Never underestimate the stupidity of UK housing

If there is such as a thing as a basic NVQ Level 1 textbook in business studies it would tell you that companies lose 20% of their customers each year.  The social rented housing is thus in a privileged position of only losing 10% of its customers each at around 440,000 of its current 4.4 million households

Yet the social rented housing is stupid in ignoring this as it means every 5 years that 50% of its customers – the tenants – are different to what they were 5 year before.  Another way to say this is that from the start of one parliament to its end half of your customers have moved on and half need to be replaced.

Some 2.2 million new tenants have to be found over the course of a 5-year parliament.

Today I received an email invitation to a Chartered Institute of Housing conference costing £279 for CIH members or £299 for non-members to come listen to the wider great and good of social housing called “Rethinking social housing – shaping the future”

Without the need to be a grammar Nazi all of this is future tense and what social housing will be in the future – a point hammered home in the blurb by Terrie Alafat the CIH chief executive which you can read in the full blurb at the end.

You will also see that many eminent professors are part of this as are so many housing ‘leaders’ and the erstwhile great and good are speaking and so far so good.  Then we find the details of the 3 core strands each of which asks two questions and here is where we find the rub of the crass stupidity of the UK housing sector.

cih nonsense 2

Now look at these six questions reader and tell me which of these deals with the 2.2 million new social tenants we will have in social housing by 2022?  If you think the answer is NONE of them then you are entirely correct.

This is a rhetorical question but what is the point of finding out who CURRENTLY lives in social housing if half of them will not be there in 5 years time in this self-proclaimed FUTURE exercise called “Rethinking social housing – shaping the future?”

Today we know that in 5 years time many changes to who can AFFORD to live in social housing will arise.  Absolutely fundamental changes will occur when we know today that from April 2020 social housing rents will increase by 4% each year (CPI+1%) and that will mean that UK social landlords will year on year refuse to accommodate ever smaller working age families due to how these rent rises interact with the overall benefit cap policy.

Now only in September some 6 weeks ago did the same CIH who is behind this “Rethinking social housing – shaping the future” initiative issue a report in conjunction with the University of Sheffield to say that an increasing number of (benefit) families are being refused social housing due to affordability.  These tenants can’t afford the rent now due to the OBC and social landlords can’t afford to accommodate them due to the financial risk of arrears now.

That affordability risk and financial toxicity of the working age benefit household now will get so much more acute every year from April 2020 with the CPI+1% inflation busting rent increases.  Every £1 the rent increases is £1 less that the benefit household will get in housing benefit and its universal credit equivalent.

A day or so after the CPI+1% inflation busting social rent formula was announced I correctly said this means that by 2022/23 and just five years away that social landlords will have to refuse to accommodate the working age benefit household with just 2 children across the UK and in some areas the working age benefit household with just one child on the same affordability grounds.

What is the point of finding out who currently lives in social housing? AND the real question that this 3 strand 6 question initiative omits to ask is Who can afford to live in social housing in the future?

  • Do social landlords target an ever increasing number of non benefit self rent-paying households in order to fill its 2.2 million vacancies every 5 years?
  • Do social landlords target an ever increasing percentage of non working-age new tenants each year i.e pensioners who are not a financial risk?

Forgive me for stating the bloody obvious reader but it has to be one or both of those two options or a combination of both.  So the futility of seeking to find out who the CURRENT tenants in social housing are is there for all to see – well apart from the 28% of socially rented households who are headed up by a pensioner in England (and I have no equivalent figures to hand for Northern Ireland, Scotland & Wales.0

Now lets take the truly alarming omission of who will comprise 50% of all social tenants in five years a step further.  Social landlords are fixated on build build build.  We have to build more and more new houses they say and they do.

Yet who are they building for if they do not even contemplate who is going to live in them in 5 years or 30 years or even 60 years time?  Or more in depth of who can afford to live in them in 5 years time which must be a major factor in what type and size of housing that is built surely?

I could say so much more but I will finish with a question that you would also find in a NVQ Level 1 business studies textbook – Why would anyone pay £299 for a seminar that is meaningless and misguided and provides no real benefit? If those six questions are the best the CIH and the great and the good of the housing sector and the great and the good of academia can come up then they and all potential attendees would be better served by buying a Business Studies for Dummies book (Level 1).


cih future nonsense


PS You noticed the typo in CIH blurb which meant to say “the project will have three streams of work” yet actually says three STEAMS!

The steams off the proverbial you can’t polish or roll in glitter anyone?


Theresa May deceives at PMQs over Universal Credit and arrears.

Today’s Prime Minister Questions saw Theresa May deceive the House of Commons over Universal Credit and rent arrears.  Below is the Hansard record that I have highlighted and the source is here.

theresa may UC lie

As you can see the context is Jeremy Corbyn asks Theresa May a question about the relationship between the implementation of Universal Credit and rent arrears.  The Prime Minister states:

“… but we see that after four months, the number of people on universal credit in arrears has fallen by a third.”

This is true yet what Theresa May fails to say is that this is still a 23% increase in arrears after 4 months and directly caused by universal credit.  What Theresa May knowingly and very conveniently failed to state was the number of tenants in arrears from universal credit implementation increase by 85% from week 1 and thus a fall of one-third or 33% after 4 months is still a huge increase.

Let me patronise you with the most basic arithmetic reader, the basic arithmetic Theresa May patronises you with and hopes that you do not comprehend.

  1. The number of tenants in arrears pre universal credit is 100
  2. The introduction of UC increases this by 85% to 185 tenants in arrears
  3. 4 months go by and 185 tenant in arrears falls by 33% to 124 tenants in arrears.

Thus the original number of tenants in arrears increases from 100 to 124 which is a 24% increase in tenants in arrears and directly attributable to Universal Credit.

Theresa may was guilt of an error of omission and of commission.  If she knows the percentage figures for UC created arrears after 4 months then she clearly knows the initial position and percentage increase in arrears that UC creates.

Put simply Theresa May has knowingly deceived the House of Commons.

Put even more simply she told a huge whopping lie.

In trying to be clever and devious and spin the horrific impact of Universal Credit on arrears – and the arrears to eviction to homeless pathway – Theresa May has been found out.

Oh but she didn’t lie, she left some things out her supporters will say. And what she actually said was likely to be correct that UC arrears fall after four months and largely due to Universal Credit allowing arrears payments to landlords in those four months that equate to 24 months of arrears payments that a court would sanction.  See here for the detail on how the DWP through Universal Credit regulations permits landlords to claim back arrears at over 6 times what a court of law would allow.

But lets cut to the chase.  Theresa May lied and a basic knowledge of the most basic arithmetic proves she lied to defend the indefensible that is her policy of Universal Credit.  If you get the chance to watch video of Theresa May uttering this lie she is also the most unconvincing liar you can imagine.  Mute the sound and a 3 year old can see from her body language that she knows she is lying through her teeth and even Hansard records her stuttering delivery above.

She even premises the UC arrears lie with:

  “There have been concerns raised—there have been concerns raised in this House previously—over the issue of people managing their budgets to pay rent …”

Theresa may really is a vile creature.  When you get no income whatsoever for at least six weeks and often longer with Universal Credit please advise how you manage a budget of zero fucking income Prime Minister?  To blame UC directly created arrears on tenant mismanagement of money that they have not got and not got directly because of Universal Credit policy is shameful and offensive.

The original Corbyn question used a lettings agency sending out pre-emptive section 21 Notice to all private tenants.  In short UC now applies in this area hence we no longer take any benefit tenants and you are going to be evicted.

Let me add to that horror with the reality of how UC affects social tenants and those not in arrears when UC implementation begins.

UC systemic arrears

The above describes the procedure using a chronology which for some incredulous reason is what happens and is legally permissible.  Take a look again at the post I issued yesterday here and the picture I used from a landlord tweet to recount what UC actually means.

kirkless apa 35%

35 per cent on an APA – alternative payment arrangement – that by default takes six times more from the tenant for arrears payment at source than a court would sanction and you see why and how universal credit arrears do come down by one-third after four months as this is the equivalent of six times that time period of two years worth of arrears payment a court would sanction as the maximum the tenant could afford to pay from benefit income.

Yet arrears numbers would still be 24% higher than before the implementation of universal credit – the lie that Theresa May informed the House of Commons today.

What a piece of work this vile incompetent lying politician is eh reader.  She is your Prime Minister who not only lies to you and patronises you but one who is prepared to let children go hungry and lose the roof over their heads because of the systemic and 100% political decision to put in a minimum 6 week delay into the universal credit policy.

By all means be ‘economical with the truth’ to defend some greater good or the national interest Prime Minister, we can all understand that.  Yet knowingly and deliberately lying to protect a failure of a policy that takes food out of the mouth of children is quite another matter.  To lie so brazenly and to be found out so easily in that lie shows that you are not even an effective politician.

It shows you are as much a failure as your flagship universal credit policy.

It is way past time for you and the policy to go.  Time you did.





Reduce the overall benefit cap to £15k per year Chancellor … You what!!??

Chancellor, do yourself a huge political and economic favour in your budget next week and reduce the Overall benefit Cap limit to £15,000 per household per year from its current limits of £20,000 in the regions and £23,000 in London … as long as you take housing benefit out of Universal Credit and the Overall Benefit Cap policy.

It is easy to criticise Tory housing and housing benefit policy. There is so much to moan about / constructively criticise after all. Rarely do we see a solution offered fro the great many ills as it is so so easy just to moan so how about a campaign asking government to take the paying of rent costs out of Universal Credit and the Overall Benefit Cap policies? 

To be frank I am amazed that all the social housing lobbies with whom the Tories have had endless behind closed doors meetings have not come up with the same solution as it really is stating the bloody obvious and mutually beneficial. 

So two simple points in this solution:

Government should reduce the overall household benefit cap limit to £15,000 per year and pay Housing Benefit as they always have.  

Universal Credit without housing costs would be 5 benefits into 1 rather than 6 and UC administration would flow much better and allow an increased roll out and save the entire UC project in which the Tories have so much political face invested.

Note that UC claimants still have to go to their local councils already for council tax relief (CTR) so a precedent exists to go outside that what UC does not cover. It would simply mean the UC tenant claims HB and CTR together rather than just CTR as now.

The effects would need to be modelled accurately of course yet it is likely to be cost neutral for central government as the £5k and £8k pa reductions are above the average SRS respective rents in the regions and London. The reduction in arrears to eviction to homeless pathway that UC and OBC systemically create would be removed while keeping the theory of benefit scroungers cutting their cloth and not simply dropping sprogs to get more in welfare. My apologies for that phraseology yet it avoids any confusion as to what is the reality of the Government intent.

The systemic pathway to homelessness for existing tenants and the huge increase in the refusal of future benefit tenants from social housing – which has 400,000 new vacancies to fill each year and each year will have to refuse more due to any ‘welfare’ or rent increase will be abated.

That is a huge issue as my undisputed figures over the proposed CPI+1% sanctioned social rent level increases from 2020 interacting with the static OBC limit will see social landlords refusing the benefit household with two children and in some cases with just one child due to affordability issues created by rent increases interacting with OBC limits. The original OBC introduced in 2013 limited these refusal rates to families with 4 and mostly 5 or more children by comparison.

The cheapest rents in the UK will not be affordable to the small sized family and the UK under the Conservatives will have created a democracy that cannot even house its most marginalised citizens and thus not meet any semblance of the basic democratic function of providing shelter for its most vulnerable citizens. 

Social landlords could afford the working age benefit tenant household if – and ONLY if – the OBC is reduced and housing benefit continues as before outside of this policy.  If this does not happen (and I’m ruling out any probability of a CPI+1% inflationary uplift to the OBC each year) an ever higher percentage of these 400,000 per year prospective households will be refused the allocation of social housing and go direct to the burgeoning homeless queue and at hugely increased financial and political cost to your government

None of the above is speculative it is simply what those pesky facts called numbers mean and given you as Chancellor have not attracted the same label that the Daily Telegraph gave to your predecessor of the ‘incompetent innumerate’ and I presume you do not wish for that to happen as you are by all accounts aspiring to replace the current PM then using facts as evidence further differentiates you from the aforementioned incompetent innumerate.

Welfare scroungers cutting their cloth?

(a) OBC

The way the overall benefit cap works is to subtract the total amount of base benefit (IS/JSA/ESA) plus child tax credits and child benefit from the cap figure. This leaves a maximum amount that can be paid in housing benefit. It means that the only benefit to be cut is housing benefit and this systemically creates the arrears to eviction to homeless pathway. 

I wonder whether that simple explanation and obvious consequence has passed your purview before or have you alongside your party colleagues simply sold the extreme ideological superficiality of this cut in isolation to an electorate that used to (a key phrase) believe austerity was a necessity and not a political choice.

In essence get a job, any job or you lose the roof over your head and that of your children. That goes way beyond harsh and outrageous in terms of morality. You can also argue this systemically creates a continuous cohort of workers who have to accept minimum wage and hours at the behest of low paying employers yet that is just morality.  However morality is never a good reason as you know in politics – yet after deceiving the electorate for 7 years with austerity and superficial ideology the current political climate is one of scrutiny and you and your party risk being found out – the gravest of political sins.

The economic aspect of this is that when the OBC household does take up the minimum working hours at minimum wage the overall welfare bill increases through working tax credits and child care costs the exchequer pays out more in welfare. In short this incentive to compel work in the OBC policy actually costs the country much more and is a perverse incentive in welfare and taxation terms.

Reduce the OBC limit and the benefit household still has the incentive to work as the benefit income is capped and the children of that household do not pay for the ‘sins’ of the parent(s). Note here that the parent(s) who formerly received the £29.05 more per week in ESA for being placed in the work related activity group (WRAG) and what we formerly called Incapacity Benefit are already £1500 per year worse off and they far outnumber those in receipt of dole yet have to work from day one by being placed in the ESA WRAG despite this benefit meaning they are ready for work if they receive support and ready for work with that support in up to two years time.  The benefit freeze also compels those out of work to seek employment.

That support to JSA / ESA / UC claimants does not exist in all reality – another thing the current rush to scrutinise welfare policies will find out – despite the Government statements that this support is done by the job centre work coach who each have a case load of 300 persons. 

Basic arithmetic equates to 7 minutes per person per week to include ‘support’ as well as all other work functions each job coach has! With the huge media attention on Universal Credit and ‘welfare reform’ generally it is only a matter of time before the electorate finds out this Tory claim of ‘support’ is blatant deceit for which the usual inevitable political consequences will flow.

The OBC thus compels many who are not ready for work to take up employment else they lose the roof over their heads. That is not clever politics and as I say it actually costs more in welfare if the Tory incentives are taken up in this nudge theory superficial nonsense.

(b) Universal Credit

We see UC act as above for the OBC but in much greater severity and with additional factors. The systemic delays for the first payment which arrives no earlier than six weeks directly creates rent arrears and hastens on the arrears to eviction to homeless pathway.

Secondly, UC is wholly inflexible and rigidly stick to a one month payment period of the same date each month. So if you are paid every fourth Friday and the month has 5 Fridays UC states you have been paid double and thus it fails to pay the correct amount and instead pays a much reduced amount which further accentuates the arrears to eviction to homeless pathway.

Thirdly, if the tenant (working or not) has a monthly tenancy and all tenancies require payment in advance then by the time the first payment reaches the tenant after 6 weeks then they are 10 weeks in arrears.

After 8 weeks and thus before the tenant receives any UC payment the social landlord issues an APA to UC and the rent plus 20% off the UC standard payment (up to 6 times more than court allows) is taken as source from the tenants UC by the landlord. For a couple this is £97 per month and for a single person / lone person £64 per month and throws the tenant into poverty (and increases all social and health care cost including longer NHS waiting times, blah, blah, blah.)

The rent and (theoretical) arrears are paid first and thus the tenant (working or not) has less money to pay all other bills and is much more likely to have to borrow in order to survive. That creates further costs of interest to the tenant and often exorbitant rates of interest too and systemically creates greater poverty.

All of these issues would be taken away IF the payment of housing costs is taken out of UC and is paid by housing benefit.

Chancellor, if you want to score huge political points which I take as read and if you want to reduce homelessness for which you will be blamed as truth and fact win out if you do not, and if you actually want to reduce the welfare bill and save the huge political face you have invested in Universal Credit, then the solution is above. 

You can always sell these changes and score political brownie points in doing that.  We didn’t get it quite right in the past and we are changing things for the better is always easier to sell for you as the new Chancellor as your previous roles were so far removed from the mess your colleagues have made of ‘welfare reform’ which you know as Chancellor have not worked as the welfare bill continues to increase as does its inevitable impacts on increased homelessness which we have.

Note too that the electorate have huge sympathy for ‘the homeless’ in the six-week run up period to Christmas (and the opposite the other 46 weeks of the year) so your decision, Chancellor, to only hold one budget per year and in late November has to take that very much into account. 

You must admit that blend of ‘caring Conservatism’ coupled with the removal of the perverse incentives of OBC and UC which if the nudge theory works costs more in welfare and so if fiscally prudent is a compelling blend for any future PM candidature. 

More importantly for me it is the no-brainer stating the bloody obvious right thing to do.  However appealing to a Tory Chancellor along those lines is something I have resisted for some reason … reasons which escape me …

Social (sic) landlords create tenant poverty in Universal Credit

kirkless apa 35%

The above is a tweet put out in the last hour from a social (sic) landlord in Kirklees which has trusted (sic) partner status with the DWP over Universal Credit.

Note well that 35% of social tenants on UC have an alternative payment arrangement (APA) that is much more sinister than it reads.

It means as I pointed out here that the social (sic) landlord has requested that six times more in arrears payment than a court would allow is taken at source from the tenant Universal Credit and paid to the landlord directly.

The landlord is directly creating much higher levels of tenant poverty by taking £99.87 per month in arrears from a tenant when a court award would only allow £16 per month to be taken from the tenants benefit income.

Social landlords lobbied government for this system which systemically creates tenant poverty by taking six times more from the tenant for arrears than a court would award.

Almost £84 per month less to put food into the mouths of the tenant’s children; Almost £84 per month less to clothe children; Almost £84 per month to pay for heating; £1000 per year more taken from tenants by greedy bastard social (sic) landlord who do not give a flying fuck about the social tenant.



The detail

A court typically awards in a suspended possession order two conditions of (a) the tenant pays full rent and (b) a sum of £3.70 per week off the arrears.  If either condition not met and tenant breaches order the landlord seeks a full possession order.

Courts have long held and decided that the benefit household cannot afford more than £3.70 per week which equates to 5% of base benefit and also to £16.09 per calendar month off arrears.

Under Universal Credit the landlord applies without any need to inform tenant for the APA when arrears have reached 8 weeks for a weekly tenancy or two months for a monthly one.  The APA is automatically awarded to the landlord and deducted from the tenants UC at source.

The UC IT system defaults to 20% of the UC standard allowance of £317.82 for  a single person over 25 or lone parent  which is £63.56 pcm which is four times what a court would allow; and 20% of the couples UC standard allowance which is £99.87 pcm and six times greater than a court allows.

NB – Social landlords lobbied for this despicable system and the Tories agreed

The UC regulations say that a tenant can ask for the arrears payment to be reduced to 10% of the UC standard allowance [£31.78 / £49.94 pcm] yet (a) that is still double what a court would sanction for a single person / lone parent and three times what a court would allow for a couple.

Yet the UC person you speak to over the phone invariably has to be told this is permissible under UC regulatins, then they have to agree to it, and then they have to get a supervisor from another UC department to manually override the UC system to apply the 10% UC reduction rather than the 20% deduction.


All social tenancies require payment in advance so a weekly tenancy is a week in advance and a monthly one a months rent in advance.

The monthly tenant is typically one month in arrears due to HB being paid in arrears and this is largely theoretical arrears and seen that way correctly by social landlords before UC became operative.  Yet we know UC takes at least 6 weeks to issue the first payment and thus the monthly tenant is 10+ weeks in arrears by the time the first UC payment arrives.  However two weeks before that the landlord informs UC that the tenant rent account has gone into 8 weeks+ of arrears and the APA is applied.

The tenant / UC claimant only realises that either £63.96 or £99.87 has been deducted for arrears that did not exist from his or her first UC payment.

The social tenant household moving onto UC thus finds their first payment has a massive shortfall to what they were expecting and that the systemic UC wait for the first payment has plunged them into rent arrears.

Before the right-wing trolls and ideologues get on their errant high moral horse, there are 1.1 million families in work and in receipt of housing benefit and this will affect them too not just the proverbial ‘benefit scrounger’ claiming ‘welfare.’  Those in low paid employment may be forced to walk to work or even give up employment because of this APA that their social landlord has imposed on them that a court never would.

Imposed on the social tenant by those landlords who remind us daily in their pithy PR that they have social purpose and social ethos and who lobbied for this outrageous system.

Note too that when a tenant does have existing arrears of paying full rent and £3.70 per week imposed by a court through a suspended possession order that UC totally ignores this.  The UC IT system can ONLY impose a 20% or 10% deduction and cannot reduce this to the typically 5% arrears payment that the courts have decided is all the household can afford.

This is cruel and inhumane and quite how the law allows UC at the behest of landlords to impose such a dire poverty-inducing deduction at source is offensive and legally perverse.  Yet UC allows a total of 40% deductions at source  … and if you read the UC regulations carefully and literally they can permit a 100% deduction and the payment of nothing at all.

Universal Credit holds many such truly offensive aspects that will become common knowledge when it rolls out more and all of those who said it is fine in theory will wholly retract that superficial and errant belief and be calling for it to be abandoned a they should always have done.

New UC regulations and varied ones have been issued like confetti ever since it became law in 2013 and have largely gone unnoticed except by the real ‘geeks’ who have worked in the welfare benefit arena for years and even in some cases by them.  This is not just a lack of democratic and parliamentary scrutiny, which is bad enough, it is in many cases due to the DWP realising that UC forgot about aspect A or regulation B has a previously not considered impact and all other forms of ‘oh shit we didn’t expect that to happen ‘ … and this is the major reason for the hugely lengthy roll out.

When UC does roll out to the non-easy cases which is typically all it covers now we will see hundreds of these ‘oh shit we never expected that‘ moments from the DWP and further statutory instruments issued piecemeal to try and save this turkey of a policy.

It needs to be abandoned not delayed.  UC is not fit for purpose and never can be.  It is quicker and more cost-effective to rip it up and start again yet politically that can never be admitted for loss of face reasons by the Tories for this ‘flagship’ policy.  That flag may well as be the Jolly Roger as claimants whether working or not are being jolly rogered by this farrago.


Rejoinder to Generation Rent report. Why pensioners in PRS will not increase

The social housing concept, a key element of the 1948 Welfare State is being resigned to nostalgia and history. That direction of travel is being aided by social landlords who do not even compete for the social media equivalent of newspaper column inches which are full of the admittedly poor lot of the private rented tenant.

Shelter, JRF and other campaigning and research groups, the Guardian, Independent and other usual national media and the pro-active challenging nature of the likes of Generation Rent bombard us with private tenant issues and remain silent as the lot of the social tenant gets worse by the day.

Social housing is in the toilet and going further round the U-bend every day yet this goes unnoticed due to the dearth of social tenant challenge and the complicity and unwillingness to challenge policy by social landlords or the tenant and resident associations they control.

The treatment of the social tenant as raw sewage that we would rather not talk about manifests in so many ways. Through the interaction of the overall benefit cap policy and inflation-busting rent increases announced from 2020 we find that many existing social tenants will have their housing benefit cut and can’t afford even the cheapest social rent.

A great deal more benefit tenant households will be refused the 400,000+ new social housing lets each year because of it and will go straight to the homeless queue. In 2013 typically this was only the benefit household of working age with 5 or more children refused yet by 2023 it will be the working age benefit household with just two children refused social housing on affordability grounds. That is not speculation it is what those pesky things called facts say and if anything is absent from housing or housing benefit policy it is facts!

Because the working age benefit household increasingly becomes financially toxic and too high a risk for social landlords we will inevitably see social landlords allocate more to the pension age benefit household. In fact social landlords will actively seek the pension age household for the 400,000 new empty properties it has each year – which is two million new vacancies in every 5 year parliamentary term; that is stating the bloody obvious.

Pension age households are exempt from the ‘welfare reforms’ such as OBC or bedroom tax and the rest and even in general needs social housing they are exempt from LHA restrictions that apply to pension age households in the private rented sector.

So when today I read a Generation Rent report which says the number of pensioners renting in the private sector is going to triple by 2035 I take that analysis with the greatest pinch of salt as it ignores the huge shift that will happen as private tenants just below pension age will move into social housing as it is mutually beneficial for them and social landlords.

The Generation Rent report in numbers says the number of pensioners renting privately will increase by 600,000 or so in the next 18 years (by 2035) – a figure of 33,000 more per year on average. Yet social housing has 400,000 vacancies a year so all it needs is for social landlord to allocate 8% more social tenancies per year to the pensioner household by allocating 33,000 more vacancies to them each year. 

7.2 million new social housing allocations will take place over this 18 year period and so 600,000 of them going to pension age households in addition to the normal allocation is easily achievable and will happen because it is in social landlords best financial interests as I explain.

That is not even a significant change in allocation policy for social landlords and those social landlords will be allocating to a cohort who are exempt from the housing benefit cuts unlike the working age prospective tenants – the key financial imperative for landlords.

Social landlords immediate reaction to the shared accommodation rate announced in 2015 for social housing was to ban those under 36 from allocation and just as social landlords allocation policies stopped under occupation on allocation for the bedroom tax from early 2013 we know that landlords react to HB cuts very quickly.

So with every welfare reform / HB cut pointing to social landlords are better off financially and reduce their financial exposure to rent arrears and eviction costs by allocating to the exempt pensioner household then that is precisely what they will do over the next few years. Pensioners are a safe bet for social landlords as they get full housing benefit.

That is the huge flaw in the Generation Rent analysis as it presumes social landlord allocation policies and preferences will stand still and not react to the myriad of housing benefit cuts. It is why the report today has little credibility and be careful with your salt intake people.

In summary I take my hat off to Generation Rent for getting their issues raised and creating awareness which is something the social rented sector simply does not do. Yet in this case their conclusions are misguided and will not happen as we will see an increase in social housing allocation to the pensioner that will mean the numbers of pensioners renting privately does not increase anywhere near as dramatically as the paper says as social landlords will be courting the pensioner tenant cohort because they have no financial choice but to do so.

Sector misguided in extremis over new proposed ‘sheltered rent.’

ALL of supported housing is in crisis, including sheltered housing, as a result of the Tories plans announced on 31 October 2017.

The housing sector is extremely misguided in suggesting that sheltered housing will be okay and the supporting living and emergency supported housing may be problematic in its funding.

This is simply wrong and sheltered housing funding is problematic for existing and future services and all other supported housing is in dire and acute risk of closure which I outline here.

The ‘sector’ needs a huge wake-up call that I detail below and before the usual alarmist or scaremongering labels are given to this I refer to the words of Domini Gunn in a recent Inside Housing article:

Ms Gunn told the conference: “Just from the conversations we’ve had in the past 24 hours, they’re just realising you can’t have a single financial model across sheltered and extra care, because they vary.”

She added that civil servants in the Department for Work and Pensions (DWP) and the Department for Communities and Local Government (DCLG) didn’t find out about the government’s U-turn on applying the Local Housing Allowance cap to supported housing until two days before Theresa May made the announcement at Prime Minister’s Questions, suggesting Number 10 is driving the policy.

She said: “It was an absolute bolt out of the blue for the DCLG and DWP. They were gobsmacked that people under pensionable age lived in supported housing. They believed you could just put it all across to pension credit, because everybody was of pensionable age. You start to have to explain very basic things.”

You start to have to explain very basic things – about sheltered housing to the DCLG the government department where housing sits and to DWP who pay for housing benefit for rent including the proposed (a) new sheltered housing rent proposed and (b) new sheltered housing extra care rent proposed.

The fact that the government civil servants still do not understand how sheltered housing in all its forms operates is alarming. The new proposals in which the government says it has listened are over six years of alleged listening as the problems they have known about since the sector responded to the original consultation from July 2011. Yet we find Domini Gunn who has worked extensively with and for governments on all forms of supported housing since at least 2003 saying the civil servants do NOT know the most basic issues after at least six years.

Ye Gods!

I now turn to address just some of the issues with sheltered housing and so as not to confuse I mostly leave aside all other forms of supported housing and only comment on them where necessary to elaborate issues with sheltered housing.

Sheltered Housing

Sheltered housing has three main types yet the government proposals state just two maximum funding options. Three into two does not go!

  1. Category 1 sheltered for ease of explanation is non resident warden schemes.
  2. Category 2 sheltered has a resident warden
  3. Extra Care is Category 2 but with on-site health and social care provision

Government is proposing just two rent maximums (maxima) for sheltered housing one for extra care and the other for both the first categories of with or without a resident warden. That is hugely problematic and especially outside of London in relation to the original proposal which is still in the minds of government in a link to the private sector housing benefit levels known as LHA.

In July 2016 I posted a blog (here) over the then link to LHA and sheltered housing about Liverpool which has LHA rates just below the national average. I will include extracts of the factual data below to explain.

Yet the first point is the average (non extra care) sheltered housing rent paid by housing benefit equated to LHA+38% or simply the average sheltered housing rent level for a 1 bed property was 38% more than a private tenant receives for a 1 bed property in general needs housing.

By contrast the average (non extra care) sheltered rent in London equated to LHA minus 38% and this is much more than exposing the original Tory policy of funding at the maximum LHA or LHA+0%. It reveals the huge disparity between rent levels in relation to LHA between regions but on a 5-minute inspection a huge disparity of sheltered rent levels within regions and even within the same local authority area.

Sheltered housing rent levels are published yearly and easily accessible through the Statistical Data Return (SDR) yet it is obvious the civil servants at DCLG and DWP have not even looked at these as if they had done they would have realised very quickly that you cannot set a one size fits all maximum amount of HB that will cover sheltered housing rent levels.

Put another way if DCLG and DWP officials did not even realise that sheltered housing accommodates a vast number of below working-age residents (typically starting at 55 and in some cases 45 year of age) then there is not a hope in hells chance that they know that sheltered housing rents have a massive variance even within the same local authority area and that in many cases it is possible (and correct) that some sheltered rents in low rent Liverpool can be higher than like-for-like sheltered housing in high-rent London.

In my post of July 2016 I included a few data tables and I reproduce them below to explain.

Figure 1 Top ten rents (not extra care)

lpl sheltered rent levels top

None of the above sheltered housing schemes are extra care schemes. As such the new sheltered rent proposed will need to cover them in its new maximum in order for the status quo to be maintained. The highest sheltered rent level equates to LHA+85% and the average equates to the aforementioned LHA+38%. The lowest sheltered rent is LHA minus 8% for a 1 bed property in Knowsley which neighbours Liverpool.

Figure 1 Bottom ten rents (not extra care)

lha 1 bed shelt low

How can you set a maximum rent level for resident and non-resident warden sheltered housing with a range from 8% less than LHA to LHA plus 85%?

That is a rhetorical question as it simply cannot be done and Liverpool or Merseyside is not an outlier here as the massive variance in rent levels in sheltered housing (not extra care) occurs in Manchester, Leeds, Birmingham and many other large cities that I have researched. This is a national issue and rents range from LHA minus x% to LHA plus a high percentage in all those areas.

London does not have this issue as typically we see inner London have a 1 bed LHA rate of £260 per week and outer London £180+ per week and thus non extra care sheltered housing rents are all within or below the LHA 1 bed rate.

Government is proposing – we are told but no detail as yet released – that the new sheltered rent maxima will vary to reflect regional differences yet that would need to cover the LHA+85% in Liverpool and also the London average of LHA minus 38%!

Note that some London sheltered rent levels are LHA minus 50% at around £130 per week too so the notion that a sheltered rent maxima can be set anywhere across the UK is wholly delusional and will not come to pass. It cannot happen because it is impossible to even set a figure except for the highest current rent level that can only massively increase ALL sheltered housing rent levels and would see the housing benefit bill increase substantially – and a ball park figure here would be at least £1 billion extra housing benefit per year!

The level of incompetence within DCLG and DWP is astonishing as the above outline detail shows. Quite how the ‘great and the good’ of the UK housing sector is lauding this as success for sheltered housing certainty is quite another!

Did all the ‘experts’ whom the DCLG and DWP consulted over this only look at London 1 bed LHA levels and think a sheltered rent maxima was somehow workable whilst ignoring the bloody obvious fact that this cannot possibly work at all outside of the English capital?

That would appear to be the case as the DCLG decision on sheltered and further consultations on all other supported housing rent funding state that the government has listened to a variety of experts in housing and academia. It doesn’t take any sophisticated statistical model or anything more than THE most basic calculations to realise you cannot possibly set a defined sheltered rent level and maxima when current sheltered rents vary from LHA minus eight per cent to LHA plus eighty five per cent!!

WTF has been going on for the last 6 years plus in the behind closed doors meetings and conversations with DCLG, DWP and all such ‘experts’ in housing and academia to arrive at a mind-blowingly stupid and wholly impractical and unworkable solution to set up sheltered rent!

Regrettably DCLG and DWP and the wider Tory government appears wedded to this solution and they will say we have consulted and liaised ad nauseam with sector and academic experts in arriving at the sheltered rent solution. That is the biggest ‘oh fuck’ moment you can imagine for both existing sheltered housing and future sheltered housing in terms of the state funding of rent there.

When, and regrettably not IF, this sheltered rent level is set what will happen? If it is the average current cost then all those current sheltered housing rent levels above this new maxima are in danger of financial survival and it would appear that (a) sheltered tenants will be charged more to make up the rent from their pensions or savings; or (b) many existing services in sheltered housing will be cut; or more likely (c) both of these.

For existing services currently below the sheltered rent then it is likely that inflation-busting rent increase will take place year on year as so-called social landlords seek to move current sheltered rent levels closer to the new sheltered rent maxima – which means they are only affordable to those in receipt of housing benefit and not to those who self-pay their rent!

In short whether the sheltered tenants current rent level is below or above the new to be introduced sheltered rent maxima then the tenant is getting screwed in one form or another! How nice of all of these housing ‘experts’ who have worked so intensely with DCLG and DWP to come up with this crock of shit that they are lauding in their blithe ignorance of what it means!

Supported Housing

One final and quick point on emergency and short-term supported housing provision such as homeless hostels and domestic violence refuges is that we ONLY have proposals for that one stage of supported housing and nothing whatsoever on other necessary resettlement stages of such provision. Nothing at all.

For a very simple explanation a domestic abuse service can typically have three stages of support. The first is outreach and advising the person to actually flee after typically 37 incidences of violence. The refuge is the second stage and the third stage is post-refuge visiting or floating support. Yet the DCLG & DWP announcement only concerns the 2nd or refuge stage alone.

A homeless hostel typical has a post hostel visiting or floating support stage after the emergency access provision of the hostel itself. Again there is nothing in the Tory announcement about this – and for both after six fecking years or more of alleged expert involvement and government listening and consideration!!

I’ll finish there to avoid a doctoral thesis length critique off the top of my head about how disastrous these proposals are for hostel and refuge provision and how despite the great many (vague) assurances from government we WILL see mass closures of hostel and refuges due to this insane and incompetent set of proposals.

___________________ UPDATE __________________

This piece from September 2017 regarding a new extra care sheltered scheme in Hull – the lowest LHA area of England – sees that rent for a 1 bed equate to LHA + 115% whereas many extra care schemes in London are still below the equivalent 1 bed LHA. Yes the setting of the extra care rent maxima is going to be just as impossible to set as the sheltered rent maxima I describe above!!

No business case for Tory supported housing funding changes

Just over a week ago the Government virtually sneaked out the detail (such as it is!) of its intended changes to the funding of supported housing. It is a mess and the proposals are unworkable which comes as no surprise.

I would urge all involved in the provision of all forms of supported housing and any political opposition to not only respond to the proposals and consultation with their specific points as to how it will affect their organisation individually, but to cut off this consultation at its knees!

The Tories business case on which all of this is premised is so spurious and so riddled with holes that the business case for change simply CANNOT be made. The entire proposal and consultation should be rejected a fait accompli for that reason.

There is NO business case here and we all need to send it back to the Tory government and tell them to go back and start again.

Note well all social landlords who were only or largely only worried about sheltered housing in the LHA Maxima Cap proposals that this outcome resulted in that the sheltered housing rent aspect of it is also unworkable and as I said here is likely to see that figure being set BELOW the LHA Maxima Cap level of something like LHA minus 10% or even 20%.

The proposals and consultations combine to be what Gordon Gecko called a dog with fleas.

suphsg turkey

The proposal and consultations

We find a typical PRINCE 2 type structure of a business case and then a series of heavily steered questions all presented as if the business case is made in the preamble of the Ministerial Foreword . 

Can we please, for once, actually scrutinise this alleged business case rather than be steered to the specific DCLG questions.  There is no legitimate reason whatsoever to change the funding mechanism.

The following explains why.

Ministerial Foreword

  1. Supporting the most vulnerable people in our society is a priority for the Government, and we value the important role that supported housing plays.
  2. We are committed to protecting and boosting the supply of supported housing.
  3. It is also an integral part of the wider social housing sector, which we will be reviewing through the upcoming Social Housing Green Paper.
  4. We recognise that we need to make some changes to the way in which supported housing is funded. Local areas don’t have sufficient control or oversight of provision and it is not always possible to ensure value for money for tenants or the taxpayer.
  5. As demand for help to live independently grows, we also need a funding model that is fit for the future and can support the delivery of new much needed supply as well as making best use of existing supported homes.

Point 1 is meaningless political rhetoric. Point 2 is an assurance to protect existing and increase future provision though it doesn’t say of what type or indeed how. Point 3 is a statement simply recognising a link between general needs and supported housing. Point 5 is another vague assurance and statement of vague political intent.

Point 4 – Ah…!

This is the interesting one and contains the premise or business case for change and that business case is not made and is a wholly false premise. Here we have separate and allegedly linked statements of:

  • A need for change of funding due to
  • Insufficient local oversight and control
  • VfM for tenant and taxpayer

These three broad points are bogus. They are without foundation or if you prefer they are complete and utter bullshit.

Need for (funding) change?

There is a political need of this government for how funding is paid and entirely due to Universal Credit; specifically because when developing UC which drops Housing Benefit and 5 other named benefits into 1 the government gave no consideration of how HB works in supported housing.

A case of dropping one social security benefit (HB) without any consideration at all of how rent levels would be paid for in supported housing – a cock up of huge proportion and it has taken the Tories six long years of behind closed doors meetings to come up with this wholly vague and new consultation. In short they still do not know what the hell to do.

The only need for funding change is because the Tories created one through their incompetence and oversight.

Need for funding change due to insufficient local oversight and control?

Totally spurious.

Control and oversight by local authorities is very much catered for under the Housing Benefit regulations that have been around for 30 years and have 30 years of higher court level case law as scrutiny too.

Local authorities administer Housing Benefit on behalf of central government and each local council has wide-ranging powers in HB administration directly from the HB regulations. They can stop and suspend payments for existing services and they can drill down each and every claimed expenditure cost by a supported housing provider on a line by line basis and regularly do so.

HB Regulations say all costs should be ‘reasonable, realistic and justifiable’ and that covers everything and every cost and any such claimed expenditure cost can be vetoed by every local council.

Rent costs through HB are always a significant proportion of total income in supported housing and suspending or stopping HB payments is a huge degree of control and oversight that local authorities now have. It is also extremely likely that the other principal funding stream for supported housing providers – support – is also under the control and oversight of the local authority too.

The notion that local authorities have insufficient oversight and control is not just spurious it is total nonsense and frankly a lie. It is the most spurious premise and yet we see the government present this business case as fact when it is the direct opposite.

For those not used to the arcane complexities of how much HB funding is controllable by local council HB departments imagine Discretionary Housing Payments (DHP) that sees councils when doing affordability tests that you should only spend £x on utilities, £x on food and all other expenditure … and then multiply that by 100 to get what powers of financial oversight and control local councils have with supported housing HB funding!!

VfM for tenant and taxpayer?

Given the extent of control that local councils have through HB regulations as I outline above then any business case for a lack of value for money straight away appears perverse and overwhelmingly is perverse.

All funding regimes have some VfM questions and always will have yet the levels of scrutiny, oversight and control are significant in the current system and always have been and the funding of rents in supported housing has less VfM concerns than many if not all other funding regimes.

There is a woeful lack of understanding by governments of how each individual supported housing scheme can produce markedly different levels to one that appears to be much the same. Each service is inordinately and uniquely complex to get the HB funding correct and it is a huge undertaking.

Quite why the government think that a tenant with say learning difficulties is able to and needs to understand the complexities of how his rent level is formulated when its complexities would tax the brain of a Finance Manager is beyond me yet that is the government argument!

I say that absurdity because it exposes the superficial nonsense of the government premise and business case over tenant VfM. Of course costs should be transparent and they are and have not only been scrutinised line by line originally by the local HB department but also subjected to external auditor scrutiny as well. Yet here we find Government raising VfM as the most superficial of kites and raised for nothing other than superficial political rhetoric.

The undertone here is that local councils allow higher HB levels than they should because central government pays the HB bill. Yet all LAs know that they need a full audit trail for the external DWP auditor who says why is Service A getting 20% more than Service B! That is uppermost in the minds of the LA HB department when they agree to any supported housing HB level in the first place. That again is further oversight and scrutiny and control of the funding amount.

I restate that the Government business case for change is entirely fallacious and spurious and should be unequivocally rejected and all involved in supported housing and beyond should ensure they make this general case as well as their individual responses.

IF government do genuinely want to have the tightest control and oversight and the best possible VfM structures in place then keep the existing system that has been refined over 30 years to be the best possible system. There is no business case at all for change let alone a compelling one and this proposal and consultations should be rejected out of hand in all consultation responses.