MD3204 Rough sleeping services for newly recognised refugees

1.1.    A total of 10,053 people were seen sleeping rough in London during 2022-23. This is a 21 per cent increase compared to 2021-22. Of these, 64 per cent were new to the streets; 16 per cent were returning to rough sleeping after not being seen in the previous year; and 51 per cent were non-UK nationals. Additionally, 71 per cent had support needs, of which 51 per cent related to mental health; 31 per cent to alcohol; and 32 per cent to drugs.
1.2.    In his 2018 London Housing Strategy, the Mayor set out his aim for a sustainable route off the streets for every rough sleeper in London. In June 2018 he published his Rough Sleeping Plan of Action, which outlines the steps that must be taken by City Hall, government and others to achieve this aim. In 2021, the Mayor refreshed his Rough Sleeping Commissioning Framework, which sets out the overarching and cross-cutting priorities underpinning the GLA’s commissioning activities from 2021 to 2024. 
1.3.    Since taking office, the Mayor has been expanding the pan-London rough-sleeping services that the GLA funds and commissions. These services – collectively forming the GLA Rough Sleeping programme – are for people with experience, or at risk, of sleeping rough. They are initiatives to tackle rough sleeping that cannot or would not be provided at a London-borough level, as they either meet a very specific need or deliver at the pan-London/multi-borough level. Since 2016, the GLA Rough Sleeping programme has supported over 16,000 people to leave the streets for good. 
1.4.    Data from the Combined Homelessness and Information Network (CHAIN) shows that between January and June 2023, 111 people rough sleeping in London had Home Office provision as their last recorded settled base. This figure has increased significantly following changes by the Home Office to cessations of asylum support in August 2023; between August and October 2023, there were 237 new rough sleepers whose last settled base, or last accommodation, prior to rough sleeping was recorded as asylum support accommodation.
1.5.    The Home Office changes include: the acceleration of asylum decision-making via the Streamlined Asylum Process (SAP) (meaning more decisions are being made at a faster rate); the reduction of the minimum ‘notice to quit’ period for asylum support from 28 to just seven days restricting the time people have to secure alternative accommodation; and asylum decisions being served to people in London-based asylum contingency hotels, in addition to outer-London dispersal accommodation. This means that more people are being evicted from asylum accommodation in London – the majority of whom will not be in priority housing need, and so will have limited housing options available to them. This puts them at risk of homelessness and sleeping rough. This is likely to continue as SAP decisions are made at scale and pace, further intensifying winter pressures for local authorities and frontline services. 
1.6.    The GLA Rough Sleeping programme is funded from the core GLA budget, supplemented by various government grants – such as the Department for Levelling Up, Housing and Communities(DLUHC)’s Rough Sleeping Initiative (RSI). The following Mayoral Decisions (MDs) pertain to this programme: 
•    MD2559 (March 2020) approved receipt and expenditure of £4.67m in government funding to expand various core services, and develop initiatives for non-UK national rough sleepers.
•    MD2789 (March 2021) approved expenditure of £13.69m of GLA Rough Sleeping programme budget to extend various core services up to March 2025; and £1.36m to continue to grant-fund various projects. It also approved receipt and expenditure of £6.66m in government funding, which included the continuation of several RSI projects. 
•    MD2853 (August 2021) approved receipt and expenditure of £24.55m in government funding, and expenditure of £0.17m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD2957 (March 2022) approved receipt and expenditure of £3.65m in government funding, and expenditure of £3.85m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD2993 (June 2022) approved the receipt and expenditure of £30.38m from the DLUHC’s RSI. 
•    MD3043 (December 2022) approved the receipt and expenditure of £0.54m in government funding, and expenditure of £1.25m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD3089 (March 2023) approved the receipt and expenditure of £0.2m from the DLUHC’s RSI, and expenditure of £0.1m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD3135 (June 2023) approved the receipt and expenditure of £3.61m from the DLUHC’s RSI; £0.05m from the DLUHC’s Controlling Migration Fund; and expenditure of £16.36m from the GLA’s Rough Sleeping Programme Budget, to fund core services and various projects. 
•    MD3161 (August 2023) approved the receipt and expenditure of £1,159,311 from the DLUHC’s RSI, receipt and expenditure of £144,535 from London Councils, and expenditure of £97,165 from the GLA Rough Sleeping programme budget, to fund core services and various projects.
Activity and funding profile 
1.7.    This decision seeks approval of funding for two new elements of the GLA Rough Sleeping programme. 
1.8.    The newly approved expenditure will be as follows: 

1.9.    Details of the services/projects in the above table, and a more detailed breakdown of the funding mechanisms and budget, are set out in section two. 
1.10.    This funding was allocated to the South East and North East London sub-regions across 14 boroughs from the DLUHC’s recently launched Move-On and Prevention funding, as part of the RSI programme. The GLA is receiving onward grant for the purpose of additional support for newly granted refugees at risk of, or experiencing, rough sleeping. A Memorandum of Understanding between the GLA and each council will be signed which confirms this agreement. 
1.11.    The GLA already delivers a variety of specific services and initiatives to support non-UK nationals to find a sustainable route off the streets. These include the following:
•    The Sub-regional Immigration Advice Service, which coordinates access to immigration advice through the London sub-regions so that all local authorities in London can ensure that people sleeping rough can access good-quality, independent immigration advice through efficient and joined-up services.
•    The Migrant Accommodation Pathways Support service, which supports any non-UK nationals sleeping rough, or at immediate risk of doing so, across London. They work to identify and clarify clients’ entitlements and accommodation options; and work with other professionals to help them out of homelessness.
•    The London Homelessness and Migrant Sectors Training Programme, which upskills the homelessness and migrant sectors to better support non-UK nationals sleeping rough in London.
•    There is also specific support for Roma communities delivered through the Roma Rough Sleeping Team, and a toolkit for those working with migrants in need of substance-misuse support.
 

2.1.    The GLA Rough Sleeping programme focuses on achieving the Mayor’s vision for everyone sleeping rough to have a sustainable route away from the streets. The programme is underpinned by the overarching priorities, set out in the pan-London Rough Sleeping Commissioning Framework 2021, and to be achieved by working with boroughs and partners. These priorities are: 
•    to prevent people from sleeping rough 
•    to provide an immediate route off the streets 
•    to deliver sustainable accommodation and solutions for those leaving rough sleeping, to ensure people have the support they need to rebuild their lives. 
2.2.    The Rough Sleeping Commissioning Framework also includes the cross-cutting priority to provide specialist advice and support for migrants who are sleeping rough.
2.3.    In 2022-23, non-UK nationals made up 51 per cent of people sleeping rough in London. Recent CHAIN data shows a substantial increase in non-EEA nationals, with a record number of 476 non-EEA nationals recorded as sleeping rough in September 2023. The funding approved by this decision will support the commitment to ensuring that all of the Mayor’s rough-sleeping services play a role in addressing the needs of migrant rough sleepers.
2.4.    In November 2023, the Royal Borough of Greenwich and the London Borough of Redbridge secured funding from the DLUHC’s RSI Move-on and Prevention Fund on behalf of the South East and North East sub-regions. A proportion of this fund is being onward-granted to the GLA to deliver two specialised sub-regional schemes for newly recognised refugees experiencing, or at risk of, rough sleeping. The funding will be spent in full in 2023-24. 
2.5.    Access to these schemes will be shared across the North East sub-region (Barking and Dagenham, City of London, Hackney, Havering, Newham, Redbridge, Tower Hamlets, and Waltham Forest) and the South East sub-region (Bexley, Bromley, Greenwich, Lambeth, Lewisham and Southwark). The North East sub-region will take 75 per cent of the referrals, and South East 25 per cent. This is based on the proportionate value of each sub-region’s contribution to the project. 
2.6.    Further details of the individual schemes for which approval is being sought under this MD are set out below. 

Refugee Council – PRS Access Scheme
2.7.    The primary aim of the Refugee Council PRS Access Scheme is to support 60 newly recognised refugees who have exited Home Office asylum support accommodation, and who are sleeping rough, or are at immediate risk of doing so, into PRS housing. The Refugee Council is a trusted partner and has successfully been delivering its own well-established PRS service delivery models since 2012. Given the acute need evidenced in the sharp rise in rough-sleeping numbers, the Refugee Council is considered to be best placed to mobilise an effective service, at pace, to address the immediate need during winter. 
2.8.    London's housing crisis means there is a large shortage of affordable homes. In the private rented sector, affordability issues have been compounded by a significant increase in rents seen in recent years. Existing PRS access barriers are further exacerbated for newly-recognised refugees who are transitioning out of Home Office accommodation, requiring sizeable deposits, advance rent payments, references and other supporting documents, all within a minimum seven day period, and without previous experience of renting in the UK. This puts them at increased risk of homelessness and rough sleeping.
2.9.    The scheme will equip individuals with the tools to independently find a home. Forty of them will be supported to secure private rented tenancies through the direct provision or facilitation of rental deposits, or negotiation with landlords to remove rental deposits. 
2.10.    The Refugee Council has been supporting refugees to enter the PRS in London since 2012. They engage landlords and vulnerable refugees to find safe and suitable long term-housing, which in turn supports people to integrate into their new community and rebuild their lives in safety. This additional funding will expand the Refugee Council’s scheme to support those who are experiencing, or at risk of, homelessness in London after the cessation of asylum accommodation.
2.11.    This MD therefore seeks approval of expenditure of £165,000 of the funds received from the Royal Borough of Greenwich and the London Borough of Redbridge, by grant to the Refugee Council in 2023-24.

Housing Justice – Supported Lodging Scheme 
2.12.    Housing Justice’s own supported Lodging Scheme will provide short-term accommodation for newly recognised refugees who have exited Home Office asylum support accommodation and are sleeping rough or at risk of doing so. The scheme aims to accommodate 36 individuals; and provide them with support detailed at paragraph 2.13 during six-month placements. Housing Justice is a trusted partner, and is already successfully delivering well-established supported lodging services. Given the acute need evidenced in the sharp rise in rough-sleeping numbers, Housing Justice is considered to be best placed to mobilise an effective service at pace to address the immediate need during winter.
2.13.    The Supported Lodging Scheme will match up potential landlords (private households with a spare room) with newly recognised refugees. The Housing Justice Emergency Accommodation Team will support placements by: 
•    recruiting and vetting prospective landlords, including DBS checks, home visits, references, property safety standards
•    ensuring that safeguarding of the lodger and the household is managed 
•    handling referrals from partner agencies into the scheme
•    matching between landlord and lodger
•    providing a framework for agreement between landlord and lodger (lodging agreement)
•    overseeing the placement and managing any issues occurring
•    facilitating incentive payments to the landlord
•    supporting move-on plan for lodger.
2.14.    The scheme is designed for people with low support needs who will be able to use the six-month placement to work on securing longer-term accommodation options. 
2.15.    This MD therefore seeks approval of expenditure of £165,840 of the funds received from the Royal Borough of Greenwich and the London Borough of Redbridge, by grant to Housing Justice, in 2023-24. 
 

3.1.    Under section 149 of the Equality Act 2010, as public authorities, the Mayor and the GLA are subject to the Public Sector Equality Duty, and must have “due regard” of the need to:
•    eliminate unlawful discrimination, harassment and victimisation 
•    advance equality of opportunity between people who share a relevant protected characteristic and those who do not 
•    foster good relations between people who share a relevant protected characteristic and those who do not.
3.2.    Protected characteristics under section 149 of the Equality Act are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage or civil partnership status (all except the last being “relevant” protected characteristics). 
3.3.    Objective 3 of the Mayor’s equality, diversity and inclusion strategy, Inclusive London, is “to address the specific barriers that prevent some rough sleepers exiting rough sleeping and rebuilding their lives”. 
3.4.    The funding referenced in this decision will help to tackle the inequalities experienced by certain groups of Londoners most affected by homelessness and rough sleeping. Of those seen sleeping rough in 2022-23: 
•    51 per cent were non-UK nationals 
•    19 per cent were Black or Black British 
•    5 per cent were Roma 
•    51 per cent had a mental health need 
•    17 per cent were female 
•    58 per cent were aged 26-45 
•    8 per cent were under 26 
•    12 per cent were over 55 years old.
3.5.    Homelessness in London, and specifically rough sleeping, disproportionately affects people with certain protected characteristics. Increasing the provision of preventative homelessness interventions will help to achieve positive impacts in line with the need to eliminate discrimination, harassment and victimisation. 
3.6.    Data from CHAIN has shown a sharp rise in the number of rough sleepers whose last accommodation or settled base was Home Office accommodation. The two proposed service provisions will contribute towards minimising the impact of Home Office policies on non-UK nationals, who make over half of London’s rough sleepers, and provide structured intervention to a sustainable route out of homelessness. 
3.7.    The allocation of funding in this decision is aimed at implementing the Mayor’s policies set out in the London Housing Strategy. In May 2018 the GLA published an equality impact assessment (EIA) of that strategy. Policies related to tackling homelessness and helping rough sleepers, to which this service will contribute, were included in that assessment. The EIA concluded that measures to support rough sleepers off the streets, and to help them avoid returning, mean they will be removed from the acute risk and social isolation that sleeping rough creates. This will benefit those with protected characteristics, especially people with disabilities whom the baseline for the EIA identified as disproportionately more likely to be seen sleeping on London’s streets. 

Key risks and issues 
4.1.    The key risks and issues for the GLA Rough Sleeping programme, and the two new schemes outlined in this decision, are set out in the table below: 

Links to Mayoral strategies and priorities 
4.2.    The projects and services for which this MD seeks approval will help meet Policy 7.2, “Supporting Rough Sleepers off the Streets”, of the Mayor’s London Housing Strategy. This will occur through a range of actions to help meet the stated central aim of the Mayor “to ensure there is a route off the streets for every single rough sleeper in London”. The GLA Rough Sleeping team works closely with partners in local authorities, London Councils, the DLUHC and the charity sector to support rough sleepers off the streets; and provides pan-London leadership and coordination. The services and projects funded form part of proposal B of the same policy, which states: 
“The Mayor will fund and commission a range of pan-London services and other initiatives to complement those provided by local councils. These will focus on identifying rough sleepers and intervening rapidly to support them off the streets, providing specialist support for particular groups, and helping rough sleepers stay off the street.” 
4.3.    The projects and services funded through this MD will also help meet the objectives of the London Health Inequalities Strategy. Addressing homelessness and rough sleeping is one of the seven objectives set by the Mayor to achieve the aim that all Londoners benefit from an environment and an economy that together promote good mental and physical health. 

Conflicts of interest
4.4.    There are no known conflicts of interest for those involved in the drafting or clearance of this report. 

Subsidy control
4.5.    The Subsidy Control Act 2022 (the “SC Act”) requires that grant funding and other potential subsidies be assessed in relation to a four-limbed test. The grant funding must meet each limb of the test in order to be considered a subsidy. Firstly, the proposed grant funding is financial assistance given by a public authority; the GLA. Secondly, although both recipients are charities, it could be argued that they are acting as enterprises, given that these kind of services are similar to other kinds of services, which local authorities procure from time to time. Thirdly, the grant funding is specifically of benefit to the two charities, who will be in receipt of it, and not to other charities, who also provide similar services. Fourthly, the grant must have or be capable of having an effect on competition or investment within the UK or between the UK and another country or territory. In this case, it is unlikely that the proposed grant funding would meet the fourth limb. Although the budget used to provide the grants has come to the GLA via grants from two London boroughs (LBs Redbridge and Greenwich), these boroughs are passing on part of the funding, which they had in turn received from DLUHC. The DLUHC funding is part of its national RSI funding, which has been provided to all regions of England. To that end, there is no effect on competition within the UK. Furthermore, the grants target the provision of assistance to homeless refugees in London. The services are provided in London to homeless people. To that end, it is unlikely that the grant funding would have an effect on competition and investment between the UK and another country. 
4.6.    In light of the above, it is unlikely that the proposed grants would meet all of the four limbs of the four-limbed test. However, in order to ensure compliance with the SC Act, an analysis of the seven Subsidy Control Principles has also been undertaken as follows. There is an equity rationale for both grants as, taken together, they will mean over 100 people are supported to find a longer-term solution to their homelessness, rather than remaining on the streets, as would otherwise have been the case. The funding to be granted is specifically to achieve these objectives and is commensurate with the resources they require for this purpose. Without this subsidy, it is clear that the policy objectives would not be achieved, as these projects would not otherwise be funded. It is only with this additional funding that the providers can deliver these projects. The GLA will closely monitor the grants to ensure that they are spent as agreed; and that they deliver the stated policy objectives of supporting newly recognised refugees to secure sustainable accommodation. 
4.7.     It is not considered possible for any less distortive means to achieve these policy objectives. It would not be feasible to achieve the same outcome through introducing ex ante competition for contracted services or via a different funding mechanism (e.g. a loan). The people accommodated or supported by these services are homeless Londoners, who would not otherwise be able to pay, on a market basis, for the services provided by the project. The low risk of any impact on competition is far outweighed by the benefits of supporting these people (who otherwise would have limited options to leave the streets) to find a longer-term solution to their homelessness. 
4.8.    It should be noted, that in the case of both grants included in this MD, it is a condition of the funding being received from Greenwich and Redbridge Councils, that the funding is subsequently granted to the Refugee Council and Housing Justice for this purpose. 

5.1.    Mayoral approval is sought for receipt totalling £330,840 where £84,272 is to receive from the Royal Borough of Greenwich and £246,568 received from the London Borough of Redbridge. This money was allocated to the two councils from the Government’s Rough Sleeping Initiative programme specifically for onward grant to the GLA, for the purpose of additional support for newly granted refugees who are sleeping rough across 14 boroughs in South East and East London. 
5.2.    Approval is also sought for the expenditure of this funding totalling £330,840 as details in the table at paragraph 1.8 and section two where:
•    £165,000 will be grant funding to Refugee Council for a PRS access service for newly recognised refugees in 2023-24
•    £165,840 will be grant funding to Housing Justice for a supported lodgings scheme for newly recognised refugees in 2023-24.
 

6.1.    The foregoing sections of this report indicate that the decisions requested of the Mayor concern the exercise of the GLA’s general powers and fall within the GLA’s statutory power to do such things considered to further or which are facilitative of, conducive or incidental to the promotion of social development in Greater London and in formulating the proposals in respect of which a decision is sought officers have complied with the GLA’s related statutory duties to:
•    pay due regard to the principle that there should be equality of opportunity for all people
•    consider how the proposals will promote the improvement of health of persons, health inequalities between persons and to contribute towards the achievement of sustainable development in the United Kingdom
•    consult with appropriate bodies.    
6.2.    In taking the decisions requested, the Mayor must have due regard to the Public Sector Equality Duty; namely the need to eliminate discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010, and to advance equality of opportunity between persons who share a relevant protected characteristic (age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation) and persons who do not share it and foster good relations between persons who share a relevant protected characteristic and persons who do not share it (section 149 of the Equality Act 2010). To this end, the Mayor should have particular regard to section three (above) of this report.
6.3.    Decision 1, above, seeks approval of the receipt of £84,272 from the Royal Borough of Greenwich and £246,568 from the London Borough of Redbridge. Officers should ensure that the GLA comply with any conditions attached to the funding by the boroughs.
6.4.    Decisions 2a and 2b, above, seek approval for grants of up to £165,000 to Refugee Council and up to £165,840 to Housing Justice.  The proposed grants may be viewed as a conditional gift rather than a contract for services and supplies. Officers are reminded to put in place an appropriate grant agreement between the GLA and the respective grantees prior to the payment of any tranches of the grant funding.
6.5.    The Subsidy Control Act 2022 requires that grant funding comply with its four limbed-test and, where each limb is met, with its subsidy control principles.  The officers have set out at paragraphs 4.5 to 4.8, above, how the proposed grants comply with those principles.