National Assembly for Wales

Welcome, everyone, to this meeting of the Local Government and Housing Committee. Committee has received apologies from committee members Peter Fox and Lesley Griffiths. Natasha Asghar is attending as substitute for Peter Fox. The meeting is being held in a hybrid format. Public items of the meeting are being broadcast live on Senedd.tv and a Record of Proceedings will be published as usual. The meeting is bilingual and simultaneous translation is available. Are there any declarations of interest from committee members? No.

We will proceed to our second item on our agenda today, which is a further evidence session with regard to the Homelessness and Social Housing Allocation (Wales) Bill. And I'm very pleased to welcome, joining us here on-site, Cheryl Emery, head of community safety and community housing for Rhondda Cynon Taf County Borough Council; Martin Cooil, housing and prevention service manager with Flintshire County Council; David Walton, head of housing and communities for Newport City Council; and Laura Garvey-Cubbon, operational manager for partnerships and joint commissioning in Cardiff Council. And joining us virtually, Emily James, service manager for housing with Pembrokeshire County Council. Welcome to you all. Thanks for joining us, either virtually or here in our committee room this morning. 

Perhaps I might begin, then, with some initial questions before we turn to other committee members. Firstly, Welsh Government's assessment is that the current approach to homelessness is not sustainable. Is that a view that you would be in agreement with? Who would like to offer? Martin.

Do we need to press the buttons to speak?

No.

Fantastic. I think the current model is unsustainable. I think post COVID, we've continued to see really, really high levels of demand for homelessness and housing support services alongside social housing. We've got a really challenging private rental sector. Cost of living is really significant. Housing hardships within all communities are a challenge for local authorities and in most authorities we've seen numbers continue to rise. Some local authorities are seeing numbers in homeless accommodation coming down, which is really encouraging, but the challenges are really significant, that's for sure.

Yes, okay. Is everybody—all our witnesses—in general agreement with that view?

Just to add to what Martin has said, there is considerable pressure on local authority housing solution departments and we're also really struggling with the numbers in temporary accommodation, and particularly as a high percentage of those numbers in temporary accommodation are single people. And as we know, there is a significant lack of single-person accommodation in order to move those people on appropriately. And another challenge is just the complexities of clients within the system. So, there are considerable challenges that we are dealing with on the front line at the moment.

If I could just add to that point as well, just to build on something Martin touched upon. I think the level of pressure is caused by a multitude of factors that are often outside the control of local authority and potentially Welsh Government's remit, so if we think about things like the welfare benefits system, the cost of renting in the private rented sector. So, in Newport, for example, the last data I've seen suggested that rents in the private rented sector increased by 20 per cent over the last year. I think the point is that it's really multifaceted, complex things, with drivers in people's personal lives, but also the kind of the socioeconomic environment. So, there's not a silver bullet. It's incredibly complicated.

Yes, sure.

Just to pick up on the private rental sector—. Sorry, Laura. There are so many competing demands now on the private rental sector. Clearsprings are doing significant work to try and secure accommodation for asylum seekers on a contract with the Home Office. People want to be in the private sector, but can't afford to because—. Well, they want to buy, but can't afford to, so there's a kind of generation rent—that's still a very real thing. There are so many competing pressures at a time when, certainly in Flintshire, our availability and private rented sector has shrunk. So, we did some analysis last year with a consultancy and private rented sector availability had come down 60 per cent in a five-year period, and that's before agencies like Clearsprings were aggressively attacking the market, in the same way that we are. We're trying to aggressively attack the market, but we can't, and it just creates so many challenges. Sorry, Laura.

Just to add to everyone's points, yes, homelessness, the approach at the moment, isn't sustainable. However, we believe that more legislation and another homelessness Bill like this will make it even more unsustainable because the unintended consequences that the Bill might bring in is increased numbers into temporary accommodation and increased length of time in temporary accommodation as well.

In Cardiff we've got an unsustainable situation at the moment. Our temporary accommodation has increased by 56 per cent over a period of five years—that's 780 units of temporary accommodation—and our focus needs to be in resettling those families and those single people into affordable housing within Cardiff, and that should be our focus, really. It's affordable housing supply rather than more legislation in this area.

So, Laura, from what you've said already—witnesses here, collectively, this morning—obviously this particular legislation is not going to solve all of the problems, given the multifaceted nature of the issues. But what you're saying, Laura—. The question is: will it make a contribution to improving matters for homelessness and allocating social housing? But what you're saying, then, Laura, is that it might actually make things worse.

Yes, that's exactly our position in Cardiff. So, what we believe, in Cardiff and in other local authorities, is that we're already trying to achieve the aims and the principles that the Bill is attempting to bring in. And we absolutely agree with the principles and the ethos of the Bill. However, what we think will happen is it will encourage more people into a system that can't cope already. And what the Bill will do is reduce personal responsibility for people's housing circumstances and will push that balance towards the local authority by the removal of priority need, intentionality, and a reduction of the provision of unreasonable failure to co-operate. So, it will push more people into a system that already can't cope, and it will undermine the principles that the Bill is trying to achieve.

So, you'd rather the Bill didn't proceed, then, Laura.

Absolutely, that's our position. 

Does anybody else on this panel of witnesses agree with that point?

I think what Laura has raised is really relevant. We are in a system that is already challenging. However, from an RCT council perspective, we do welcome the opportunity to work alongside the prevention aspect. The earlier that we can intervene and help people is really, really welcomed. And that aspect, as I said, is something that we would totally support. However, as Laura has said, other aspects will possibly increase the amount of people already coming into an overcrowded system when we don't have housing supply to meet that need. So, that is a real challenge.

I see.

Just to add, from a Newport perspective, I think, very similar to Cheryl and Laura, actually, there are elements of the Bill, whether it's prevention, whether it's the 'ask and act'—if that can be defined really tightly, with sufficient thought as to what the principles for enforcement are, where agencies aren't working with us, then that could really, really help.

I think some of the other aspects, particularly around the removal of intentionality and priority need, could really increase the pressure on our system. And similarly to Cardiff, homelessness in Newport is—. The pressure is significant. Last year we did see a reduction, of about 40 per cent, of families in temporary accommodation, but we saw a corresponding increase by about the same percentage of single people. Unless we can find a sustainable flow of housing supply to meet that demand, I can't see any other scenario than people spending longer in unsuitable, temporary accommodation, and being unable to move on with their lives and being able to move away from homelessness.

Okay, thanks for that. Let me just bring in Emily online before I bring in Lee Waters. Emily.

Thank you Chair. Yes, from Pembrokeshire's perspective, we do welcome the Bill. I completely agree with what Laura is saying around the unintended consequences of the Bill, but, from our perspective, homelessness is not everybody's issue at the moment, and with the new legislation and the new duties on public bodies, we feel that that is changing the entire view and how we approach the prevention of homelessness. So, that aspect of the Bill is really important for us.

If I could just touch on what my colleagues have said about the private rented sector, we’re still dealing with the unintended consequences of the Renting Homes (Wales) Act 2016 implementation. That was a piece of legislation that was brought in post COVID, but it was actually written prior to COVID. And we are dealing with the ongoing issues there, in terms of the security of tenure in temporary accommodation, and we would still like an outcome around that, because we were advised that that would be considered.

We lost a number of landlords within the private rented sector in Pembrokeshire as a result of that, which has again increased the pressure on the affordability within that part of the sector. We have used Welsh Government funding through the private rented sector leasing scheme to try and fill some of that gap. But we aren’t able to meet that demand, and, as Martin has said, there are lots of other aspects now—people all trying to get into the same type of property. So, the challenges are that supply issue, but the challenges are also around providing appropriate accommodation for people to move on to.

Cheryl touched on the complexities that we have of customers who are in temporary accommodation, or who we’re working with to try and prevent homelessness. And in order to do that, we really do need the level of funding to come with that, to provide appropriate supported accommodation, or wraparound support services to make that a success. Otherwise, there will be repeated homelessness presentations, and it will not be rare, brief and unrecurring, which is the whole ethos and desire of Welsh Government with the legislation.

So, we do welcome the principles of it—absolutely—and that’s where we want to work to. And I would say most local authorities have already adopted many of those principles already, and are working to that six months, for example, rather than the 56-day prevention period. We really welcome that level of prevention input. But those new public body duties are so crucial to making this a success.

Okay, thanks very much, Emily. Yes, Martin.

If I could just give Flintshire’s position. Whilst acknowledging everyone else’s points, which are all really valid, we're possibly a little bit warmer towards the legislation in Flintshire—less concerned about intentionality and priority need, which we may well come on to later.

Yes. 

But every local authority is different, and I think this is what’s really important, that the impact of the legislation, which is all-Wales, will be felt 22 different times over, based on the culture of organisations, the spirit of partnership within existing infrastructure and organisations, and supply. Everything comes back down to supply. I think the legislation will be positive over time, but it’s going to be really difficult, and it’s great that we can inform the fine-tuning of it in this process now. But it’s not just legislation, it’s everything that goes alongside the supply issue, the collaboration within public and third sector, and that move to the rapid rehousing model, which I think every local authority has made real progress on.

Some have seen the start of turning the tanker in terms of the emergency accommodation pressures. Others can see that road map. So, I completely understand the instability within service delivery that a whole shift in legislation brings, but, for me, the most important part is, as Emily said, the partnership working, and, as David said, the 'ask and act', and how that is going to work, and what the levers are that we pull on when collaboration isn’t there. Services don’t want to not collaborate, but they haven’t got the resources either. Social care haven’t got the funding that they need to be able to support us with complex people, but I’m sure that we’ll come on to that later.

I'm really, really sorry, can I just make one more point?

Sure, go on, David. 

Sorry. I think we’ve already spoken a lot about supply, but I think within the context of the Bill—and this would need to be worked through—it’s really important that you understand how those judgments are going to be made. I think the point Martin made around every local authority being different is really important, both in terms of the authority, but in terms of our local housing markets. In Newport, for example, we’re, if not the fastest, probably one of the fastest growing cities in Wales. We’re also a non-stock holding authority, so, actually, we have really positive relationships with our local registered social landlords. But it makes kind of fine-tuning that judgment really difficult, even within our local market. And as we’ve already touched upon, there are real pressure points with different types of accommodation.

I don’t have any answers to this, but it’s an incredibly difficult judgment as to when, for example, priority need or intentionality will be removed, and how that judgment can be made against housing supply across Wales. And that’s going to be an incredibly complex task, and a very difficult judgment to make, I think.

And just to add, on that point, the partnerships issue that other local authority colleagues are raising, we've developed a fantastic multidisciplinary team in Cardiff. We protect the most vulnerable because we have excellent partnership relationships with other agencies, statutory and non-statutory. We believe that you can achieve the policy aims of this Bill by good partnership working and policy within your local area. To go to Martin's point, we don't need legislation that's national. What the legislation will not allow us to do is to make local policies that work for local authority areas, and that's our real concern.

You think that the policy aims can be better achieved without the Bill. 

Absolutely. 

Okay. Lee.

I just want to follow up on that. The majority of local authorities are saying that they support the principle, but there are some real concerns about the practicality of implementing it, given the very challenging situation you face currently. So, that's a question of how it's done, the timescale in which it's done and the resources available. Cardiff's position seems to be different. Even though you say that you're already implementing the principle of the approach, you actually have some in-principle ideological objections to it. You said that you were very concerned about the erosion of personal responsibility. Can you say some more about that?

Yes, of course. On intentionality, as a principle, we don't actually apply intentionality decisions. We haven't made anyone intentionally homeless in the last one or two years. However, it acts as a vehicle to encourage less poor behaviour within the private rental sector. We see families and single people coming in to us and saying, 'I'm desperate for social housing. I want to give the keys back to my landlord. I want to not pay my rent deliberately', so that they can come in to the homelessness system and gain social housing. What the intentionality clause allows us to do is to discourage that behaviour by its very principle being in the Bill. By taking that away, it sends a message out to the public that, no matter your behaviour in the private rental sector, you can come into temporary accommodation and be housed. We don't apply it, because it's not in line with our principles in Cardiff, but the existence of it there allows the vehicle for us to make sure that people don't behave poorly in a private rental just to game the system to get into social housing. 

But does the Bill do that? Because the Bill's going to replace it with a deliberate manipulation test. 

It's not enough. It's a confusing message to send to people that you won't get social housing if you come into temporary accommodation. The deliberate manipulation test is after the fact. So, people could behave poorly in private rented accommodation—they could not pay rent, things like that—get a poor tenancy history, come in to temporary accommodation and then the only thing available to them is private rented accommodation. And it's very difficult to house someone back into accommodation who has behaved poorly and has got that poor tenancy history. 

When you say 'behaved poorly', that's a very loaded term, isn't it? The evidence that we had last week from some of the charities who work with people who are vulnerable is that we say that we support a trauma-informed system, and yet we have this rather blunt tool, which as you say is seldom used, but it is a threat to somebody. It's saying, 'We're going to deliberately make you homeless. We think that you're behaving badly', as you said, but we have a tool as the state to say, 'We are not going to house you and we're not going to co-operate with you', which is a very draconian step, which, as you say, is very seldom used. Clearly, these are very complex cases, and people are complex, for sure. But if we are trying to get to a trauma-informed system, do you think it's really appropriate that you have this tool, which you've just described yourself as holding over people to try to influence their choices? Do you think that, in a trauma-informed approach, that's an appropriate thing for the state to be able to do?

In a small minority of cases, it is appropriate. We're not blaming people at all for their behaviour. We recognise that the housing market is broken. It's very challenging to find affordable private rented accommodation. So, the very small minority of people who come into the system in the hope of getting social housing at the end of it, you can understand that. However, there needs to be a vehicle that stops that behaviour of people coming into temporary accommodation because they wish to get social housing. 

But you said yourself that it's a small minority of people. Based on your judgment, should we be basing a whole system to try to stop the manipulation of a tiny number, whereas, in fact, its overall impact would be a good one?

In terms of the overall impact to us in Cardiff, we don't make any intentionality decisions now, but what it would do to the public perception is a greater emphasis here.

Well, except it depends how this deliberate manipulation test works in practice, doesn't it?

The deliberate manipulation test will be after the fact and it's around social housing, rather than coming into a homelessness system.

Okay. The representative from Pembrokeshire wants to come in, Chair. 

Emily, yes. 

I don't think it's the draconian element of it; I think it's the ability for us to be able to engage with those customers. So, when you're having those conversations about intentionality, it only comes at the very end stages of the current legislation anyway. We're already not applying it, as Laura has referred to. When you look at the statistics across Wales, they're very low in number, but it is about having that ability to have those conversations with the customer, do that prevention work and engage with them. Because if you have a system that doesn't allow for changing behaviour and buy-in to change that behaviour, then it leaves us in a situation where, as Laura said, the reliance on the social housing sector is going to be there to pick that up.

If I can give you an example: if you're consistently not paying your rent, what will happen is that you will come back into the system, you will continue to not pay rent, and we'll still have to keep accommodating you. I appreciate the deliberate manipulation test is there, but as Laura said, it's the timing of that test and how it refers to the entire housing sector. By only looking at people's circumstances on the social housing register—as they currently are today, not at previous behaviour and previous trauma, as you said, and how we can look to intervene and support in the most appropriate way—you're not going to see a huge change in behaviour. We're not able, as local authorities, to get that level of engagement either, so it's that tool that comes with it. It's not a case of trying to go in with a draconian tool and resource to local authorities—it's a case of that engagement. That's how I would look at it and how we perceive that from a Pembrokeshire perspective.

Social housing is already under massive pressure. We need to be making sure that we're utilising that and making sure that people's homelessness journeys are rare, brief and non-recurring. And if that test isn't there, I think we need to really monitor how that is impacting on the sector in terms of rents, in terms of behaviour, as you said—there are significant antisocial behaviour cases that most local authorities and RSLs would be able to give you examples of—but we need to be able to go in and manage that in a really productive and proactive way.

So, can I just check: you said, again, that you supported the principle of the Bill, but in this regard you don't support the principle of the Bill.

Personally, I'm on the fence with this one. I was part of the expert review panel, I can see where the third sector agencies are coming in here and the lived experience, and I think we need to understand that more. But, yes, we would say that the intentionality test really does need to remain. Just as we're working through the Bill—I know it's about the timing of that implementation—I think we really need to give more thought to the unintended consequences of that, and how we look at whether the removal of that, and the timing of the manipulation test—. It's making sure that we do a bit more work on that really, so that at least local authorities are not left holding hundreds of thousands of pounds worth of rent arrears, for example, because that's also not fair on us as local authorities to be picking that up.

Sorry, can I just clarify? I'm not entirely clear on what you're saying. Are you saying that your concerns are about the practicalities of implementing this and the options it gives hard-pressed local authorities to use, or are you saying, as Laura said, that as a matter of principle, you think that it's eroding the personal responsibility that people have as citizens? They're two different things.

A bit of both, to be honest, and I think that's why—

So, you're not in favour of the principle, then, are you? I wish you'd say that you're not in favour of the principle if you're not.

I do agree with the principle. I think it's just how you work through that principle and how that is going to be—

Well, forgive me, but I just asked you that and you said 'a bit of both', so which is it? Do you think it's just not practical, or do you think it's wrong in principle?

It's not practical at the moment is what I'm saying.

Okay. But Cardiff thinks it's wrong in principle. And the others?

I think it probably just needs a little bit more thought in terms of implementation. As we say, none of us want to make anybody intentionally homeless, but there are challenges within the system around some cases that we work with. If we are keeping the statement of applicants who deliberately and unreasonably refuse to co-operate, it will require very strong guidance for local authorities in understanding what that means.

That's the implementation, isn't it? And that's fair enough.

If we do remove it, there has to be some way of being able to work with clients or applicants who contact us who may be deliberately manipulating the system in order to get social housing, and I think sometimes that is a very real thing.

I think from the Newport perspective, very similar to everything that's been said, I think it's the unintended consequences that really need to be thought through. The reality is that when we're considering intentionality, we have to have regard for someone's personal circumstances. Certainly in Newport, and with all of the colleagues on the panel today, if someone is vulnerable and those vulnerabilities have led them down the path of those decisions, legally that decision wouldn't stand up anyway. We couldn't make that decision. I think the problem we have with moving to a deliberate manipulation test focused on access to social housing is that there's a huge risk that we end up with more people in temporary accommodation for longer.

This is the point Laura made. If the private rented sector, for example, is the only tenure you're going to be able to access because you've deliberately manipulated the system, then people are stuck, and the reality of life in temporary accommodation is that it's incredibly difficult for people. Rents can often be high because of the short-term nature of the accommodation. People can need to move at short notice, and people can often be sharing facilities, and that can have an impact on lots of different areas of someone's life. So, I think there's a real risk that there's an unintended consequence that the experience of homelessness almost becomes a little bit more traumatic because of that.

Forgive me, Martin; I'll just move on, and you can address this in the other points if you wish. In terms of the issue of removing priority need, the Government tells us that most local authorities have already done this, that in practice they're not making that distinction, and the Bill removes it. Do you have concerns about that? Do you think that's a sensible thing?

On priority need, the number of not-priority-need decisions that we make as a local authority is really small, maybe 2 per cent, and that's just our interpretation and application of it. For Flintshire, I don't see this as a massive issue; other local authorities may. I think we're in a good place to be able to respond positively. We often say in the office that we're working priority need blind anyway in our interpretation—

So you don't think it'll make much difference. 

No, but I do think that alongside priority need and intentionality, there needs to be some real clear comms messaging to the population and to partner agencies and communities, so that we don't unintentionally create homelessness as a pathway into social housing, which I think is one of the big risks. So, we have to be really clear that, yes, intentionality, trauma-informed, it's quite judgmental, it can be applied inconsistently. They're my concerns about intentionality, so I support and Flintshire supports the removal of it. And priority need-wise, our preparedness for getting there, we think we're in a strongish position.

Does anybody take a different position on priority need? 

I think from a Newport perspective, we've got real concerns. Rough-sleeping was made a priority in 2022, and clearly that's something to be welcomed, but if we just look at our year-end snapshot of single people in temporary accommodation, that's increased by 238. Our concerns are that that demand rises further, and we just, at this stage, don't have the stock to meet that demand in terms of good-quality affordable social housing or housing in the private rented sector. To set that in context, our local housing market assessment—the data the Welsh Government called for—was in 2022-23, I think. That predicted a shortfall in supply of about 711 one-bed flats over the next five years, or one-bed properties over the next five years. So, for us, it's that supply issue. In an ideal world, if we had supply to meet demand, it could work brilliantly, but it's how that judgment is made around supply being sufficient to cope with additional demand into the system, and that's a really difficult judgment—

But should we be designing a system based on being driven by practical considerations, rather than designing a system that, in principle, is the right approach and then working, after the fact, to make the practicalities fit it, not the other way around, which is what you seem to be suggesting?

I think we need to look at the system as a whole, so to really understand the other drivers. You know, at the moment, there's the renting homes Act that we're still working through. There are huge amounts of work going on to develop more housing, so I suppose, from our perspective, we've got real concerns around the abolition of priority need, but then it becomes the practical point around how you make that judgment to remove it and how you forecast any increase in demand to be able to actually, effectively support people and to improve their lives.

The representative from Pembrokeshire has been trying to come in.

Yes, Emily.

Thank you for that. I just want to lead on a bit from what David referred to there. I'm in support of the priority need test being removed. We're already applying that. We saw the increase in customers coming in as a result of that during COVID, and we've continued to work with that. But I would agree that it comes down to the resources and funding that come with that, because there is going to be a greater demand for temporary accommodation whilst the other local authorities work through that and the additional all-Wales local connection tests. So, for me, it's about making sure that we recognise there's going to be a bubble whilst we work through the supply issue.

Social housing in itself is under pressure on its own. We are a stock-holding local authority. We are working through the ambitions of the Welsh Government around Welsh housing quality standard 2, the decarbonisation agenda, the damp, mould and condensation work. We've got to do an awful lot of work to our existing stock, which often requires us to decant customers and move them around, which is putting even more pressure onto the system so that there is less availability, which means we are more reliant on forms of temporary accommodation. In itself, temporary accommodation isn't suitable, because, as our colleagues have said, it's about the support that comes into those temporary accommodation units. We need a better supply of supported accommodation. We need that level of investment, really, from the Welsh Government to achieve this, because there will be increased pressures even though local authorities aren't all applying the priority need test.

Okay. Thank you. Laura.

Just to come in on your point of should we design a system for what we really want, or should we look at practical things in the system, what we see here is one part of the puzzle. So, homelessness legislation is one part of a very big housing puzzle, and what we think this might do is increase demand in a system where you don't have the levers that would really, really make an impact in people's lives, which are an increase in local housing allowance—that is one of the biggest things that could make a real difference—and that increase in housing supply. Those two things will make the biggest impact in people's lives and people being able to not come into the homelessness system. It's not further legislation, we don't think.

Sure, that's a very strong point, and I completely agree with it, but isn't this a slightly different point? You're saying, 'If we had more supply and more options, we could serve more people.' Absolutely. This is about the principle of should authorities make a distinction between somebody who they say is a priority and those who are not, because the evidence we had last time was that this, in fact, doesn't work in the way that common sense would assume it works. It's a tick-box exercise, we were told. It's an arbitrary judgment. You're either in priority or you're not priority. It's not, 'Do you have a need?' It's a rather crude approach was the evidence we had last time. So, even if the supply problems were solved, this would still be a rather blunt instrument for deciding who should be helped is the argument. I just wonder if you have a response to that.

We make a handful of non-priority need decisions in Cardiff. It really is a small number, less than 1 per cent, I would say. I wouldn’t say that it’s a blunt instrument; I think a lot goes into the real consideration of someone’s vulnerability. What the priority needs provision allows us to do is prioritise scarce resource for the people who need it most. If the housing supply issue was solved, then, yes, we would be able to help as many people as possible on a prevention duty. So, this is our real approach in Cardiff, in that we don't think that more single people should come into temporary accommodation, and that's what the priority needs abolition will do. If the housing issue was solved and we had enough supply, enough affordable housing for people, we could house them when they're threatened with homelessness, and that really should be our focus: improving housing supply and the issues with local housing allowance.

Isn't the theme of your position that you are taking a rationing approach, a defensive approach of, 'Here is our limited resource; we've got to protect it', which I understand, rather than, 'This is legislation to design an approach to homelessness prevention.' Isn't the danger in your approach that you're designing it from the wrong end of the telescope?

So, in Cardiff, over the last two years we've moved into a prevention-first approach. We already apply the six months instead of the 56 days. We put in a lot of resource in terms of prevention. But what we've found is that no matter how much resource you put into prevention, our levels are around 80 per cent and they've remained at 80 per cent, because there are still people who, no matter how much resource you give, no matter how early you identify them, there isn't the private rented accommodation to solve their housing issue and they have to come into temporary accommodation. So, we're absolutely for the principles of prevention and protecting the most vulnerable, but we are concerned that the abolition of priority need in conjunction with intentionality will mean that more people come into a system that currently can't cope for the next 10, 20, 30 years.

Okay. That's clear. Thank you.

We're going to have to move on, Lee.

Yes. I was just going to briefly ask about the local connection test. If it's possible to answer this briefly—apologies. Removing the local connection test to create a new local connection to Wales test, does anybody have any problems with that?

I think that's really positive; there are no issues there at all.

Okay, fine. Does anybody disagree? No. Everybody thinks that's positive. Okay. Thank you very much.

Okay. Thanks, Lee. Just before we move on to other committee members, is there anything any of you would like to say in terms of being a bit more specific about some of the issues you've identified as hugely important in this overall picture—for example, housing supply, the timing of some of the provisions? Would any of you like to offer a specific view as to what should happen on those fronts?

Finance is a huge risk in terms of additional contact points with residents, which we all support through the prevention, support and accommodation plans. That's going to take front-line staff time. We're all anticipating increases in presentations, so that needs resourcing. There are challenges around how we do that because statutory posts need to be council funded as opposed to through housing support grant. So, we'd welcome some flexibility whilst protecting the spirit of housing support grant—some flexibility around how we use that grant and how we are supported as local authorities through the transitional period.

With previous legislation, on implementation, there was transitional funding; we need some transitional funding for this. I think a lot of it is, for me, around that messaging on intentionality, priority needs, implementation, making sure that all public services have a clear understanding of what their duties are and how they support us. Public duty isn't just pointing someone to the local homeless team and crack on; it is actually keeping people away from the local homeless team. Resource wise, we're going to have to spend a lot of time and money implementing a cultural shift within our partners and that's going to take lots of engagement. So, implementation needs to be resourced.

Yes. I think we would all support that, Martin. Also, our IT systems are completely out of date and would, obviously, need to be looked at in terms of new models. So, like everything, funding is quite a big aspect of this new Bill as well, and particularly around, as you said, additional staffing resources, if required.

Yes. Is everybody—? Emily.

Thank you. Yes, I've written a few things down there, Chair. For me, as my colleagues have already raised, on the housing support grant and the funding that goes into that, from a Pembrokeshire perspective, we've been a bit of a poor relation in terms of the housing support grant. We were advised that the formula would be reviewed yet again, and each time there's been a slight increase to that, which we really welcome, we're already at a detriment because of that current formula, which means that we don't have some of those resources available to us to meet some of the reasonable steps required in the current legislation, let alone in the future legislation. So, for me, the housing support grant, the funding, the implementation and the transitional funding that comes with the Bill are really crucial, as Martin and Cheryl have referred to. But I think it goes a little bit wider than that. You're going to be looking at additional review periods, additional reviews in terms of the PSAPs, but also the ongoing support and that 12 months after, which I completely agree with, but, in the current resources that we have within homelessness services, we're not going to be able to meet that demand.

I know, within the additional document, there were some costings put down there in terms of the impact of the legislation, and I think one of the elements in there was that it takes three and a half hours to do a review. It doesn't take three and a half hours to do a review; I would say that takes at least a whole day, if you're going to do it and do it justice.

On the IT element that Cheryl refers to, we also need to be really making sure that we're capturing the right data coming out of that, particularly around the prevention work. If we're asking public bodies to take on that additional 'ask and act' aspect, we need to be capturing that prevention work on a much wider scale, not just in the homelessness teams or the housing support grant services.

Can I just add to the point—? Sorry, Martin—I keep doing that. Just to add to the point around funding, Emily has really clearly explained what we think some of the issues are around the costings. But I think there's a wider point that, actually, because of the rise in demand for temporary accommodation, local authorities—certainly Newport and, I know, elsewhere—have invested significantly in the homelessness services, increasing the budgets available to us. I think that really does need to be taken into account as the costings are looked at, and as that transitional funding, the new burdens funding, is developed, to recognise that, actually, we are in a system that is unsustainable in terms of human need currently, but also unsustainable financially in many ways.

A key prism that I think that needs to be viewed through is the fact that the housing benefit subsidy arrangements for temporary accommodation mean that local authorities cannot recover the full cost of providing that accommodation. So, we have a statutory duty to provide the temporary accommodation, but we can't recover that full cost from housing benefit. For context, the amounts that we can recover are set at the 2011 LHA rent rates, or even 90 per cent of the 2011 LHA rates. So, I think there's a real need to really delve into those costings, and I think they're probably going to be significantly higher than those set out in the regulatory impact assessment guidance notes.

Okay. Martin.

We, obviously, talk a lot about prevention, and that's core to the Bill and core to the culture of everything that we do. Laura was talking about the prevention unit and the approach there in Cardiff. From Flintshire's perspective, when we look at our homelessness presentations, 40 per cent of our homeless presentations are from people who are 'homeless on the day'. There isn't much prevention going on there. There's some mediation and there are some reconciliation services where we will try and mediate with family, friends. When we look at the percentage of 'homeless in 72 hours', so three days, it's 56 per cent, and that's been pretty consistent for the last six months, since we've really been digging into the data. The reason I raise it is because, obviously, a lot of our services are around prevention, but the pace of presentations and the nature of the reasons why people become homeless are a significant challenge to some of our prevention services.

We're just about to do some analysis on some of our 40 per cent, digging into people's circumstances to try and work out, 'Are you a repeat visitor for homeless services? Have we known about you before as a homelessness department? How could we have pushed messages in a different way?' And then, most importantly, and this takes us back to the partnership element and public sector organisations' duties, we want to know how many of those residents in that 40 per cent were known to other public sector services, and did those public sector services know something was rumbling at home. Sometimes it'll just be life: the marriage breaks down, the relationship sours—fine. That's fine. Or is it that there's a young person, 19-years-old, been known to social services before, tensions at home, something's been rumbling, and someone within my own organisation, the council, knew about that—what were they doing? And I think that's where the real power of the public sector duties will come to light. Because, actually, as a homelessness service, we can't do it on our own; it's everyone's business. We need homelessness to be the new safeguarding, the new Welsh language duties, health and safety, so that everyone knows what their role is in terms of homelessness prevention. 

Sorry, can I just add one point to Martin's around the wider public sector duty? I understand the practicalities and the reason for this, but I do think it's a weakness that education and primary care aren't included as relevant public bodies. We need to think through who the trusted people are. It's a tiny pilot in one primary school in Newport, which has only been running for six to nine months, but we've actually got one of our—. Maindee Primary School receive some funding so staff can go out and do welfare checks and understand where people are living in inappropriate accommodation, or indeed are threatened with homelessness, and the power of that is that as a school or as primary care, they are trusted individuals. I think people are probably more likely to share that they're worried about their housing with their child's class teacher than their social worker, just because of the difference in relationship. 

Absolutely, just to add on to David's point there, in Cardiff, we've got a service called Upstream Cymru, which is run by Llamau, which is a really innovative approach to homelessness prevention, where you survey entire secondary schools in terms of their relationships at home, and it picks out all the risk factors, really, in terms of someone presenting as homeless in two, three years. That's a really innovative approach to homeless prevention, that we're not just talking about six months, this is years down the line and getting in early. And that's not about housing supply, it's about relationships, it's about making sure the right agencies are involved in families' lives, to stabilise them, and to repair those relationships. So, yes, really important.

Okay, thank you very much. We'll move on to Siân Gwenllian. Siân, we've covered a lot of ground in terms of prevention, but we haven't mentioned prisons yet. So, I wonder if you could deal with that, and then possibly move on to partnership working.

Sorry, can I come in and try and answer this one?

Yes, Cheryl.

In RCT, we've had a very successful partnership with Crisis, which is a national homelessness charity, and we've been doing some work around offenders through this particular project. It's called Built for Zero. And we've had, I have to say, significant success in reducing the number of offenders that are presenting as homeless through, again, significant partnership work with all of the local prisons, with our local probation service. We also have a dedicated offender pathway, and we've had some real success in getting our offender numbers down, because they were, at one point, the main reason for homelessness in RCT. I have to say, we've obviously fed in some of our work to some of the task and finish groups that have been held by Welsh Government colleagues, and I have to say, we've had some great success in working with offenders. But, again, it's that word that keeps coming up: it's partnership.

Would anybody else like to offer anything on the prison point?

So, in Cardiff, this will affect us quite significantly. We have a prison of around 800 people. What I think we're concerned about is a prison's ability to refer all those prisoners at the right time to us, to make that prevention work really meaningful. We still get applications on the day sometimes of someone's release, despite, you know, the prisons should be telling us 56 days in advance. I think it's a real concern, the practicalities of that: will that actually make a difference on the ground?

And Cheryl. Sorry, Emily. Sorry. Sorry, Cheryl, you've already offered a view on this subject. Emily.

Thank you. I think we just need to flag that not all of the prisons are in Wales. So, we need to be mindful of that, and make sure that there's a really strong memorandum of understanding in place with HM Prison and Probation Service, so that the English prisons do have some level of buy-in, because obviously they're working to slightly different legislation within England. So, that's an aspect we need to make sure that we're giving a bit more thought to.

But I think, as Cheryl has said, it's around the timing and that prevention, making sure that we're given the right resources, the right partnership working, early enough. We work very closely with our colleagues already. We don't have a prison in Pembrokeshire, but we work very, very closely with our colleagues in probation services to look at who's coming out to be released. So, the impact of having those conversations at an earlier stage is really important, but it's about making sure that it happens in practice, because we've had the prisoner pathway in place for quite a long time now with the current legislation, and as colleagues have said, it's not always working and it's not always being followed. So, we need to make sure that we're really working consistently to that approach.

I think the approved premises are also a little bit of a concern for us, purely because of the supply, and sometimes cases involving multi-agency public protection arrangements in particular need that level of step-down to go into some of the approved premises, prior to coming back out into the community, because of the planning required around that in terms of community safety, appropriate support services and appropriate types of accommodation, and it comes back down to that supply issue.

Okay, Emily, thanks very much. David.

I'd echo everything that colleagues have said. Similarly, we're doing everything we can to get upstream conference calls into prisons. I suppose it's just one distinct point I'd make: it’s just through the implementation, and as things develop, ensuring that we've got an eye to the pressures within the prison system, and things like potential early release schemes, just to ensure that alignment, so we're not caught in a situation where we're unable to effectively prevent because of those drivers of demand. 

Martin. 

Going back to the 56-day notification point, I think this really highlights a significant challenge for us all in terms of implementation. We know what the reference points are, the time frames. When it doesn't happen, what's the consequence? Where's the accountability? All roads lead to homelessness services being the end destination, so if things on that track to get to the homelessness service go slightly out of sync, off track, the challenge sits with the homelessness service. So, I think consistency and accountability within the new legislation, and how is Welsh Government and how is this committee in years to come going to know that what we all intended is actually being delivered? Yes, you can have outcomes. Yes, you can have data. There's loads of great stuff that's happening through sub-groups of the ending homelessness national advisory board that I sit on, so I know there's great stuff. But, actually, how do you know the spirit of the Act is being implemented and interpreted? So, that kind of leads us to training and consistency and monitoring that isn't just numbers; it's qualitative as well as quantitative.

One final point, and it goes back to Emily mentioning APs, approved premises, because my ears picked up then. It's really scary that we have people with significant risks, significant vulnerabilities, who are being refused by APs. They still have homeless duties that are owed to them, but they're too high risk, too dangerous, too complex to go in part of the semi-secure estate. And they just come to the homeless service, so we'll manage that risk. That's really frightening. When we talk about trauma-informed, person-centred ways of working, us as leaders within our organisations have to be person-centred, trauma-informed with our workforce, because they are working under immense challenges and significant strain. They're doing it with a smile on their faces because they're bloody brilliant, but when you hear in the office that we have someone coming out and he's been refused from AP because of his risk, staff just think, 'We're just being dumped on here.' I think that really is a significant risk, a very specific bit, but something that I couldn't not raise. So, thank you, Emily, for pricking my ears up.

Okay. Siân. 

I'll start, if you like. I think there's already some really good partnership working in place. A bit like Cardiff, we also have a multidisciplinary health team, which is funded through health and the area planning board, so we use that team a lot to support some of our vulnerable clients. We also have great partnership working with our registered social landlords and lots of other organisations. I do think, though, the 'ask and act' aspect, again, requires some strong guidance, because whilst you can train the staff within organisations up to understand how to 'ask and act', people move on. So, it's just about how we continue to provide that continuation of service to all organisations, the training. I think a colleague has already mentioned that we are missing a trick by not having GPs and primary care as part of the 'ask and act' aspect as well. In terms of partnership, I think there's some great stuff already going on, I would suggest, isn't there?

Okay, would anybody like to add to that?

I think there is some really good stuff. I think sometimes complex case work, multidisciplinary team approaches can be the responding-to-a-crisis part of the job, and we are dead good at that in terms of services coming together in a crisis. So, someone is having a mental health episode, someone is kicked out and known to other services, can that service mediate to get them back in? I think it's the earlier intervention, like we said before, that's where we need to get the improvements in multidisciplinary work.

To go back to funding, the transitional period, there are limitations on what we can fund at the moment through the housing support grant. I would love a couple of social workers to be embedded, sat with us in our homelessness service. My colleagues in social services do not have that flex in their budget, and their case loads are significant, so they're not able to say, 'Go on then, there's two really good officers, you can have them.' Sometimes we're working with shared clients, sometimes we're not. Sometimes we're fighting to get our people into services where there are significant barriers, and the gateways and pathways are not there. So, if we had some flex in funding for HSG, because I can't fund social workers through that, through the creation of additional funding through transitional pots, which we could use as a 'whatever it bloody takes' pot, that would be really, really welcomed, because there are structural challenges around finance, not just to do with there isn't enough money, but actually grant conditions and how we use the funding.

Okay. Emily. 

Thank you, Chair. So, yes, I agree there are some really good pockets of excellent work going on across Wales, and I think that that probably isn't being recognised in full. But, for me, it's going back to this early identification, making sure that we're putting as much emphasis as possible on that. We can learn some lessons from our youth homelessness colleagues, who we work very closely with in Pembrokeshire. They're doing a lot of work on early identification, very similar to what Lauren was saying about that Upstream project, so that we're able to intervene at a much earlier stage collectively as partners. We need to make sure that there is consistency, but also flexibility in terms of each local authority will do things in a slightly different way, so not to be penalised that we're not necessarily following that consistent approach across Wales, because we all need to come at things slightly differently.

I think it's also really important—and I have put it in the response to you—that the legislation is reflected. I know that the Social Services and Well-being (Wales) Act 2014 is going to be amended, particularly around 16 and 17-year-olds, but any relevant legislation needs to be reflective of this new 'ask and act' part of the process, and the new public body duties. We need to make sure that all sorts of training that Wales has control over—so, social work development, things like that—really include all of this—nursing. Anything that is going on within that sector that we can make sure that that starts becoming the normal way of thinking would be really important. Homelessness officers have had to change over the years, and we're all being more trauma-informed et cetera, but I don't feel like there's a consistent approach around homelessness prevention in other areas.

Okay, Emily. Thanks very much.

GPs and schools as well, as David has mentioned before. And just to add, really, on the partnership element of this Bill, we have a very good multidisciplinary team in Cardiff. We're very lucky to have excellent relationships with our social services colleagues. We've got social workers embedded within those multidisciplinary teams, for young people as well as for adults, and this approach works. We really have got the right agencies involved and invested within homelessness in Cardiff. What we've done is we've got them because we've said the impact is for their organisations. We've got the Cardiff and Vale health inclusion service that sits within emergency units within Cardiff hospitals. We've got GPs going out to rough-sleepers, to our homeless hostels. We've done that by showing the benefits to health in terms of budget reductions, as well as more complex cases being dealt with in a better way. So, this approach absolutely works.

Okay. Thanks for that.

Sorry, I was just going to mention, we've similarly got the same service in RCT. I can't advocate enough that that is something that is invaluable in the way that we work within the homelessness service. We've got social workers; our relationship with our adult social care and children's services departments is through these particular workers. And I have to say, it works, doesn't it? It's a really excellent model.

Thanks very much.

I think the need to evidence cost-benefit—Laura, you picked up on that—that's how we get our partners to want to work with us, I guess. So, I'm interested, after the session, to learn what your cost-benefit model is, because it has to be a consistent one; I can't calculate it differently to other local authorities. But the logic's there, isn't it? The evidence will be there if we dig enough. The better the prevention work that we do, the more it saves prison services, police services, health services—common sense. But a consistent approach to that as well would be good.

Absolutely. Okay. Laura Anne Jones.

Diolch. Thank you, all. This has been a very useful session. I've just got some questions about allocations. Some of you have already touched on this next question of mine, but, if you've got anything else to add, that would be very useful. Thanks. We want to know whether the Bill strikes the right balance in its approach to social housing allocations, and also what your view is on the duty on registered social landlords to comply with a request from local authorities, and will that help local authorities. Diolch.

I can take that first, maybe.

Okay. David, yes.

I think—. So, as I said, Newport's a non-stockholding authority. So, we are really, really dependent on having positive relationships with our RSL partners. I'd say that, over the last 12 months, in terms of our approach to working with people in temporary accommodation, that's really developed. That's been quite a positive experience. It's been based very much on partnership work and trying to understand that we've got this pressure. But also, RSLs, if they're accepting a new contract holder, are thinking about the wider place, about ensuring that they're creating cohesive communities.

So, I think, in principle, the move to require RSLs to work more closely and, potentially, to accept nominations from us, for want of a better phrase, is positive. I just have concerns in terms of the ability to escalate issues to Welsh Government and the mechanics, and how that works within a framework of us actually needing to maintain—. In Newport, we have to maintain positive and focused relationships with RSLs, both in terms of a homelessness perspective, but also for our development programme.

So, I think, again—I've probably said this quite a lot—the devil will really be in the detail and understanding actually how it's implemented, and getting ourselves into a place on the ground where we're never escalating. I'm sure that's the thinking behind it, that escalation will happen in very, very rare circumstances. But I wonder whether a lot of those objectives can be achieved through ensuring that we've got the best partnerships possible—based on our experience in Newport anyway.

I guess it's similar to the existing duty to assist.

Yes.

It's in the legislation. Very rarely triggered, if at all, in the decade that we've been working with it—certainly, that's my experience. So, it's kind of there, it's something you might reference, but I wouldn't even know how to trigger.

Yes. Emily.

Thank you. So, for some context, we are a stockholding authority, and in terms of the—. We already operate a choice homes policy, which is a partnership policy. It already exists. But, for me, there's one thing having a consistent approach and having a joint housing register, but, to do justice to the homelessness prevention, you need to have a joint allocations policy, and that is the bit, for me, that's missing out of the proposals within the legislation. I would have preferred to have seen that that joint allocations policy was in there, because I think that might prevent some of the issues then being raised about getting RSLs to co-operate in terms of making those offers and being directed by local authorities. Because what we don't want to do—. We don't want the unintended consequence from the legislation to damage those relationships. They may well be quite fraught in some local areas, and you don't want to make that even worse. And what we don't want either is—. You know, what happens to that offer of accommodation whilst that request has gone in? Does that offer have to stay open? We also don't want the Ministers having huge amounts of referrals going into them and it being managed. So, again, as colleagues have said, it's the devil in the detail of the code of guidance, really, that I think needs to be strengthened. It's about making sure that you've got a tight partnership agreement within each of the local areas, and, again, really, for me, that one missing piece, which is that joint allocations policy.

I think just to support Emily, from an RCT—

One of the—

Oh, sorry.

Just a sec, Laura. Yes, Cheryl, go on.

From an RCT perspective, for the last 10 years, we've had a common housing register and a common allocation policy. And I have to say, positively, I would never have had to contact anybody to say there was an issue, because the policy, as Emily has referred to, is there. You go to the person at the top of the list and who that best matches. So, yes, obviously I would totally support the need for a common allocation policy. I think it does away, as Emily has said, with all the other issues that might arise through this process. And, actually, our partnership is with 12 RSLs, so I think that advocates the positivity that we have in working with them.

Okay. Thanks for that. Laura.

Diolch. I have a few more questions, but I'm conscious of time. But one of the main aims of this Bill is to ensure that no young person leaving care has to present as homeless in order to access suitable accommodation. Do you think the Bill will achieve this aim, and what else needs to be in place? 

Again, for me, I think it's a very positive aspect of the Bill. In some ways, I'm not sure it goes far enough, because, despite the reference to reasonable preference within allocation policies, they are still competing with other people within some of the higher bands. So, it may be that it needs to be a reasonable preference plus, but that's just a personal view.

Would you be in general agreement with that, our other witnesses, that that needs to be the case, that there needs to be something additional?

Yes. In Cardiff, we give the highest possible priority to care leavers and young people moving through our supported accommodation process. However—and I don't know whether I'm reading the Bill incorrectly here—I'm concerned that that provision is local connection blind within the social housing allocations policy, in which case it would mean that any care leaver within Wales could present to our waiting list in Cardiff and get that high priority. So, that needs to be clarified, I think, within the Bill, because that would be of concern for Cardiff, being the capital city.

Diolch. What impact do you think the Bill will have on accessing social housing in Welsh-speaking communities, please? And are there any other changes you'd like to see to enable that? 

Okay. Anybody like to—? Emily.

Sorry, my response isn't around the Welsh language preference, it goes back to the 16 and 17-year-olds. I think, for me, this comes back to funding, again, because, if we haven't got appropriate supported accommodation available to young people, then that option is immediately going to be that they go into temporary accommodation. Because even though—. What I don't want to see is that, just because the accommodation isn't available, they then can't go into temporary accommodation either, because we need to ensure that they're accommodated. But we also need to work on some of the needs of some of the 16 and 17-year-olds. I've got a young lad now who's just transitioned from services. He's in the secure estate now; he's made threats to kill. You know, there are going to be some behaviours that, unfortunately, are not age related and that—. I'm not sure what accommodation will automatically work for certain pockets of customers.

So, it's, again, making sure that the funding is provided to us to make sure that we're making that a success, because, within our current resources, Laura, we're not able to meet that demand. So, I just want to make sure that that's clear. What I don't want is local authorities then getting—housing departments getting—into trouble because, 'Why have you got a 16 to 17-year-old in your temporary accommodation?' And if the response is, 'That's because we don't have supported accommodation,' I don't want us being penalised for that.

And, again, the local connection blind test, I think we need to be really careful here that—. There's preference within allocations policies, which I agree with—we've got it in ours for care leavers—but that is solely relying, then, on social housing, and social housing is not necessarily the only answer. It's about making sure that the right level of support and the wraparound agencies are available to that young person to make the success of that tenancy real for that person to prevent them coming back round the system, which often happens at the moment.

The local connection test, for me, was more about—. So, if I've got a young person from Pembrokeshire who's been placed in, say, Swansea, and they've been there for five or six years, well, they're going to want to stay in Swansea. I'm just giving that as an example. So, for me, that's where the allocations policy should be—. The test needs to be quite clear that, if they have a connection to another area because they've been placed there, then that's fine, that's where the local connection, potentially, can be then triggered in another local area. So, sorry, it wasn't to the Welsh language issue, but I just wanted to make those couple of points really clear.

Thanks, Emily. Would anybody like to address the Welsh language issue and whether there's anything additional that should be in the legislation regarding Welsh-speaking communities and access and allocations there? Not really?

No.

No. Okay. Well, thank you very much, Laura Anne. Natasha Ashgar.

Thank you so much, Chair. Good morning, everybody. The Bill gives local authorities a broad range of accommodation options for discharging the main housing duty, so do you feel that this will ultimately support local authorities and could there indeed be any unintended consequences?

I think the answer is 'yes' again—everything is welcome that is within the Bill, it's just that we come back to that terminology, 'supply'. It's just that there's not enough of anything, really, in terms of trying to meet what might be the high demand at that time. But, yes, I don't think there's any significant concern in relation to that, is there?

It's the devil's in the detail, isn't it, again.

It is. And also, options like supported lodgings, my only concern would be just the scalability. Actually, are they going to make—? I would be surprised, if I'm honest, if they're going to make a fundamental dent in the supply issue. It's going to be quite a specific, bespoke offer for individuals.

With this issue, I would really like to see the list of those accommodation options including supported accommodation. Supported accommodation can sometimes be the best place for someone for a number of years because it allows that wraparound support to be provided to the person in situ. And I know that's not quite in line with rapid rehousing, but supported accommodation, for some people, is absolutely the right place for them to be. And what this will mean is that we would have to review that person's circumstances through the prevention, support and accommodation plans every eight weeks while they're in that accommodation. The best person to support people while they're in supported accommodation is their support worker on site; it's not necessarily the local authority. So, I would want to see the list of what we can discharge into including supported accommodation.

Okay.

Thank you so much.

Anybody got anything to add on this matter? No.

Sorry. The supported housing 12-month discharge, obviously, what we don't want is the system to inadvertently create some bedblocking within supported housing. Because someone might just need six to nine months in supported housing and then they're ready to move on. So, that was going to be the point of the devil's in the detail.

Yes, okay. Okay. Well, we've just about reached—in fact, we have reached—the end of our allotted time. Sorry, Lee.

Sorry, can I ask a final question? It strikes me that quite a lot of the answers were about the importance that guidance is going to play in how this is done in detail. We all know all parts of the system are struggling with capacity and, in parts, capability. Are you confident that the Welsh Government has the ability, the heft, the bandwidth—whatever metaphor you want to use—to be able to carry forward the changes that, operationally, are going to make these changes effective?

It all comes back to funding—

No, it doesn't.

—and to areas of responsibility.

No, it doesn't. It's not about funding, it's about whether the civil service in the Welsh Government able to do—? Cheryl is smiling, she understands my question.

I think I'm going to say 'yes'. I know that, in Wales, we work very closely with Welsh Government colleagues, and they're always ready to listen. Some aspects of the Bill, obviously, we're not always in agreement with, but I think, overall, they will consult. And as long as there is that will to come and speak to front-line people who know about service delivery, who know what some of the issues are, I think the answer would be, for me, 'yes', as long as that consultation and speaking to us happens.

Okay. Does anyone take a different view?

I agree with Cheryl. I suppose the only point to make is that there are elements, with regard to the Renting Homes (Wales) Act 2016, where we're still working through the implications of that legislation. We can't lose sight of that—

That hasn't built confidence amongst local government. Is that fair to say?

I think we've got to hold both pieces of work, simultaneously, if the system is going to be improved for the clients coming through it.

Okay, I think Laura is wearing her very best poker face. Is there anything you'd like to add, Laura?

We were pleased to see, with the consultation that happened on the Bill, that parts of it was scaled back. So, that shows that we are working in partnership with Welsh Government. The renting homes Act did have unintended consequences that has made it very difficult to work in homelessness services in the past few years. So, I would be cautious and just make sure. I would want Welsh Government to really listen to local authorities' concerns. We are the people that will be implementing this Bill, not anyone else.

Thank you.

Okay, Emily, finally. Emily.

I just want to say that I'm very confident, actually, with the current people that are supporting us in Welsh Government. I was on the expert review panel, as were two other local authority areas, and the level of engagement has been really good around this particular piece of legislation, as it was with the Housing (Wales) Act back in 2014. Those two pieces of legislation have been really well supported, and our colleagues in Welsh Government are really clear that they're working in partnership with us to deliver this. As my colleagues have said, they are coming back to us and asking those questions, and they are taking on board things that we're saying, and we're having really good dialogue around that.

But, again, the caveat is the renting homes Act. That did not happen, and we're still waiting for some of that to be worked through, and for some answers to that, particularly around the tenure within supported accommodation, temporary accommodation. We really do need that to be relaxed to be able to make the Bill a success.

Okay, well—. Martin.

I'd agree with everyone—the support from the policy team and civil servants is great. I guess they understand that they don't have all of the levers to pull on, and this is, perhaps, where my funding point was going to go to. Welfare reform is a massive challenge. The fact we haven't got control of that, as a devolved nation, is huge. That would be another lever. They want to pull on it, and we give them all the information, they listen, but it's not a lever we can pull or they can pull.

No. Okay, well, Emily, Cheryl, Martin, David, Laura, thank you all very much for coming in to give evidence to committee this morning and the way that you've engaged with committee. Thank you very much. You will be sent a transcript to check for factual accuracy. Diolch yn fawr.

Okay, committee, we'll break briefly for five minutes.

Welcome back to committee members. We move on to a further evidence session on the Homelessness and Social Housing Allocation (Wales) Bill, and we will take evidence in this session from housing associations. I’m very pleased to welcome, joining us here on-site, Clare Way, director of operations with Tai Tarian. We have Luke Takeuchi—is that the correct pronunciation?

It is, yes.

Okay—chief executive officer with RHA Wales. We have Elly Lock, head of policy and external affairs, Community Housing Cymru, and Helen White, chief executive officer with Taff Housing. And joining us virtually, Sarah Schofield, director of customers and communities with Adra, and Suzanne Mazzone, executive director of housing services with Clwyd Alyn. Did I get your name right, Suzanne, or was that wrong?

No, you got it right, it's fine. 

Did I? I'm doing well this morning. [Laughter.]

Okay, let me just begin, then, with some initial questions before I bring in other members of the committee. Firstly, really, do you agree with Welsh Government’s assessment that, in terms of our current approach to homelessness in Wales, it’s simply not sustainable? Would you all accept that or—?

Yes, I think we would agree with that. But I think the core thing is there are not enough homes. Too many people are experiencing housing need of all different varieties, and then there is a need for more preventative measures, and more support for people to retain homes and to get into sustainable tenancies. So, we can see the role that the legislation would play here. I think everyone else would agree.

Yes?

Just one thing to add—22 years ago, I started my career in homelessness, and I found myself in an RSL. And I think we’re all very understanding, and we’ve got very similar challenges around temporary accommodation, around supply. And we’re really focused on trying to help as much as we can with that. So, there’s a real understanding that that is the right thing to do.

Yes, okay. So, just in terms of the Bill, then, given that the current position isn’t sustainable, in terms of this Bill and its aims, is the legislation necessary to achieve those aims, or do you think they could be achieved without the Bill?

So, I think you’ve heard from a lot of other witnesses that the expert review panel went through all of the different options, and concluded that these are the ones that are needed in legislation. And we definitely broadly agree, because the legal framework is so embedded in the way that homelessness is dealt with, that the legislation is definitely required to make these kinds of system changes.

The one point I would draw out is that we did think that you could achieve the aims on allocations without legislation. That came through in our White Paper response. But we understand the strength of feeling around making sure that allocations are going to homeless households, and we think there’s a way forward with the duty that’s in the Bill. And we want to be really pragmatic and kind of work with that, and focus on partnership working to make sure that we’re getting homes to the people that need them.

Okay. Well, if everybody’s happy with those general positions, that’s great. And perhaps I can move on, then, and just ask, in terms of this Bill and housing associations, what you might wish to flag up to committee in terms of the opportunities and the risks.

I’ll kick off, and then I’ll bring other people in. There are loads of opportunities. We really welcome the principles of the Bill, especially looking at earlier prevention, to stop people getting to that crisis point. That would be a really powerful change, and bringing in more support for people, a more co-operative multi-agency approach, and I think, especially, bringing in different partners who are outside of the housing world. That’s going to be really important in meeting people’s needs, where they stem across different bodies that they might come into contact with. So, all of that, well funded and well implemented, should put housing associations in a really good position to meet the needs of their tenants, and to keep working on things like ending eviction into homelessness.

There are risks, though, as well, that should be flagged. I think it has to be noted that, especially on allocations, there’s a step into controlling RSLs more than has been the case in the past. There is a risk there about the classification of RSLs. So, they're independent organisations that have previously been classed by the Office for National Statistics as being in the public sector, and all of the difficulties that that brings with bringing debt on to the balance sheet, and we can certainly provide more information on that point. So, there's that risk. But, moreover, housing associations need to be able to manage their properties, do good housing management and make sure that they're meeting the needs of their tenants, and have some discretion and flexibility in how they do that. So, that's the focus from us and the risk there about making sure that they can still do the job, the bread and butter of managing properties for the benefit of tenants and communities. So, that's why we've asked for some, I think, quite limited changes on parts of the legislation, just to make sure it works.

We're not taking any of the principles away, not asking for anything to be removed, but changes that safeguard, for example making sure that when an RSL is asked to house somebody, they have all the information they need about that person's support needs and that we have a good understanding of what is a good reason to say 'no' to that, in order to meet tenant and community needs, and making sure that the Bill is drafted in a way that works. So, we can come on to this, but the common housing register section, which we fully support in principle, doesn't work in the way it's drafted, operationally, for RSLs.

So, those are some of the operational risks. As you'd expect us to say, there has to be funding to make this work for local authorities but also for support funding. That's one of the big step-changes that I think the legislation is aiming to get, that more support reaches people at the right time in their lives when they need it. So, the funding has to match that in quantum, in certainty and in the sorts of support that it can cover.

We think that there's a potential missed opportunity in not doing more on data sharing. There's this aim of multi-agency co-operation. There will be risk aversion and fear about sharing sensitive information between partners and agencies, unless that is explicitly clear. So, I think that there are parts of the legislation where that could be written on the face of the Bill and that would be really powerful. 

And finally, I think there's the risk that this could be seen as the last step and not the first step—housing supply needs to follow. I've been really reassured from everybody speaking to the committee that this is well understood, but this only goes so far without more homes. 

Just in terms of supply, it's very difficult to put a figure on this, but would you say anything about the scale of increase that's necessary?

I welcome views from members. I would agree with the committee's suggestion that a long-term aim is to increase the proportion of social homes that are in the country, so up to 20 and 30 per cent. So, that's looking at a big change in the numbers of homes being delivered. I don't know if anyone wants to add to that. 

Well, I think that it's only fair to add that we've been operating in what feels like a period of a housing crisis for so long now that it's become a bit of a perma-crisis, so you almost lose sight of what would solve that in terms of an absolute number because the need is so great. Whatever additional homes we could get we know that we could allocate those in a way that would help to tackle the shortage but is unlikely to resolve the crisis, because we're seeing huge growth in the number of households, for a whole number of reasons. So, it feels like it's almost as if we're never going to be able to solve that problem around having enough homes. So, making sure that we've got the right provisions in the Bill to make sure that we're making the best use of the homes that we've got is going to be more important than ever. 

Yes. Okay. Did you want to come in, Clare?

Yes, if I could just come in quickly, there, just to add to what Helen and Elly have already said. It's the supply of the right type of property as well. So, it's not just numbers, it is the right type in the right locations, where people can benefit, then, from, perhaps, the support networks that they've built up. But we also know that there are people in temporary accommodation who have got specific needs and perhaps a general needs-type tenancy isn't what they need, they need supported accommodation, and supported accommodation in a particular location and of a particular type. So, I think it's important that we don't forget that aspect of the supply as well. 

Okay. And Suzanne.

It was just to come in on the supply issue, and I totally agree with what my colleagues have said around the right type of properties and the right type of places. We've done some analysis across north Wales, and in terms of the people on the waiting list, there are double the people on the waiting list waiting for a one-bed property as compared to the combined total for those waiting for a two or a three-bed property. So, it's that right type of property. We do a lot more now of walk-up one-beds, where we're not looking at communal, big blocks of flats, but looking at the provision of those smaller units of accommodation and how we can meet that demand.

Okay. And could I just ask—? I'll bring Lee Waters in in a minute, but just before I do, in terms of what you've said about funding—I mean, obviously, the more funding we can get into housing and homelessness, the better—would you have anything to say about how confident you'd feel that, at national and local levels, this legislation will provide a greater focus and higher funding levels for homelessness and housing?

I suppose I'd say that I'm hopeful rather than optimistic. We haven't got any certainty over that funding coming in yet. I know that that would be the aim, but until that's absolutely clear-cut and given, you can't make plans. So, I think the funding that is needed for the implementation of the legislation needs to be given certainty as soon as possible after the legislation is passed, so that all of the partners in the sector can gear up towards it.

Okay. Lee Waters.

I just want to, first of all, just probe you a little further on what you said about the changes you'd like to see in the Bill to remove the risk of the classification of public debt going on the balance sheet by restricting the freedom of housing associations. So, what changes do you think would be necessary to do that? 

So, there are some on the allocations area that would just give a bit more balance to the duty. So, there are three main changes on that area: one is an additional duty for local authorities to provide the RSL with housing and support needs. When they ask an RSL to take somebody and house them, that's to make sure that we can match the home to the tenancy, and so it means that you have the information you need to make that decision. It's not a blind decision that you are being told to make—it puts more of a partnership focus on it, and it makes it less of a, 'You must do'. That, I think, for me, reduces the classification risk, because it puts it more into a partnership focus.

The second thing is around a bit more in the legislation on the areas that the guidance should cover, so in terms of good reason, so including things like safeguarding and safety and social cohesion, those sorts of things, so that it's clear that the guidance must cover those areas. That gives RSLs a bit more confidence that there are good reasons to say 'no', and that that is understood in the partnership arrangements.

And, thirdly, I think that guidance must be produced so that it's clear how that tool will work. I don't think it's the plan of Welsh Government by any means, but there shouldn't be any situation in the future where this duty on RSLs comes in and there isn't the guidance to say what's a good reason, what's a reasonable time period. All of that should make it really clear how it should operate and that it's not just a,  'We say, you do', but that it puts a few more parameters around it. That goes some way to making it feel like there's a bit more flexibility and less like we're shifting into that classification risk.

The other thing, as well—I'll also bring Helen in—on a separate area is where we are listed on the face of the legislation as a 'public authority'. I think that could just be reworded to 'listed authorities', which I think it is in the ombudsman Act. We are not a public authority. RSLs are independent organisations and I think that's just a point of clarity.

Those go some way, but to be clear, there will still be a risk to classification. We understand that the ONS are not planning to look at it now, but it's that incremental cumulative shift that maybe gives less room in the future to do other things with RSLs that might tip it over. Sorry, Helen.

Well, that's all I was going to say, really, that it's that accumulative effect of change over time that could tip us into the danger zone of being reclassified, really. And it's comforting to hear the ONS say now that they're not in that place, but we don't know what's coming down the line that could push us further in that direction. And I think it is also fair to say that, as housing associations, yes, we absolutely pride ourselves on working in partnership, but we're also really proud to be independent organisations that have that ability to operate independently, knowing our communities, knowing lots of us, as traditional housing associations, have been around a long time, and are really rooted in our communities and are working very much in partnership but independently.

And if I can just ask Elly: those three points—are those based on specific legal advice about the risk to classification?

No, that's based on practice and what we think will work in practice. It may or may not have any impact on classification, but I think it will position RSLs in partnership with local authorities whilst retaining the ability for local authorities to say, 'You must do this', when partnership working hasn't worked.

Because those could be three things that you, for good operational reasons, think would be an improvement, but you're using classification as a bit of a lever to try and get your way on those.

I think the way I would look at it is more around the operational point of view, and that classification is just a risk that we need to be aware of.

Yes, so there are good things to do—classification is possibly a red herring you're using there to try and concentrate minds.

I think the classification risk is just sitting over this whole legislation, and we can put it to the side.

I take the cumulative point, I think that makes sense to me, but your specific points sound like negotiation to me.

No, sorry, it's more about the operational impacts.

Okay. Just to move on, then, to your views on removing the priority need and the intentional homelessness tests. We've just heard from local authorities some concerns about eroding people's personal responsibility, for example; that was one concern from Cardiff. I wonder if you have views on these parts of the Bill. Anybody who wants to—Clare, did you want to—?

Yes, I don't mind starting on that. I think in terms of the priority need aspect of it, our understanding is, from an RSL point of view, that lots of local authorities aren't implementing the priority need classification at the moment, and it is very much an all-in approach that they're taking to that.

In terms of the intentionality aspect of it, again, I think local authority colleagues would have perhaps a different view to myself on that. I note the introduction of the deliberate manipulation test, obviously, in place of the intentionality test, and that's a particular area where we would welcome more information around, around how that will operate—more the operational implementation of it, as opposed to what would be in the legislation there. And just understanding the impact on, I guess, the work that we would do with applicants, so when they're coming through the homelessness work stream, through the stream, where we would stand in terms of allocating a property, and when that manipulation test would happen. We wouldn't want to get to a position where we've allocated a property, they perhaps have moved in, and then the test happens. Or equally, we operate choice-based letting, so they would have perhaps bid on a property under our system, and then the manipulation test comes in. So, for me, it's more the replacement of what's proposed in the legislation, as opposed to the removal of priority need.

Do you have the same understanding as the local authorities have that the deliberate manipulation can only be applied retrospectively? Is that your understanding as well? Because they said that can only be applied after the fact.

I understand why the intentionality aspect is being removed. All of us sit here today and want people who are homeless to have the full range of access to support and advice. At the moment, it's not clear where the manipulation test—to myself—where that will come in. And currently, we've got a process where, for the local authority area I work, almost, people who are assessed as being owed a duty are passported through to our allocation system. So, not knowing where that manipulation test is going to happen at the moment, it's not clear whether there'll be an unintended administrative burden on housing associations to perhaps look at that, and maybe then not be able to take the passported application through. So, I think it's just more information, it's not that we're objecting to it.

Sure. 

I think my understanding is that where the intentionality test sat on whether you had the homelessness duty, the deliberate manipulation test sits at the point of whether you get a preference for social housing allocation. So, it's much further down the line, and as Clare said, that means you need to know when that test is going to be performed. You don't want to get to the point of allocating someone a home and get them to sign a contract before somebody thinks to perform it. That's down to practice.

So, it's a guidance issue.

It's a guidance issue, I believe, yes.

Okay. Any other views on that?

The only thing I'd throw into that one is probably on the ground, some operational, optical issues we're going to have to deal with in future. So, what I mean by that is, inevitably, we have some tendencies that fail because things go wrong at times, and the reality is that that person is then back in a system and could then re-present for an allocation back with the RSL within a period of time, and that could have ended because of behaviour, or it could have been significant debt on the property.

So, our view is that that's an issue that needs to be remedied, and us just stepping away and saying, 'We can't rehouse that person' is not necessarily the answer. But there is an interesting discussion around what 'good reason' then entails, and is 'good reason' previous tenancy history and some significant issues in that home that would mean that that person re-presenting to the same RSL 12 months later. Optically, for staff on the ground when they've dealt with those challenges, it could be an interesting one to have to explore. I think, just to make clear, we come from the point of, 'We need to work as a collective across RSLs and local authorities, but there will be some operational implications of that on the ground.'

Do you have any concerns about people gaming the system? We heard suggestions of that earlier.

In my experience, and, again, it's been across homelessness and RSLs, when you look at proportionality, the large majority of people within the system are in it for the reasons that they need to be in it, which are to be housed, because they've got a housing need.

But do you accept—? Sorry, John.

It's just that Suzanne wanted to come in, Lee. Suzanne.

Sorry, just to clarify that, you'd accept there are some people who do game the system, but you're not overly bothered by that, because, in the round, it's not a huge issue?

I haven't got the experience to draw on to say where I've seen those examples, to be honest.

Okay, thank you. Sorry, Suzanne.

It's probably just to follow up on Luke's point. I think this will link very heavily with the partnership working and how this doesn't just become a local authority problem. When we get to that stage, I think in terms of removing priority need, a lot of local authorities have been working that way anyway, and the same with intentionality, the numbers across Wales are really low.

Again, it will link with the support that we can provide to people, but I think strengthening those partnership arrangements in line with something similar to multi-agency risk assessment conferences, and everybody coming to the table to look at what we can do to work with somebody—. Because ultimately, it's not just a local authority problem, we all need to work together.

And then what's the view on the replacement of the unreasonable failure to co-operate test?

I think we understand the reasons for the changes on that. We wondered on the ending duty due to violent behaviour towards staff whether there's a case to extend that more widely to neighbours and the immediate local community. 

I have heard the concerns of others giving evidence here about ending the duties being too harsh an outcome, and I could share their concerns on those, but equally share the viewpoint that there needs to be a point where local authorities can say, 'We've done what we have to do.' I think housing first is really important here. It's this sort of service that is really important for people who have multiple needs and for whom other approaches haven't worked, so continued funding for that will be really important. I don't know if anyone else wanted to say anything.

Just to say I think the language is quite emotive, isn't it, around 'gaming' a system. It is quite an emotive term. I think anybody who does behave in a way that could be considered gaming or poor behaviour is coming from a place of absolute desperation around their housing need, and so we generally accept that, yes, there will be some poor behaviour, but we know that's coming from a place of just being beyond desperate in terms of what's going wrong in your family, in your home, in your household.

Well, not always, according to Cardiff Council's evidence. There are a small number of people where they were implying there was malign behaviour.

Well, again, coming from a—. It's coming from a place of desperation, not coming just for the sake of it—it's coming from a place of being in a dire situation, and nobody chooses, as far as I've ever witnessed, to go and make a decision to behave poorly or to game a system, only to try and meet their desperate housing needs, really. 

But one thing, interestingly, a kind of counterpoint, really, to some extent, is some of the offers we are making now, particularly to those who are in high priority need, are being refused, because I think people think this is their one chance to get their home, and they are really conscious that they want the right home for their family or for their household. So, we are concerned that we are seeing an increase in refusals and how that might then filter through in terms of that duty being discharged. Of course, that then brings you back, as do most things in this discussion, to a lack of supply, a lack of suitable, good-quality homes for people.

Sure. And then just on the—

Sarah wanted to come in, by the way, Lee.

Sorry, apologies.

Sarah.

I think the conversation touches on the timing, the understanding and the consistency of the application. So, as the legislation is changed, which will have effect for many years to come—it's important to remember that the funding will need to fund for many years to come, so it will need to be very long-term funding, and can anybody guarantee that? But it's about the culture, not just the legislation and the partnership working, and everybody having a consistent application and understanding of the legislation and the guidance. I think that aspect of it is going to take time, it’s going to need training and conversations and workshops. I’ve seen this morning that you’ve spoken to the local authorities, then you’re speaking to the registered social landlords, but all the partners need to come together about the application and the culture of the changes that are needed. So, I think that’s just something to bear in mind about the training that’s going to be needed and that consistent application of everything, going forward. And there’s a lot of terminology being discussed and different areas will interpret it differently.

Thank you. Yes, that's an important point. I just wanted to ask about the creation of this new local connection to Wales test, as opposed to a local connection. Do you have any views on that in the Bill?

I think this has been one of the areas that has been quite hard to unpick exactly what it does. It’s quite complex in terms of where it sits in the legislation. My understanding is that it’s about ensuring that the benefits of this new legislation are felt by and aimed at people with a connection to Wales, and we support the aims of helping communities in Wales, certainly. I think we understand why they haven’t gone further on local connection more generally in the legislation, and the concerns of local authorities in that space, but we retain our position that there are some cases where people don’t have a local connection and should still be supported, such as veterans and care leavers and refugees and people from LGBTQ+ communities. I don’t know if anybody else wants to—

But would the Bill allow that, in your view?

Not as drafted currently, but I understand that the plans are for secondary legislation to be used to set out some categories of people who are exempt from the local connection test, and that those people may well be included in that secondary legislation.

Thank you. Are there any other views on this question? No. Okay, thank you.

Just on that, it has been—

I think Laura's got her hand up, sorry.

Oh, sorry. Yes. Laura.

Sorry. Chair, just on that, I don't know if you were going to say the same thing, but I'm just wondering, do you think that secondary legislation is the right way to do that to protect those vulnerable people you've just outlined, like veterans, those who've been abused, refugees, and so on, because they won't have those local connections? I've seen, even in my own casework, how that's quite hard on those people. Do you think doing it with secondary legislation later on, perhaps, hopefully before the end of this term, is a good idea? Or does that not guarantee it enough? Should it be on the face of the Bill? Diolch.

I can see the benefits of it being on the face of the Bill, in terms of knowing now that those groups are exempt. Whether there are legal challenges and implications around that, it's outside my field of expertise. You will achieve the same thing by doing it through secondary legislation, but without the guarantee that that will happen, but they're taking that power. So, I'm probably relatively neutral on which route you go down, but I understand why there may be a desire to put it on the face of the Bill, to guarantee it. 

Natasha Asghar.

Thank you so much, Chair. Good morning, everybody. I'd just like to know what your view is on the new duty to provide help to retain sustainable accommodation, and what it will need in terms of resources. Just to make you all aware, the committee is aware that the RIA estimated that this would cost an additional £7.8 million annually. So, I'd really love to hear your input on this. Thank you. 

Thank you. I will bring others in on this point in particular, but generally to say we're really supportive; this is a step change in helping people with that kind of support. On the RIA point in particular, I do think the assumption of 10 per cent of people needing support needs some further stress testing. I don't know if anyone wants to say some more on that, in your experience. 

It sounds low to me. Based on what I'm hearing from our neighbourhood officers on the ground who are dealing with managing our general needs tenancies, as we would call them, we're finding that people are having more complex issues that that housing management, neighbourhood management approach is trying to support, but without a level of funding that enables them to do that to the full extent that it could be done.

We have examples where we're seeing young people who are in our supported accommodation—. It's anecdotal, but there's evidence to suggest that they are expressing suicidal ideation, are actually self-harming, or attempting suicide once every three days. There's an incident to that effect once every three days.

The reason we're able to manage that is because we have housing support grant alongside that individual to help support them through those really difficult times. If we're finding that people are coming through the homelessness route into our general needs property management area, they're not going to have that support, and that really does concern me, not only for the individuals who are in those properties, but also for those who are trying their best, from a general perspective, to support those tenancies.

So Helen, a sub-question to what you just said then, putting on my ex-public accounts hat on, if this £7.8 million is a low number, what's your magic number then? What would you ideally like to see? How much would you like to see invested in it?

Percentage-wise, in terms of how many tenancies I think would need support, do you mean? Yes. We had this conversation before we came in, didn't we? We were saying that some people would say 50 per cent, some people would say 80 per cent. Even though the vast majority of our tenants come to us at Taff through the general needs allocation, their needs are not that general. They are generally trauma experienced and have needs that go beyond what would be considered just a normal tenancy sustainment level of support.

Thank you very much. Chair, I notice Suzanne's got her hand up.

Yes, Suzanne, and then Luke. 

Thank you. I think for this one, to me, it links to the suitability of accommodation, it links to the duty to comply, so it goes back to that joint agreement that the property is most suitable at the very outset, really, giving the person the best chance to live independently. Without that, the duty to retain might be impossible to achieve. I am also cautious about whether 12 months is the correct timescale. If we're taking that person-centred approach, we possibly need to recognise that some people require ongoing support, and that might be for a very long time. We probably need some further guidance on how the decision to end that support is going to be managed. Would it be a joint decision between the RSL and the local authority, or is it purely a time-stamp decision? What happens if the landlord and local authority disagree around support needs, with that support ending and the needs still ongoing?

In terms of the actual support and the help to retain that accommodation, we often find that cases get closed by support providers for non-engagement. My view around that is that, as a landlord, we're best placed, we can develop those support services, and we do have support services that are HSG funded. So, it's about, I suppose, enriching some of those in order for us to be able to assist with this duty. Because, as a landlord, we can never close a case due to non-engagement. We simply have to continue to attempt to make a connection with somebody to prevent those evictions into homelessness. So, it's looking at is there a system of possibly direct payments to landlords that come across to enable them to put support packages into place to make sure that we can meet the needs of this potential duty. 

My point specifically relates to further evidence on the point Helen raised around support and the need. One of the things we are really keen to get across to the committee is that, in reality, the resident base we're dealing with is far more complex. I think those complexities existed 10, 20 years ago, but what staff are telling us on the ground, and what we're seeing, is that the scale of that has increased significantly, particularly since COVID, but actually prior to that.

The challenge is, for us on the ground, that we're no longer managing significant numbers of general needs residents, as would have been the reference before, it is more of a higher support need, and, obviously, we haven't been set up to do that, traditionally. We've relied on statutory services. Access to that has been more challenging than it would be, understandably, for local authority partners, because they'd have those existing relationships. So, I think having that support in place will really help the system to keep people in homes and stop them going back into the homelessness system.

When you look at some of the comparisons across Beacon, which is the organisation I'm representing, we've got a region to the east of Wales and a region to the west, both with very different allocations policies, and that flexibility and discretion—which doesn't mean preventing people accessing homes, but the discretion and the skill set on the ground to work out who's best placed in which area and which accommodation—will definitely reap rewards in the long term, and that tenancy is less likely to fail.

When you look at less discretion, less flexibility, and, 'A person needs to be housed because they're in temporary accommodation, please house them', then you get more chaotic tenancy failures. You get things such as abandonments, leaving accommodation because of support needs. So, it's a really important aspect for us to make sure we get right, as part of these discussions.

Just briefly to add to that, given that support is obviously vital to ensure that homelessness is rare, brief and unrepeated, obviously, we've got to get this right. There's lots of innovative work going on within the sector, with local authorities and voluntary agencies in terms of trying to meet that need. It does start with making sure that the property is in the right location, because there may be informal support that they can benefit from in that respect, from family, friends, et cetera—networks. But it is vital that we also distinguish between those that have come through the homelessness system—. A large proportion, the fact that they've come through the homelessness system, may require support. I would be pitching it at 80 per cent, 90 per cent, even if it's only short-term support in terms of that resettlement. And then, there will be a cohort of people that need that longer term support, because they are the more complex cases that we come across. But it is about looking at all the avenues to secure that support.

Thank you very much. Siân Gwenllian.

We're really supportive of this measure and think that it's going to make a huge difference to the lives of people that we touch in different services, different agencies. But I think one of the things that we'd like to be clearer in the legislation is how partners can request and initiate a response, recognising that sometimes there may be others that are connected that are in a better position to do that than the local authority. And again, I think it links with the issue that Elly raised before around making sure that we've got those data-sharing provisions included in the Bill, so that we can, I suppose, move with haste when we need to.

Suzanne, is it clear who actually initiates the protocol? 

Not really, I would say, within the legislation. You're looking at those public agencies, but as a landlord there are times when we need to be able to do that as well, and we need to be able to ask people or call people to the table to help us. Because oftentimes, particularly in this day and age when you haven't got other public services involved, eligibility criteria are so high, thresholds are so high, the landlord or the housing officer is the one constant in a person's life. So, we need to be able to be in a position to initiate that process.

Does anybody want to add anything to that? Clare.

Only a small point from me. I don't want to take us off the particular question, but multi-agency working, absolutely that's something that we would support, and we do on a day-to-day basis anyway. But the extension from the 56 days to the six months in those complex cases where you want to have that multi-agency wraparound is obviously going to be key to that as well, particularly for the complex cases.

Okay, thank you.

Diolch. I'm generally supportive of the 'ask and act' duty. I've heard the evidence around whether it should be going back to the White Paper language around identify and act and refer, and I think there's some benefit in that. What the language says is a semantic point, maybe, but I definitely think the action should be to identify and then 'ask and act'. That's definitely how I would read it. So, if we don't think the legislation does that, then that should be looked at again.

Residential social landlords do this day in, day out. This is what the organisations do, working with people on their housing and making sure that they're supported in their homes and preventing homelessness. They’re quite a unique body on that list of authorities. I don't know if anyone else wanted to add anything on that.

Oh, and in terms of the organisations on the list—sorry, the last part of your question—I think it would be powerful to have primary care and education on there, which aren’t at the moment. We understand the reasons why those are difficult areas where you don't want to put additional burdens onto those public sectors, but they are also places where people so often come into contact with individuals who are experiencing a housing crisis and housing need.

The only thing I would add really briefly is, absolutely, we would welcome the opportunity for as many people who are playing a part in the support of somebody to point them in the right direction to have that duty. Of course, that may increase the number of people who are presenting and coming into the system, so if there is an increase in the number of those people who are going to be involved in that process, then that would need to be reflected in the funding, because it's likely to increase the demand. So, that’s not saying it's a bad thing, but the unintended consequences would need to be considered, perhaps.

I think we're exploring just what it means for RSLs in terms of the group that needs to be supported. Is it just tenants or is it also wider groups? That will come out. We can provide more information on that.

Diolch, Chair. I just wonder what your view is on the duty on housing associations to comply with a request from a local authority. Will it address the levels of variation between housing associations in the proportion of allocations that go to households owed a homelessness duty? Diolch.

Thank you. Just first to address the point about variation in levels, RSLs, as we've heard from people here today, are not all the same, and the types of homes that they own are not the same—the size, type, location and the specialist provision that might be provided. Populations across Wales, obviously, are also different in terms of their needs. So, there will naturally be some variation that is in the system, and it will always remain, but we understand that there is this variation in levels of allocation to homeless households. I think we have an emerging picture from the data on the reasons for that, but we haven't really got the whole story on what sits behind it and clarity on what that is. But we understand that that's creating a perception that RSLs are not housing people that they should be. 

What we think is really clear from the evidence of what works, looking at Scotland as well, is that partnership working is really important, and bolstering partnership working with shared priorities on both sides. So, that is, I think, the bit of the Bill that will really enable an increase in allocation to homeless households. It's that increased partnership working, agency working and, really crucially, support that will all enable RSLs to offer those homes to people more often.

In terms of the duty itself, obviously that plays a role. We suggest that that should be a backstop when partnership working has broken down. I don't think we'd want to be in a position where, as a regular way of working, local authorities are dictating to RSLs what to do. That's not what happens now, and I think you've heard from local authorities that they have some abilities now to require RSLs to do things and they haven't had cause to do that. So, I think we're looking at it as a backstop, so that in those cases where partnership working has broken down it will allow that allocation to go to the homeless household, if that's the right thing.

The focus from us is about making this work for, yes, RSLs as organisations, but also for tenants and communities. There will be cases when an RSL has to say 'no' for various reasons—you know, if you've just not got the right type of home or the right type of support to make that sustainable and make it work for somebody. This is where more supply comes into the picture. I don't know whether any of my colleagues want to say anything more about that.

Yes, thanks, Elly. Just to add to that, obviously, in preparation for today we were having some conversations internally with colleagues who are experiencing this on the ground, and I think there are some really strong examples that they gave, which I could give, over a number of years. If people are refusing accommodation or applications from the homeless, the question for me is, 'Why?' As non-profit social purpose organisations, there's always a drive to house people in housing need, and I think that if you lifted the lid and looked at the portfolio of homes we've got across Wales, you would see that. 

I think that losing and not having the flexibility to be able to make those decisions on the ground—. So, an example given to me—and I completely understand that the system, unfortunately, doesn't support long-term, sustainable tenancies. So, the system is that someone presents as homeless, as everyone well knows, and there's a driver to get that person out of temporary accommodation and into a permanent offer of accommodation, understandably. Now, the local authority are pressured to do that because of a number of different constraints. For us, when we take that person on and we give them a home, it's really important that that's for the long term. Unfortunately, we do see incidents where, if I take a block of apartments we've built with social housing grants—affordable, attractive accommodation—where we took in applicants directly from a waiting list who were in temporary accommodation, but they just weren't equipped to be able to sustain that tenancy independently, and quite quickly, I was receiving correspondence from the local council, the MS, understandably, because community cohesion was impacted within a number of weeks.

When you've got those challenges on the ground, that's a prime example of why we as RSLs need, because we've got that knowledge, to be able to say, 'This person with drug and alcohol issues is not going to work in this accommodation, and we need to have some flexibility to be able to move them to this particular accommodation, which we think could work.' So, there's not only the support issue, but the drivers from our local authority colleagues. I've been there, and I completely understand it, that the system dictates you've got to move people out into permanent. But there should be a measure, and a measure for local authorities, in my view, which a colleague helpfully suggested to me recently, of looking at the long term of, 'Okay, the offer was made, what was the outcome of that? Are they still in that tenancy in 12 months' time, 18 months' time?' I think, when you look to those figures, that would be really interesting to see. Because, effectively, they're going back into the system after that.

This is why we've got some asks to make this part of the legislation work better for everybody. It's around having more clarity on the support needs of the tenant before accepting a referral, more details on the guidance, just to give reassurance that, for the types of cases that Luke's talked about, it's reasonable to say, 'You know what, we're not going to put someone with drug problems in a block with known drug issues.' This is about meeting people's needs where they're at. We hope those are quite pragmatic changes that could be taken on board.

Just to add quickly, we are, particularly here in Cardiff, but I know it's an issue across Wales, dealing with households that are severely overcrowded. We will often use those moves to tackle overcrowding in some of our existing homes. So, you still free up a property for somebody else. But if we were to lose some of that control to do what we would consider just being able to discharge really good housing management to support community cohesion, it would be really unfortunate. I think we absolutely understand and respect the pressure our local authority colleagues are under, and we work in partnership with them, day in, day out. I personally don't think that having a legislative framework to push us any further will make any difference, because we are, wherever possible, working in partnership to do the right thing.

Okay.

Sorry, Chair, but just because it relates to that. I thought a colleague from Newport City Council—we were sat having a coffee—summed it up perfectly in terms of how it can work effectively: when you've got the relationships and the partnerships, which are often in place across a number of RSLs and local authorities, in effect, it works anyway, but in a more mature way, rather than saying, 'We have to take a particular applicant for this reason.' So, we don't think that's the answer to improving partnership working, necessarily.

Okay. I'll just bring in Suzanne, and then Clare. Suzanne.

Thanks. In terms of will it actually help to increase housing for some of those homeless people that we have, I think the issue, again, comes back to supply. At the moment, we have agreements with local authorities, and we've had them in place since COVID, where we aim for 50 per cent of lets to homeless applicants, and particularly those in temporary accommodation, to move them on. In reality, what happens is we send them all of our voids, and they will have a look if there's anybody in temporary accommodation that matches those voids and actually nominate them back to us. But, practically, when you look at our lets to alleviate homelessness, we're at 45 per cent. So, the issue is that the stock that we have doesn't meet the demand within the homeless services, so it is about exploring and widening that. It's not about the will of the housing associations.

We have that relationship with local authorities and we do work really, really closely. Some local authorities will just say, 'Only send us your one beds through, because that's what we need.' But, again, when we go back to some of that immediate work that we did, particularly around the pandemic and the urgent bringing everybody in and rehousing, I think that some of those allocations failed because of the intensive levels of support that were needed and the lack of support and funding that came across with it. So, I think it's quite multifaceted, really, in terms of that there's not one particular thing. We have got strong partnerships, we've got a single access route to housing partnership, which is a common housing register across three local authorities and RSL partners. We have a steering group. We have a compliance officer that works on that, that looks at all of the allocations and whether we're overriding people where we shouldn't be overriding them. That's overseen by a steering group. So, we already have a lot of those great partnerships in place.

Okay. And Clare.

Not to repeat what colleagues have said, but I absolutely agree with perhaps more detail being provided around this particular part. For example, where we're asked to accommodate some people sometimes, there's a need to draw on information from other organisations and partners, such as the police, for example, in order to identify appropriate accommodation and long-term accommodation, so they don't end up in that revolving-door situation.

I think the other point for me is that it does cross over on to the prevention, support and accommodation plan suggestion, and what pressure, perhaps, local authorities may be under to actually invoke this piece of the legislation if, within someone's prevention, support and accommodation plans, they have identified this aspiration to be accommodated in the social housing sector. And therefore I guess our assumption at the moment is that this is a safety net, and actually they may be in a position where they may be having to invoke this, because, actually, that's what's been drawn up with the individual. And obviously, within the prevention, support and accommodation plans is that right to a review, to make sure all reasonable steps have been taken. So, that's just another area, I guess, operationally, I'd want to explore, to make sure this particular aspect of the legislation is used as it was intended.

Okay, Clare. Thanks very much. We've only got a few minutes left, but we've got a few more questions. Laura Anne.

Diolch. The White Paper proposed giving additional preference to homeless households, but this has not been included in the Bill. I'm just wondering what your thoughts are on that, please. 

I think we agree with that change, for the reasons that Welsh Government has also set out around not driving people to a point of crisis in order to access social housing. I don't know if anyone wants to say anything in addition.

Everybody in agreement with that? Yes. Okay. Laura Anne.

And finally, what are your views on the requirement to have common housing registers and accessible housing registers in all local authorities? Diolch.

We fully support the idea of common housing registers and accessible housing registers; both will make a big difference to the experience of tenants and people trying to access social housing. But we can't support it as drafted. Our written response sets out more detail. I'm happy to follow up, but it currently would cover all landlord housing, so it would include market, rent, intermediate. I don't think that's intended. And the other thing that it doesn't allow is for transfers. So, if Mrs Smith's roof caves in, house is flooded, landlords need to be able to move somebody out right then. And at the moment, what the law would say on that is that someone has to be put on the register before they can be moved, because all allocations of housing have to go through the register. I don't think that's intended.

There are other sorts of moves, some more management transfers, so in order to meet your obligations as a landlord. Helen's talked about people being overcrowded and you maybe move someone in that instance, or their health needs have changed, they've developed a disability. Moving within stock is a really important part of good housing management. And at the moment, again, the way it's drafted would require all of that to go through the register. So, I think there's some work there to make it operationally work, but absolutely the idea of a common register that everyone goes through is absolutely shared.

We know most areas already have a common housing register—not quite the case an accessible housing register. Those that don't—the three areas that don't—will need a bit of extra support to get there. And I think we can draw on best practice from things like the SARTH partnership in North Wales and on accessible housing registers, things that exist already, like Adapt in Swansea.

Okay, diolch yn fawr. Okay, Laura?

Diolch.

Just one final question from me: in terms of access to social housing in Welsh-speaking communities, are there particular issues there that you'd like to bring to the committee's attention? And are there any changes in terms of the Bill that you'd like to see?

I'll defer to Sarah on this one.

Sarah.

Diolch yn fawr, Sarah. Thank you very much.

Okay, well, thank you all for coming in to give evidence to committee this morning. You will be sent a transcript just to check for factual accuracy. Diolch yn fawr.

Committee will break briefly until 11.35 a.m.

Welcome back to committee members, then, for our further evidence session with regard to the Homelessness and Social Housing Allocation (Wales) Bill. I'm very pleased to welcome here joining us in the committee room Dr Ayla Cosh, who's clinical director for Cardiff and Vale health inclusion service. I very much welcome you.

Thank you. 

Okay, perhaps I might begin with some initial questions and then we'll bring in other committee members, Dr Cosh, if that's okay. Firstly, then, very generally, could you give an overall summary of the strengths and weaknesses of this proposed legislation?

Obviously, I speak from my experience, which is health—that's my area of expertise—but, overall, I would say that the strengths would be the policy intention to strengthen prevention of homelessness, to improve access to support and social housing, and to broaden the responsibility for addressing homelessness across public services, which is something that is very important, and I would agree with. They are very good principles, and the duty to ask and act also very much highlights the fact that health and housing are intrinsically linked and can't really be separated. Housing is undeniably a fundamental determinant of health, and health is a determinant of people being able to sustain tenancies as well. So, I think those overall things are very, very positive.

I think you could argue whether there is a need for legislation to deliver the stated policy intentions. In some areas, there's lots of partnership work going on at the moment and it works very well, whereas in some areas there may not be. So, that's a question, but I suppose accountability and performance management is needed as well across areas.

I think in terms of weaknesses, there's a risk that the policy intention may be negated if housing services are overwhelmed with the removal of priority need or the issues around intentionality, although that is not my area of expertise. If there's no revenue or capital to follow the implementation of the legislation, I think that's a risk. There's no duty on primary care, which I would consider a very large gap in this area, and there's also no mention of those who face no recourse to public funds conditions, which is another gap, I'd say. So, I think those are probably the weaknesses.

Okay. Thanks very much for that. So, are you neutral, then, in terms of whether the aims of this Bill could be achieved without the legislation? As you say, you think perhaps some aspects possibly could, but possibly other aspects not.

I think it possibly depends on the area. So, I know in Cardiff at the moment with the health inclusion service and our partnership work with Cardiff local authority, we're working very, very closely in partnership. We couldn't do anything more to work in partnership apart from looking at pooled budgets, potentially. I think the legislation for us just around the ask and act duty—I'm not talking about the intentionality; obviously, that will have a big effect on my local authority colleagues—in terms of the ask and act and the partnership between housing and health, I'm not sure that this legislation will make a huge difference in Cardiff. I can't speak for the rest of Wales, obviously.

No. Okay. And as you say, in terms of priority need and intentionality, you can see issues there, but obviously that's not your specific field of expertise and experience.

Not specifically. If we're removing priority need, I would be concerned that temporary accommodation might become overwhelmed, and then those who actually do have a priority need may not be prioritised. Speaking from a health point of view, I'm talking about people with significant health issues and concerns.

Okay. More directly, then, in terms of health and the health sector, the costs and benefits to the health sector, the Welsh Government has set out its regulatory impact assessment. Have you had a chance to look at that in terms of those health costs and benefits and form a view as to whether what the Welsh Government has put in that assessment is realistic?

I haven't read the RIA in detail. I think what I would say is that measuring outcomes and looking at the impacts of Bills like these obviously is highly complex, but that needs to be measured across public services. These individuals that face homelessness, especially the increasing complexity that many of these individuals face, the cost is across public services—so, health, local authority, criminal justice, DWP—and so the impact of any legislation in this area, my question would be how would that be measured across all public services. 

Would you say anything specific about health, though, not specific in terms of figures or anything, but the likely impact on health of this legislation? As you say, there's such a close connection between housing and health in both directions, isn't there? 

I think there would be an impact on health, but that would need to be front-loaded with investment or changes, or a change in the way that things are done operationally, to implement the 'ask and act' duty. For example, an individual who's repeatedly presenting perhaps at hospital or in a health setting, and where the nub of the matter isn't being got to, obviously, if things are put in place to try and prevent homelessness or to address it very quickly, so it's brief and unrepeated, that will obviously have a positive impact on the health spend down the line, because you would hope to prevent deterioration in mental health, you'd hope to prevent people not managing chronic disease, all those sorts of things that go along with experiencing homelessness. So, ultimately, yes, there's definitely a positive effect, but it's complex, and to get to that point, there would need to be expenditure or resource input.

So, you've got the short-term, medium-term and long-term picture, really. 

Yes.

'Ask and act' is obviously very significant in all of this in terms of health and the health sector, isn't it, so let's move on more specifically to that, and Siân Gwenllian.

Thank you for the question. It is already happening on a small level in Cardiff, and it's in its infancy at the moment. As I explained earlier, CAVHIS, the health inclusion service, which is managed by Cardiff and Vale health board, is working in partnership with Cardiff Council to come together, and we've created a system where, if individuals are identified in the EU or in secondary care or in our community service, if they're identified as being homeless and not having an open duty, we directly refer to front-line housing colleagues, and we've done that via a Microsoft form. So, it's a very slick process with minimal time input, minimal information, and then housing colleagues will pick up that referral and do what's necessary. So, that's already going ahead.

As I said, it's in its infancy, so we don't have any data to look at on the outcomes of what that would be, and I think it's important to specify what outcomes we want to see, so we can give information on how many referrals are being made, and then what the action is from local authority colleagues. But I suppose, in terms of the success of that, you'd want to be looking at are people then moving into long-term accommodation, are they sustaining tenancies, and looking at their health outcomes as well, and that's obviously a huge piece of work. But, yes, we have started to do that locally in a very small way, and we're hoping to build on that process as we go along and roll that out onto all the wards in secondary care and, potentially, at some other sites across the health board as well.

So, presumably, having it in legislation is going to help you with that roll-out and help across Wales in other circumstances where this is not happening. Do you think the other provisions around 'ask and act' are clear enough, especially the 'ask' aspect? Does it become a bit of a tick-box exercise, or is there really identifying a problem happening?

I don't think the legislation won't help at all; obviously, it's really good when front-line practice matches that. And I suppose, in Cardiff locally, we're trying to implement the policy intentions before the legislation comes. So I don't think it won't help; I think it will definitely help across Wales, perhaps in other health boards where homelessness doesn't have such a high profile amongst health colleagues.

I think the 'ask and act' is clear; I think there's a difference between identifying if someone is homeless and asking, and I think it might be helpful to have a little bit more clarity around that. I think health colleagues may come back and say, 'Well, are we meant to now ask everybody if they're at risk of homelessness or if they're homeless?' And that is potentially quite a large burden on health colleagues as well.

I think identifying someone who's at risk of homelessness or is homeless would require an education package across health as well, and helping local health boards to implement that. I suppose you could say the difference between asking or identifying is, perhaps, just semantics, but I think there is a subtle difference there and we need a lot of input with education around that in health.

In your written evidence, you have said that a short mandatory training module for NHS and other partners would be helpful in terms of 'ask and act'.

I think there are two aspects with education. It's education specifically around this Bill and the duty that's needed, which a lot of colleagues won't have heard of, but it's also education around identifying those who are homeless or who are at risk of homelessness that's also needed.

Your paper also talks about the importance of data sharing—we've heard this this morning from a registered social landlord—but how important is this data sharing between the various agencies?

I think this is vital. Not just practically, in real time, when we're talking about people accessing services and being referred between services, but it's also important with regard to assessing the outcomes and the success of legislation.

In Cardiff, we've got many data-sharing agreements between public services, but what I think we actually need to see for this cohort is an almost single-view approach, where you can access one dashboard and see how many public services a homeless individual is involved in. I think this would prevent duplication of work, rereferral where it's unnecessary, and would also help to measure outcomes in the future. So, yes, information technology and data is key, I think, to the success of this. 

Yes. It's pretty challenging at the moment—all that area; all the digital.

It's highly challenging. Yes, it's extremely challenging, but it's not insurmountable. I think it's just a dedicated focus on this, and with the data-sharing agreements, I do think we can get there.

You are concerned that primary care isn't included in the list for 'ask and act'. In your paper, you're talking about a three-tier model for primary care. Could you explain a bit about that? 

I think I'd be concerned that primary care are not included because they see the majority of interactions in health and they would see the majority of people who are at risk of homelessness. So if we're looking at prevention as being a key part of this legislation, I think the duty needs to be on primary care.

By the time someone is homeless and is presenting to the accident and emergency department or the emergency unit all the time—repeated presentations and recurrent discharges—they're likely to already have a duty open and be known to services. And if they don't have a duty open, speaking anecdotally, it's because they face the no recourse to public funds position or they're out of area, but then, even so, they'd be linked in with the reconnect team.

I really think primary care is the key to unlocking the prevention part of this duty, not secondary care. We can pick up people in secondary care who are homeless 1 or 2 who might not be known to local authority services, but locally, in Cardiff Council, again, anecdotally—I've worked with them over many years—it's rare to come across people who are homeless in a health setting who are not already known to the local authority, apart from those who are completely under the radar and NRPF. So, I think the key here is primary care.

The Government tell us that they hope to change the contracts with GPs and that through those discussions this can be included in that way. Do you think that that's the way forward, or would you prefer to see them named on the face of the Bill?

I think the contract change forms a small part of this. I'm thinking back to a tiered approach of primary care with regard to health inclusion—not just homelessness now, but prison leavers who are in and out of prison, or Roma, Gypsy or Traveller people who are on unauthorised campsites, or high-risk sex workers. I think all those individuals, those cohorts of people, come under the health inclusion umbrella. Actually, having a primary care system that allowed a tiered approach—so, a tier 1 or 0, which is the routine GMS contract, and then you can have a higher tier, so a tier 2, where you could have a locally enhanced health inclusion service specification, which gave allowance for increased consultations, the co-location of public services, more time for those clinicians to then refer people into services. And then you've obviously got a tier 3 level service, such as CAVHIS, which actively does outreach into those different settings to meet those cohorts with their outreach, as I've previously mentioned. So, in terms of the tiered approach, I think that approach coming alongside contract negotiations to put the duty onto primary care is probably what's needed, not just specifically to address this legislation but to look at reducing health inequalities as a whole across the system.

Just to go back to the previous point about education, what's the best way of educating health professionals so that they can actually be aware of the need to notify risks of homelessness?