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Response To Consultation On Wag 10 Year Homelessness Plan February
Response To Consultation On Wag 10 Year Homelessness Plan February
Response To Consultation On Wag 10 Year Homelessness Plan February
Consultation Questionnaire
The Welsh Assembly Government’s National 10 Year Homelessness Plan will
guide the development and delivery of services to people in housing need. It
will aim to reduce homelessness to a minimum over the next decade.
We are undertaking consultation on this Plan to find out what all our
stakeholders, including services users, think about this Plan.
The information you provide will be used to check that we have identified the
areas that need to be addressed in order to achieve our aim. It will also be
used to help guide how we take the Plan forward. It is therefore important
that you tell us what you think by completing this consultation questionnaire.
When we have completed this consultation, we will write a report to
summarise the key findings and the impact that these have made on the
drafting of the final version of the plan. This report will be made available to
all of our stakeholders.
Space is given after each question for your answer. If you have printed out
this questionnaire, you might need more room for your answer. If you do,
then you can use additional sheets of paper to continue your answer. If you
do use additional sheets of paper, please put on these the number of the
question that your answer relates to.
Please return you completed questionnaire to:
By post:
Housing Strategy and Services
Welsh Assembly Government
First Floor South Wing
Rhydycar Business Park
Merthyr Tydfil,
CF48 1UZ
OR
By email:
HousingManagement&HomelessnessBranch@Wales.Gsi.Gov.Uk
Please note that the closing date for responses is 25 th February 2009
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
Section A Your Details
The information you provide will help us to record who is responding to our
consultation so that we can ensure that we have taken into account views
from a broad range of stakeholders.
The information you provide in your response will be subject to the Freedom
of Information Act 2000 and Environmental Information Regulations, which
allow public access to information held by the Department. This does not
necessarily mean that your response can be made available to the public as
there are exemptions relating to information provided in confidence and
information to which the Data Protection Act 1998 applies. You may request
confidentiality by ticking the box provided, but you should note that neither
this, nor an automatically generated email confidentiality statement, would
necessarily exclude the public right of access.
Please tick this box if you want us to keep your response confidential. ¨
¨
1. Name
________Ewan Hilton_______________________________
We deliver a number of services to people experiencing mental illhealth and are homeless/ at
risk of homelessness. This includes housing advice services, tenancy support services and a
‘hospital to home’ scheme, which works to ensure those leaving psychiatric inpatient settings
have suitable accommodation to go to.
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
5. In which county do you have experience of homelessness?
Swansea, Neath Port Talbot, Caerphilly, Merthyr Tydfil, Blaenau Gwent, Torfaen, Newport,
Rhondda Cynon Taff, The Vale of Glamorgan and Cardiff.
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
Section B – Comments on the Plan
6. Do you think that the Plan has covered the areas that need to be
addressed if we are to achieve our aim of reducing homelessness? Are
there any areas that you would have liked to have seen covered that are
not? If so, why?
We do feel that the draft Plan covers many of the areas that need to be addressed, but
wish to make comments on the following areas:
o Preventing homelessness we were pleased to see prevention of
homelessness featuring as one of the strategic aims and hope that this will
result in the current gatekeeping arrangements being broken down so that
people can access services before they become homeless. Many of the
individuals who we work with are only referred to us once their situation has
reached a crisis point, and it is clear that many would have benefited from
support at an earlier stage.
o Providing housing advice we also welcome the focus on advice services,
which we feel is particularly pertinent at a time when many private legal firms
are pulling out of social law contracts and Citizen’s Advice Bureau are so
overstretched that people can face prohibitive waiting lists to access their
services. We do feel, however, that this section of the draft plan could be
expanded to include advocacy as well as advice, and to clarify the difference
between the two.
o Developing the private rented sector we agree that developing the sector is
important; in some areas, this is only housing option people have and so needs
to be opened up. Our experience is that landlords are reluctant to rent to those
experiencing mental illhealth and many letting agents won’t take on people
who receive benefits.
o Improving life chances – although we agree it’s important to provide people
with opportunities to access skills and employment, we were concerned to see
employment rate targets featuring in a homelessness plan. We were concerned
that this may echo the DWP’s White Paper on Welfare Reform, which
emphasises compulsory work in return for benefits. It is important to recognise
that some people are too unwell to engage in employment or training and,
equally, that employment is not the only answer – people in work can still be at
threat of homelessness.
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
o Supporting People we were pleased that there’s a section on Supporting
People in the draft Plan, as we feel that housing, homelessness and supported
housing should all be part of one seamless agenda.
o Enabling Moveon although we were pleased to see a section on ‘move on’
within the document, we feel it needs to consider more than just those in
temporary accommodation. Bedblocking in supported housing, for example, is
a big issue for us, and for other service providers. It can take months, if not
years, to move people onto lowerlevel support or independent living, as the
housing just isn’t available and, because the individuals are not actually
homeless, they are not considered a priority. This is extremely frustrating to the
individuals (who, if left waiting for long periods, may experience a decline in
their mental health) and means valuable spaces are being taken up by those
who no longer need them, depriving others of the opportunity for support.
We were surprised to see that the draft Plan does not cover the issue of mental health in
any particular detail. We note, for example, that mental illhealth is not included on the list
of factors that put people at risk of homelessness (pg 4), which runs contrary to our own
experience and to a number of studies 1 . We are aware that the link between mental health
and homelessness is sometimes masked by the fact that individuals may be experiencing
a number of difficulties, and that their case may therefore be recorded under ‘young
person’, ‘prison leaver’ etc. We are concerned that if the prevalence of mental illhealth
among those who are homeless/ at risk of homelessness is not recognised, adequate
provision of services cannot be planned for and provided.
1
a survey by the Centre of Housing Policy at York University, for example, established that, compared to the general
population, mental illhealth was eight times more prevalent among those in hostels and B+B’s and eleven times more
prevalent among people sleeping rough (The Health of Single Homeless People, W. Bines, 1994).
7. Do you think that we have identified the issues and concerns associated
with reducing homelessness? If not, what do you think we have missed
and why do you think that this is important? Is there anything in the Plan
that you do not agree with?
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
Although many issues and concerns associated with reducing homelessness have been
identified, there are a number of points missing from the draft plan that we feel would
merit consideration:
o Although the draft plan does include a section on Supporting People, it does not
acknowledge the concerns around the distribution of Supporting People money. It
is widely recognised that, rather than being determined by need, funding has been
largely based on previous levels of transitional housing benefit claimed in each
area, resulting in considerable geographical discrepancies. It has also generally
resulted in commissioning being based on the amount of funding available, rather
than the needs of the local population.
o Although the draft plan includes “discharge from prison, care, hospital or armed
forces” as risk factors associated with homelessness, the plan does not go on to
mention, for example, the need for housing advice to be provided when people are
admitted to hospital. Through our ‘hospitaltohome’ link work, we’ve found many
people are not given (or given inaccurate) advice, which leads to them losing their
homes unnecessarily. Those entering the criminal justice system are in a similar
position, with the added complication that they may be serving their sentences out
ofcounty, possibly in England.
o The document does not mention the impact of recent developments in housing
policy such as stock transfer (which has made it harder to house vulnerable
people) and choicebased letting (which those who are unwell find difficult to
engage with and can lead to inappropriate accommodation choices).
o The draft plan does not really consider those who need more than housing advice
but less than services provided under Supported People. There are a large number
of people, for example, on waiting lists who might need support until they can
access appropriate accommodation to meet there needs, and there are others who
may have an initial issue (such as housing arrears) resolved through an advice
service but would need additional support to consider how that situation had arisen
and ensure it does not happen again. For some people, homelessness prevention
will not be a oneoff, short term intervention, but will require longterm, ongoing
support.
8. The Welsh Assembly Government will work in partnership with a range of
stakeholders, including service users, to develop an action plan which will
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
detail what steps will be taken to achieve or aim of reducing homelessness
to a minimum. What steps do you think need to be taken to reduce
homelessness and why? What agency or organisation do you think
should carry out these activities? Examples include the Welsh Assembly
Government, local authorities, criminal justice agencies, health
organisations, housing associations, or third sector (voluntary)
organisations.
We were disappointed that such an action plan was not included as part of the
consultation document. We feel that this has resulted in a draft plan that is heavy on
rhetoric and aspiration, but which leaves the reader with no real idea for what might
actually be going to change ‘on the ground’ to achieve any of these objectives. As a result,
it is very hard to accurately scrutinise the consultation draft.
There are, of course, a wide variety of actions needed to reduce homelessness, but what
follows below are a few suggestions for inclusion in the action plan, based on our own
experience and our thoughts on reading the consultation document:
o Obviously, ensuring availability of an adequate supply of housing is a key factor in
preventing homelessness. There is often a mismatch between housing need and
where (geographically) housing is available or what type is available. Among the
individuals we work with we’ve found a shortage of affordable singleperson
accommodation to be a particular issue. The National Housing Strategy, currently
out to consultation, recognises the need to “radically [improve] our knowledge of
need and supply”, an action which will need to be mirrored in this plan.
o There is a need for a wideranging education programme, developed in
partnership between the Welsh Assembly Government, local authorities and the
voluntary sector, delivered both in schools and in the community. This should
include financial literacy, information about housing options and where to go for
help. A separate education programme should be developed for healthcare staff
and other frontline works to raise their awareness of benefits and housing issues,
to try to ensure people do not lose their homes when they go into hospital etc.
o To address the reluctance of landlords to house vulnerable people and those in
receipt of benefits, the Welsh Assembly Government should look to work with the
WLGA and Community Housing Cymru to extend the bond guarantee scheme.
Where local authorities (or other organisations) are guaranteeing rents for a year
or more, people are accessing housing much more easily and have the stability of
a longerterm let.
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
o The Welsh Assembly Government should develop a pilot of ‘onestopshops’ –
too often people in need have to make contact with a confusing array of different
departments and organisations and often have to have their needs assessed
multiple times. Having everything in one place would be better for the individual,
and enable more joined up working between services.
o As mentioned on page 10, there is a need to develop a mechanism to make
Supported People funding more flexible. At present, as a Supporting People
provider, we find it very difficult to quickly stepup or stepdown levels of support
to respond to people’s fluctuating needs. The most effective services are those
which can be delivered when people need then (including ‘outofhours’) and at a
level that’s right for them – which may mean considerable more hours one week
than the next – and we would like to see the Welsh Assembly Government
encouraging local authorities to allow providers to work more creatively.
o Page 9 of the draft document suggests that lenders should notify homelessness
services when people might be at risk of losing their homes, and we are also
aware of some housing management services informing homelessness services
when they are initiating court action for rent arrears. We feel that this could be a
useful mechanism for ensuring early intervention, and would emphasise the need
for this to happen as early in the process as possible.
o The Welsh Assembly Government should issue guidance to local authorities
about appropriate supported housing provision for street drinkers, as there is a
critical shortage of this at present.
For this strategy to be effective, however, we believe that it is vital that the action plan
contains only those actions which are realistic and measurable. They must all be fully
costed, with a timetable for implementation, and accountability for delivery must be clear.
9. The Welsh Assembly Government believes that the only way that our aim
can be achieved is if everyone who works across the range of statutory,
voluntary and third sector organisations, within the fields of health, social
care, housing, community safety, welfare and employment, works together
to complete the actions needed. Do you think that the Plan will help to
ensure that everyone does play their part? What else do you think needs
to be done to help improve partnership working?
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
We absolutely agree that tackling an issue such as homelessness will require more
joinedup working across sectors and across disciplines. Whether this Plan will support
this is difficult to say without seeing any action plan, but detailed below are a number of
thoughts about partnership working that arose when reading the consultation draft:
o There are, of course, some good examples of partnership working already in
RCT, for example, our Housing Advice team work out of the Council’s Housing
Advice Centre, which also houses their statutory services and other agencies –
and these should be rolled out as models of best practice.
o If the aim is to be more ‘joinedup’, should this 10 Year Homelessness Plan and
the recently published consultations on the National Housing Strategy (a “long
term” strategy, which will be accompanied by a 3year action plan) and the
Supported People Housing Related Support 5year Strategy all be separate
documents? They are clearly closely linked, and there is a concern that by having
them separate the actions won’t fit together. At present, it often feels that
homelessness sits outside of housing, and it would be a shame if an opportunity to
blend them together were missed. This is also true at a local level, where local
housing strategies will undoubtedly have to take forward many of the actions from
this plan if it is to succeed.
o The nature of our work means that we are particularly interested in the links
between health and housing. Our services encompass both, and we have often felt
that there are instances where joint/ shared budgets would help facilitate
partnership working. There will be a particular challenge in the near future, as
health bodies and local authority’s boundaries will no longer be coterminous,
making strong working relationships even more important. In our experience,
health rarely turns up to local homelessness planning groups at present; equally,
it’s rare to see someone from housing at a CPA meeting. There obviously must
need to be greater incentives for them to do so.
o We see the fact that the plan is a ten year one as positive, and should be
conducive to better partnership working, particularly if it is reflected in
commissioning – at present many of our contracts, for example, are annual, which
makes it difficult to develop links or plan strategically.
o In addition to working across sectoral boundaries, we would emphasise the
importance of breaking down geographical ones. It is ridiculous that, for example, a
person is not accommodated at a hostel in Cardiff when there are no available
beds in Caerphilly. We can also see an advantage to more regional
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
commissioning, with improved economies of scale enabling more sustainable
commissioning and better equity of access to services.
o Sometimes joinedup working is difficult because different partners have different
priorities. Page 5 of the consultation draft, for example, mentions the need for
housing assessments to be more holistic, and look beyond just housing need –
something we wholeheartedly agree with. This can only be achieved, however, if
the nonhousing services are available. As an example, a 17yearold may present
as a priority need for housing, but even if a mental health need is identified, they
might well find themselves unable to get support because they fall between
CAMHS and adult services.
10. How do you think that the success of this Plan should be measured?
As mentioned above, we are less concerned with the draft plan as presented for
consultation than with the action plan that will arise from it, as this is what will determine
any actual changes to people’s experiences. It is vital that the action plan contains specific
and measurable actions, with a clear timetable and details of responsibility for delivery. An
annual update on the progress of this action plan could then be published and scrutinised.
It may also be appropriate to convene a group to oversee the implementation of the plan,
including representatives from the Welsh Assembly Government, local authorities,
voluntary organisations and other relevant stakeholders.
If the ultimate aim is to ‘reduce homelessness to a minimum’, then some way of monitoring
this must be included for any evaluation, although exactly how that is measured is likely to
prove complicated.
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Welsh Assembly Government 10 Year Homelessness Plan
Consultation Questionnaire
11. Are there any other comments you would like to make?
There were a couple of points that we wanted to raise that fell outside the questions
asked:
o Firstly, we felt a homelessness plan should not just be about reducing
homelessness, but improving services for those that are homeless. For example, it
is extremely difficult to access mental health services when homeless, as referral
for these is usually through a GP, and individuals are often unable to access a GP
when homeless.
o Finally, we have grave concerns about the way priority need is being determined,
particularly in relation to mental health. In some areas, the emphasis seems to be
on a person’s diagnosis; in others on the type of medication they’ve been
prescribed. Neither method takes the needs of the individual into account. The
emphasis, surely, should be on how unwell that person is (which does not always
correlate with diagnosis or medication) and on the relationship between their
housing need and their health.
The Welsh Assembly Government would like to thank you for taking the time
to read the draft version of our Plan and complete this questionnaire.
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