Memorandum from College of Occupational
Therapists (COT) (BDO 03)
1. SUMMARY
— Occupational Therapists recommend
the benefits of good practice in integrating individual tenants'
needs for improved accessibility, particularly with bathrooms
and kitchens, into housing providers' planned refurbishment programmes
carried out within the Decent Homes Agenda. Such practice needs
stronger incentives for housing providers in order for it to spread.
— The potential for the Housing Health
and Safety Rating System to identify, in particular, private sector
home owners who require improvements of accessibility to their
properties should be investigated further with a view to encouraging
good practice in this area.
— Local good practice in co-joining
DFG together with Home Improvement Loans and Warm Front funding
should be identified and disseminated more widely.
— In some cases, availability of funding
for home improvements as a loan may operate as a barrier to use
of Disabled Facilities Grant, particularly for home owners who
cannot or will not consider a loan. A systematic investigation
of the size of this problem is recommended.
— The London Housing Design Guide
is an example of locally developed guides which benchmark quality
in housing design and that would offer beneficial underpinning
some of the strands of Decent Homes Agenda over and above basic
criteria from mandatory regulations
2. INTRODUCTION
The College of Occupational Therapists (COT)
is pleased to provide a response to the Communities and Local
Government Committee's announcement of a new enquiry into; "Beyond
Decent Homes: decent housing standards post 2010" consultation,
which has been assisted by the COT's Specialist Section—Housing.
The College of Occupational Therapists is the
professional body for occupational therapists and represents over
28,000 occupational therapists, support workers and students from
across the United Kingdom.Occupational therapists work in the
NHS, Local Authority social care services, housing, schools, prisons,
voluntary and independent sectors, and vocational and employment
rehabilitation services.
Occupational therapists are regulated by the
Health Professions Council, and work with people of all ages with
a wide range of occupational problems resulting from physical,
mental, social or developmental difficulties.
The philosophy of occupational therapy is founded
on the concept that occupation is essential to human existence
and good health and wellbeing.Occupation includes all the things
that people do or participate in. For example, caring for themselves
and others, working, learning, playing and interacting with others.
Being deprived of or having limited access to occupation can affect
physical and psychological health.
3. INFORMATION AND
RECOMMENDATIONS
3.1 Housing Adaptations funded by Disabled Facilities
Grant (DFG) may seem to be a separate agenda to Decent Homes but
in practice, occupational therapists find that there is overlap
both to the benefit and detriment of their service users.
3.2 On the positive side, the College of Occupational
Therapists (COT), through its Specialist Section membership, has
experience of local authorities and Housing Associations in which
social housing programmes under Decent Homes and general repair
programmes include people's mobility and access needs within refurbishment
plans. As far back as 2003, a good practice case study now published
on the Department of Communities and Local Government website,
gave an example of a London based Arms Length Management Organisation
(ALMO) altering a bathroom to accommodate the tenant's wheelchair
during a Decent Homes programme.1
3.3 Occupational therapists commend good Local
Authority and Housing Association practice in which tenant's needs
related to disability are identified prior to the commencement
of major refurbishment programmes. Any specialist assessments
will be carried out at this point so that the tenant does not
have the upheaval of refurbishment followed by the upheaval of
an adaptation. The works are completed under one specification
and, by amalgamating costs of both aspects of the specification,
a lower final price may well result. Local agreements between
Housing Associations and Local Authorities on levels of provision
of adaptation could take this aspect of the Decent Homes agenda
into consideration to spread such good practice.
3.4 Aligning refurbishment programmes and improving
accessibility in and to people's homes is practice COT would recommend
as benefitting both tenants and public spending. However, with
current spending streams and performance indicators, there is
little incentive for Housing Associations and Local Authorities
to go to the extra organisational trouble involved in identifying
need and making extra assessments. This is due to an unintended
consequence of current funding through Disabled Facilities Grant
for "one off" adaptations which does not impact on housing
provider costs. Completing adaptations within the overall cost
of a refurbishment programme passes the cost to housing providers
with no compensation for bearing these costs. In addition there
is no recognition for this innovative way of meeting disabled
people's needs through quality audits within Decent Homes performance
measures. It is therefore unsurprising that in 2007, "very
few authorities were systematically building lifetime homes considerations
into their schemes, most dealing with these issues as adaptations
on a one off basis"2 and thus treating access needs as a
separate issue to Decent Homes activity.
3.5 In the private sector, occupational therapists
are aware of cases in which officers visiting home owners for
the Housing Health and Safety Rating System (HHSRS) or subsequent
Home Improvement Loans identify people in vulnerable households3
as in need of social care assessments and particularly assessments
leading to adaptations such as stairlifts and improvements to
property access. This may well be a result of change in focus
under the HHSRS system, directing the officer implementing the
tool to have a concern for potential occupants' experiences of
fall hazards on stairs, and uneven surfaces as well as excessive
cold. Local authorities report confusion over whether the person
they are to have in mind in administering the tool is simply an
imaginary subject or the actual occupant.4 This confusion may
have the inadvertent benefit of bringing the actual occupant's
situation more clearly into focus for the visiting officer. Again
this is local anecdotal practice and not mainstream. COT is not
aware of data collection and analysis on the relationship between
implementation of HHSRS and "referring on" practice
among officers carrying out this rating system. Systematic investigation
would provide evidence for disseminating this potential for practical
benefit in encouraging integrated 'health and housing' thinking
by front line workers.
3.6 Following the government drive to bring
non-decent homes up to standard in the social housing sector,
the private sector is now of concern. According to Housing Survey
Bulletin of January 2008, 3.2 million of the vulnerable households
are accommodated in other tenures than social housing, forming
43% of non-decent homes occupancy in comparison with 33% of social
households. Worryingly, the vulnerable households form a greater
tranche of non-decent homes occupancy than do non-vulnerable households
at 36%5
3.7 Loan products developed to support upgrade
of non-decent homes, particularly Home Improvement Loans, may
be used with Disabled Facilities Grants to add flexibility of
funding to the work needed e.g. Warm Front funding. For instance,
if the internal works to a property are deemed necessary and appropriate
to meet the disabled person's needs and are close to the Disabled
Facilities Grant limit; the cost of dealing with a Category 1
Hazard for the uneven surface on access to the property may be
dealt with under a Home Improvement Loan and still meet the disabled
person's access needs. This is purely a local decision to operate
co-joining of the DFG and Home Improvement Loan funding streams
for a specific case and whilst benefit accrues to the applicant,
no substantial incentive in terms of recognition is offered to
the local authority to encourage such creative approaches. A time
of economic uncertainty is likely to result in a retreat to the
known risks of the tried and tested rather than encourage new
and creative funding approaches unless there are counterbalancing
drivers from external support and encouragement.
3.8 On the negative side, bringing homes up
to Decent Homes' standard may be a barrier to using Disabled Facilities
Grants for some people. Category 1 hazards require mandatory action.
As described above, that may work to the disabled person's advantage
but where the product directed to meet access needs is a grant,
whilst the product directed to Category 1 hazards is a loan, the
disabled person may have reasons to refuse the loan with its charge
on the property. In that case the Disabled Facilities Grant will
normally not proceed—for instance it would be unreasonable
to install an electrically powered lift when the electrical wiring
is already unsafe.
COT is not aware of any systematic research
into the unintended impact of loan products as loans on the uptake
of associated grants, but bases this point on anecdotal experience
of individual members. Given the number of vulnerable households
in non-decent property cited previously, it is a point to be raised
and further systematic investigation of the extent of risk involved
would be useful.
3.9 Finally, it would also be helpful to ensure
the Decent Homes Agenda is not developed in isolation from other
home and neighbourhood design agendas. For instance, the new London
Housing Design Guide, currently under consultation (see London
Development Agency at http://lda-consult.limehouse.co.uk/portal),
has the laudable aim of benchmarking design and quality of London's
housing and thus is not a separate issue to the overall Decent
Homes agenda as it affects London. It would be helpful to integrate
the principles of such design guides, and London is by no means
alone in developing such guides, into the Decent Homes agenda
to take basic expectations beyond the regulated minimum for space
and accessibility.
REFERENCE PUBLICATIONS
FROM DEPARTMENT
OF COMMUNITIES
AND LOCAL
GOVERNMENT WEBSITE:
1 Decent Homes Case Studies (2003) Good Practice Guidance
2 Implementing Decent Homes in the Social Sector
(21/02/07) page 24
3 Making Private Sector Homes Decent (14/07/07)
4 Implementing Decent Homes in the Social Sector
(21/02/07) page 22
5 Housing Survey Bulletin. Issue Number 2 (January
2008)
August 2009
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