Question 1
Do you agree that there are issues with the current arrangements for housing adaptations, which need to be addressed?

If so, has the Adaptations Working Group identified the main issues?

Which issues are most important to address?
Argyll & Bute Council welcomes this opportunity to respond to the Adaptations
Working Group consultation and would agree in principle that the main, high level issues in respect of funding and delivery of adaptations have been identified. The requirement for housing adaptations across all tenures constitutes the single largest component of current housing need in this authority as identified in the Argyll & Bute
HNDA (2,000 of around 7,000 households currently in need) and has been prioritised as a key objective within the Local Housing Strategy. Given the potential impact of an increasing ageing population and the policy imperative towards preventative and personalised public services within a context of increasing pressures on public spending, it is crucial that the organisation and resourcing of housing adaptations is addressed effectively. It is vital to make the process work better for older and disabled people and to embed adaptations as an integral part of housing, health and social care strategies and programmes. While there are examples of good practice and effective joint working in Argyll & Bute in respect of adaptations, partners would acknowledge that there are many operational and organisational issues affecting the delivery of services and that there are a number of geographical, sectoral and tenure-related inconsistencies and anomalies in the current system.
Multiple delivery arrangements can be overly complex and lead to inefficiencies, inconsistencies and lack of cost-effectiveness. There is certainly a danger of service silos and conflicting authority boundaries (eg council and health boards) leading to adverse impacts and geographical anomalies in service provision for individuals within the existing system. At the operational level, problems can arise from lack of clarity regarding differing responsibilities (for both immediate provision and future maintenance or replacement), diversity of funding sources, and the specific nature of prioritisation frameworks and variations in types of adaptation (minor and major works).
However, we would also make the following comments about the complexity associated with funding. In fact, it has been suggested that the system is not necessarily complex for individuals but there is real danger of inequalities and inconsistencies and disparity in service delivery across tenures. Delays in the RSL sector are often due to conflicting priorities. Access to adaptations in Argyll & Bute appears to be easier for owners. There is a lack of guidance on when adaptations are actually appropriate. Senior health and social work managers have no involvement with major adaptations and don’t appreciate the work involved in delivering them or the impact they can have on an individual’s health, care and housing needs. Adaptations and equipment are split and quite distinct.
The fundamental issue however remains adequate resourcing to meet current and future demand.
1

Question 2
Are there parts of the current arrangements that you think work well and should not be changed?
In Argyll & Bute, a more focused strategic approach has been implemented and improved joint working across agencies and services is developing, with good partnership between Housing/Health & the third sector.
Historically, the Private Sector grants system has worked well and Care & Repair managing the grant process for private sector has proved effective.
Question 3
Which of these minor (streamlining) changes do you think would improve the current arrangements for delivery of adaptations? Why?

Do you think these changes would be sufficient to address the issues?
While we welcome in principle a move towards sensible and more efficient streamlining of arrangements for delivery of adaptations, this Council and its partners would not necessarily consider all of the proposed changes to be minor or easily implemented.
Certainly, there is a key role for housing services and associated partners in improving consistent and comprehensive information & advice provision and developing linkages with the housing options approach. This also enables and empowers people to plan for their own future.
There is also potential for recycling within RSL stock through effective utilisation of the allocation process.
Forward planning/early intervention is crucial and is currently often lacking both operationally across agencies and culturally among individual service users (whilst acknowledging that there will be cases where adaptations are only required at a point of crisis, there are also many cases where the requirements can be anticipated and pre-programmed more effectively through data sharing, joint case working etc).
Housing health checks should be promoted and individuals should be encouraged to use this approach.
Self-referral however needs to be well managed and considered with due caution and appropriate safeguards and checks put in place (often what clients want is quite different from what they actually need – it is not actually always the case that the client or carer is best placed to assess their own needs albeit we do not challenge the general principle of the person-centred approach).
Responsibility and funding for future maintenance and also for linked repairs are concerns particularly for RSLs and greater clarity here would be beneficial.
Question 4
Which of the three approaches to organisational responsibility (through local housing authority, Health and Social Care Partnerships or the individual) do you believe would provide the most effective basis for the delivery of housing adaptations and the greatest benefits to people who need adaptations? Why?
While there are pros and cons with each option, we believe that the council as the local housing authority would be most appropriate and best fitted to carry out this responsibility, building on current practice and the best aspects of the existing system. This sits well within the wider housing strategy and coordinating role of the
2

local authority and would facilitate continued effective Partnerships.
Given the ongoing review and proposed restructuring/integration of health & social care partnerships, there is a danger that this process could take some time to evolve and “bed in” and that housing issues could be sidelined or stalled in the short to medium term. As a consequence, there is a danger that the adaptations agenda and in particular funding could be lost or displaced in the process.
Question 5
Are there issues or risks with any of the three approaches to organisational delivery that are not covered above?
Proper, clear and consistent prioritisation of needs framework is required across all tenures.
Adequate resourcing is essential.
Guidelines for OTs to cut out some non essential expenditure would be a positive benefit.
Standard design guides would help as would common shared terminology.
Architects need to be included in early discussions and have increased awareness about disabled adaptations.
Question 6
In the context of personalisation, what are the most important things to put in place to ensure that people who need adaptations and their carers are at the centre of the process and have choices?
Good access to timely and comprehensive information on housing options will empower individuals and promote personal choice and decision-making.
Effective support should be provided to individuals to explain and help understand what different options mean.
Linked up communication and information sharing between all health, housing and social care professionals is fundamental to ensure the individual receives consistent and appropriate treatment and advice whatever their point of entry to the system and so that fully informed choices/decisions can be made that are most appropriate in each specific case.
Question 7
Which of the three approaches to funding (through local housing authority,
Health and Social Care Partnerships or the individual) do you believe would provide the most effective basis for the delivery of housing adaptations and the greatest benefits to people who need adaptations? Why?
We believe an integrated funding pot is essential to ensure consistency and equality across tenures, services and geographic areas. The current allocation of resources is overly complicated.
The most appropriate approach is for an integrated, central budget within housing
3

resources administered by the local authority.
While the person is clearly and undoubtedly at the heart of the process, physical adaptations are usually building-related and often sitespecific to the person’s environment rather than necessarily to the individual’s particular disability or personal circumstances (i.e. not always necessarily transferable between different properties) and therefore would be better handled by housing professionals than health and social care professionals. Housing authorities are better placed to ensure the optimisation of existing stock and maximising effective matching of persons and properties.
Question 8
Are there issues or risks with any of the three approaches to funding that are not covered above?
As stated above, there is a risk of losing adaptations funding within broader health & social care agenda if it were to be incorporated in health and social care partnerships particularly at a time of significant change and restructuring.
The consultation paper clearly outlines additional issues in respect of both the health
& social care and the individual options.
Question 9
Do you think we currently have the fairest arrangements for people, who have personal resources, including both income and equity in their current home, to contribute to the cost of their own adaptations?

If you would like to see changes, what would these be?
In general we would endorse the Adaptations Wor king Group’s principle that assessment and access to financial and other supports for adaptation should be equitable, fair and antipoverty (based on ability to pay) and that those who don’t have personal resources are not disadvantaged. While a review of current subsidy levels is required it could be argued that a greater emphasis on individual owner’s responsibilities would be in line with the culture shift proposed for private sector repairs and improvements in general. We agree that there is a need for a reliable and accessible national loan fund or alternative borrowing options to support older or disabled owners
The Adaptations Working Group should also provide a full Equalities Impact
Assessment on the various proposals to enable consultees to appraise the likely impacts on all sectors of the target client group(s).
4

Question 10
Do you have any comments on any other issues related to the future delivery of housing adaptations, which aren’t covered above? If yes, please provide details.
The constraints upon funding for new build supply is likely to increase pressures to consider adapting existing housing stock and consequently we believe that it is essential that investment for adaptations is increased and managed more efficiently and effectively.
Nevertheless, in an area such as Argyll & Bute a significant proportion of existing stock is unsuitable for adaptation due to age/construction type etc and we agree with housing professionals that the principle of preventative public spending would ultimately be best served by increasing investment in new build stock which is truly suited for lifetime occupation and fit for varying needs over time. Therefore, in tandem with the proposed improvements to the provision of adaptations we would urge the Scottish Government to ensure adequate investment in new supply as the most cost-effective and beneficial action to address the needs of those with particular needs.
5