Follow the links below to see links to Homeless Link’s recent consultation responses.
This Ministry of Justice consultation sets out plans to reform the probation service. Key elements include extending support on release to offender following short term sentences, movement to a payment by results model, a structure of providers similar to that of the Work Programme and a focus on wider causes of offending such as housing, health and employability. Our response included proposals to strengthen the accommodation arrangements for prisoners upon release, linking these to ‘through the gate’ provision and also concerns about the lack of accountability in supply chain management. See our response here. Alongside our consultation response document we also submitted a joint letter with SITRA and Nat Fed.
Proposals to strengthen the NHS Constitution are set out in this consultation. The consultation follows work carried out by the NHS Future Forum on how the Constitution could be strengthened. The Government accepts the Forum's recommendations in full and the new proposals reflect this. Our consultation response highlights some of the ways this could be applied to be effective for homeless people, as suggested by our Expert Advisory Panel. We also suggest ways in which the draft constitution could be strengthened.
In recent years there have been some big changes to the benefits system. One of the biggest changes has been the introduction of Employment and Support Allowance (ESA). Everyone who applies for ESA has to go through a Work Capability Assessment (WCA) to decide whether they can do some type of work. Additionally, all recipients of Incapacity Benefit (IB), Income Support (IS) in lieu of (IB) or Severe Disablement Allowance (SDA) will also be required to attend a WCA to be migrated onto either ESA or Jobseekers Allowance (JSA) by 2014.
Homeless people often have significant and complex physical and mental health issues. Homelessness is not only caused by poor health, but also exacerbates it. In our joint paper and letter of response we highlight the challenges of the current system and make recommendations for its improvement.
The guidance is for Health and Wellbeing Boards and their partners to provide a framework to undertake JSNAs and JHWSs. It will:
• Lay out the statutory duties, which underpin the undertaking of JSNAs and JHWSs by clinical commissioning groups and local authorities through health and wellbeing boards.
• Explain how JSNAs, JHWSs and commissioning plans fit together in the modernised health and care system.
• Set out how an enhanced JSNA process and JHWS will enable the NHS and local government to make improvements to the health and wellbeing of local people.
The JSNAs and JHWSs will determine what is commissioned in the new health and social care structures. We used this consultation opportunity to ensure that the voices of the most vulnerable in our society, including both statutory and non-statutory homeless people, are represented when the health and care needs of communities are assessed.
We also submitted a joint response with other interested voluntary sector partnerswho work with vulnerable people.
The new NHS Commissioning Board will oversee the way that over £80 billion of taxpayers’ money is spent to secure NHS services for the people of England.
The mandate is one of the most important ways for the Government to set objectives for the Board, but it is just one part of a broader relationship through which the Secretary of State will hold the Board to account for its performance. Ministers will continue to be accountable overall for the health service as a whole. In our response to the draft Mandate, we underline the importance of homeless people's health needs being acknowledged and understood by the Commissioning Board.
Plans by the DCLG propose that from April 2013, the Homelessness Prevention Grant will be rolled into a new local grant under the Business Rates Retention scheme, part of the reforms to local authority finances.
This potentially has two risks: the homelessness prevention grant will no longer be a visible grant, and is might mean an end to transparency about how this is spent. In our response to this consultation we highlight the value of the HPG, and demand that steps are taken to ensure this doesn't result in funds being diverted away from the homeless people it is intended to help.
Homeless Link has responded to the DWP's consultation on the guidance manual for Discretionary Housing Payments (DHPs) that is provided to local authorities. The current guidance has been updated in light of changes to welfare benefits. There will be significantly more funding available for DHPs over the next two years which is to be used where people are disadvantaged by the benefit reforms.
Homeless Link is concerned that the discretionary nature of this funding means that in some areas people will be supported, but the same circumstances in another area will not. We are also keen to ensure that DHPs will still be available for safeguarding, tenancy sustainment and homelessness prevention, even where people are not directly affected by the changes to welfare. It is also important that the guidance is clear on the many and varied uses of DHPs – they are a housing payment, but not specifically limited to rent or council tax payments.
Homeless Link responded to the proposals to amend the data colleced for alcohol treatment. We agreed with many of the proposed additions to the dataset including outcome data on dual diagnosis. We also raised that outcome new measures which are devised need to capture harm reduction outcomes as well as those related to completion of treatment and abstinence.
Homeless Link has responded the Social Security Advisory Committee's Call for Evidence on the Universal Credit (UC) and Related Regulations. In our response we expressed our concerns that the Regulations do not go far enough to protect vulnerable people and those furthest from the labour market. The lack of detail in the Regulations gives too much power and flexibility to guidance. We believe that Regulations should define particular exceptions and set certain limits, in order to prevent homelessness and destitution. We are also concerned about a number of matters that are omitted from Regulations, particularly the way eligible charges in supported accommodation will be managed under UC. we have recommended a number of changes to the Regulations which could strengthen protections and support for vulnerable people.
Download our response here
The draft regulations and explanatory memoranda are available on the DWP website.
The Localism Act 2011 enables local authorities to discharge their main homelessness duty with an offer of suitable accommodation in the private rented sector, without needing agreement of the individual.
The proposed draft Homelessness (Suitability of Accommodation) (England) Order 2012 sets out those circumstances in which accommodation used for the private rented sector offer to end the main homelessness duty is not to be regarded as suitable. This consultation covers what regulations should cover in order to identify when accommodation is "unsuitable". Proposals include the local authority being satisfied that the property is in reasonable physical condition, the premises is safe with regard to fire, electrical equipment, gas, etc, as well as the location of the property being deemed suitable. In our response we require properties with Category One hazards to be deamed 'unsuitable' and advise on the strengthening of the suitability of location.
Following the publication of Liberating the NHS: greater choice and control, A summary of responses, the Department of Health has launched a follow up consultation on detailed proposals to implement the Government’s commitment to giving patients more say and choice over their care and treatment.
The consultation proposes a model of shared decision-making all along the patient pathway, which should be relevant irrespective of patients’ conditions, their clinical pathway or progress along it. The model indicates where patients would be expected to have more say in decisions about their care in primary care; before a diagnosis; at referral to secondary care; and after a diagnosis had been made. In our response we detail ways that the voices of homeless people need to be heard in this new landscape.
The DWP plans to reform the appeals process so that in future, claimants and other persons disputing a decision on their benefit claim, will follow an escalating process of mandatory reconsideration before formal appeal. The consultation states that this will allow the DWP to improve the appeals process and carry out a 'robust review' of the disputed decision.
In our response we highlighted the fact that the increased bureaucracy and timeframes may increase social exclusion for the most vulnerable. We believe that many will disengage because they have support needs which limit their ability to sustain the process. We asked for the time limit to appeal to be extended to two months and claimants who have received a disadvantageous decision receive a reminder before the time limit expires.
The DCLG consulted on new draft statutory guidance on social housing allocations for local authorities in England. The new guidance is intended to assist authorities to take advantage of the provisions in the Localism Act 2011 which give back to local authorities the freedom to manage their own waiting lists, and make it easier for them to move existing social tenants to more suitable accommodation. It also encourages authorities to make use of the existing flexibilities within the allocation legislation to ensure that social homes go to people who "need and deserve them the most." Read Homeless Link's response to the Allocation guidance here.
The Department of Health asked for views on its draft guidance to support health and wellbeing boards and their partners in undertaking Joint Strategic Needs Assessments (JSNAs) and joint health and wellbeing strategies.
It is vital that homeless people's needs are taken into account in these processes and it is also important that the JSNA process meaningfully involves local providers and service users so that their views are incorporated. Download our response to the JSNA guidance, which we produced with St Mungos, or visit our JSNA page for more information about JSNAs.
In late January the DWP released a General Information Bulletin which asked for information to gauge the potential impact of a proposed change in housing benefit legislation. The proposed change will make the utilities and housekeeping of rooms of common use an ineligible service charge for a wide range of housing types. Currently and technically, only sheltered accommodation can claim this as an eligible service charge. There is no definition of sheltered housing, so for a very long time LAs have treated hostels and lots of other supported housing as sheltered accommodation for the purposes of housing benefit, and thus accept these eligible service charges. The survey was open for 14 days.
Our key asks were:
It was clear that this change would have an enormous impact on services and with a huge amount of support from members we submitted this evidenced response to the DWP. We also met with senior officials at the DWP and highlighted the level of concern expressed by members at this potential change to legislation. We will be closely tracking the progress of this issue and maintaining pressure on the DWP on behalf of members.
In November 2011 DWP published an informal consultation on new arrangements extending data sharing powers between DWP and local authorities, in relation to the provision of welfare services and social security benefits.
Homeless Link believe that accurate data is essential for ensuring an individual's needs and entitlements are promptly and appropriately catered for. The ethical sharing of data between departments has the potential to speed up processing times and ensure that claimants are accessing the most appropriate and effective benefits and services.
This consultation proposes a new mandatory power of possession for anti-social tenants whoes behaviour has been considered by a court. Where a social tenant breaches the conditions of their anti-social behaviour sanction the landlord can seek possession of the property without having to go to court. This consultation also responds to the London riots of 2011 and proposes that the existing discretionary ground for possession for all anti-social behaviour and criminality is broadened. Currently only activity perpetrated in an individual's neighbourhood can be used as grounds for possession, this consultation proposes that this is broadened to acts that are perpetrated anywhere in the United Kingdom and that possession can be sought to remove a whole family due to the acts of one member.
Homeless Link is concerned that these proposals run contrary to DCLG's committment to ending rough sleeping, are unfair because they subject social tenants to sanctions that canot be enforced on private renters and owner occupiers, and that they are too heavily weighted towards punitive interventions and have not sought to make use of the support components that can be issued with an anti-social behaviour sanction.
Please use this link to access our complete response to A New Mandatory Power of Possession.
The Department of Health has published a consultation on Suicide Prevention. The strategy highlights numerous groups who experience disproportionately high prevalence of suicide risk factors and aims to target prevention work at these groups. Homeless Link welcome the explicit acknowledgment that homeless people experience an inflated risk of suicide. However, there is a concern that given the scale of health inequality experienced by this group and the sheer number and diversity of the suicide risk factors they experience, the focus on this population group should be stronger. Research has shown that homelessness in itself increases risk of suicide this client group however, also commonly experience mental health problems, issues around substance misuse and isolation all of which are considered suicide risk factors in their own right.
You can use the following link to access Homeless Link's complete suicide prevention consultation response.
The changes proposed in the Housing Benefit Reform – Supported Housing Consultation will have significant impact on homelessness services and their funding. The ending of the ‘exempt accommodation rule’ and other proposals in the consultation risk creating a vacuum where there is no explicit responsibility for the housing costs of vulnerable people and a gap between what the DWP contributes and the real costs of providing this form of housing. The DWP has not provided a robust business case for the two main aspects of the consultation - why housing benefit for supported housing has to come under Universal Credit, or why the exempt accommodation rule must be scrapped in its entirety.
Our key asks:
The Ministry of Justice (MoJ) published a consultation asking stakeholders to comment on 5 options for addressing squatting. Option 1 proposes creating a new criminal offence of squatting, and at the other end of the scale option 5 proposes retaining the laws that govern squatting in their current form while promoting the new squatting guidance published on the Direct Gov website. The consultation also aimed to establish a demographic picture of people who squat and uncover the extent of the issue.
Homeless Link, along with some of the UK's leading homelessness organisations, is a signatory of a letter to Crispin Blunt (MP) that raises numerous concerns about the proposed reform. The letter highlights the fact that amongst the people who squat are many vulnerable homeless people and urges the Minister not to make the situation worse for some of society’s most vulnerable by criminalising them. Our consultation response reinforces this argument through highlighting the diverse vulnerabilities of people who squat. We also propose that the focus of the consultation changes from a punitive approach to one that promotes joint work between homelessness and emergency services that will increase engagement with this portion of the hidden homeless population. Please use this link to access our response to Options for Dealing with Squatting.
The Government has outlined significant changes to housing benefit, including the proposal to increase the age threshold for the Housing Benefit shared accommodation rate (SAR, previously the shared room rate) to 35 years. Homeless Link made a submission to the Social Security Advisory Committee consultation in which we raised concerns around the effect this will have on homeless and vulnerably housed individuals. The principal concerns raised are that this proposal further limits the number of avaliable properties for homeless move-on; the affect on those within the new age threshold who are currently occupying one bed properties; the silting up of hostels as move-on becomes problematic; and the suitability of shared accomodation for individuals experiencing complex vulnerabilities. You can access Homeless Link's complete consultation response here.
Homeless Link has submitted joint amendments with the National Housing Federation and St Mungos to be tabled as the Bill is recommitted. Download our breifing for the Second Reading of the Health and Social care Bill. We were pleased see many of these issues highlighted in the debate in the Lords. To read more, please download our short summary of the key concerns which we submitted to the Future Forum which highlights their recommendations and Government's response. You can see the current status of the Bill as it is re-committed to Parliament here.
The Future Forum, set up to review the Health and Social Care Bill have published their recommendations and the Government has announced it response to these. We are encouraged that many of the issues we raised in our submission to the Future Forum about protecting the health of homeless and disadvantaged patients have been picked up both by the Future Forum's Recommendations and by the Government in their response, with specific changes identified by the Government to address these. Over the coming weeks we will be working with the sector to ensure these, and our other concerns, are carried forward as the Bill is amended.
Please read a summary of our recommendations and how these have been picked up by the Future Forum.
If you have any specific comments you would like to add to Homeless Link's ongoing work on the Health Reforms please contact Helen Mathie. For more information about Health, visit our original response to the NHS Reforms, or download our easy read Health Glossary which explains some of new healthcare structures and how they will interact with each other.
The Department for Communities and Local Government have consulted on which data sets should be collected on a local and national basis. This consultation proposed sliming down the detail and dissemination of numerous data sets relevent to homelessness service providers.
Homeless Link stated that evidence is essential to crafting relevant interventions for people experiencing homelessness, and that government should pay close attention to the complex needs of excluded groups before curtailing any data collection activities.
Please access the complete consultation response using this link Homeless Link response to Draft Statistics Plan2011-12 Consultation.
Homeless Link submitted evidence to the Health Committee’s Inquiry into Public Health. In accordance to the Committee’s guidelines we are unable to publish our submission until the Committee has reviewed the evidence, however we will do this as soon as possible.
The Public Health White Paper launched on 30th November 2010 promised a ‘radical shift’ in the way public health is tackled in England. The paper includes a number of structural changes to delivering public health services, including a new service, Public Health England (PHE), which will be set up as part of the Department of Health with a protected budget. Homeless Link produced a summary of the key aspects of the strategy which suggests some of the main implications for homeless people.
Homeless Link responded to the two consultation papers included in this process:
The Ministry of Justice consultation ‘Breaking The Cycle' closed on 4 March. Our response highlighted the role homelessness services already play in supporting ex-offenders, the need to include voluntary sector providers in payment by results model planning and the need for a sophisticated measurement tool that shows distance travelled and a payment model that acknowledges such. Key asks included organisational and managerial support for cross sector working, commitment to the ETE programmes offered by homelessness services, endorsed the Real Lettings model, noted the need for a variety of housing provision including supported and social housing and commitment to real cross sector working in order to provide the coherent package of support which addresses all an individual’s needs. Please download our response and our briefing document on the Green Paper is available here.
These two concurrent consultations sought views on two themes central to the government's new vision of the NHS. In our response to the Information Revolution, we propose how data collection and access to information can be improved to bring about positive changes for homeless people. In our response to Greater Choice and Control we suggest that the emphasis on patient choice in the new commissioning structures risks marginalising those individuals who are excluded from mainstream services. We make a number of suggestions about how local services and commissioning structures can ensure homeless people can also particpate in this important shift towards greater patient choice.
Summary of key points:
Summary of key points:
The full response can be downloaded here.
We endorse the broad principles of the document, particularly in terms the emphasis the consultation places on open access to data sets that can facilitate effective commissioning and elucidate trends and outcomes for service users.
Although broadly we welcome this move towards increased data transparency, there are a number of provisions that need to be embedded to enable local communities to make best use of any published data. Furthermore we believe that some data is of such value that it should be collected on a national basis. From the perspective of a homelessness service provider it is crucial to maintain and publish homelessness data for the following reasons:
Please access the complete consultation response using this link Homeless Link response to Transparency Code Consultation.
Homeless Link has responded to two consultations from the Department for Business, Innovation and Skills; one on the future direction of skills policy and one on the skills funding system and methodology. Selected asks across both consultations were that:
Homeless Link has responded to the White Paper Equity and Excellence: Liberating the NHS. The paper sets out the Government's long-term vision for the future of the NHS. Its proposals include abolishing all PCTs and Strategic Health Authorities and giving greater commissioning control to GPs.
In our response, among our key asks, we called for:
A summary of our main messages can be found at the start of our response.
We have responded to the government's recent consultation on changes to the welfare system. Three key points we made were:
Please download our response in full here.
In our response to the Drug Strategy Consultation 2010 we welcomed the broad principles outlined in the strategy document. In our response we emphasised the focus on taking a holistic approach to drug use, with issues being tackled alongside housing, health and employment. We strongly believe that drug use cannot be tackled in isolation from these issues which often underline and interlink with an individual’s drug problem. In particularly, we feel it is very difficult to reduce, prevent or stop somebody’s drug use without stable and appropriate accommodation to underpin their recovery. Download our response here.
The Emergency Budget on 23rd June outlined significant changes to housing benefit. These changes include resetting LHA rates at the 30th percentile of local rents, reducing housing benefit to 90% after 12 months for claimants of Jobseekers’ Allowance, and uprating local Housing Allowance rates based on the Consumer Price Index (CPI). Some changes come in to effect from April 2011, and others later on following passage of secondary legislation. Homeless Link has submitted evidence to the Work and Pensions Select Committee inquiry, and the Social Security Advisory Committee inquiry. The submission outlines our concerns that the changes to housing benefit will impact on the most vulnerable people in society. We feel many of the changes outlined by the Emergency Budget pose serious risks to:
As well as providing evidence to the Work and Pensions Select Committee, Homeless Link has submitted evidence to the Social Security Advisory Committee's public consultation on the Housing Benefit (Amendment) Regulations 2010.
Communities and Local Government conducted a consultation on the street counts methodology which ended on 3rd September. Homeless Link responded to the consultation and submitted draft guidance on undertaking both estimates and street counts. The CLG has published their response and the main changes are that the methodology is now broader to reflect people who are intending to sleep rough as well as those actually bedded down and that all local authorities must carry out a count or conduct an estimate once per year. Independent verifiers are now the responsibility of Homeless Link. Information about Homeless Link's new role and details on changes to the methodology can be found on our new web resource Evaluating the Extent of Rough Sleeping.
The Comprehensive Spending Review is government’s review of spending for all departments for the next five years. Homeless Link submitted evidence to the spending review asking to sustain investment in homelessness support to ensure the most vulnerable groups are protected as well as avoiding impact on more costly acute services in future. Please download our submission here. Please see our response to the published Review here.
The Department for Work and Pensions has commissioned an independent review of the Work Capability Assessment. The Work Capability Assessment is a part of the Employment and Support Allowance claim process, designed to determine which claimants are capable of undertaking work, or work-related activity. Homeless Link has made a submission for the independent reviewer. The independent reviewer will then make recommendations to the Secretary of State, which will be laid before Parliament in the form of a report.
This DWP consultation set out the package of reforms designed to improve the support provided via the Social Fund. In our Social Fund reform response we welcomed many of the principles of the reform which seek to make the scheme easier to access and offer more support to claimants. However, we express some concerns about increased conditionality; the implied reduction in the choice clients will have under a proposed single gateway scheme; and new measures to re-assess eligibility – both for loans and in particular for resettlement grants.
We published our response to this consultation in February 2010. This consultation sets out the government's plans to progress reform of housing benefit. It proposes 'a simpler and fairer system of housing support which supports work incentives, excludes the highest rents...and pays a fair rate of benefit to customers.' One of the measures proposed is a 'Transition into Work Payment' which could provide extra housing benefit, at the out of work rate, for people moving into work. Read our two-page summary of the consultation here. Our response sets out the conditions we believe are needed to support homeless people in obtaining and sustaining both housing and employment.
In January 2010 we published our response to the Mayor's Health Inequalities Strategy. Health remains an area where life-chances for people who have experienced homelessness still lag far behind those who have not. It is in this context that we welcome the London Health Inequalities Strategy as extremely timely and strongly endorse the Mayor’s commitment to prioritise the health needs of society's most marginalised individuals. We have structured our comments around three main themes in the strategy - empowerment; improved access; and joined-up delivery.
Our specific interest in responding to this consultation is in raising issues around the older homeless client group. Evidence from the Older People's Audit developed by the Coalition of Older Homelessness shows that some older homeless people stay in hostels for even ten or twenty years. Hostels are designed for temporary accommodation and are not suitable for people to grow old in. Our paper calls for a care system which works for everybody and takes into account those people on the margins. Read our response to the Shaping the Future of Care consultation for further details.
This important document guides local authorities on changes they should be making to their approach to commissioning services and assessing individual need. This summary of the FACS consultation gives background to this debate and how it affects homeless people. You can also read our response to the FACS consultation which closed in October 2009.
Homeless Link has responded to the Department of Health's new mental health strategy New Horizons. It aims to 'promote good mental health and well-being, whilst improving services for people who have mental health problems'. The consultation closed on 15th October 2009 and you can download our response to New Horizons here.
Homeless Link responded to St Mungos Call 4 Evidence on Mental Health. St Mungos asked for views about homelessness and mental health which will help inform a report due for publication this Autumn. We submitted our recent Mental Health Policy briefing as part of our feedback to this consultation.
Homeless Link has written to the National Offender Management Service in response to the Reducing Re-offending in London 2009-11, which outlines the proposed priorities for the delivery of prison and probation services in the capital and the joint working to reduce reoffending.
To view more consultation responses please see our Archive of Consultation Responses