HC 576 Progress towards the implementation of Universal Credit
Written evidence submitted by City West Housing Trust
The consultation covers an number of areas of which two are particularly relevant to us :
· The proposed arrangements for claims and payments and the provision of support and advice for claimants; and
· Impact monitoring.
Arrangements for claims and payments and the provision of support and advice for claimants
1. City West Housing Trust is a key service provider for the community we serve. Our role takes many forms from the more traditional ones of maintaining, developing and improving an attractive and safe environment to emerging roles in developing the local economy and employment opportunities. Supporting our customers through the changes of the Welfare Reform Act and the challenges it presents is central to this role.
2. The introduction of Universal Credit is an opportunity for us and the wider housing industry to build on our role as a community champion. City West Housing Trust provides initial support and advice to claimants. We have a strong a presence in the local community as City West Housing Trust with an extensive network of locally based offices. We are able to access our customers homes and speak to people around difficult issues. Given the local reductions in specialist debt and welfare rights advice provision, we aim to act as a benefits 'triage' either by directly providing IT facilities and helping customers complete forms online or by signposting them elsewhere for further specialist support and advice. Through customer insight, we have some understanding of our tenant’s household circumstances and income we have already made contact with customers who are going to be affected by the changes. In line with recent learning from the demonstration projects, however, we recognise that:
• we do not hold or have access to currently, the data required to assess claimants readiness for direct payment and the need for support;
• although we have very strong existing links with support partners, resource is going to be an issue, particularly migrating claimants with support needs on to direct payments – the demonstration projects have shown that resources demands have been managed at the expense of services outside the project scope;
• coordinated activity between housing providers and the DWP on communications is key due to the ongoing lack of general awareness of reform and its impacts on individual households – there are good examples of communications activity in the early learning summary; and,
• even with infrastructure and IT in place, the length of lead in time and preparation for implementation will be crucial to the success of UC, with a period of 6 months being required to engage with, assess and prepare a selection of 2000 claimants being noted in the demonstration projects.
3. In the early days of Universal Credit failure demand and avoidable contact will be high. A poor experience will increase claim handling costs, lead to claimants failing to claim benefits to which they are entitled, leave customers vulnerable and increase frustration for all those involved. City West Housing Trust and other Registered Providers (RP’s) are well placed to diminish this. As mentioned earlier our customers that we believe will be affected by the changes have already been encouraged to contact us for advice and support. Not only does this include advice on changes to their benefit entitlement but also on their options should, for example, their Housing Benefit award no longer cover the cost of their rent because of the under occupation of their home. Take up remains slow, however, and demonstrates that even with existing positive relationships, many claimants may not act until the change is upon them without individual, face to face intervention that is prohibitively resource intensive.
4. Our customers have traditionally accessed benefits either in a face-to-face basis or over the telephone with written documentation sent to the claimant to complete and confirm claims and awards. Moving towards greater digital inclusion is clearly beneficial for our customers social and economic opportunities, and City West Housing Trust support this progress. Tenants of all RP’s have been shown to have low levels of internet access but we can ease this. City West Housing Trust area offices are ‘on line’, and we can easily make terminals available for our customers to pursue their claims in a supported and confidential environment. Our estate based staff have mobile IT and we can further support claimants in their own homes.
5. A key element of the success of this approach will be funded training, aligned to the current verification framework which will enable a high level of quality control and reduce central administration workloads and claim failures and make sure our staff are using their knowledge appropriately. This will also help us in dealing with what has the potential to become an increasing drain on resources – the pursuance of rent payments and the recovery of arrears.
6. The change to a monthly payment process for people who have barely managed on very low incomes on a fortnightly basis for some time will be challenging. This is a shock to household budgeting for those migrating into employment already and will be an experience shared by those moving to UC. We would welcome a supported and gently phased movement to monthly payments. If the change happens quickly people will find it difficult to manage and there is a likelihood of some overspending and finding themselves short towards the end of the month. We are concerned that this will drive many to expensive ‘pay day’ loans or door step lenders and loan sharks and permanent or increasing indebtedness.
7. With regard to the payment to one person in the household we would prefer that an element of the Universal Credit payment is made direct to the main carer, reflecting the practice of Child Tax Credit and the childcare element of Working Tax Credit. We are concerned that budgeting by the main carer (commonly a female lead household member) will be compromised if only one Universal Credit payment is made to the main claimant (usually the male partner). Less money going to the main carer could lead to more hidden poverty within families. There are concerns that the ‘wallet vs purse’ impacts of a single household payment could exacerbate or initiate financial abuse within troubled households. Experience and general acceptance of the procedures adopted with Child Tax Credit and the childcare element of Working Tax Credit provides substance for our concerns around this.
8. Presently we are not in a position to provide advice and support to all people living in our communities. The service would have to remain restricted to those who are our ‘customers’, that being tenants and their household and people who are applying to live in our accommodation. We do consider ourselves well placed to serve the wider population but would need support in doing this.
9. IT systems
10. To date, we have had no involvement in contributing to the development or design of IT infrastructure. We have a long standing relationship with our local authority for the exchange of data essential to the smooth administration of Housing Benefit, much of which (including changes to households and changes in rent charges) will remain relevant under UC and we would welcome discussion on how this is intended to be managed in the preparation for implementation.
11. Vulnerability and support needs
12. Given a low level of understanding of claimants financial confidence support needs, including ownership and use of financial services and products, we would welcome early discussion of proposals to identify (before implementation) of claimants that require support before migrating to direct payments. We think it would undermine the success of the scheme to identify these claimants after implementation.
13. Furthermore, we would welcome an impact assessment of proposals for DHPs to cover benefit restrictions relating to, for example, foster families and those looking to downsize for who alternative accommodation is not currently available. Although the budget for DHPs is increased, we are concerned that this will be either exhausted early in the financial year or will be necessarily so tightly controlled that some financially vulnerable customers will find themselves in debt.
14. We are conscious of the negative outcomes the tax/benefit regime has brought to our some of our customers. Long term reliance of out of work benefits is an issue on our estates and many of our customers are the target audience in respect of return to work initiatives. We would welcome closer joint working on responding to this. Equally, we continue to work hard to ensure we are making best use of our stock and part of this is addressing the under-occupation of properties. The ongoing tension between households’ relationships with the properties which have become their homes and the affordability of maintaining rent payments will become worse from April 2013 onwards and we believe we will face increased demand for stock from existing customers, demand which already cannot be met. We have advertised 743 properties to let in the period January to July 2012 that attracted over 31,000 bids.
15. We would differ as to the causes of this and the most effective means of addressing these issues. We would prefer an approach that involved more ‘carrot’ and less ‘stick’ but nevertheless we will continue to work with all agencies in securing the most preferable outcomes for our communities. In this, we are confident of sharing a common aim.
16. The changes are aimed directly at our customers and our communities and we are uniquely placed to record the impact in detail. Again, no other agency can report the change in benefit claimants lives like RP’s. Uniquely we can report on the number of our customers who have sought alternative accommodation, been subject of a possession order or changed their household composition because of the changes in their benefit award. Possibly, more importantly we can comment, in partnership with the local authority, on the impact it will have on our communities through such things as an increase in voids and rent arrears and movement between tenures.
17. We would welcome dialogue on developing shared aims around impact monitoring and the development of ongoing structures to discuss responses to emerging intelligence.
18. Universal Credit is also about cultural change and this is less easy to measure. The notion carried by some, that tenants of social housing see claiming benefits as a form of career and that living on social housing estates creates a mind set that makes it difficult for people to leave them, are all issues RP’s are well placed to comment on. These are issues, which are played out nationally, and it will be interesting to see how benefit claimants, who are also tenants of RP’s, fare in different areas of the country where economic conditions differ. We would suggest that a series of selected RP's around the country recording change can produce a detailed 'in the round' picture of the impact of Universal Credit on a national basis.
17 August 2012