Section 2: Principles of the Prevention Review Group - wider public bodies and landlords
1. Do you agree that these are the right foundational principles?
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The shared public responsibility for homelessness is the approach providing there is 'buy in' from all parties. The health and social care partnerships in particular have an important part to play.
Prevention at an earlier stage is also the right approach however chaotic life styles will always mean that in some cases a reactive service is required.
Prevention at an earlier stage is also the right approach however chaotic life styles will always mean that in some cases a reactive service is required.
2. Are there any other principles that should be included? If so, why?
Please say what other principles should be included, and why
The main issues are covered
3. Do you agree with the proposals to introduce new duties on public bodies to prevent homelessness?
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Intoducing new public duties is the right approach. With GPs struggling to deal with appointments at surgeries at the moment this will be a challenge. The 'Near Me' app works well but I'm not sure that without spending time with people in person that GPs will be able to identify those threatened with homelessness easily, particularly with only minutes to see patients. GPs are also not a public authority but private practice - will this have an impact?
4. Do you agree that public bodies should be required to ‘ask and act’ to prevent homelessness?
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Without asking and acting it would be difficult to prevent homelessness
5. Which public bodies do you think a new duty to prevent homelessness should apply to and why?
Please say which public bodies you think and why
Health and Social Care Partnerships
GPs
Housing Associations
Third Sector Organisations, for example Care Providers, Inspire, Cornerstone etc
Educatioin
Criminal Justice
Womens' Aid Organisations
All these agencies would be able to identify those threatened with homelessness and act to prevent this happening
GPs
Housing Associations
Third Sector Organisations, for example Care Providers, Inspire, Cornerstone etc
Educatioin
Criminal Justice
Womens' Aid Organisations
All these agencies would be able to identify those threatened with homelessness and act to prevent this happening
6. Do you agree to introducing a statutory duty on public bodies to prevent homelessness for anybody leaving an institution within six months?
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To an extent this happens already and protocols are in place for hospital discharges, childrens' homes, prison etc. So this would legislate for what is happening on the ground.
In Aberdeenshire Langstane Housing Association works with Aberdeenshire Council to provide 'taster' flats for those leaving care. The young person chooses where they wish to live and we provide the accommodation on a Short Scottish Secure Tenancy. Support is provided by the through care after care service. After six months the tenancy can be converted to a SST and another flat provided to the service. The success rate is high and homelessness is prevented.
In Aberdeenshire Langstane Housing Association works with Aberdeenshire Council to provide 'taster' flats for those leaving care. The young person chooses where they wish to live and we provide the accommodation on a Short Scottish Secure Tenancy. Support is provided by the through care after care service. After six months the tenancy can be converted to a SST and another flat provided to the service. The success rate is high and homelessness is prevented.
7. What would help public bodies to meet this requirement and how might it work in practice?
Please say what you think would help and how would it work in practice
Communication is essential.
The main barrier is data sharing. Langstane has recently met with ACVO and the local Health and Social Care Partnership in relation to a shortage of care workers in the sector. If information could be shared about who needs support then the housing associations (not just Langstane) can help with even a welfare call to prevent crises situations arising - so not just people being discharged from hospital but those going into hospital.
The same with people being discharged home - if information is shared then a shared approach will help with any crises.
The main barrier is data sharing. Langstane has recently met with ACVO and the local Health and Social Care Partnership in relation to a shortage of care workers in the sector. If information could be shared about who needs support then the housing associations (not just Langstane) can help with even a welfare call to prevent crises situations arising - so not just people being discharged from hospital but those going into hospital.
The same with people being discharged home - if information is shared then a shared approach will help with any crises.
Section 2: Prevention Review Group proposed recommendations for Health and Social Care
8. Do you agree with the proposal that Integration Authorities should identify the housing circumstances of people using health and social care services, and where necessary work with partners to ensure that service users are assisted into suitable housing or prevent the risk of homelessness?
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Please say why
Health and well being plays an important part in homelessness prevention. Identifying when this is an issue is essential as is working together with housing organisations including the private sector and other agencies which will assist with prevention.
9. Do you agree that a new legislative duty on Integration Authorities to identify housing circumstances of patients is the best way to prevent homelessness?
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Please say why
The legislative duty will assist with preventing homelessness. Is it more than just identifying that housing circumstances are an issue? Is it working closely with other agencies and not just making a referral for example and then having no further input.
10. Do you agree that the Integration Authority should have primary legal responsibility for meeting accommodation and support needs where cases are so complex that they cannot be met in mainstream accommodation even with support?
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Working with other agencies is important e.g. Cornerstone, Inspire and SAMH. So perhaps not the legal responsiblity for meeting accommodation and support needs perse but working with others to provide this.
11. How would the Integration Authority having primary legal responsibility where cases are so complex work in practice?
Please say how this would work in practice
As above - I think they would have to work with other organisations to make this work in practice
12. Do you think a duty on the Integration Authority would positively impact on preventing homelessness for people with a range of more complex needs?
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Please say why
There would be accountability
13. Do you agree with the proposal for a social worker or social care worker to have a duty to ‘ask and act’ about housing issues or the risk of homelessness?
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I think this is happening on the ground. Langstane for example often liaise with social workers if the tenancy is in jeopardy to prevent homelessness and resolve issues, particularly the criminal justice team
14. Do you agree that a duty to co-operate on the Integration Authority is the best way to ensure that people who are homeless or at risk of homelessness, as a result of unmet health or social care needs, get the support they need from health and social care services?
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Strongly Disagree
15. What changes to existing practice do you think local authorities and relevant health and social care services would have to make, to ensure they meet the needs of those leaving hospital and those with mental illness and impairment?
Please say what changes you think need to be made to existing practice
Not just local authorities. When an applicant is referred to a housing association there is also a need to make sure those with mental illness or impairtment are supported in order to sustain tenancies and prevent homelessness. Communication and sharing information is essential
16. Do you agree with the proposal that the local authority must provide assistance to anyone who is going to be discharged from hospital?
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Please say why
Perhaps not everyone but those who have no or unsuitable accommodation to go back to. The applicant is at a vulnerable point in their life and needs support. Saying this many local authorities already have hospital discharge protocols in place
17. What would be the main challenges of introducing a statutory duty on local authorities to house those due to be discharged from hospital within the next six months?
Please say what you think the main challenges would be
The main challenge is likely to be finding suitable properties which are adapted for the patient where required. When a suitable property becomes vacant the local authority can't hold the void for 6 months so timing and availablity will be a challenge.
Training GPs on homelessness issues may be a challenge given their workload
Training GPs on homelessness issues may be a challenge given their workload
18. Do you agree with the the proposal that GP practices are required to refer to local authorities where there is a risk of homelessness identified?
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I agree with the proposal but not sure how this would work in practice. GPs are not public authorities and with only minutes for a consultation how will they identify a risk of homelessness readily?
19. Are there any additional approaches that could be adopted by GP practices to better identify and respond to housing need?
Please say any additional approaches
More time and resource for GP's - perhaps a dedicated liaison officer within each practice who has knowledge of the homelessness legislation
Section 2: Prevention Review Group proposed recommendations for case co-ordination for people with multiple or complex needs
20. Do you agree with the proposal that a statutory duty to put a case co-ordination approach in place for people requiring input from two or more public services is the right approach?
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A lead person would be required to co ordinate services but I'm not sure this would necessarily be someone from a public service. For example if we think of the Housing First approach this could be a third sector agency - the important issue would be the buy in from all services to ensure the best outcome for the applicant
21. If this statutory duty is established, how would it work in practice? What challenges would it present and how could these be best addressed?
If this statutory duty is established, please say what challenges it would present and how could these be best addressed
This approach works well for housing first but the challenge would be ensuring buy in from all agencies
Section 2: Prevention Review Group proposed recommendations for Children's Services, young people and 16 and 17 year-olds
23. Do you agree with the proposal to establish a duty on health visitors or head teachers to identify a housing issue or risk of homelessness to a local authority?
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Strongly Disagree
26. Do you agree that a local authority, possibly in partnership with others, should have a family mediation service as part of its legislative duties to prevent youth homelessness?
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This would be useful. It would also be useful to provide information to young people in schools on homelessness
27. Do you think the proposal for 16 and 17 year olds would positively impact on the prevention of homelessness for young people?
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Positively Impact
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No Impact
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Negatively Impact
28. Could there be any ‘unintended consequences’ for 16 and 17 year olds in taking this approach to legislation? If so, how can this best be addressed so that any new legislation improves outcomes for 16 and 17 year olds at risk of homelessness?
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Yes, there could be 'unintended consequences'
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No, there could not be any
Section 2: Prevention Review Group proposed recommendations for domestic abuse
36. Do you agree that the set of proposed measures on domestic abuse are complementary to each other and consideration should be given to implementing them in full?
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37. Do you have any comments about the implementation of any specific proposal made in relation to preventing homelessness as a result of domestic abuse, and is there anything missing from these proposals?
Please say your comments, and if you think there is anything missing from these proposals
Womens' Aid organisations also have their part to play in the implementation of the domestic abuse proposals through training and can also support survivors of domestic abuse to access exclusion orders. Only by organisations working in partnership will the issue be addressed
Section 2: Prevention Review Group proposed recommendations for a local authority duty to respond to referrals
38. Do you agree with the proposal that there should be a statutory duty on a local authority to accept a referral from a public body to prevent homelessness, as part of legislative change that places a duty on public bodies to ‘ask and act’?
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Strongly Disagree
Section 2: Prevention Review Group proposed recommendations for social landlords
44. Do you agree with the new legislative duties to ensure social landlords take specified reasonable steps to prevent homelessness where a risk is identified?
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Disagree
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Strongly Disagree
Please say why
As a Registered Social Landlord, our current escalation policies for both arrears and anti social behaviour have a focus on a prevention first approach. Notification to a local authority via Section 11 protocols are in place but earlier notification may assist better with prevention. The Section 11 notifications are perhaps too late to be of real benefit. In my experience RSLs do everything they possibly can to prevent homelessness and so the impact of the notifications may be limited.
45. Are there any other reasonable steps apart from those listed that a social landlord should be legally obliged to take to prevent homelessness?
Please say any other reasonable steps
N/A
46. Do you agree with the proposal to legislate for the establishment of protocols by social landlords in relation to domestic abuse?
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Yes this is fine - protocols should include Women's Aid organisations who can provide enhanced support which the local authorities may not be able to provide.
47. Do you agree with the proposal to legislate for the establishment of protocols by social landlords in relation to where tenants face court proceedings?
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This is place for Section 11 notifications but as noted above will help if earlier notifications are made provided the local authorities have resources to assist
48. Given that landlords are already expected to notify local authorities of raising proceedings for possession, do you agree with a new legislative provision to ensure it happens earlier than under current arrangements?
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This will give the local authority time to consider the notification at an earlier stage
49. What further statutory measures beyond the existing Section 11 provision are needed so landlords notify and work with local authorities as soon as possible to prevent homelessness?
Please say what other statutory measures are needed
Noted above
50. At how early a stage should a landlord be expected to notify a local authority about the risk of homelessness?
Please say how early a stage
3 months
Section 3: Principles of the Prevention Review Group - reforming homelessness legislation to prevent homelessness
57. Do you agree with these principles?
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In my view these principles are currently working in practice - certainly in the North East.
Including this in the statutory framework will reinforce the commitment to reducing homelessness
Including this in the statutory framework will reinforce the commitment to reducing homelessness
58. Are there any other principles that should be included, if so, why?
Please say what other principles should be included, and why
N/A
59. What outcomes do you foresee if the above principles were to be adopted to amend the statutory homelessness framework?
Please say what outcomes you foresee
The outcomes would be clearer and measurable
Section 3: Changing the current homelessness legislation - meeting the needs of specific groups
73. Do you agree with the proposal for meeting the needs of specific groups?
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It's very important that organisations work together to ensure a smooth transition and services are provided throughout the process.
As an example protocals are already in place between Housing Associations and the local authorities in terms of nomination agreements and regular meetings take place. More information could perhaps be shared to support the applicant
For the groups mentioned and where homelessness cannot be prevented the transition to other accommodation has to be supported for vulnerable groups.
Once the applicant is housed by the Association for example support has to be in place to ensure the tenancy works and homelessness doesn't become a revolving door.
For any vulnerable group the main issues is accessing furniture / white goods and carpets - the start of the tenancy is the most important element of sustainment and prevention, particularly for those referred from the local authority. It's not just about choice but practicalities.
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As an example protocals are already in place between Housing Associations and the local authorities in terms of nomination agreements and regular meetings take place. More information could perhaps be shared to support the applicant
For the groups mentioned and where homelessness cannot be prevented the transition to other accommodation has to be supported for vulnerable groups.
Once the applicant is housed by the Association for example support has to be in place to ensure the tenancy works and homelessness doesn't become a revolving door.
For any vulnerable group the main issues is accessing furniture / white goods and carpets - the start of the tenancy is the most important element of sustainment and prevention, particularly for those referred from the local authority. It's not just about choice but practicalities.
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74. Is there anything you would add to these proposals that may strengthen legislative changes to prevent homelessness amongst specific groups?
Please say what you would add to these proposals to strengthen
Communication and data sharing protocals in place
75. Do you agree with these proposals on preventing homelessness for people experiencing domestic abuse?
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Disagree
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Strongly Disagree
Please say why
Protocals are already in place to deal with domestic abuse for many organisation. For example Langstane Housing Association works closely with Grampian Womens' Aid if we are aware of any tenants experiencing abuse. This is to provide support to remain in tenancies if this is the wish of the applicant. To widen this out and include the local authorities accessing exclusion orders is welcome as is the expansion of the definition.
About you
111. Are you responding as an individual or an organisation?
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Individual
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112. If responding as an organisation, what is the name of your organisation?
Organisation
Langstane Housing Association
115. If you are responding as an organisation, please indicate where your main responsibilities are:
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Housing and homelessness
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Health and social care
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Children’s services and young people
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Prisons
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Court services
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Police
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Domestic abuse
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Social landlord
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Private landlord