Care Bill [Lords]

Written evidence submitted by Imogen Parry (CB 03)

The case for including housing as a statutory member of Safeguarding Adults Boards

From: Imogen Parry, Independent Safeguarding Adults Consultant, Researcher and Trainer for the Housing Sector



My background includes: social work, social policy lecturing, older people’s housing policy, chairing a national charity promoting sheltered housing (erosh) and publishing 6 good practice guides on sheltered housing.

I currently specialise in adult safeguarding research, consultancy and training and have just completed the MA in Safeguarding Adults: Law, Policy and Practice at Keele University. I have published eight articles this year on housing and safeguarding (Parry, 2013 a-h) and spoken at several conferences on the subject.

My MA dissertation on ‘Adult Serious Case Reviews: lessons for housing providers’ (for which I was awarded a distinction, and which is due to be published, abridged, next year in the Journal of Social Welfare and Family Law) provides much of the evidence base for this submission, along with the outcome of my survey this year of Independent Chairs of Safeguarding Adults Boards (SABs) regarding the extent and benefits of housing representation on SABs. My research has contributed to the forthcoming Department of Health commissioned Social Care Institute for Excellence (SCIE) guide on housing and safeguarding.



This submission supports the case for the inclusion of a new Clause in the Care Bill requiring housing representation on SABs. It argues that this would:

· encourage greater leadership and involvement by housing staff in adult safeguarding

· improve the quality of Serious Case Reviews/Safeguarding Adults Reviews

· contribute to wider agendas including prevention and awareness raising, domestic abuse, crime, hate crime, self-neglect, hoarding, anti-social behaviour, poverty

· reach into local communities, address professional boundaries, reinforce that safeguarding is everyone’s business, contribute funding, involve housing in the development of policy

· improve joint working between housing and adult social care.

The submission suggests solutions to the problem of achieving housing representation in two tier authorities.


Joint Committee on the Draft Care and Support Bill

I submitted written evidence to the pre-legislative scrutiny committee of the Care and Support Bill (Joint Committee on the Draft Care and Support Bill, 2013, p. 103), recommending that housing should be added to several clauses, including to: the list of partners (Clause 4 – Co-operating generally); the list of statutory members of SABs (Clause 35, Schedule 1).

That committee accepted both of these recommendations, quoting my evidence on partners (Joint Committee on the Draft Care and Support Bill, 2013, paras.118, 119, p. 33) and SABs (para.163, p. 42).


Care Bill

The Government rejected these (and several other) recommendations about housing in its response (Department of Health, 2013). However, during the subsequent passage of the Care Bill through the House of Lords, clauses about housing as partners were successfully introduced as amendments (Clause 6 (3) (d); Clause  6 (4) (b)). However, the recommendation that housing should be included in the list of statutory members of SABs was not pursued. This submission focuses on the case for reconsidering this.


The Government’s case for the rejection of housing representation on SABs

The Government stated in their response to the recommendations of the Joint Committee on the draft Care and Support Bill that ‘We have intentionally restricted core statutory membership to a few core public bodies, leaving local areas with maximum flexibility whilst securing the statutory position of adult safeguarding. We anticipate and expect membership to be far wider. We would be most concerned if SABs did not address the role, contribution and responsibilities of housing providers in adult safeguarding. We would also expect SABs to draw on the housing sector for in-put, collaboration and advice. Government will not dictate how this happens, as this will depend on local circumstances, which vary widely across the country. For example, in some areas the SAB may operate sub-groups, including one devoted to housing-related issues that reports back to the main Board’ (Department of Health, 2013, p.67).


The case for the inclusion of housing representation on SABs

There are several arguments to be made for the inclusion of housing representation on SABs:


To encourage the engagement of housing in adult safeguarding

I have written elsewhere (Parry, 2014, forthcoming) that ‘had the recommendations on the inclusion of housing on SABs been accepted (by Government), they would have been the most likely to increase the involvement of housing providers in adult safeguarding in general, and in improving the quality of housing related Serious Case Reviews in particular’.

I consider that the inclusion of housing on SABs would help to encourage housing providers to take safeguarding more seriously, in the absence of other legislative and regulatory requirements on housing providers to engage in safeguarding (Parry, 2013a, p.16). Housing providers currently under-report abuse, largely due to lack of staff training on signs and indicators which is due to lack of strategic leadership by senior housing managers. I have argued elsewhere that less than one in a hundred cases of abuse are referred by housing staff into social services adult safeguarding procedures (Storr, 2013a,b).

Up to a half of tenants of general needs social housing are vulnerable, yet most staff training has been focused on those working only with tenants living in sheltered and supported housing (Parry, 2013a, p.16). Half of all the murdered, abused and neglected individuals who were the subjects of the housing-related SCRs studied for my dissertation lived in general needs housing, the other half lived in sheltered and supported housing (Parry, 2014, forthcoming).

Serious case reviews have indicated that housing providers could or should have played a more effective role in adult safeguarding. My dissertation research concluded that housing providers should improve:

· data bases of all tenants ensuring that vulnerabilities are identified

· support and contract monitoring involving vulnerable tenants

· awareness of safeguarding by all staff and ensure effective reporting of abuse (Parry, 2014, forthcoming).

There is growing recognition that all front-line housing staff are ideally placed to prevent, detect and report abuse. Evidence of increased Government recognition of the potential of all housing staff is demonstrated by the Department of Health commissioning:

· PASAUK to run a workshop on housing and safeguarding (PASAUK, 2013))

· Social Care Institute for Excellence to produce a guide on housing and safeguarding (SCIE, 2014, forthcoming).


Improve the quality of Serious Case Reviews (SCRs)

My dissertation research on published housing related SCRs (Parry, 2014, forthcoming) commented on the poor quality of 8 of the 21 SCRs studied. The defects included:

· inadequate detail on the role or actions of housing providers

· a lack of awareness of the Quality Assessment Framework requirements under the Supporting People programme

· a disconnection between the findings and the recommendations for housing

· no reference to how the implementation of recommendations would be monitored.

I suggest therefore that the presence of housing representation on SABs would ensure that housing representation on any SCR (to be replaced by Safeguarding Adults Review) panels would be likely to prevent these deficiencies in the future.


Other perceived benefits of housing representation on SABs – evidence from current Independent Chairs of SABS

In April this year, I surveyed, via email, all 63 independent Chairs of SABs and received responses from 17 individuals who chair 26 SABs. All but two of these 26 SABs had housing representation on the Board. The Independent Chairs stated that the benefits of housing representation on their SABs included:

· Contribution to wider agendas including: prevention and awareness raising, domestic abuse, crime, hate crime, self-neglect, hoarding, anti-social behaviour, poverty

· Reaching into local communities

· Addressing professional boundaries, reinforces that safeguarding is everyone’s business

· Engaging with Serious Case Reviews

· Contributing funding

· Involving housing in the development of policy, practice, improvement plans. (PASAUK, 2013).


Improve joint working between housing and adult social care

My dissertation research on housing related SCRs found that housing providers are inhibited in their effectiveness in adult safeguarding due to:

· Barriers to information sharing, often caused by negative attitudes towards housing staff

· High referral thresholds by adult social care

· Failures of risk and capacity assessment and diagnosis by adult social care (Parry, 2014, forthcoming).

The presence of housing providers on SABs could help to address these barriers at a senior and strategic level.


Overcoming difficulties in the two tier authorities

One argument put forward to support the case against housing representation on SABs is that, particularly in the two tier authorities, it is too difficult to secure district council representation (there could be up to 10 such councils) and housing association representation (there could be dozens). I consider that this is not sufficient reason to abandon the goal of housing representation on all SABs. My own advice to SAB chairs and others regarding this issue is: secure one committed senior district council rep who can speak for all of them in the county AND secure one committed senior housing association rep who can ‘represent’ (in the loosest sense) housing associations across the county – find this person through existing cross county housing forums of chief officers; ensure good channels of communication between these representatives and those they are representing.



‘The role of housing in preventing and addressing adult abuse is neglected in legislation, policy, practice and research’ (Joint Committee on the Draft Care and Support Bill, 2013, para.163, p.42, quoting my written evidence to that committee).

The inclusion in the Care Bill of a Clause requiring housing representation on SABs would address not only the first of these neglected areas (legislation) but would also improve policy and practice. The change argued for in this submission would have a lasting, symbolic and significant impact on the protection and safeguarding of adults at risk and I urge the Committee to consider the arguments made.


The Care Bill [HL] Bill 123. Published 31.10.2013. As brought from the Lords.

Department of Health (2013), The Care Bill Explained: Including a response to consultation and pre-legislative scrutiny on the Draft Care and Support Bill, Cm 8627, 10 May 2013. London: Stationery Office Ltd.

Joint Committee on the Draft Care and Support Bill (2013), Draft Care and Support Bill, HL 143, HC 822, Session 2012-13 . The Stationery Office: London.

Parry (2013a) ‘Adult safeguarding and the role of housing’, Journal of Adult Protection,(1), pp.15-26.

Parry (2013b) ‘How social workers can help housing staff understand safeguarding’, Community Care, 2.4.2013.|SCSC|SCDDB-20130402-GLOB|news .

Parry (2013c) ‘Adult safeguarding – the need for all staff to engage’ in Thornhill, J.(ed.) ‘Learning today, leading tomorrow – skills and learning for the housing industry of the future’, Coventry, Chartered Institute of Housing. % 20download%20pdfs/Learning%20today%20leading%20tomorrow/05%20Adult%20safeguarding%20Parry.pdf .

Parry (2013d) ‘Hidden agenda’ Inside Housing. 26.7.2013.

Parry (2013e) ‘Adult safeguarding: engagement issues for housing providers’. SITRA bulletin.

Parry (2013f) ‘The need for adult safeguarding specialists within all housing organisations’. CIH blog.

Parry (2013g) Adult safeguarding – towards better outcomes’ Nuisance News. Social Landlords Crime and Nuisance Group.

Parry (2013h) ‘Housing and adult safeguarding’. Information pack. Housing Learning Improvement Network.

Parry (2014) ‘Adult Serious Case Reviews: lessons for housing providers’ Journal of Social Welfare and Family Law (forthcoming).

PASAUK (2013) ‘Report of a workshop ‘Adult Safeguarding and Housing’ London, 4 June 2013’. Sponsored by the Department of Health. Authors: Imogen Parry and Pete Morgan'Adult%20Safeguarding%20and%20Housing'%20final%20pdf.pdf

SCIE (2014) ‘Safeguarding Guide for the Housing Sector’ (forthcoming).

Spurr, H. (2013a) ‘Workers fail to report abuse’ Inside Housing, 22.11.2013.,201BE,7UMPOP,774OF,1

Spurr, H. (2013b) ‘Under the Spotlight’ Inside Housing, 26.11.2013.,20CRC,7UMPOP,78AOQ,1

January 2013

Prepared 10th January 2014