Written evidence submitted by Papworth
Trust
EXECUTIVE SUMMARY
1. Papworth Trust is concerned at the proposals
to reduce Housing Benefit to 90% for claimants of job seekers
allowance of one year or more. This will impact greatly on tenants
and housing associations, with no clear guidance about what assistance
will be provided to those who are unable to make up the shortfall
in rent. Whilst we understand the principle behind this measure
is to encourage benefit recipients into the labour market, this
penalty offers no support to those vulnerable people who are genuinely
struggling to find work.
2. For a long time Papworth Trust has been concerned
about the outcomes of the Work Capability Assessment (WCA) which
suggest it is a flawed assessment. Our concern was further compounded
by the announcement of changes to Housing Benefit. We believe
the WCA has so far demonstrated its inability to correctly assess
the fitness to work of particular groups, including people with
mental health issues, fluctuating conditions and learning disabilities.
We are concerned that vulnerable people are being wrongly placed
onto Jobseeker's Allowance (JSA) meaning they receive a lower
sum of benefits and less support to find employment, and it will
now have a significant impact on their housing benefit after the
first twelve months. Until the failings of that assessment are
corrected, we do not believe other parts of the benefits system
should be linked to its outcome.
3. When responding to this inquiry Papworth Trust
believes that other changes in the welfare reform agenda must
also be taken into account such as the moves to a single benefit
system. At present, Housing Benefit recipients have the option
to request that their payment is directly sent to their landlord.
We believe this is an important feature which many recipients
opt to take up, given it removes the temptation to spend their
rent money elsewhere. We believe this right to request must be
retained in the development of any future system.
DETAIL
Reductions in Housing Benefit for tenants in receipt
of Jobseekers Allowance for more than 12 months
4. Papworth Trust is concerned that the proposal
to reduce Housing Benefit to 90% for JSA claimants of 12 months
is regressive. This will impact greatly on tenants and housing
associations, with no clear guidance about what assistance will
be provided to those who are unable to make up the shortfall in
rent. Whilst we understand and fully support the principle behind
this measure to encourage benefit recipients into the labour market,
this penalty offers no support to those vulnerable people who
are genuinely struggling to find work.
5. According to the Office for Disability Issues[40]
disabled people are far less likely to be in employment. Although
there have been significant improvements in the employment rates
of disabled people in the last decade, the employment rates of
disabled people are around 47%, compared with around 77% of non-disabled
people. Given the economic downturn, we already experience a large
number of job seekers applying for any vacancy. We are concerned
that the measure to reduce housing benefit after one year is punitive
and offers no support to vulnerable people into work in these
difficult times.
6. Under the proposals it remains unclear what
assistance the Government will provide those tenants who are unable
to make up the sudden shortfall in rent, and what assistance will
be given to housing associations who will potentially experience
an upsurge in arrears. Unless we can be sure there are appropriate
jobs available, the number of people needing support will rise.
Housing Benefit claimants will be faced with a clear choice: either
go into debt or move. Moving is not cost-free or always possible;
therefore the option will be harder to reach for those who do
not have sufficient funds. For the housing provider, we and other
housing associations will be faced with the additional cost burden
entailed with collecting arrears.
Work Capability Assessment
7. Papworth Trust is extremely concerned with
the failings of the current Work Capability Assessment, the assessment
by which claimants are placed on either JSA or Employment and
Support Allowance (ESA). We believe many disabled people are being
wrongly placed onto JSA, meaning they receive less money and support
to find work. We believe the assessment is based entirely on a
person's physical capability and is unable to recognise the impact
of learning disabilities, fluctuating conditions or mental health
issues. We have vast experience of clients being wrongly assessed,
confirmed by the DWP's own statistics[41]
and the high volume of claimants winning appeals against their
decision. Our concerns are further compounded by the realisation
that this assessment will now have far reaching consequences to
other benefits than originally anticipated.
8. In July 2010, Papworth Trust chaired a roundtable
discussion with other disability charities and employment providers
to share our concerns about the WCA outcomes. As a result, Papworth
Trust will be leading an industry-wide submission to Professor
Malcolm Harrington's independent review of the Work Capability
Assessment.
9. Papworth Trust urges the Government to delay
the proposal to reduce housing benefit until the WCA has been
reviewed and changes are implemented. If it is not delayed, we
feel the housing benefit reduction would fall disproportionately
on the most vulnerable people in society.
21st Century Welfare
10. Papworth Trust welcomes the principles behind
moving to a single benefit system, and will be responding separately
to the DWP's consultation on "21st Century Welfare".
We support the moves towards an integrated system, given the current
one is disparate, and both confusing to understand and administrate.
11. In designing the move to a single benefit
system Papworth Trust urges the Government to retain the option
which allows Housing Benefit recipients to have their rent paid
directly to their landlord. We encourage our tenants to opt for
their Local Authority to pay their rent to us directly, believing
that this removes the temptation to spend rent money on other
things. In the longer term, entering rent arrears not only causes
financial difficulties but can mean that a tenant is unable to
move until the arrears are cleared.
16. Papworth Trust believes the introduction
of a Transition into Work payment should help ease the move into
work. We would urge the Government to use this opportunity of
reviewing the current system, to ensure that the continuation
of benefits from being "out of work" to "in work"
is made automatic. The delay time for "In Work Benefits"
commencing, specifically Working Tax Credits, tends to be anything
between four and eight weeks. When completing a Better Off Calculation
with clients to encourage them to return to employment, the difference
between it being viable financially or not usually depends on
them being in receipt of Working Tax Credit. Therefore we often
find that with the current one-month Housing Benefit run on, it
is sufficient for the first month but it can be financially difficult
by the second month. Consequently an extension to the period they
remain on Housing Benefit would be highly beneficial and allay
some of the concerns of our client group.
17. Papworth Trust believes that the extension
of Housing Benefit for three months is the right length of time
and should ensure that Working Tax Credit is up and running. We
do not believe that a three month period would encourage cyclical
unemployment for customers claiming Incapacity Benefits or ESA.
Instead, we believe that a three month run-on would be a welcome
support mechanism whilst they await their first wage slip and/or
Working Tax Credit payment.
CHANGES TO
THE LOCAL
HOUSING ALLOWANCE
(LHA)
18. As a social landlord, the changes to Papworth
Trust's rents are dictated through the Government's rent formula[42].
At present, the rent formula and the Local Housing Allowance (LHA)
are entirely separate. Therefore from a purely price perspective,
we do not expect to be affected by the proposed changes to LHA.
19. The Committee will be aware that LHA is paid
to low income households who are renting a room or property from
a private landlord. LHA is therefore designed to help those people
who are unable to live in social housing, perhaps due to a lack
of suitable social housing in that area. We are therefore concerned
that any moves to reduce LHA will create an unmanageable increase
in demand for social housing for that local rental area.
20. If LHA is reduced, tenants will be required
to make any shortfall in their rent. If they are unable to do
so, they will need to look for a new property. This will lead
to increased demand for affordable housing. Unless the Government
matches its plans to reduce LHA with plans to create more affordable
housing, the rented market will not be able to cope. Papworth
Trust is concerned that standards may slip within the unregulated
private market, and people will be forced to move to cheaper areas
and further away from employment centres, falling heavily on the
most vulnerable in society.
21. Whilst the Government is considering sweeping
changes to Housing Benefit, Papworth Trust believes it is time
to consider plans to introduce regulation to private landlords.
We are aware there are many private landlords in existence who
have a much greater housing stock than ourselves, some reaching
over 1,000 properties. Combined with this they may also target
specific and vulnerable groups, including older people, and it
is vital there are measures in place to protect these groups.
Drawing on our own experience, we see that the majority of vulnerable
people living in unsuitable accommodation are private tenants,
not with social landlords. We would therefore argue that these
tenants need protecting as much as, if not more than, social housing
tenants do.
DEDUCTIONS FOR
NON-DEPENDENTS
22. Papworth Trust agrees with the concept behind
the proposals to bring deductions for non-dependents in line with
inflation, but would like more detail on how this change will
be implemented and how the Government will work to ensure the
result does not fall disproportionately on housing associations.
We have made the assumption that non-dependents will be earning
and therefore contributing towards the household costs. Therefore
it is only right that Housing Benefit should be reduced to take
account of this. However, we would urge the Government to introduce
this increase gradually over a number of years. We predict any
shock in changes to income may cause unnecessary problems for
housing associations that will be forced to recoup any housing
arrears from this.
HOUSING ENTITLEMENTS
AND THE
ISSUE OF
SOCIAL MOBILITY
23. Papworth Trust is sceptical about how plans
to better reflect the family size for working age people in the
social sector will work in practise. Reducing overcrowding must
always be a key priority; however more detail is needed as to
how the Government plans to set the criteria and offer incentives
to existing tenants to move. In our experience, there is not a
deluge of one and two bedroom properties on the market. Therefore
how will we incentivise existing tenants to move, if there are
no desirable properties into which they can move?
24. Papworth Trust is concerned that the Government
has started its thinking with the underlying assumption that everyone
has, or has the capability of having, social mobility across the
housing sector. This is simply not true of the current social
rented housing market. Lettings policies prioritise applicants
according to key criteria (including whether a person is homeless,
problems of overcrowding and other "urgent needs") and
it is based on these criteria that a decision will be made on
who will receive an offer of a property. In addition to this policy,
tenants are often required to prove that they have a local connection—either
working within the area, having lived in the area for at least
six months, or having family members who have been resident in
the area for a significant period of time. Until these robust
criteria are reviewed, and possibly relaxed, it will be difficult
for tenants to ever have true 'mobility' within the social housing
sector.
25. Disabled people often have additional barriers
to overcome in requesting a move, which has been termed in the
past as the rules of "ordinary residence". Disabled
people can be prevented from moving home or moving from residential
care to independent living because such a move must be agreed
by their Local Authority of origin as to whether they will continue
to support and pay for their care needs. They are entirely at
the mercy of their Local Authorities.
26. We believe there is also an age-related consideration
that needs to be taken into account. In our experience, older
people tend not to want to face the upheaval of moving and in
practise there is an upper age limit which will need to be considered.
27. Until all of these considerations are reviewed
and clear proposals are put in place to overcome them, Papworth
Trust does not believe the Government will achieve its ambitious
view of social mobility in the social housing sector.
ENTITLEMENT FOR
AN EXTRA
BEDROOM FOR
NON-RESIDENT
CARERS
28. Papworth Trust welcomes the proposal which
will see disabled people who need a non-resident carer entitled
to funding for an additional bedroom. This is long overdue. We
have campaigned for the system to recognise the role of the non-resident
carer; the house is their place of work and being asked to sleep
on the sofa is unacceptable.
29. We believe this proposal presents an opportunity
to go a step further with a fuller review of the fair size criteria
to recognise that disabled people need to occupy a property that
is fully accessible to their needs. By example, disabled people
may require additional rooms to meet their medical needs or to
accommodate additional storage demands. The fair size criteria
needs to be more flexible and go beyond the current policy of
looking at the number of people living in that property.
3 September 2010
40 Office for Disability Issues website, key facts
and figures for employment. Back
41
DWP: Employment and Support Allowance: Official Statistics, July
2010 Back
42
Currently set at RPI +/- 2%. Back
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