Housing Support for Homeless Households - Analysis of Consultation Findings- Report

Section 3: The content and scope of provision of support services

3.1 This section presents the findings on the content and scope of provision of support services (Questions 4-6).

Prescribing the period for which housing support should be provided

3.2 Question 4(a) asked:

(a): Should Scottish Ministers specify the period for which housing support services should be provided? Yes/No Please explain why.

3.3 A total of 56 respondents addressed this question (85%). There was a majority against the specification of the period for which housing support services should be provided. 82% of those who addressed the question expressed disagreement, while 14% expressed agreement and 4% did not express a clear preference. There was a majority against the specification of these matters in all sectors.

3.4 All of those who addressed this question provided additional comments. In the small number of cases where specific reasons were given to support the view that Scottish Ministers should specify the period for which housing support services should be provided, these comments focused on: the needs of the client; outcomes; and the provision of clarity. A few respondents qualified their agreement or made other comments.

3.5 A small proportion (around an eighth) of those who made additional comments gave reasons in support of specification related to the needs of the client. The comments made were that: this would ensure that the client receives support when required; some problems emerge at a later stage and prescribing a minimum time period can allow other needs to be identified; and the client needs to know how long they are committed to a support plan. Closely linked to these reasons, a few respondents suggested that specifying the time period would have a positive impact on the maintenance and sustainability of a tenancy, or on a client's motivation or likelihood of engaging with support. It was also suggested that there is a need to clarify at what stage a local authority can discharge its housing support duty (an issue raised by other respondents and discussed at Question 7).

3.6 Where respondents qualified their support, or made additional comments, one stated that it would depend upon whether specification was of a minimum or a maximum period. Other comments included that: the time period should not be exact/specific; there must be a means of ensuring that support can continue for as long as required; and there must be a holistic approach with regular reviews and monitoring.

3.7 Most of the additional comments, however, were from respondents giving reasons for the view that the period should not be specified, and more than three quarters of those who made additional comments focused on such issues. While a small number made reference to comments made elsewhere in their response, many provided more detailed reasons for such a view. The two most common themes were: the nature and basis of provision; and the variation among service users and their needs. Other themes identified by smaller numbers of respondents included: a preference for guidance; the perceived impact on service provision or outcomes; cost/resource issues; and general views that it would be difficult to specify the period of provision.

3.8 Comments on the nature and basis of housing support provision focused largely on the view that the period for which housing support should be provided should depend on the individual needs of the client, which in turn will be determined by the needs assessment, and subsequent involvement of the individual. It was suggested that a specified period would risk moving from a person-centred, user-led, outcome-focused approach. It was also suggested that it would be "unnecessarily Government-led" and would be restrictive. Other issues raised were the views that: support should be made available for as long as required; should not be time-limited; and should allow for changes to individual needs. Two respondents expressed the view that housing support should be for short term interventions, while working to ensure that people can access specialist support.

3.9 Additional issues relating to the nature and basis of housing support as a reason not to specify the time period were the view that support should be: flexible; based on a plan; reviewed regularly; and adjusted accordingly, with the local authority determining the duration in conjunction with the service user. One respondent stated that moving on from support should be a carefully managed process.

3.10 Related to these issues, a number of respondents who disagreed with specifying a time period made specific comments about variation in individual needs. Issues raised included that: individuals have different needs, with considerable variation between them in their nature and complexity; the duration of support needed is longer for some than others; the pattern of support required will vary; and the point at which support is needed will vary. Several respondents also stated that individual needs (and the level of support required) can change over time (sometimes rapidly) and can reflect changing circumstances (e.g. household circumstances; age; seasonal changes; the nature of personal issues; progression of an illness). It was also suggested that there are differences in service provision, including, for example: differences in types of provision and activities; and different geographical issues for providers. One respondent stated that there are also different levels of commitment among service users.

3.11 Several respondents, as at other questions, expressed a preference for guidance, or stated that this would be beneficial.

3.12 Several respondents identified a perceived negative impact on service provision, or on outcomes of specifying a period for which housing support should be provided. One expressed concern that the specified period would become the maximum period. It was also suggested that there could be a negative impact on the effectiveness of provision and that support could be removed from service users when there was still a need for this. Other comments included that individuals may: feel more vulnerable; lack confidence in their service providers; fail to establish a relationship with service providers; and feel pressured to resolve issues within a specific period. It was also suggested that tenancies may fail and service users be exposed to homelessness as a result of a specified period. A few respondents stated that, as well as the danger that support could be removed when still required, some service users would continue to receive support when they no longer needed it. One respondent also identified a perceived impact on other services, and another on their charging policy.

3.13 A few respondents cited cost/resource issues to support the view that the time period should not be specified, including that: there would be a cost to local authorities; the provision of support to those who no longer needed it would be wasteful; and specification of times must be linked to resource availability. A few respondents expressed a general view that it would be difficult to specify the period of provision or that it would not be beneficial or sensible.

3.14 Where respondents qualified their view, or made additional comments, a number of issues were raised. One, for example, suggested a danger of engendering dependency with non time-limited support (with a perceived need to underpin support with suggested good practice). Another stated that, if Ministers make any prescription of time, it should only be to specify a maximum period. Other views expressed included that: support should not be open-ended or longstanding; there is a need to distinguish between homelessness-related housing support and other types of housing support; services need to be able to discharge their responsibility (e.g. with clients who do not engage); and there is a need for reassessment and review.

The prescribed period

3.15 Question 4(b) asked:

(b): If you have answered yes, what do you think the prescribed period of provision should be? Please explain why.

3.16 Only a few respondents [although most of those who expressed agreement at Question 4(a)] made comments on the prescribed period of provision. Of these, a few specified a period or a point at which they believed input should be made, while a few expressed a view of the way in which such a decision should be made.

3.17 In terms of the prescribed period, one respondent suggested that support should be a minimum of 3 months, and in many instances 6-12 months, as this is the period when the most serious issues appear. Another suggested a 3 month period as an appropriate time to identify issues, but stated that a minimum period should only be enforceable where the service user agrees to accept the support offered. One respondent raised a specific issue for prisoners, stating that support should be provided at any point during incarceration when a change of circumstances requires this, and definitely at least 6 weeks prior to liberation.

3.18 A few respondents made comments on how such a decision should be made. Two suggested that this should be based on the assessor's recommendations (one of whom suggested the use of an independent support assessor). Two stated that this should be determined through a review process (with one stating that there should be exit strategies when support services are coming to an end). One respondent stated that support provision in hours may be a consideration for the Scottish Ministers.

Ensuring provision of housing support services

3.19 Question 5(a) asked:

(a): Should Scottish Ministers specify matters to which a local authority is to have regard to when ensuring provision of housing support services? Yes/No Please explain why.

3.20 A total of 51 respondents addressed this question (77%). There was a majority against Scottish Ministers specifying which matters a local authority is to have regard to when ensuring provision of housing support services. Almost two thirds (63%) of those who addressed the question expressed disagreement, while under a third (29%) expressed agreement, and 8% did not express a clear preference. Among all sectors, there was a majority against this proposition.

3.21 Of those who addressed this question, 48 (94%) provided additional comments. When asked to explain the reasons for their views, a few respondents (both who agreed and disagreed) made reference to their previous answers.

3.22 Just under a third of those who made additional comments gave reasons to support the view that Scottish Ministers should specify matters to which a local authority is to have regard to when ensuring provision of housing support services. The most common issue identified (although still by only a few respondents) was the promotion of consistency (as has been the case at other questions). Other reasons given also reflected issues raised earlier, and included comments relating to: ensuring that clients' needs are met; providing definition of services; and the implications for cost/resources.

3.23 Comments relating to the promotion of consistency focused on the view that specifying matters would enable: a standard framework; consistency of approach/ service delivery throughout Scotland; identification of minimum expectations in all authorities; universal provision and equality; a "level playing field" for service users; and reduced potential for a "postcode lottery". One respondent stated that it would prevent authorities being able to "play-off" against each other.

3.24 A few respondents stated that specifying matters would provide the best means of ensuring clients' needs were met (e.g. by specifying that all services are of good quality and sufficiently resourced to meet the needs assessed; by using deprivation indices to identify the level of need; or by specifying the value of a specific form of support).

3.25 A further reason given by a few respondents in support of specification was the view that it would provide clarity and definition of services. It was suggested that it would define essential housing support services for purchasers and providers, as well as clarifying roles and responsibilities and issues relating to prioritisation. One respondent stated that specifying matters should assist in benchmarking for tendering exercises. One stated that specifying matters would assist in determining resource allocation based on prioritisation of assessed need.

3.26 One respondent qualified their response as a "tentative" yes, while another stated that there should be a strong degree of flexibility to encourage development and innovation.

3.27 Over half of the respondents who made additional comments gave reasons to support the view that Scottish Ministers should not specify matters to which a local authority is to have regard to when ensuring provision of housing support services. Again many of the issues highlighted have been raised in response to previous questions. The most common themes were: the implications for the nature of services and decision making processes; and the preference for guidance rather than prescription. Other reasons included: the view that current legislation and practice are sufficient; the need for flexibility; and issues relating to costs/resources.

3.28 Several respondents gave reasons relating to the nature of services and decision making processes. For example, comments included that support should be based on the needs of the individual and should be outcome-focused. Views were also expressed that local authorities: have discretion to determine these needs and draw up plans in consultation with the service user; are best placed to identify local needs; and have to take account of their budget and local circumstances. One respondent expressed a concern that specifying matters would remove choice from each individual and that this would contradict the Care Commission Regulations. It was also suggested that the nature of services is wide ranging, and two respondents stated that there are particular issues in remote/rural communities. Other issues raised were the views that specification would: narrow the options available; curtail the scope of support; affect the structure and provision of services; affect the ability to meet local priorities; and have a negative impact on their effectiveness.

3.29 Several respondents emphasised the need for flexibility to meet diverse needs and respond to local issues, or stated that specification would constrain this or detract from such an approach.

3.30 Again, several respondents expressed the view that guidance and the identification of a best practice framework would be preferable to prescription, or that this would be welcome.

3.31 A few respondents expressed the view that current legislation, regulatory processes and practice are sufficient, and one stated that this provides a clear definition and service standards for housing support. Specific examples of some existing requirements were given, and one respondent expressed the view that Scottish Ministers should specify that local authorities should have regard to the existing statutory duties in their provision of housing support services.

3.32 A few respondents raised issues relating to costs/resources as among the reasons for the view that Scottish Ministers should not specify matters to which a local authority is to have regard when ensuring provision of housing support services. These included concerns relating to: increased costs; wasted resources; and the perceived need to be able to target scarce resources to achieve the best outcomes.

Matters to have regard to when ensuring provision of housing support services

3.33 Question 5(b) asked:

(b): If you have answered yes, what matters do you think should be specified? Please explain why.

3.34 Almost all of the respondents who expressed agreement at Question 5 (and a few others) made comments on matters to be specified. The most common theme related to overarching issues in the provision of services and the nature of the process. Additionally, small numbers of respondents in each case identified some specific types of support needs to which local authorities should have regard.

3.35 In terms of overarching issues relating to the nature of the process or the provision of services, matters identified were:

• Availability of support services.
• Quality of services.
• Budgets and resources.
• Policy frameworks (e.g. relevant to children and young people).
• The local environment (e.g. deprivation; public transport infrastructure).
• Roles and responsibilities (including RSLs).
• Partnership working and the adoption of a holistic approach.
• Reasons for homelessness.
• The views of the household.
• Identification of positive outcomes.

3.36 As noted above, a few respondents in each case identified specific types of support needs. These reflected some of the specific areas highlighted earlier and will not be repeated in detail here. In summary, these included: financial issues; health, mental health and wellbeing; relationships, personal and social issues; accommodation; substance misuse issues; living skills; education, training and employment; and support to offenders.

3.37 Additionally, one respondent expressed the particular view that accommodation with support has been proven to be more effective than outreach services. Another stated that, in relation to provision of support to offenders, there should be a primary period of provision within 72 hours of admission to prison, and a compulsory period of provision a minimum of 6 weeks prior to release.

Different provision for different purposes and different areas

3.38 Question 6(a) asked:

(a): Should Scottish Ministers make different provision for different purposes and different areas? Yes/No Please explain why

3.39 This question was addressed by 51 respondents (77%) and a majority did not support the view that Scottish Ministers should make different provision for different purposes and different areas. Only a fifth (20%) of those who addressed this question supported making different provision, while around two thirds (67%) disagreed with this, and 14% did not express a clear preference. All bar two of those respondents who addressed the question provided additional comments (96%).

3.40 Under a quarter of those who made additional comments gave reasons to support the view that Scottish Ministers should make different provision for different purposes and different areas. These related to the perceived existence of: different individual and local needs/circumstances; different geography/demography; and different service provision in different areas. A few respondents qualified their support or made additional comments.

3.41 In terms of the identification of different individual and local needs, detailed comments included that there are: general variations in service users' needs and problems faced; differences between people in different circumstances; different levels of financial resources available; and different levels of socio-economic deprivation. In terms of differences in geography/demography, it was suggested that there are: differences in the volume and range of homeless populations; differences in cultures; distinctive issues in rural, urban and city areas; differences in demographic make-up, such as age, gender etc.; differences in housing tenures; and differences in population density. One respondent provided a local example of work to address specific local circumstances. In terms of differences in provision, it was suggested that there are: diverse generic and specialist providers across Scotland; different national and local agencies; and differences in access to, and availability of services in different areas (with rural issues highlighted).

3.42 A few respondents qualified their view that there should be different provision, or made additional comments. Two, for example, expressed the view that, while there are different local needs requiring local delivery, there should be a minimum or universal standard of provision. One respondent stated that there needs to be a clearer understanding of what different provision for different purposes and different areas means, expressing the view that everyone should have access to support that meets their needs and there should not be a postcode lottery.

3.43 A few respondents who did not express a definitive view at this question, and a few who expressed disagreement, stated that there was insufficient information in the consultation document to interpret fully what is meant by different provision for different purposes and different areas, or how this would operate in practice.

3.44 Most of the additional comments at Question 6(a), however, focused on reasons to support the view that Scottish Ministers should not make different provision for different purposes and different areas, and just under two thirds of those who made additional comments identified such issues. A few respondents made reference to answers given elsewhere in their response. Where specific reasons were provided, themes included: the impact on the nature of processes or provision; the perceived need for consistent access to support; a preference for guidance; and a perceived need for flexibility.

3.45 Where the reasons given related to the impact on the nature of processes or provision, it was suggested that: local authorities are best placed to identify the support needs of local people; these should be identified through local processes; and Scottish Ministers making varying provision may be confusing and bureaucratic. Comments also included: the perceived value of local responses being locally led and regional variations developing naturally; and the view that the adoption of a person-centred approach would make it unnecessary for Scottish Ministers to make different provision for different purposes and areas, as this would take personal and local circumstances into account. In terms of the perceived impact on the nature of support, it was suggested that different provisions could lead to limiting access, could curtail the scope of support, and may require to be updated depending on changes in local circumstances.

3.46 Comments relating to consistency focused on the need for consistent access to support, and a consistent approach, to ensure that clients' needs are met in each area. It was also suggested that making different provisions for different purposes and areas would defeat the objective of trying to ensure consistency. One respondent stated that regulations should ensure consistency by providing a baseline, making it unnecessary to introduce different provision for different purposes and areas. Other comments included that: Ministers should not differentiate the value of different areas of support (e.g. prevention, crisis, or support in reducing homelessness); different provisions might prove divisive; and inconsistencies can also impact on other relevant organisations.

3.47 A few respondents mentioned a preference for guidance, or stated that this would be sufficient. One respondent suggested that this would complement the existing statutory framework and councils' own experience of effective service delivery within their local context. Another suggested that guidance should be sufficient to accommodate local variations and different service models. It was also suggested that this would allow a flexible response to local circumstances.

3.48 Linked to this, comments relating specifically to flexibility included: the general need for this; the complexity of needs; the view that a formally prescriptive approach would be inappropriate; and the perceived importance of a person-centred approach.

3.49 One respondent commented, however, that if Option 1 were to be selected, then it would be vital to recognise the geography of Scotland and the variegated nature of support needs across the country.

The nature of provisions for different purposes and areas

3.50 Question 6(b) asked:

(b): If you have answered yes, what do you think these provisions, purposes and/or areas should be? Please explain why.

3.51 Only a few respondents made comments on these matters, and these were made largely (although not only) by respondents who expressed agreement at Question 6(a). Suggestions (by a small number of respondents in each case) focused on the means of decision making and the identification of elements of provision considered important/essential.

3.52 Suggestions relating to the means of decision making included: the use of deprivation indices to decide upon the allocation of resources for housing support; the need to reflect the diversity of the community context, service user groupings and identified needs; and the need for the local authority to have the ability to determine provision in line with the findings of its local housing strategy and other key strategic documents.

3.53 Suggestions relating to elements of provision considered important/essential included support with:

• Health, mental health and wellbeing (e.g. mental health support; assistance with long term conditions; support with learning disabilities; provision of physical adaptations).
• Relationships, personal and social issues (e.g. development of social networks and inclusion services).
• Substance misuse (with the suggestion that there should be increased addictions services and that the delivery of the Scottish Government drug strategy could be assisted through the effective delivery of housing support to homeless households).
• The provision of services to older people.

Business impact of proposals

3.54 Questions 4(c), 5(c) and 6(c) asked:

What is the likely business impact of your proposals? Please include an indication of likely costs, where appropriate.

3.55 As in the previous section, comments on the business impact of various aspects of the legislation and on proposals made were made at Questions 4-6. There was considerable overlap between the issues raised at these different questions, and with issues raised in the previous section and at Question 8. As noted previously, some respondents provided the same comments throughout, or referred to previous answers. All of the comments relating to the perceived business impact of each of the questions will be presented together at Question 8.

Other comments on the content and scope of provision

3.56 Some other comments were made at Questions 4-6, which included:

• The nature of housing support.
• Other considerations in provision.
• The time period of housing support provision.
• Issues for guidance/clarification.
• Regulation of support.

3.57 These issues will be considered in more detail in the following section.

Summary of findings: the content and scope of provision of support services

3.58 In summary, the main findings relating to the content and scope of provision of support services are as follows:

• In relation to Question 4, a majority of those who addressed the question (82%) were against the specification of the period for which housing support services should be provided, while 14% expressed agreement and 4% did not express a clear preference.
• Among those who addressed Question 5, there was a majority (63%) against Scottish Ministers specifying which matters a local authority is to have regard to when ensuring provision of housing support services, while under a third (29%) expressed agreement, and 8% did not express a clear preference.
• At Question 6, two thirds (67%) of those who addressed this question did not support the view that Ministers should make different provision for different purposes and different areas, while 20% supported making different provision, and 14% did not express a clear preference.
• Additional comments were made to support the views expressed at each of the questions.