in terms of the types of homes we build (smaller), their design (more flexible and suitable for sharing), or the services we offer (brokering shared tenancies). Will people just accept that they will have to live differently? What will this do to our neighbourhoods? Will they be better, with contemporary products and services aligned to demand and delivered more commercially, or will social housing become more transient and residualised? Next Steps Given the evolutionary application of welfare reform, we would recommend that the Inquiry remains open and we continue to seek evidence along the lines already outlined. If the APPG would like a particular focus we will be happy to accommodate this. In terms of interim recommendations we would suggest that as a minimum the following be applied: That the Inquiry is kept open, that learning is shared across the housing sector and that parliamentarians are kept informed That we undertake a cumulative impact assessment of all aspects of welfare reform and we ask Government to agree to similar impact assessment process. That we revisit evidence around local support services once these are fully developed and can be subject to assessment re demand/need and delivery. Northern Housing Consortium February 2013