Health and Social Care Bill

Memorandum submitted by the Chartered Institute of Housing (CIH) and Northern Housing Consortium (NHC) (HS 118)

1. The Health and Social Care Bill provides an opportunity to embed a wider approach to the health and wellbeing of individuals and communities. As the bill currently stands, we think this broader approach could be compromised by the lack of inclusion of housing and other partners relating to the wider social determinants of health. This paper sets out proposed amendments which, we believe, would strengthen that integrated approach and result in:

· more comprehensive assessments of local needs;

· more effective integrated approaches to transforming public services;

· improved value for money in service delivery; and

· better outcomes for individuals and communities

2. We - CIH and NHC - are organisations that are committed to the benefit of communities through the best use of housing and related services. We believe that the benefits for communities can be more effectively realised where health and social care bodies also consider how, at a local level, they link their work with housing, to maximise on the benefits of decent and suitable housing to achieve better health and wellbeing.

The amendments we propose, and the reasoning/ evidence for the amendments, are listed below.

3.. Part 5 section 178 states:

Local authorities are required to establish a Health and Wellbeing Board for its area, to consist of:

At least one councillor of the local authority; Director of Adult Social Care; Director of Children’s Services; Director of Public Health; a representative of the local Healthwatch; representatives of each relevant GO commissioning consortia, and ‘such other persons, or representatives of such other persons as the local authority thinks appropriate’.

We request that this should be amended as follows:

To include explicitly ‘Director or designated senior manager with responsibility for housing from the local authority’ and, in two tier areas, this should be extended to include ‘Directors of Housing from partner local housing authorities’.

In addition we request that a power be inserted for the Secretary of State to produce regulations stating such other persons as s/he considers appropriate, to bring additional local expertise to the Health and Wellbeing Boards. This would allow the inclusion of such housing and other local experts, such as the Chief Executive of a local housing provider partner (ALMO or large scale voluntary transfer association) or a representative from any local housing provider fora.

4. Reason for amendment

4.1 The Health and Wellbeing Board will sit at the level of a unitary authority or, in two tier authority areas, at the county level. As such, the effectiveness of housing as a contributor to individual and community wellbeing has the potential to be missed from the expertise of the Board. The Bill allows for such other persons or representatives as the authority thinks appropriate, which in some areas may include Directors of Housing in district/ borough authorities. However, making the inclusion of housing discretionary to each local area will result in differentials in the level of inclusion of housing expertise and risks missing a key social determinant to the health and well being of communities.

4.2 The varied and patchy inclusion of housing as a partner for evidence and delivery can be seen in the evaluation of Joint Strategic Needs Assessments. Guidance advised health and social care to include housing bodies and their knowledge and understanding of local communities, but the actual level of inclusion proved varied and in many cases, extremely low. This was evidenced in a national evaluation by IDeA in 2009 [1] , and again in a regional evaluation by NHC [2] .

4.3 The current financial pressure on services, and the drive to transform public services to improve quality and choice, and increase individual and community involvement and control will require a more comprehensive and inclusive approach of all partners providing services in a local area, and that should start with needs assessment and understanding of communities’ and individuals’ aspirations. Involvement of housing will enable health and social care partners to widen their ‘reach’ into local communities and find new ways of addressing key health and social care agendas (such as prevention, more effective re-ablement etc). CIH’s report from 2009 [3] gives examples of where and how such strategic integration is beginning, and the benefits it achieves.

5. Part 5 section 176 relates to the duty of local authorities and GP commissioning consortia to prepare a Joint Strategic Needs Assessment and develop joint health and wellbeing strategies based on the most recent assessment. This and the strategy should then inform the way the partners meet local needs.

The amendment we request would:

· Ensure involvement of housing partners in the assessment of needs and ,

· Strengthen the role of the assessment and strategy in shaping local services.

Section 176 states that the commissioning consortia or responsible local authority ‘may consult any person it thinks appropriate’

We request an amendment to read ’must consult such persons as stated within current or future guidance’, to reinforce the inclusion of key local partners such as housing partners in the development of the JSNA, given their connection to and awareness of the needs of local communities reflect consideration of the guidance that currently exists.

6. Reason for amendment

6.1 The JSNA will be the primary process for identifying needs and will provide a transparent, evidence based rationale on which to base all local commissioning plans and decisions around investment and disinvestment. Guidance is quite clear that community partners, including housing, are amongst those best able to provide data and intelligence on the needs of communities especially those at risk of exclusion from health programmes, yet the research referenced above shows that the involvement of housing partners in JSNA has been limited. This provides the opportunity to reinforce the inclusion of wider partners to encapsulate the social determinants of health as well as medical/ clinical assessments.

7. Section 179 provides for a duty on the Health and Wellbeing Boards to encourage integrated working

(1) A Health and Wellbeing Board must, for the purpose of advancing the health and wellbeing of the people in its area, encourage persons who arrange for the provision of any health or social care services in that area to work in an integrated manner’.

This should be amended to read ‘encourage persons who arrange for the provision of any health or social care services in that area, or who arrange for the provision of services that support health and wellbeing, to work in an integrated manner.’

A power should be given for the Secretary of State to issue regulations or guidance on the extended range of services, which should include housing and related support services.

8. Reason for amendment

8.1 Decent housing and housing related support services have been recognised as supporting health and social care policy and practice and in providing considerable benefits, including financial savings, for both sectors. It is important that services which support the delivery of health and social care outcomes are also included in a local integrated approach. Integrated working across health, social care and housing is promoted widely in government publications such as ‘No Health without mental health’ and ‘A Vision for adult social care’. A failure to reinforce this in the Bill could result in a risk that opportunities may be lost to maximise the impact of joint working across housing, health and social care.

March 2011

[1] IDeA (2009) Joint Strategic Needs Assessments: Progress so far

[2] NHC/ Integrated Living Network (2009), JSNA and Housing: a review of Northern approaches

[3] CIH/ NHS Housing LIN (2009), Housing, health and care