Council Housing Consulatation Guidance Notes

Move to points and group based system  

Within the current allocation policy, housing need can't be compounded with applicants awarded the priority pass with the highest level of reported need within each pass group based solely on the basis of date.  

This means that we have household's with multiple housing needs assessed as having a lower level of priority than households with a singular housing need, solely as a result of them having a later application date.   

It's proposed that the new policy is based on a points and groups system that will allow need to be compounded while still being able to apply set quotas to priority groups, transfer applicants (those resident in a social rented tenancy in East Renfrewshire) and applicants on our waiting list . A number of other local authorities operate in this way.  The proposal is that the policy reduces the number of Bands to 3:

• Strategic Priority (which is mainly Homelessness and Looked After/Throughcare)
• Waiting List
• Transfer

Strategic Priority groups would still be allocated in date order with quota allocation targets set for each of the individual strategic groups.  All other applicants would be awarded points based on their individual assessed need.  

The points would be allocated across 7 key areas of need: 

1. Security of Tenure 

2. Health and Social Care 

3. Merging Households 

4. Facilities  

5. House size  

6. Harassment and Anti Social behavior 

7. Relocation  

Extending Strategic Priority Groups ( currently known as Band A) 

The current policy awards a Priority A pass to the following strategic priority groups  

1. Households assessed as unintentionally homeless/ threatened with homelessness within 2 months  

2. Resident in an ERC Care placement and ready to move to independent living  

In addition, the current policy may award 'special case' status for a very small number of households if they meet certain exceptional circumstances criteria and their needs can't be met within the allocation policy. In real terms this means that the household is added in date order priority to the bottom of the existing strategic policy priority groups (Band A) and they then have to bid on properties under our choice based lettings system  It's proposed that special cases are removed completely with the strategic priority group extended to meet the needs of certain households, namely: 

1. ERC Households who are prevented from being discharged from hospital due to them having either no property to return to or significant barriers within their existing property preventing them returning.   

2. ERC residents where there the applicants circumstances are such that they have an urgent and immediate need for re-housing and the Allocation Policy does not reflect this.  

These cases would be given strategic priority but would be made a directly matched offer of a suitable property instead of bidding via choice based lettings. When a vacancy is considered suitable (as supported by an occupational therapist assessment, where appropriate) for the applicants need they'll be made a direct award.  If the offer is unreasonably refused the priority status will be removed and their housing application reassessed and household moved to alternative banding (under current policy) or awarded points under proposed new policy. 

Medical Priority Award 

The current medical priority assessment process allows for a medical priority award to be given to households who reside out with East Renfrewshire, based on the assertion that their current property is having a detrimental impact on an existing medical condition.  This is above the legal threshold which states that we must consider whether a household needs to move to another local authority area to give or receive support. The law does permit a level of priority to those resident within the local area. It's proposed that the new policy (and the current policy pending implementation of the new policy) remove the ability to award a medical priority (points under new policy) to household's resident outside East Renfrewshire.  Medical priority (points) will still be awarded to residents of East Renfrewshire based on a newly developed robust framework.  

It's proposed that the new framework will utilise an initial assessment matrix to determine if the household meets set criteria. If criteria for assessment are met then the application will be assessed by a lead officer, instead of the current panel system, who'll take into account any and all supporting information, including any information provided by HSCP colleagues. HSCP colleagues will be asked to undertake an OT assessment of the applicant's existing property, to determine if any aids or adaptation can be provided, prior to any medical award, where appropriate.

It's proposed that under the new policy the same framework will be utilised to award points for medical need under the need area titled health and social care.  

It's also proposed that we reassess all existing households with a medical award against the new framework to ensure this banding is being appropriately and fairly applied to all.  

Immediate Changes to existing policy 

It's likely to take some time to implement the new policy and it's proposed that we make some changes to the operation of the existing policy prior to this in order to improve its operation and ensure we are continue to meet the needs of those in most need.  

The changes proposed are:

• Amend priority date from date of application to date moved into the priority banding

Under the current policy (excluding Priority A and Medical Bands B1, B2, B3 where priority is awarded by the date the applicant moved into that banding) priority within the bandings is awarded on the date they submitted their original waiting list application.  This is regardless of whether the applicant had any housing need at that point.  In practice this means that an applicant could have applied for housing in 1990, had no housing need and was placed in band E.  The household then has a change in circumstances and requires another bedroom, as they are overcrowded. They are then placed in band C.  If the applicant has earlier application date they have greater priority that applicants who have been living in an overcrowded position for a number of years and in housing need for a significantly longer period. 

Non East Renfrewshire Residents with no housing need  

The current policy awards a Band E priority to East Renfrewshire residents with no housing need.  However, the policy awards a higher priority D to non-East Renfrewshire residents with no housing need who wish to move to the area because they have a relative living here.  It's proposed that this is removed from the current policy and the same banding is applied to non East Renfrewshire residents with no housing need as East Renfrewshire residents with no Housing Need.  

Non-resident applicants who wish to move to the area to be nearer a carer or relative for support reasons will still be awarded a Band D priority, subject to appropriate proofs.   

Households adequately housed in the private sector 

Applicants resident in the private sector both in East Renfrewshire and outside East Renfrewshire are awarded D priority despite having no housing need.  

The proposal is to amend this to award D priority only to applicants resident in the private sector who have been issued with a no fault notice to quit. This will give a degree of priority to those in the sector whose tenancy is at risk.  Where the Tribunal has determined an eviction date, the applicant could then receive Priority A, following a homelessness assessment (there is no change to this).  All other residents in the private rented sector with no housing need will be placed in Band E. Under the new policy it's proposed that points will be awarded for this group under the need category of Security of Tenure. 

Direct Matching  

The current allocation policy details 4 areas where direct offers of accommodation can be made, without the applicant bidding via the Choice Based lettings system, these are:

• where the MAPPA (Multi-Agency Public Protection Arrangement) have made a recommendation about accommodation and the responsible authorities have recommended a restriction of choice

• where a Priority Pass A's time limit has expired and we consider that poor use was made of the priority through the bidding process. Where this is the case, we'll have a discussion with you about your bidding pattern prior to deciding whether or not to make a direct match. We'll try to ensure that any direct match in these circumstances will be in the nearest geographical area to your preferred area, dependent upon availability

• Where you require a very specifically adapted property, we'll work with the support you receive from Health and Social Care Teams to identify an appropriate match

• Where we require to use a property to temporarily house an existing tenant whose home is in need of major repair. 

• Point 2 above proposes to add hospital discharge and exceptional cases to this list. 

It's proposed that the group detailed above be amended to include management transfers, this would  allow senior management, in exceptional circumstances, to sign off a direct offer of accommodation to existing ERC tenants in housing need. This is to both make best use of housing stock and meet the needs of our most vulnerable tenants.   

This is also mirrored in the proposed new policy. 

6 month free bid restriction 

Currently households assessed as unintentionally homeless / threatened with homeless and in priority need have a 6 month window in which they can choose the properties that they bid on and would be exempt from a direct offer of accommodation. There are however some low demand properties which would be suitable for some homeless applicants, but direct bids are prohibited owing to the 6 month free bid restriction. In real terms this will affect very few households as homeless applicants on average wait in excess of 12 months for an offer of permanent accommodation, during which time applicants bid freely.  

It's proposed to remove any reference to a timescale for free bid restrictions.  This is also mirrored in the new policy for Strategic Priority Groups.  

Owner occupation restriction  

Section 5 of the 2014 Act removes the previous prohibition on taking ownership of a property into account when allocating social housing.  This applies to ownership of, or value of, heritable property owned by the applicant, a person who normally resides with the applicant, or a person who it's proposed will reside with the applicant, this is unless:- 

• you can't access your property

• occupying your property would lead to abuse

•  occupying your property would endanger your health

The current policy states that in assessment of your need we'll take account if you, or anyone who will be living with you, own any property.  

It's proposed that we are more robust in both the assertion of this restriction and its assessment both within the existing policy and in the proposed new policy.   

Publication of letting outcomes 

Section 9.6 of the current Allocations policy states that "we will publish the results on our website on a weekly basis so that it's easy for you to see which priority groups the successful bidders were in and how many bids there were per available home.  This will help your understanding of your likelihood of success in further bids and in time will give you information about which types of properties in which areas become available most often".    

In practice while we publicise statistical information we do not publicise which group each individual property is allocated to.  This is primarily as a result of GDPR (data protection legislation).   It's proposed that we remove this from the current policy and instead replace, in the current policy and new policy, a commitment to publishing anonymous letting information on a bi- annual basis.