The reason six years ago I started to blog was the Tories release of the original LHA Maxima Cap consultation in July 2011. The idiots of the Tory-led coalition government were seeking to damage supported housing as much as the Labour idiots who preceded them in government.
[ Aside – Please take those above points in to those who accuse me of a left-wing bias and label me in their shoot the messenger ignorance]
Thankfully and rightly the LHA Maxima Cap 2011 version was quickly buried yet it has now been resurrected (a) on even worse terms and (b) is scheduled to become operational in April 2019 with, (c) we are informed without any detail a year long lead-in which begins in April 2018 less than 8 months away.
My Speye Joe name is Joe keeping an eye on SP (Supporting People) that was the principal funding stream in supported housing which the idiots in the last Labour government decided to take away its ring fence in 2009 and thus directly caused the crisis we now have in social care as local authorities chose to swipe the SP funding and so the preventative agenda of support that SP had was no more. That same ring fence removal madness is manifest in the much touted Crisis report of today on homelessness which reveals 5,000 fewer homeless hostel beds in 2016 then in 2011, though I note Crisis do not make the bloody obvious connection between the 134% increase in rough sleepers in this time in the official count and 5,000 fewer hostel beds!
The larger supported housing providers are moaning like hell over the LHA Maxima Cap coming into force in 2019 yet the same moaned liked hell and actually did challenge the 2011 version of it and that challenge got the policy dropped. These larger supported housing providers by contrast did NOT moan like hell over the 2019 version as they were in cahoots with the Tories and had much bigger fish to fry with them over for instance the extension of the right to buy to housing associations – the same larger supported housing providers – and the HAs had an overt policy of not challenging the Tory government!
Yet just as you will read in any business manual by whichever business guru is de rigeur now or in the past supported housing has its showstoppers.
Showstoppers? In a general business context imagine a provider of widgets who can source 99% of parts or services from a thousand suppliers … yet they are reliant on the widget to work on one small specialist provider for the other 1% and without which the widget is useless. The de rigeur business guru exhorts the businessman to ensure for instance that it pays this small specialist provider on time and not have it wait the 90 day payment reality on 30 day invoices it has for the other 99% of suppliers. If the small specialist provider goes so does the business of selling widgets in short.
Supported housing has a wealth of small specialist providers (SSP) without whom the system falls apart. Yet because they are small they became the proverbial easy target for local councils to remodel or decommission when the SP ring fence was removed in 2009 and their expertise went with them as support staff who were experts in the nuances of support to 1-legged Peruvian glue sniffers or any such specialised vulnerable group largely chose to go stack shelves in Tesco as it paid more and without the hassle!
My company HSM worked with and advised over 200 SSPs and deliberately so rather than the larger support providers such as HAs. These providers were not just specialists who delivered phenomenally good levels of service that saved their respected local councils a fortune and helped the larger more generic support services, they were protected by the SP ring fence and the grant conditions that went with SP. Post 2009 they became vulnerable as hell thanks to the sham we call the commissioning process and in essence they lost the right to receive such necessary and vital funding SP provided.
Commissioners in local authorities simply saw them as an easy target to take back money so they could spend it in repairing pot holes or more typically to set against their care budget deficits. The example above of 5,000 fewer hostel places reveals the old tactic of the ‘deserving’ and ‘undeserving’ that is another typical subjective short-term madness of the LA commissioning process, that was bolstered and deflected with the superficial mantra of local councils know local needs best – a mantra not even worthy of the bullshit label!
We are now returning to even greater local authority control and subjectivity and short-term myopic madness in the LHA Maxima Cap policy. The small specialist providers that have somehow managed to survive to date will discover an even greater survival threat in the LHA Maxima Cap commissioning process.
- Councils as commissioners will become ever more parochial and insist that all services only accept in-area cases and not accept out-of-area cases as a support contract term and that will by definition deny specialist provision that typically sees perceived need only on a regional or national basis with for example acquired brain injury services as a better example than 1-legged Peruvian glue sniffers as a client group.
- I can give many examples that have happened such as one councillor stating in very forthright terms I am not having this service in my ward or my city about a support service for mentally disordered offenders that took those released from Rampton. The same will happen with more generic probation hostels and a whole host of other perceived NIMBY groups
- This literal NIMBY practice (Not In My Back Yard) will also be put in place to services such as domestic abuse refuges who by necessity take out-of-area cases due to safety reasons and if you think the tiny amount of male domestic abuses services will get funded then how’s the weather on Cloud Cuckoo Land?
What the LHA Maxima Cap policy like Supporting People before it share is the denial and non-consideration of capital funding. Existing specialist and accommodation-based services even to the very ‘deserving’ client groups came about years before the revenue funding of SP and its second incarnation in LHA Maxima Cap commissioning. As a result we see D/deaf services sporadically located in a few geographical areas with just one or a handful of services in a wider region such as the North West or the West Midlands and their residents may even originate from outside such regions never mind outside the specific local authority area in which it is located.
The Supporting People programme originally sought to protect such services and government created a public list of services of national importance yet that soon became meaningless as it was dropped. The LHA Maxima Cap policy has to date no detail whatsoever even on basic processes and commissioning and decommissioning never mind any protection for these services of national importance or any other conditions on the monies over and above the LHA level that will transfer to local authority commissioning pots.
The SP programme had a full three year lead-in period in the Transitional Housing Benefit Scheme (THBS) and that is universally regarded as being too short yet the LHA Maxima Cap policy has only a one year lead-in – which for dire want of a more professional term is the smelliest shit hitting the biggest fan you can imagine!
The LHA Maxima Cap policy and its unworkable LA commissioning process does not operate in a bubble but in the context of many other factors too. I posted earlier today about the DWP essentially forcing those with autism, learning difficulties and severe mental health conditions into supported employment. Yet if this fails, which it will, and even during its pilots if supported housing tenants refuse will they be sanctioned and put many such supported housing services at risk because the vulnerable resident with SEVERE mental health conditions loses their benefit? The mind shudders!
Given that the vast majority of disabled persons live in social housing – both general needs and supported – as their needs do not fit the private rented model, this one policy will also affect many in general needs social housing not just supported housing. So when and again not if many now general needs social housing tenants with disabilities such as SEVERE mental health conditions see their needs increase in severity that they need specialist supported housing such provision will not be there due to being decommissioned thanks to the LHA Maxima Cap policy of local councils know local needs best superficial bullshit that in reality is just blame deflection from central to local government.
Support providers are NOW whether rightly or wrongly in a moral sense but logically in business sense, are quietly refusing to take out-of-area cases as they are too much of a financial risk. Hence the post LHA Maxima Cap perversities are already having an effect today almost 18 months before the policy goes live. The Tories have not just managed to make general needs social housing increasingly asocial, they have made the most social form of social housing in supported housing increasingly asocial.
Unlike in general needs I can see why and fully support small specialist providers having to take in only in-area cases. The disaster that will happen when local council commissioners say we will only pay the LHA Maxima Cap top-up to those residents who originate locally and the provider must get the funding for out-of-area residents from their host local authority is a nightmare – and as there is no mandatory legal basis to pay for support this funding will never flow.
These are just some of the issues, a tiny proportion of the issues, that all supported housing providers face with the ideologically bankrupt LHA Maxima Cap policy and issues that all providers, large and small, need to be addressing now. All support providers need to have radically revisited business plans for post 2019 survival and those that bury their heads in the sand or postpone this urgent matter will not survive the farrago that is the LHA Maxima Cap.
I cannot press the URGENCY of this strongly enough and especially on supported housing provision that is NIMBY or ‘undeserving’ or who take out-of-area residents or who are small specialist providers. The lack of awareness of how urgent and how radically the LHA Maxima Cap affects existing support providers is stark and in large part excusable as all such providers are constantly tick-boxing and constantly jumping now to the ignorant LA commissioner tune and just don’t want to see the much greater threats and impositions and radical remodelling that is needed before this horrendously inept policy comes into operation.
As the old saying goes fail to prepare, prepare to (inevitably) fail .…!