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CHAPTER FOUR: MONITORING AND INTERIM OBJECTIVES

136. The consultation paper stated that it would be necessary to have robust monitoring systems in place in order to plan the next steps towards 2012 and also to assess the capacity of local authorities, and other accommodation and service providers, to implement the changes required to meet the 2012 target. It also stated that it will be necessary for the statement to contain interim objectives in order to fulfil legislative requirements and to ensure that the path ahead to 2012 is agreed and progress can be monitored along the way.

137. This section of the consultation paper identified the following key areas:

Measuring capacity

138. The consultation paper stated that it was considered to be useful to agree an indicator, or a small range of indicators, which give a top-level assessment of supply and demand which is relatively straightforward to measure and understand. The proportion of social lets required to house homeless people was suggested as one such possible target.

139. In measuring capacity, the consultation paper comments it would be necessary to look at the full range of housing options open to local authorities (local authority, RSLs, private sector and voluntary organisations) and to consider issues of mismatch between housing stock and need, and that it might be relevant to look at the number of social lets relative to the size of the population in order to gauge capacity to meet wider housing need. Temporary accommodation statistics are identified as a possible indicator of pressure. The support needs of homeless households in permanent accommodation was also seen as important to assess.

Benchmarks/targets

140. The paper requested views on whether it would be possible to set quantifiable benchmarks, which if met would be taken to show that local authorities are capable of implementing change.

Measuring progress

141. The paper set out the existing mechanisms for measuring progress, these are: Communities Scotland Regulation and Inspection regime, monitoring of homelessness strategies through annual reporting and local outcome agreements, and reporting by local authorities to the Executive on targets they have set for reducing repeat homelessness (the paper suggested that there may also be alternatives to looking at repeat homelessness in terms of measuring the effectiveness of solutions - for instance looking at tenancy sustainability directly). The paper notes that there is no target related to preventing homelessness or set method of assessing the effectiveness of preventative interventions. It also noted that it may be considered unwise to assess the effectiveness of preventative measures solely by focussing on the number of homelessness assessments as this may introduce a perverse incentive to discourage early interventions which may in fact boost the number of people making a homelessness application but allow for a more effective and quicker solution.

Phasing the abolition of priority need test

142. The timing and content of any phased expansion to priority need categories was identified as one possible area around which interim objectives could be set. The paper noted four approaches, identified through research by Tribal HCH and discussions with the Homelessness Monitoring Group, these are:

• A 'big bang' approach, whereby the distinction would be abolished without a further phasing stage;
• A second phase around 2007/8 to include a further group of 'in need' households;
• A gradual phasing, based on local targets; and
• Abolishing the vulnerability test that currently attaches to some categories of applicants, so that anyone in these categories is in priority need without having to demonstrate vulnerability.

143. The paper also asked whether it was thought that the current challenges facing local authorities should preclude any announcement of a further expansion of priority need in the Statement.

Interim objectives

144. The paper also requested views as to whether there are other specific interim objectives that should be included in the statement. Areas for consideration for potential objectives identified were:

• Specific milestones in relation to any of the policy areas set out in Section 4;
• Revision of homelessness strategies;
• Gathering of additional evidence;
• Date by which expansion of priority need should be announced if not in this
• statement;
• Revision of the statement at a later date; and
• Fulfilment of capacity measures.

145. The specific questions raised in this section were:

Q8) How should capacity be measured and is it possible to set relevant benchmarks?

146. There were 38 responses to question 8, of which 31 addressed issues of capacity, and 22 commented on the possibility of setting relevant benchmarks. Some confusion was evident in responses between measures or indicators of capacity and benchmarks. Of the 22 who made specific comments on the possibility of setting benchmarks, roughly two thirds (14) believed it would be possible. Of the remaining third, 2 believed that it would only be possible if such benchmarks were relevant at a local level, 2 believed that it was not yet possible, 3 that it would be very difficult, and 1 that it was not possible. Reasons given for the difficulty of setting relevant benchmarks were the wide ranging diversity between authorities, and the gaps identified in the evidence base which lead to a reservation on making suggestions as to how to measure capacity. For those who felt it was not yet possible to set benchmarks, it was felt that the level of any benchmark set would impact upon the wider housing system and local authority allocation policies and that therefore a much clearer understanding of the relationship between homelessness and allocation policies would be required before any benchmark could be set.

147. Other issues raised in relation to setting relevant benchmarks were that it could be appropriate for the Scottish Housing Best Value Network to carry out work in relation to setting benchmarks, that guidance on key benchmarks may be necessary but that local variations should be allowed to reflect local circumstances, that benchmarking would only be useful between LAs sharing similar characteristics, not measuring all against one nationally aggregated benchmark and that issues of quality and location of housing should be considered. In addition, it was suggested that local benchmarks could include assessing the progress on the number of private sector properties that meet the higher standards set out in the Housing Bill and the number of private landlords who are willing to offer longer tenancies.

148. There was support from several responses for using the proportion of social lets to homeless households as an indicator of capacity, and also for using the length of time spent in temporary accommodation. There was a concern from some respondents that measurement of lets to homeless households should be combined with that of lets of those in other housing need. One respondent suggested that no more than 50% of allocations in any year should be made to homeless households, but that this must be balanced with ensuring that households did not spend longer than 6 months in temporary accommodation. Some other comments in relation to this issue were:

It would be possible to set relevant benchmarks, but it is important to remember that homelessness is only one needs group. It is vital to ensure that the impact on other needs groups is appropriately monitored. ( APN 27)

The proportion of social lets which is required to house homeless people is considered to be a good indicator of capacity. However, the other side of this equation is to have a measure of the social housing need as a whole. ( APN 29)

SHFA therefore believes that, in considering housing supply and capacity, the ministerial statement should consider, not just proportions of social lets going to homeless households, but specific needs groups being housed from housing lists and monitoring of how this changes in relation to rising proportions of lets going to homeless households. ( APN 41)

149. The need to address not just total capacity but also the suitability of available housing, for example by matching social rented accommodation available in a given year (by area, size and type) to the number of households with whom a statutory duty is owed, was also raised. There was a view that in considering location, using local authority boundaries would not be sufficient, particularly for rural areas. Some respondents were also concerned that measurements of capacity should reflect local circumstances, and be based on local provision and the local profile of homelessness. Other comments included that capacity measures should be linked to Local Housing Needs studies on supply and demand, that prevention of homelessness would be a key factor and that the local dynamics of the private rented sector and the capacity to deliver housing support to homeless / at risk households would also need to be taken into account.

150. Specific measurements of capacity were also suggested, these were:

• 'Conversion rates' for the percentage of unintentionally homeless people rehoused in permanent accommodation from present levels to 100%;
• Use of section 5 referrals and the number of people being housed by housing associations;
• Time taken for assessments of homelessness;
• Housing Support outcomes;
• Performance against Care Commission Standards;
• Waiting list and transfer applicants time on general waiting lists;
• Turnover/availability of accommodation to rent;
• Improved management of voids and reduced void times;
• Tenancy success and failure rates;
• Key Performance Indicators and Statutory Performance Indicators (when reviewed); and
• In addition, there was a view that information on the proportion of lets to homeless households should be broken down by sector, and that the use of and time spent in temporary accommodation should include both non-priority and priority households.

Q9) Should local authorities be required to report against a broader set of targets?

151. There were 36 responses to this question. It was not always clear from responses whether respondents were in favour of a broader set of targets and many respondents commented more widely on information gathering. It is possible to say that the view that this was definitely not appropriate was less common (4 responses), with the remainder of respondents expressing views varying from the belief that this would be a good idea (or that it might or could be under certain circumstances) to the view that a shift was necessary from quantitative to more qualitative indicators. There was also a recurrent view that it was important to ensure the accuracy of existing data collection and references were made in this respect to reviews of the HL1 and HL2 data collection systems. To lessen the burden on Local Authorities by increasing reporting requirements, there was a view any new targets should be developed and implemented via the HL1 system.

152. Reasons given against introducing a broader set of targets were: that increasing data is resource intensive and that certain data / outcomes are difficult to measure; that it will be important for Local Authorities to continue to report against the existing targets in Homelessness Strategies; and that it is too early for specific targets to be set. There was also a concern expressed about creating a further level of reporting requirements and several respondents commented that Local Authorities already gather and report upon a considerable amount of information.

153. Suggestions of areas where targets may be appropriate were: lost contacts; repeat homelessness; time in temporary accommodation; affordability; prevention activity and outcomes; how many homeless households get their support needs assessed and met; the possible 'knock on' effects of legislative change; tenancy sustainment; numbers of tenancies established with support; and demonstrating good use is made of RSL nominations, private sector landlords and low cost ownership.

154. Comments were also made in relation to the need for local level sensitivity, there was a view that national level indicators would need to be augmented by a set of local indicators and that targets should be set individually for each council as there are too many variables between councils to have one set of targets. There was also a suggestion that consideration should be given to developing a broad range of indicators across all local authorities based on current practice in each. In this respect it was suggested that the Executive could conduct an audit of targets currently in use and then decide if a standard range of targets should be adopted, it was thought this process could also identify Best Practice issues.

155. There was also a view that the obligation to report should be expanded to include all housing providers, not just local authorities, and for RSLs to report on how they will prevent homelessness and comply with Section 5 duties. A similar view was that information on a wider range of socio-economic activities should be sought to ensure both that there is a unified response with all agencies playing their parts and that long-term steps are being taken to prevent initial and recurring homelessness.

156. There was a view that a shift of focus was needed to measuring individual outcomes of people in housing need, whether they were homeless or at risk of being homeless and that the impact of prevention activity is only measurable through the impact on housing and support needs of individuals in terms of their progress towards permanent, sustainable solutions. There was also a view, however, that reporting requirements should focus on outcomes arising from Local authorities' strategic approach rather than detailing outputs against each individual action.

For one respondent "effort put into strategy-setting can be seen as diverting resources from front-line provision, and can therefore be justified only to the extent that it improves that provision. Therefore there has to be a balance between the two". ( APN 23)

Q10) Would it be useful to resubmit homelessness strategies following the publication of the statement?

157. Forty respondents addressed this issue, 22 of whom were of the view that re-submission following the statement would not be appropriate. Amongst these respondents, there was a common view that the existing review procedures and information given in Local Outcome Agreements should be sufficient. Some respondents were in favour of requiring Local Authorities to submit an annual statement outlining progress towards the 2012 target and noting any changes to their homelessness strategies rather than a formal resubmission. There was also a view that Local 2012 Delivery Plans should be considered the key document for reporting on progress. Of the remaining respondents, 13 believed that strategies should be resubmitted, 4 that this would depend on the content of the ministerial statement, particularly in relation to the inclusion of any interim objectives for phasing the expansion of priority need categories, and one response was of the view that strategies should either be resubmitted or a short addendum attached to existing strategies.

158. Among those not in favour of resubmission, there was a view that resubmission would require a diversion of resources from service provision and strategy implementation. There was a view that "already administration around homelessness reporting is impacting on resources available to develop additional services" ( APN 16).

159. Of those in favour of resubmission, the importance of outlining how abolition of priority need will be achieved and demonstrating proactive movement towards any phases introduced in the statement was seen as important. Some expressed a view that resubmission should occur at a point sufficiently after any changes introduced to ensure that it was possible to fully consider the impact of such rather than eliciting 'knee-jerk' reactions. Possible dates suggested were 2008.

160. There were also suggestions that it would be useful to develop a central resource to collate and disseminate examples of good practice identified through reviews and evaluations of homelessness strategies.

Q11) Should the statement contain an interim objective in relation to the abolition of the priority need test or is this precluded by the current position?

Q12) If an interim objective on the abolition of the priority need test is incorporated, how should it be framed?

161. Of the 42 respondents who answered question 11, 38 stated views as to whether an interim objective should be contained in the Ministerial Statement. Respondents were divided roughly equally on this (16 were in favour, with a further 3 probably in favour, 18 were against and 1 was possibly in favour). Of those who believed an interim target should not be included, 8 were of the view that locally set targets were preferable to national ones, 6 that the current position with regards to lack of capacity and ability to meet current demand precluded setting any interim targets and, one that there was insufficient evidence to provide feedback.

162. Some comments made in relation to each of these points are:

It is not considered realistic to expand the definition without further pressure being placed throughout the housing system. ( APN 6)

The impact of proposed interim measure for this area are attached which outline that the housing stock is not available to meet this demand at any interim period … a phased approach … will currently only serve to place the Council in a position where it cannot fulfil its statutory obligations earlier than is necessary. ( APN 10)

There should be no interim objective until all current responsibilities are met and the waiting list of unintentional priority cases is reduced. ( APN 21)

South Lanarkshire Council believes that as far as possible, Local Authorities should plan their own progress towards readiness for 2012. If they wish to establish interim objectives for themselves as milestones in this process, then they should have the ability to do so. ( APN 12)

Unless it is possible to confidently predict significant changes and milestones which are relevant to ALL Local Authorities this would be a very prescriptive approach. ( APN 44)

163. In addition, there was a view that any expansion of priority need would need resourcing:

On the question of an interim objective I would question its validity. Not because I necessarily support the concept of a sudden abandonment of priority need but because without backing it up with the resources to develop the services needed to make 2012 a reality it would be quite meaningless in my opinion. As we cannot provide enough appropriate accommodation for those who need it currently, unless something radical happens 2012 will remain a concept. ( APN 25)

We are not opposed to a statement that contains an interim objective but the scale of the issues that encompass homelessness and the costs associated with targeting initiatives would require a committed financial resource to allow LAs to meet the objective. ( APN 17)

164. Comments on phasing made during the regional seminars indicated support for a set of local targets linked to benchmarks identifying resource requirements necessary to meet them. It was felt that if such resources were not forthcoming it would not be possible to meet the targets. There was concern that locally set targets could lead to further pressure on councils providing the best services.

165. One respondent was of the view that the consultation paper asked if there should be an option of not expanding priority need in light of the challenges faced by some local authorities. The respondent felt that this was not acceptable, and that challenges must be met by expanding provision, rather than restricting services. Another respondent expressed concern that any interim objective would be used to extend the 2012 target. There was a view that interim objectives would allow for monitoring of the impact of legislative changes, and for the pace of change to be slowed down (or accelerated) as required.

166. Those in favour of an interim objective saw this as necessary to aid planning and ensure that the target was met. One respondent emphasised the importance of ensuring any interim objectives resulted in beneficial outcomes for homeless households:

Whilst evidence suggests that the removal of priority need will be very challenging, we support in principle the statement containing an objective regarding abolition of priority need. We would qualify this by saying that if the statement contains a target that Local Authorities are unable to meet then implementation is likely to disadvantage households further by resulting in, for example, excessive times spent in temporary accommodation; households perhaps being housed outwith the community with which they have links and increasing stigmatisation as homeless households are seen as taking all allocations. In these respects final outcomes could be worse for homeless households. ( APN 45)

167. With regards to how an interim objective should be framed (question 12) there were views both that phasing or interim objectives should be set nationally (16 in favour) and locally (11 in favour). There was a view that locally set targets should be approved and monitored, Communities Scotland, the Scottish Executive and the Homelessness Monitoring Group were suggested as bodies that could undertake this task. Some of those in favour of a national objective thought this should be qualified by taking into account the capacity of local authorities to comply with it. There was support for phasing to be based on withdrawing the vulnerability test and / or to be based on age. There was also a view that looking at support needs, types of applicants e.g. families, or by specified needs groups could be beneficial. Other suggestions included that local authorities could review their homelessness strategies and identify new priority need groups from a collated analysis of these, or that local authorities could be required to draw up local implementation plans specifying their approach, to be approved by the Scottish Executive. It was thought that these should be able to include a case for the extension of abolition beyond 2012 where this could be demonstrated as necessary, and also that the Scottish Executive should have access to powers (possibly through Communities Scotland R&I process) to ensure progress where this was lacking. There was also a contrasting view expressed that it should be made clear that the 2012 target is non-negotiable.

168. The importance of clearly setting out the approach to be taken, providing adequate resources for implementation and monitoring, giving detailed timescales and encouraging prevention activity were also raised.

169. With respect to the timing of any phasing, there was support for a variety of options including a three-staged approach in 2009/10, 2010/11 and 2011/12, a target of 2008 for either complete abolition or at least 50% of those currently not considered priority need to be included, the proposed date of 2007 and a phase in 2008/09. One respondent was of the view that:

it is important that incremental targets are set sooner rather than later. There is a real risk if that does not happen the commitment will begin to fall into disrepute and there will be a growing belief it will slip, undermining one of the most fundamental planks of the Executive's commitment to tackle the injustice and social impact of homelessness. ( APN 50)

170. Concerns were raised about the possible interaction of a locally based gradual phasing with the suspension of Local Connection, with possible detrimental impacts on both service providers and homeless applicants. There was a view that evaluations should be conducted following the introduction of any phasing, and that this should include an assessment of impact on homelessness services, supporting people services, temporary accommodation provision, RSL waiting lists and achieving balanced communities.

Q13) What other interim objectives should be set?

171. There were 24 responses making suggestions for possible interim objectives to be included in the Statement. Some respondents felt the areas set out in the consultation paper would be appropriate. Others suggested various areas where targets could be considered. Areas indicated suggested targets both for local authorities and for the Executive, with some respondents also requesting that targets be set for RSLs, particularly in relation to prevention work and tenancy sustainment. There was also a view that broader targets should be set locally and agreed by the Executive.

172. Suggestions made included:

• The levels and impact of prevention activity;
• Requirements for effective monitoring and reporting;
• Completion dates for research, including into single homelessness;
• Increases in the number of private lets to homeless people;
• Increases in fully furnished tenancies;
• Increases in the range of models for single homeless;
• Short SSTs with support for homeless applicants who have demonstrated they lack the skills to sustain a tenancy; action to address information gaps;
• Specific actions to ensure coordination between homelessness legislation and other relevant areas of work such as Joint Futures and Anti-Social Behaviour;
• Progress on policy areas identified within the Consultation Paper and responses to it including the Strategic Investment Framework;
• Levels of investment, numbers of affordable housing completions/ increasing provision of affordable social housing;
• Financial and other resource commitments; and
• A proposed date for the end of Local Connection.

173. Other comments made in response to this question were that clarification is sought on the proposals for removing intentionality, that there are concerns over the proposed removal of the local connection test - specifically in relation to how this would impact on the responsibilities of Dumfries and Galloway towards prisoners on release from Dumfries Prison who have no local connection, that the issues of short-term funding needs to be addressed, that concern over pressure on Supporting People budgets needs to be addressed and that the Executive should set national guidelines for the proportion of lets made to statutory homeless households by RSL, and consider a similar system for local authorities.

Key points

174. Respondents felt that considering the suitability of housing stock to needs was very important when measuring capacity. Several also emphasised the need to consider capacity issues in the wider housing market. In addition, local level data on capacity and needs and information on prevention work were seen as important.

175. Respondents appeared to support a requirement on authorities to report against a broader set of targets, again emphasising the importance of sensitivity to local issues. The following were identified as potential areas for targets to be set:

• Lost contacts;
• Repeat homelessness;
• Time in temporary accommodation;
• Prevention activity and outcomes, and tenancy sustainment work;
• Assessment and provision of support needs;
• Potential 'knock on' effects of legislative change; and
• Demonstrating good use is made of RSL nominations, private sector landlords, low cost ownership.

176. Just over half of those who commented were against a formal resubmission of homelessness strategies, favouring either normal revision processes or annual updates / addendums. Of those in favour of resubmission, the importance of outlining how abolition of priority need will be abolished and demonstrating proactive movement towards any phases introduced in the statement was seen as important.

177. Respondents were divided roughly equally on whether the Statement should contain an interim objective. The two main reasons against an interim target were that there was not sufficient capacity to meet one and that locally set targets were preferable to national ones. There was no clear consensus on the framing or timing of an interim target, though several respondents thought it important that any target was sensitive to local issues.

178. Suggestions for other interim targets included both those for Local Authorities and for the Scottish Executive. Some respondents also requested that targets be set for RSLs, particularly in relation to prevention work and tenancy sustainment.

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