MD3046 Single Homelessness Accommodation Programme

1.1 The Mayor is securing funding from the government’s new £270.6m national fund to deliver accommodation and associated support for rough sleepers – the Single Homelessness Accommodation Programme (SHAP). This new fund forms part of the cross-government Rough Sleeping Strategy that was announced on 3 September 2022. It has been developed to help meet gaps in current provision for former rough sleepers with high or complex needs; and young people who are homeless, or at risk of homelessness.

1.2 The delivery of the Rough Sleeping Accommodation Programme highlighted gaps in provision which that programme was not designed to meet. These gaps were primarily related to the absence of sufficient high-support accommodation-based services with on-site staffing. SHAP has been developed to help meet these gaps in provision.

1.3 £270.6m (£175.4m of capital and £95.2m of revenue) nationally will be made available for the delivery of homes during 2023-25, and the provision of up to three years’ support to the residents of this accommodation. While London’s final allocation is still being confirmed, current modelling sets out that around £75.2m of capital and £31.4m of revenue is expected to be allocated to the Mayor. SHAP is expected to fund 2,400 long-term supported homes nationally, of which around 800 are expected to be in London.

1.4 The GLA and DLUHC will enter into a Memorandum of Understanding (MOU) that sets out the basis for the agreement between DLUHC and the GLA in terms of how the SHAP funding is allocated to the GLA to administrate and the responsibilities of each of the parties. The MOU will cover: the indicative allocation set out in this MD; the intention that up to 800 homes are delivered in London, in line with the programme principles set out in this MD; and the way in which the GLA and DLUHC will interact on the programme. It also confirms that DLUHC will fully fund all revenue or capital allocations that are ministerially agreed, provided the allocations are spent within the agreed financial year(s) and in accordance with the terms of the grant.

Capital and revenue funding to deliver homes and provide support

1.5 The grant funding will be able to be used for a wide variety of schemes and approaches on a capital-only or revenue-only basis, or with a combination of capital and revenue. The following delivery routes are eligible under the programme:

i. purchase and repair of properties, either as freehold or on a long lease

ii. refurbishment and repurposing of existing stock, including former hostels and care homes

iii. lease and repair on shorter-term leases, although longer-term homes will be favoured

iv. acquisition of existing properties that require no or minimal work to bring them into use (‘existing satisfactory’)

v. development of new-build properties (including modern methods of construction), including modular homes, although this is expected to be minimal due to the programme timeframes

vi. contribution towards social investment programmes that deliver the aims of SHAP.

1.6 The homes delivered through the programme will be geographically dispersed throughout the capital. A variety of delivery approaches will enable the fund to maximise the number of homes delivered. All homes will be affordable.

1.7 A key feature of this fund is that it includes an element of revenue funding. For every home delivered within the programme, there is the possibility of funding for up to three years’ support. Support can be provided by the housing provider delivering the homes; by an organisation partnering with the housing provider, including local authorities; or through the Mayor’s Tenancy Sustainment Teams. Support will typically consist of caseworkers, each working with a set number of tenants on areas such as tenancy management, financial inclusion, documentation and move-on planning; and specialist roles supporting individuals to address issues including substance misuse and mental ill health.

Administration funding to deliver the programme

1.8 The GLA will receive funding to cover staffing, legal and other administration costs associated with delivering the programme in London. Any GLA posts created will be subject to parallel approval through establishment control processes.

Co-production and bidding process

1.9 Funding guidance for SHAP will be published on the GLA’s website shortly, and continuous bidding is expected to open later in this financial year. A prospectus and guidance will set out that bids will be considered from housing associations, local authorities, charities and others who have an ambition to develop SHAP homes. All bids will need to be supported by the relevant local authority. The prospectus will also cover funding criteria and preferences. Assessment will prioritise funding schemes that procure freehold or long-term leasehold interests in properties, rather than short-term leases. Preference will be given to schemes providing homes that are additional to, or bring additional homes into use in, the sector. This includes schemes that would involve significant modernisation, conversion or adaption – particularly where not undertaking such works would leave properties vacant in the long-term, moribund or set for disposal.

1.10 The GLA and DLUHC will support organisations to produce bids. Bids will be periodically assessed by GLA and DLUHC officers, and in accordance with criteria set out in the guidance. Following joint review, they will make recommendations for funding allocations. Individual funding allocations will be approved by the Secretary of State for DLUHC and the Executive Director of Housing and Land for the GLA (see paragraph 1.13).

Delegated authority

1.11 As an affordable homes delivery programme, the established operational processes for the Affordable Homes Programme will be aligned with wherever possible.

1.12 Funding allocations are subject to ministerial approval by DLUHC. They will then be approved by the Executive Director for Housing and Land, in line with decision-making processes for the Affordable Homes Programme (as set out in Mayoral Decision Making in the GLA) and the SHAP MOU.

1.13 This decision delegates authority to the Executive Director for Housing and Land:

i. to approve the final version of the MOU, in line with the agreed principles of this MD

ii. to approve receipt of the final London allocation of capital and revenue funding (including administration funding) when the exact amount is confirmed

iii. to take decisions on individual allocations in line with the established internal processes for the Affordable Homes Programme, and delegated decision processes set out in Mayoral Decision Making in the GLA.

2.1 The aim of the programme is to boost delivery of affordable homes for two groups of Londoners with high support needs – former rough sleepers, and young people who are homeless or at risk of homelessness – and to provide them with the support they need to move on and rebuild their lives. Approximately a third of delivery will focus on provision for young people, although this will potentially require a smaller proportion of the allocated capital fund compared to delivery for high and complex needs.

2.2 The key objectives are:

i. to meet unmet needs by ensuring appropriate accommodation and support solutions for those with high or complex needs who are sleeping rough, or are already in a rough-sleeping pathway

ii. to provide a route into longer-term accommodation and a support pathway for young people who are homeless or at risk of homelessness

iii. to provide opportunities for sub-regional and pan-London services to meet the needs of groups from whom demand in any single borough is too low to justify a borough-specific service

iv. to free up spaces in hostels by providing move-through in existing pathways.

2.3 DLUHC has not set specific targets on outcomes, with the aim of being sufficiently flexible on a range of positive outcomes; but has agreed to monitor the T1000 cohort (identified as the most entrenched rough sleepers in London) as an outcome indicator to assess impact.

2.4 Outcomes will include:

i. more appropriate options for people with high or complex needs who are sleeping rough; and young people who are homeless, or at risk of homelessness

ii. fewer people sleeping rough in London

iii. more young people prevented from becoming homeless/sleeping rough

iv. greater access to affordable accommodation

v. improved mental and physical health, well-being, and resilience

vi. greater financial inclusion

vii. engagement with treatment, for those with substance misuse needs

viii. engagement with employment, education, training, volunteering or meaningful activity

ix. move-on to lower levels of support or fully independent living, where appropriate.

3.1 Under section 149 of the Equality Act 2010, as public authorities, the Mayor and the GLA are subject to a public-sector equality duty; and, in the exercise of their functions, must have ‘due regard’ to the need to:

i. eliminate discrimination, harassment and victimisation and any other conduct that is prohibited by or under the Equality Act 2010

ii. advance equality of opportunity between people who share a relevant protected characteristic and those who do not

iii. foster good relations between people who share a relevant protected characteristic and those who do not.

3.2 Relevant protected characteristics under section 149 of the Equality Act are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

3.3 Of those seen rough sleeping in 2021-22:

i. 48 per cent were non-UK nationals

ii. 6 per cent were from Gypsy/Romany/Traveller communities

iii. 50 per cent had a mental health need

iv. 35 per cent had at least two support needs around drugs, alcohol and mental health; and 10 per cent had support needs in all three areas

v. 17 per cent were women

vi. 59 per cent were between 26 and 45

vii. eight per cent were under 26

viii. 12 per cent were over 55

ix. 20 people were under 18.

3.4 The most recent data from Centrepoint’s Youth Homelessness Databank reports that 15,200 homelessness approaches were made to London local authorities by young people in 2020-21.

3.5 As those with protected characteristics of race and disability are over-represented among rough sleepers, the proposals in this paper are likely to have positive impacts on Black, Asian and Minority Ethnic Londoners, and those with disabilities. As the majority of people sleeping rough are men, more men than women are likely to benefit from this provision. Younger Londoners (18-25) are also likely to benefit from this programme, given the focus on part of this provision for young people at risk of homelessness.

Key risks and issues

4.1 Key risks are set out in the following table:

Links to Mayoral strategies and priorities

4.2 Since 2016, the Mayor has coordinated efforts through his Life Off the Streets taskforce to identify, implement, lobby for, and monitor the effectiveness of interventions to tackle rough sleeping. In his London Housing Strategy, the Mayor set out his aim that there should be 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 need to be taken by City Hall, the government and others to achieve this.

4.3 Since taking office, the Mayor has been expanding the pan-London rough-sleeping services the GLA funds and commissions. These services collectively form his Life Off the Streets programme. They are services for rough sleepers, or initiatives to tackle rough sleeping, that cannot or would not be provided at a London borough level, as they are pan-London or multi-borough in their remit.

4.4 The projects funded through SHAP (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 works closely with partners in local authorities, London Councils, DLUHC and the charity sector to develop projects that will support rough sleepers off the streets; and provides pan-London leadership and coordination. The projects funded by SHAP will 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.”

4.5 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.

4.6 As 50 per cent of individuals seen sleeping rough in London in 2020-21 had a mental health need, supporting rough sleepers through the services and projects funded via this MD will additionally meet Aim Two, “Healthy Minds”, of the London Health Inequalities Strategy.

4.7 The aims of the Mayor’s core rough-sleeping services include ensuring that all those new to the streets have an immediate route off the streets. The projects and services in this paper form a key part of this, and link to the several of the nine recovery missions that are part of the Mayor’s COVID-19 London Recovery Programme. By helping excluded and marginalised groups, which are highly represented in London’s rough-sleeper population (see 3.2., above), and working in partnership with local authorities, housing associations and charities, these projects will help meet the “Robust Safety Net” aim, and several of the projects will support the “Mental Health and Wellbeing” and “Building Strong Communities” recovery missions.

Consultations and impact assessments

4.8 The London Housing Strategy sets the strategic framework underpinning SHAP; and was subject to public consultation and equalities impact assessments in 2017-18.

4.9 The Rough Sleeping Plan of Action was developed with the support of the Mayor’s Life Off the Streets taskforce, which includes representatives from across London’s homelessness sector.

4.10 An equality impact assessment was completed by DLUHC when developing SHAP, and officers are conducting a screening assessment to localise this assessment to the London region. Any findings from the screening will inform plans during the development of the programme and future programmes to reduce inequality for Londoners.

Conflicts of interest

4.11 The officers involved in the drafting and clearance of this form have identified no known conflicts of interest.

5.1 The decision is seeking approval for the GLA to receive and allocate London’s allocation of the nationally available £270.6m (£175.4m of capital and £95.2m of revenue) from DLUHC, to deliver homes for the Single Homelessness Accommodation Programme (SHAP) and provide support for people in those homes. The homes are expected to be delivered during 2023 to 2025.  The decision is also seeking approval for the GLA to receive funding for the administration of this programme, which would be approved by the Executive Director of Housing and Land when the MoU and the figures are finalised.

5.2 Approval is also sought to delegate authority to the Executive Director of Housing and Land to approve funding allocations in line with decision making processes for the Affordable Homes Programme, as set out in Mayoral Decision Making in the GLA) and the MoU with central Government for the Single Homelessness Accommodation Programme.

5.3 The indicative profile of the delivery funding from DLUHC is set out below, exclusive of the revenue for programme administration, and is subject to change within the total programme envelope for inside and outside of London:

5.4 The GLA will receive grant receipts from DLUHC for all revenue and expenditure costs for the SHAP programme. The grant will be paid to the GLA quarterly in arrears. DLUHC would also provide funding to the GLA, to cover the costs for staffing including the internal corporate recharge cost per externally funded post, legal and other administrative costs associated with delivering the SHAP programme.

6.1 Section 30 of the Greater London Authority Act 1999 (as amended) (GLA Act) gives the Mayor a general power to do anything that he considers will further one or more of the principal purposes of the GLA. The principal purposes, as set out in section 30(2), are:

i. promoting economic development and wealth creation in Greater London

ii. promoting social development in Greater London

iii. promoting the improvement of the environment in Greater London.

6.2 Given the above, and section 34 of the GLA Act, which allows the Mayor to do anything that is calculated to facilitate, or is conducive or incidental to, the exercise of any of his functions (including his functions under section 30), the GLA is empowered to receive funding from the government and provide financial assistance for the purpose of the recipient providing affordable housing and/or tenancy support.

6.3 In determining whether or how to exercise the power conferred by section 30(1) of the GLA Act, the Mayor must:

i. have regard to the effect that these decisions will have on the health of persons in Greater London, health inequalities between persons living in Greater London, the achievement of sustainable development in the United Kingdom and climate change and its consequences (sections 30(3-5) of the GLA Act)

ii. pay due regard to the principle that there should be equality of opportunity for all people (section 33 of the GLA Act).

6.4 In taking the decisions requested of him, the Mayor must also 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, and foster good relations, between persons who share a relevant protected characteristic (race, disability, sex, age, sexual orientation, religion or belief, pregnancy and maternity, and gender reassignment) and persons who do not (section 149 of the Equality Act 2010). These matters will also need to be taken into account when preparing the funding guidance and when assessing specific bids for funding proposals and entering into funding agreements.

6.5 In respect of paragraphs 6.3 and 6.4, the Mayor should have particular regard to section 3 (above) of this report.

6.6 In addition to the above, where the Mayor is proposing to use the power conferred in section 30(1) of the GLA Act, the Mayor must consider consulting in accordance with section 32 of the GLA Act (see sections 4.8 to 4.10 above). The Mayor will need to consult in accordance with section 32 of the GLA Act, as appropriate, prior to entering into any funding agreements.

6.7 Where funding is to be granted by the GLA for the provision of low-cost rental accommodation, it should be noted that sections 31 to 36 of the Housing and Regeneration Act 2008 (as amended by section 333ZE of the GLA Act) will apply. This includes a requirement upon the GLA to impose a condition ensuring that a registered provider of social housing is the landlord when the accommodation is made available for rent.

6.8 The award of GLA funding under this programme is not a payment for services and is not therefore subject to the requirements of the Public Contracts Regulations 2015. This notwithstanding, the GLA is still subject to the overarching duties of fairness and transparency. Officers must ensure that the funding is distributed fairly, transparently, in accordance with the GLA’s equalities duties and in a manner that affords value for money in accordance with the GLA’s Contracts and Funding Code.

6.9 Legal advice should be sought on the forms of funding agreement to be used for this funding programme, including advice as to any subsidy control requirements, and no commitment to fund should be made before the relevant funding agreement is entered into.

6.10 Section 38 of the GLA Act provides that any function exercisable on behalf of the Authority by the Mayor shall also be exercisable by, amongst others, any member of staff of the Authority, if or to the extent that the Mayor authorises and subject to any conditions imposed by the Mayor. The Mayor may make the requested delegation to the Executive Director of Housing and Land, if he so chooses.

7.1 An indicative timeline is set out below: