In February, the National Housing Federation's Spending Review Submission set out the bold goal of Saving Supported Housing, noting that this model helps half a million people and acts as a key pillar in a sustainable housing, health and social care system – and one which needs to expand for the NHS to meet its goal of delivering more care in the community.
That publication like many before it, points to the downstream public savings generated when quality supported housing models meet needs before they spiral into homelessness, or presentation to acute care, mental health, justice or other frontline services – for homelessness and temporary accommodation, for those facing domestic abuse, for older people, for those with learning disabilities and autism, and for others.
The sector has had its trials through its association with lease based finance models, with the Regulator's well-documented concerns about the strength of some of those models and the level of governance and financial oversight taken by some providers called into question. However, it remains – like mainstream affordable housing – a sector with many high quality providers (of both housing and support) and one into which institutional investment can be attracted, on appropriately risk-balanced terms, to enable growth through the maximum gains enabled by a combination of public and private sector funding.
In the background we have the recent consultation on the Supported Housing (Regulatory Oversight) Act 2023, which on its face is about the regulation of supported housing as a whole but which in fact seeks to regulate only "Supported Exempt Accommodation" (aka the four forms of Specified Accommodation covered by Housing Benefit, of which Exempt Accommodation offers the most flexibility for landlords and tenants around the overall benefits cap, securing rents above LHA levels and the "spare room subsidy"). In practice this limits the scope of the Act to accommodation provided by not for profits and public bodies. This is perhaps something of a missed opportunity in terms of a holistic approach to sector regulation regardless of the nature of the landlord. It also suggests that the real intention may be to further limit the ability of Housing Benefit to fund supported housing, with ongoing tenant access to HB dependent on the landlord holding and retaining a licence in accordance with National Supported Housing Standards and Local Supported Housing Strategies.
The consultation also suggests a revisiting (tightening?) of the definition of "care support and supervision" as defined in the HB Regulations – better described as enhanced supported housing based tenancy sustainment services i.e. HB eligible costs associated with the delivery of supported housing models.
There was some hope that the Spending Review would include policies directly addressing this key element of overall affordable housing delivery. However, while the commitment to £39 billion capital injection into social and affordable housing was universally welcomed, we didn’t see any big announcements about supported housing, with Homeless Link aptly describing a supported housing size hole in the Spending Review announcements.
However, there is room for some optimism - since the Spending Review announcements, via commentary from Baroness Taylor of Stevenage, the Lords minister for housing and local government. She stated in debate on 19 June that and the details around specialist housing will be included in Government’s Long-Term Housing Strategy, which is to be published later this year, and that Government is intending to work with both public and private sector funding to deliver as much housing as possible.
As such, while the Spending Review didn’t address specialist and supported housing models in particular detail, it is hoped that more will follow, ideally drawing together some of the existing policy asks to ensure the ongoing viability of these models in both capital and revenue terms, and drawing those policy asks around incoming sector regulation via the 2023 Act. Sector participants will no doubt be looking out for and seeking to influence those policy asks, to seek to reverse the declines in provision driven by lack of financial support and highlighting the overall costs savings good quality supported and specialist housing can bring to the overall public purse.
