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Guide supported by Foundations Independent Living Trust, Anchor, Habinteg and Taylor Wimpey

Report from Foundations Independent Living Trust

Produced in partnership with Habinteg and Anchor Hanover with the support of Taylor Wimpey.

Report and new guidance on delivering better home adaptations in social housing.

Housing Associations and Home Adaptations

Following the publication of the Independent Review of DFG in 2018 we wanted to take a deeper dive into the workings of adaptations for social housing tenants. We knew that the housing world had changed significantly from the previous guidance in 2008 and that too many tenants were facing delay and frustration.

Thanks to our partners Habinteg and Anchor Hanover and the continued support of Taylor Wimpey we commissioned this new guidance which examines the current situation and makes key recommendations for improving delivery.

The report was researched and written by:

Sheila Mackintosh has been a housing consultant for the last ten years. Prior to this she was an academic at the University of Bristol. Alongside her consultancy she was a Research Fellow in the Centre for Public Health and Wellbeing at the University of the West of England and is now a Visiting Research Fellow. She was the co-author of the previous guide to housing associations and home adaptations and was a member of the team that carried out the DFG Review in 2018.

Rachel Frondigoun has worked within the ‘DFG world’ for over 25 years. She has worked in both ‘in-house’ and external Home Improvement Agencies and within Local Authority Housing Strategy departments as the DFG budget holder working with an external HIA provider. She went self-employed in 2018 and since then has worked with over a dozen local authorities and HIA providers.

Download the DFG Landlord Application Form

Recommendations

Introduction

What are home adaptations?

They include small modifications such as grab rails, extra stair rails, and ramps, through to more substantial alterations such as level access showers, stairlifts, through lifts, changes to the internal layout, and accessible ground floor extensions.

Adaptations help to make properties accessible, allow people to carry out essential daily activities like washing, cooking, and getting to toilet, and let them get in and out of their homes safely. They benefit disabled people of all ages including, families with disabled children, students, people of working age and those in later life.

Adaptations can transform the way people live

They help people stay in their own homes, give them back their dignity and confidence, make homes safe, reduce falls, overcome the fear of falling, improve life for carers and family members, reconnect people with the outside world, increase wellbeing and mental health, and help people retain or gain employment.

They also save money for landlords by creating stable tenancies, generate considerable cost saving for health and care services by keeping people independent in the community, and produce national economic benefits by helping more people to work.

Aims of this study:

  • To look in depth at how adaptations are funded and delivered in the sector – including minor adaptations and use of the Disabled Facilities Grant (DFG).
  • To examine how funding arrangements might be improved and the delivery process made quicker and more effective.
  • When adaptations are not the right solution, to see how the moving process might be improved.
  • To encourage a longer term and more strategic view of home adaptations.

It follows on from an independent review of the DFG in England in 2018. The focus is on housing associations rather than the retained council stock as associations use DFG funding while the council stock uses the Housing Revenue Account. It covers England as the arrangements for the funding of adaptations are different in Wales, Scotland, and Northern Ireland.

The research identifies:

  • Good practice, particularly in LSVTs that control their own adaptations budgets, those fully engaged with their disabled and older tenants, or where there are effective partnership arrangements.
  • Issues in funding and delivery including splits in legal responsibility, a confusing pattern of funding, a post code lottery in the type of services provided, complex customer journeys and frustration for staff in local authorities and associations.
  • Rather than saying ‘yes’ to adaptations, barriers are often placed in the way and adaptations may be refused, especially in general needs properties. They may also be removed unnecessarily when tenancies change.
  • Moving home is not easy if a home is unsuitable or not possible to adapt.
  • Not enough accessible homes are being built and adapted homes are not recycled effectively. Asset management databases are sometimes incomplete, there are few accessible housing registers, void times are too short, and there is not enough support to match people to properties or provide help with moving.
  • Home adaptations lack importance – although disabled tenants form a substantial part of housing association populations, most associations see adapting homes as a minor operational issue. It is not part of a strategic plan to make the stock work for everyone.
  • A lack of disabled people working in the sector – a National Housing Federation Survey in 2021 showed that disabled people are under-represented as staff members, not visible as leaders in the sector, and only 4.8% of board members identified as disabled.

This report provides recommendations for associations, local authorities, central government, and the Housing Regulator to sort out the confusion about funding and improve the speed and effectiveness of home adaptations delivery.

It provides practical solutions to put disabled and older tenants at the heart of decision making, an inclusive approach to services, and for home adaptations to be part of the new customer-focused inspection regime.

How are housing associations performing?

Housing association tenants
  • 54% have a long term illness or impairment
  • 18% of new lettings are to people with a defined disability
  • 43% are 55 and over – average age 52.
Suitability of the stock
  • 21% of disabled tenants say their accommodation is unsuitable
  • 56% of those needing adaptations do not have them
  • 21%-18% decline in the proportion of adapted homes in the housing association sector in the last decade (in contrast it has increased in the retained council stock).

Target Audience

  • Government and national organisations – central government policy makers, Homes England, the Housing Regulator, Ombudsman services, and national organisations representing housing and local government.
  • People in housing associations and the local authority sector – at strategic and operational level as well as those delivering adaptations.
  • Tenants, tenant organisations and those in the charitable sector.
  • Other organisations – it will also be helpful for those delivering council adaptations, private sector landlords with ambitions to develop portfolios of affordable housing, and other investors in new affordable homes.

Further information

Background Report – this provides detailed findings from surveys, interviews, case studies, discussion groups, webinars, and national data sources. It provides links to all the sources of information used in the Summary Report: Housing Associations and Home Adaptations: Finding Ways to Say Yes.

Online Design Guide – aims to help professionals working to deliver home adaptations to improve the attractiveness and quality of the adaptations they provide. The aim is to allow more to be approved, and fewer removed at change of tenancy: https://www.foundations.uk.com/design/.

 

Responsibility for adaptations

The adaptation of people’s homes was never properly designed as a service. It has evolved from various strands of legislation and guidance issued over the last 30 years. A complicated pattern of funding and responsibility has developed (see Table 1). Some associations (mostly LSVTs) fund all their own adaptations in the same way as the council stock. Most other associations do minor adaptations but refer major work to the DFG. Some pay a contribution to DFG costs, but others do not.

Table 1 summary of legislation, guidance and funding

Legislation/Guidance Responsibility and sources of funding
Social care legislation including Care Act 2014 Responsibility for disabled children and adults lies with social care services. There are funds for equipment and minor adaptations under £1,000 but limited resources.
The Equality Act 2010 Gives tenants the right to ‘reasonable adjustments’ to be made to their homes and any communal areas, to enable access to their home and to accommodate any needs because of disability. A landlord should only refuse permission for adaptations if they have ‘reasonable’ grounds for doing so.
Regulatory Framework for Social Housing Landlords must understand tenants needs and co-operate with other organisations to provide a service to meet need.
Housing Corporation guidance 1996 Housing associations are expected to fund and deliver minor adaptations – original threshold of £500 per case.
Housing Grants, Construction & Regeneration Act 1996 Central government allocates funding to local authorities for the mandatory Disabled Facilities Grant (DFG) via the Better Care Fund. It provides major adaptations (such as showers and stairlifts) for owners, private tenants, and housing associations.
Retained council stock and ALMOs Council and ALMO tenants can apply for a DFG but must use their own Housing Revenue Account to pay for adaptations as they are public sector organisations.
Direct funding for housing associations (removed) 1996-2008 Housing associations used to get direct funding for adaptations – gradually removed just at the time the sector was expanding through stock transfers. As private organisations they are allowed to use the DFG, but guidance given when the funding system changed was confusing.
Large scale transfer organisations (LSVTs) 1990s onwards Funding varies – the first LSVTs did not have designated budgets as they initially got direct funding but now use the DFG. Later LSVTs were set up with their own substantial budgets, although some arrangements have now ended.

Forthcoming changes

New government DFG guidance will be issued in 2022 to improve the effectiveness and efficiency of DFG delivery. This will be followed by consultation on other aspects of the DFG including:

  • How funds are allocated to local authorities to better align with local need
  • The maximum amount that can be paid for a single adaptation
  • How to update the means test and better align it with the test for social care.

New arrangements for adapting the common parts of dwellings will also be introduced (Section 36 of the Equality Act).

There will be additional funding for repairs and adaptations to allow more handyperson services to be developed. This report provides evidence for the policy makers involved in decision-making.

This report provides evidence for policy makers involved in decision-making about these issues.

 

Funding adaptations

Minor adaptations

Minor changes to the home such as small ramps, rails (outside, up the stairs, or in the bathroom), changes to steps, additional lighting, easier to use fittings (taps, door handles, heating controls, window catches) or other small modifications are vital to keep people safe and independent.

Budgets – nearly all housing associations do their own minor adaptations, but budgets vary, even amongst associations of the same size, from less than £1.00 per unit of stock to over £50.00 per unit Budgets are usually based on last year’s figures rather than any evaluation of need.

Staffing resources are also limited, usually a single adaptations officer. Few associations employ their own occupational therapists (OTs) or trusted assessors, and some have no lead officer, and no adaptations policy.

The threshold per case varies from £500 (the level set in 1996) to £2,500 or more. The majority use a threshold of £1,000 (the same as social care) but interviews with adaptation staff indicated that this was too low, and they could do so much more if it was £1,500. Some associations have increased the limit still further to offer more preventative and responsive services.

The threshold per case affects what work can be carried out – some associations pass even simple work to the local authority, while others do their own ramps and stairlifts. Where budgets and thresholds are too low more cases are referred, leading to longer waiting times, not just for tenants, but for people from all tenures. It also makes it hard to innovate.

Research shows that poor adaptation design leads to people becoming a target for crime and prevents people coming forward to seek help earlier. It also makes it more likely that adaptations get taken out at change of tenancy.

Major adaptations and the DFG

The central government DFG allocation doubled after 2015/16 to reach £573 million by 2021/22. The baseline allocation will be £573 million until 2024/25.

Uneven use of the DFG – on average housing associations use 36% of DFG resources, but in a few local authority areas it is more than 50%, much higher than might be expected given that associations only own 11% of the private sector stock (Figure 1). The high usage figures partly reflect the large proportion of disabled tenants in the sector, but it is also the legacy of the confused way funding developed. Some areas have much higher use of the DFG relative to stock levels, especially those where associations had no designated adaptation budget at the time of stock transfer (Figure 2).

The majority of associations refer tenants for a DFG for stairlifts, through lifts, level access showers, extensions and other major work. Recipients are split evenly between those of working age and those who are 65 and older, with 7% going to families with children.

Figure 1 Trend in use of DFG by tenure 2010/11 to 2019/20

Figure 2 The provision of DFGs to housing association tenants 2019/20 The Provisions Of Dfgs To Housing Association Tenants

 

Uneven spread of DFG resources – the DFG allocation formula has not been updated since 2011. The 2018 DFG Review showed that some areas have sufficient resources while others struggle to meet demand. The way DFG funds are allocated to local authorities does not take account of uneven use of the DFG by housing associations.

Authorities with limited resources and high demand from association tenants are very dependent on receiving financial support from associations. Where associations make contributions, these vary from 10%-60%.

Agency services – there is no statutory requirement for local authorities to offer a full agency service to guide people through the application process, find contractors or supervise the work.  Most provide support, but others pass responsibility to landlords.

More flexible DFG policies – the Regulatory Reform Order 2002 allowed authorities to develop Housing Assistance Policies to be more flexible in the way they use the DFG. Where there are sufficient resources, authorities offer a range of discretionary grants to meet local needs (e.g. fast-track grants, grants to support hospital discharge, or grants for conditions such as dementia). Some have removed the DFG means test for certain cases and some contribute to work above the £30,000 threshold. The result is a confusing mix of services for associations working across local authority boundaries.

Recommendations for associations

  • Review adaptation budgets and set the minor adaptations threshold at a minimum of £1,000 per case (preferably higher to follow best practice) to prevent handovers to local authorities, long waiting times for tenants, cover the rising cost of work, and develop better designs.
  • Ensure home adaptations staffing levels are sufficient to meet demand and always have a named officer to lead on home adaptations.

Different perspectives

Housing association perspective

  • Limited budgets
  • Often a single aids and adaptations staff member
  • Only about 10% have their own OTs and only 25% trusted assessors.
  • Dealing with numerous local authorities – in some cases a 100 or more:
    • Paperwork – different in each authority
    • Funding – contributions requirements vary
    • The way payments have to be made differs
    • Not all authorities have a full HIA service
    • Contractors – many authorities want three quotes even if the
      association has its own in-house contractors
    • DFG installations do not always fit with own specifications making them hard to repair and maintain.
    • Warranties and maintenance arrangements vary.
    • Not always told that work has been completed to update asset register
    • Complex spreadsheets needed to monitor different arrangements.

Housing associations want more consistency in the way the DFG operates and more control over the construction process.

Local authority perspective

  • Staff levels have not kept pace with rising DFG allocations.
  • Increasing number of integrated DFG services but some still split – DFG team in housing while OTs are in social care (often at county level).
  • Authorities work with numerous associations each with different policies.
  • Two thirds of OTs in our online survey said that some HA referrals were inappropriate – adding to waiting lists for people from all tenures.
  • Each association has a different approach to sharing costs, but obtaining contributions is getting more difficult – fewer partnership arrangements.
  • A few authorities are very dependent on housing association contributions.
  • Most want associations to contribute to DFG costs to make sure they take care of disabled tenants and put adaptations on their operational agendas.
  • The tenant usually makes the DFG application but almost two thirds of staff said that delays in getting the necessary landlords’ consent for work happens ‘a lot’.
  • Communication a major issue – close relationships with some associations but unclear who to contact in others, which requires a lot of chasing.
  • Concern about adaptations being refused (especially in general needs properties or above the ground floor) and tenants being asked to move.
  • Concern about adaptations being removed at change of tenure.

Local authorities want consistent contributions and better communication.

 

There is frustration on both housing association and local authority sides about inconsistencies in the way the funding and delivery process operates.

Housing association home adaptation staff also have their landlord function to consider. The high demand for homes and long waiting lists means they try to make ‘best use of stock’, particularly to free up family homes. This can sometimes come into conflict with the desire to make a property work for a disabled person meaning that some people are encouraged to move rather than adapting the existing home. As one interview respondent said,

“I have a landlord head and a disabled adaptations head.”

Housing association respondent

 

“All [associations] different & take very different approaches in meeting the needs.”

Local authority respondent

 

“I get so confused about who is doing what. You have to know so much about so many different places.  I wish they would all operate the same way.”

Housing association respondent

Good practice

During the research for this project we talked to many housing associations and local authorities and uncovered a great deal of good practice which is recorded in the Background Report.

Some of the best services were in LSVTs with big budgets and specialist staff in control of the whole adaptations process in-house. The provision of adaptations is closely integrated with other housing association services offering seamless support for tenants and effective monitoring of outcomes.

There were also housing associations of various types (local, regional and national) who were working in partnership with local authorities to use a mix of funding to deliver effective services. Good practice organisations had increased their own budgets to ensure that straightforward work was done by the association and not passed to the local authority.

Some organisations were also actively seeking out people who needed help by doing home MOTs. Others offered specialised support with home moves.

Most good practice organisations had close working relationships with their disabled and older tenants who had an input into decision making, including improving adaptation design.

Good practice examples

  • WDH Wakefield – well-resourced and fully integrated adaptations service
  • Flagship Group – flexible budgets to keep tenants safe at home
  • Longhurst Group – Improving lives strategy including home safety checks
  • Walsall Council – comprehensive housing partnership arrangements
  • St Helens Borough Council – DFG partnership arrangements
  • Cornwall Home Solutions and Coastline – new DFG process
  • Eastlight Community Homes – strong resident involvement
  • Bolton at Home – help with moving home
  • Invisible Creations – improving the design of home adaptations

The barriers for customers

Handovers and delays

There are committed staff in all housing associations and local authorities doing their best to support people needing adaptations. However, in most organisations restricted budgets and complicated customer pathways make the adaptation process slower and more difficult for tenants than it needs to be (Figure 3).

There is no single point of contact for the tenant through the process. Waiting lists at various stages add to delays. The handovers also make it difficult to measure outcomes to feed back into service improvements.

Figure 3 Complex pathways

Figure X Complex Pathways

Incomplete data about tenants and adapted properties

Information about tenants – GDPR data protection regulations have made housing associations reluctant to collect and store information about disability and impairment. Mergers mean that bigger associations have a patchwork of data, some incomplete. Increasing reliance on central call centres rather than neighbourhood offices means a lack of personal contact with tenants.

Outreach services developed during Covid19 may have improved understanding of more vulnerable tenants, but many disabled people may still be invisible to their landlords.

Without good data services are reactive rather than preventative. There is growing evidence that intervening early is essential to prevent people’s situations deteriorating.

Some groups lack support – people from minority ethnic groups appear to have lower rates of home adaptations.

Information about adapted and accessible property is also incomplete because of the handovers in adapting, repairing and maintaining homes. Only 58% of respondents to our association survey thought their asset management records were up to date, the rest said ‘no’ or were ‘not sure’. Gaps in records make repair and maintenance of adaptations difficult.

Access to services

Websites – some associations make it hard to find out about home adaptations. Although many clearly signpost it on their websites, it does not appear at all on some sites and is hidden deep in others.

Handyperson services

Some associations lack access to handyperson services for minor adaptations.

Assessment of need

OT only needed in specific cases – good practice guidance from the Royal College of Occupational Therapists makes it clear that an OT assessment is not required for all cases and more could be done by technical staff and trusted assessors. Landlords could speed up the process for tenants and reduce handovers if their staff had the right training and support.

Refusal of consent

It is hard to know how often housing association landlords refuse to give permission for DFG adaptations. Surveys of local authority staff conducted for this report indicated that it happens for three main reasons: a) reluctance to adapt general needs homes; b) concerns about water leakage which prevent level access showers (the most common DFG adaptation) being approved above the ground floor; and c) because landlords prefer small households to move to free up family homes.

Void policies and loss of investment

The number of adapted homes has declined from 21% to 18% in the last decade, despite around £200 million a year of DFG investment in the housing association stock, alongside what housing spend themselves. In contrast the proportion of adapted properties in the council stock has increased from 17% to 21%, perhaps because councils pay for their own adaptations and have more control over the process making them less likely to take them out (Figure 4).

Figure 4 Trends in adapted homes 2009-2018

Some adaptations will always need to be removed if they have reached the end of their life, but local authorities are aware that some associations have a standard practice of removing through floor lifts, stairlifts and hoists because it takes too long to find someone who might need the adaptations. It is a loss of investment and reduces the options for the considerable number of tenants needing more accessible homes.

Moving versus adapting

There are times when a move is the only solution if the home will not meet needs, or the adaptation work is not reasonable or practicable due to the nature or condition of the property. Some people will welcome the chance to move to a more suitable home.

Long waiting lists for homes means that there is huge pressure on landlords to encourage people to move, especially smaller households occupying family homes.

The concern is that disabled and older tenants are not always aware of their rights and may defer to professionals, even when what is proposed is not what they want.

A High Court Ruling in 2020 stated that that a DFG for an adaptation cannot be refused and a person asked to move as the DFG is tenure neutral.  An application from a tenant must be treated the same as one from an owner occupier. (McKeown, R (On the Application Of) v London Borough of Islington [2020] EWHC 779. https://www.bailii.org/ew/cases/EWHC/Admin/2020/779.html.)

Those who are less confident, in poor health, have communication problems, or mental health issues may find it very difficult to argue against a decision made by their landlord.

Fear of being asked to move may also prevent some people coming forward to get help with adaptations.

All too often the need for changes to the home only becomes apparent when someone falls or visits hospital. At this point moving home would be particularly disruptive and difficult to cope with. It is particularly hard for people to move if they have conditions like sight loss or dementia where their independence is based on their memory of a familiar environment.

Finding a suitable home

We are not building enough accessible homes and not recycling adapted homes effectively. For example, outside London only 1.5% of all homes planned over the next decade will be wheelchair accessible.

In some areas people will have options to move but in others the choice is much more limited. For younger disabled people who make up a high proportion of those in unsuitable homes, the options are often very restricted.

Specialist housing for older people is not evenly spread geographically. It only makes up 15% of the sector’s stock and is either held by small providers with less than 1,000 units or by a small number of large providers. Some areas have very little, or only have older sheltered units with awkward layouts that are difficult to upgrade or adapt.

In any case, not everyone wants to move to retirement housing. Many prefer to stay in their familiar neighbourhood where they have support, surrounded by people of all ages.

Finding a home is not easy. Work by the Equality and Human Rights Commission showed that two-thirds (65%) of local authorities are unable to estimate the proportion of social and/or affordable housing that is accessible, and only 19% of authorities in England have an adapted housing register.

Opportunities to move are hampered by the removal of adaptations at change of tenancy and strict void times make it very hard to match people to suitable properties.

Research shows that disabled people find the moving process difficult, but not all associations provide practical support with the application process, viewing or moving.

Summary of the issues:

  • Handovers and delays
  • Incomplete data about tenants and adapted properties
  • Access to services
  • Assessment of need
  • Refusal of consent
  • Void policies and loss of investment
  • Moving versus adapting

Solving the problems

Several issues were uncovered by the research that need to be addressed.  These include:

  • Lack of consistency in the amount housing associations contribute to DFG funding.
  • Handovers and lack of a single point of contact for consumers.
  • Delays in the process – especially in getting landlord’s consent for work.
  • Lack of control over the adaptation process for some associations.
  • Adaptations being refused or removed at change of tenure.
  • The need for tenants to move but poor information and lack of support with the process.

 

The remainder of this summary report looks at possible solutions.  Some can be implemented now, but others require changes to legislation, regulation or guidance and need to be part of forthcoming central government consultation about the DFG.  Other changes will require action by Homes England and the Housing Regulator.  All require more engagement by housing association senior managers in addressing the flaws in the way home adaptations are currently delivered.

Solving the problems - Contributions to DFG costs

At present contributions to costs are variable, with some associations paying nothing, others a percentage, while others only pay towards certain cases. The surveys conducted for this study showed that what housing association adaptation staff wanted most of all was consistency.

“We need something at national level – we need consistency.”

Housing association respondent

A survey of local authorities showed that payments have reduced, particularly as associations have merged or joined bigger groups.  A few authorities have removed the need for housing association contributions as DFG allocations have increased.

Not only are the percentages different with varying thresholds, but some authorities want the agreed funds paid at the beginning of each financial year, others ask for invoices on completion of each job, while others want an aggregated payment at the end of the year. The services associations get for their contributions also vary considerably as not all get a full agency service. A survey of local authorities showed that payments have reduced, particularly as associations have merged or joined bigger groups. A few authorities have removed the need for housing association contributions as DFG allocations have increased. However, 40% of authorities said contributions are still important and some are very reliant on them, particularly in areas where associations use a high proportion of the DFG.

In our survey most local authorities thought associations should pay towards DFG costs. It is not just about the funding. Authorities felt that DFG contributions made adaptations more of a strategic issue and encouraged associations to be more aware of the needs of disabled tenants. Having to make a payment also brings greater parity with the council stock and LSVTs that use their own funding rather than the DFG.

Some proactive authorities, such as Walsall, ask for contributions as part of a wider partnership agreement which can include access to framework agreements, grants for improving communal areas, paying the extra costs of providing accessible homes in new build schemes, the costs for adaptations in planned repair schemes, and home energy and insulation projects.

Housing partnerships were recommended in the DFG Review to co-ordinate local strategy about adaptations and moving home for disabled and older people. The Social Care and Integration White Papers published in late 2021 and early 2022 also recommend stronger place-based planning and closer integration of health, care, and housing.

Getting consistent contributions

Several options have the potential to make the funding situation fairer and more transparent and allow housing association contributions to be more consistent. Some would require a change in the DFG legislation, some require a change in the funding allocation, and others could be implemented through guidance. In summary, the possible options are:

Option 1

To carry on as things are now is not working. It only operates well in areas
where there is a substantial DFG allocation or where strong local authority leadership has allowed the negotiation of large contributions. It is not working for:

  • Associations that operate over numerous local authority boundaries
  • Authorities with high DFG use by associations but an insufficient DFG
    allocation
  • Authorities with a confusing patchwork of contributions.

It leads to considerable inequalities:

  • Tenants get variable services depending on where they live
  • Owners and private rented tenants are less likely to hear about the grant or face delays if too great a proportion of the DFG budget goes to housing associations.
Options 2 and 3 (major change)

Making associations fund their own adaptations as happens in the council stock may not be justifiable. Returning to direct payments (as happens in Wales) would be difficult to implement and goes against the need for better place-based planning.

Options 4 and 5 (medium change)

Removing housing association contributions entirely or making it a standard percentage contribution. Both require a change to the allocation formula and/or an increase in central government funding to compensate authorities that currently rely on high levels of contributions from associations. Local authorities would prefer a standard contribution as it puts adaptations on the strategic agenda of housing associations. This needs a decision by government. It should be part of the forthcoming consultation about the DFG. 

Options 6 and 7

Alter the delivery methods – by top-slicing the DFG or using landlord applications. These could both be introduced relatively easily.

Solving the problems includes:

  • Getting consistent contributions
  • Using landlord (rather than tenant) DFG applications
  • Top slicing the DFG
  • Making further changes to the DFG – allocation of resources, works over the upper limit and the means test
  • Adaptations to common parts
  • Working in partnership over home technology
  • Improving the construction industry
  • Developing better home adaptation design
  • Providing support to move home

Solving the problems - Landlord DFG applications

Advantages of landlord applications

Advantages for the tenant:
  • The tenant has one point of contact – their landlord.
  • The landlord is made aware earlier that a tenant needs help with their home.
  • It will initiate better discussions about housing options.
  • It will reduce delays in getting consent and speed up the process.
  • Removing the means test reduces paperwork.
  • No means test will help more households go ahead with work – 23% currently drop out because they must pay a contribution.
  • It treats housing association tenants the same as other social housing tenants who are less likely to be means-tested. It also gets rid of the post-code lottery due to some authorities removing the means test in their local Housing Assistance Policy while others still apply it.
Advantages for the landlord:
  • Some will welcome the opportunity to take more control over the process.
  • The ‘contract’ for completion of works is with the landlord and contractor (rather than tenant) so that they can control who completes works in their properties. It makes it easier if things go wrong either during or after works have been completed.
  • Landlords will find it easier to top up the grant to get better designs.
  • Landlords can do their own CRM compliance.
Advantages for the local authority:
  • It makes it easier to resolve problems with the application process as there would be a named housing association contact on every form.
  • It speeds up the process of dealing with paperwork and reduces delays.
  • Authorities can reclaim specialised equipment when no longer needed, such as stairlifts.
  • Local authorities can retain nomination rights for a period of five years to make sure DFG investment is protected and adapted properties are relet to other disabled people.
  • Agreement about future maintenance could become part of the contract.
  • If more associations took over project management, it would reduce the workload allowing authorities to focus on owner occupiers and private tenants who otherwise have little support
  • Local authorities retain control of the funding to meet their statutory duties.

Disadvantages of landlord
applications

Disadvantages for the tenant:
  • Tenants have less support if an application is refused by the landlord, or they did not agree with the adaptation work proposed.
Disadvantages for the landlord:
  • Although many associations will welcome the chance to have more control by managing adaptation work themselves it will require more staff resources and the right contractors – many will still prefer the local authority or HIA to manage the work.
Disadvantages for the local authority:
  • There would be an impact on DFG spending in some areas if the means test was removed. However, as contributions are often quite small, removing the test might not add much to overall costs.
  • There would be a loss of the local authority agency fee if associations take over project management.
  • If housing associations take over more of the process, they will need to provide output and outcome data for DFG cases so authorities can show they are meeting their statutory duty and can make the annual DELTA statistical return to DLUHC.

Top slicing the DFG

For associations that work closely with individual local authorities, another option is for them to be allocated a certain amount DFG funding each year to allow the housing association to control the whole adaptation process.

This has already been done in number of areas and is currently being piloted in Cornwall. Top-slicing would work best where an association has a considerable amount of stock in a local authority area.

Ideally the housing association would employ an OT (or have one seconded) and have their own trusted assessors so that they can deliver all aspects of the adaptation service themselves. This would provide a much faster and more seamless service for residents. It would allow them to mirror some of the good practice highlighted in the Background Report such as that offered by WDH in Wakefield.

This would provide a much faster and more seamless service for residents.  It would allow associations to mirror the good practice highlighted in the Background Report, such as that offered by WDH in Wakefield.

If more associations took over customer support and project management, it would reduce local authority workloads allowing them to focus on owner occupiers and private tenants who otherwise have little support

Housing associations will need to provide local authorities with output and outcome data so that authorities can show they are meeting their statutory duty and can make the annual DELTA data return to central government.

Landlord DFG applications

At present the tenant makes the application to the local authority for a DFG, but their landlord needs to give consent before work can go ahead. Getting consent is the biggest cause of delays.

The 1996 DFG legislation and guidance allows an application to come from the landlord.

Landlord applications would result in a simpler customer pathway as the tenant would turn to their landlord for help and would have a single point of contact. At the present time the landlord may not find out that a tenant needs help until they are asked to give consent for work weeks or even months after the tenant was first referred.

The landlord would have more control over the adaptation work, and any additional repairs and improvements needed, as the contract would be with them and the contractor, not the tenant and the contractor. They would also know when work was completed allowing records to be updated more easily.

Recommendation for housing associations and local authorities

  • Landlord (not tenant) applications to be used for DFG cases using standard paperwork.

Recommendation for local authorities

  • Top-slice DFG funding for specific associations to allow them to manage work themselves.

 

Solving the problems - Guidance and consultation about further changes to the DFG

Government guidance about effective and efficient ways to deliver the DFG is being issued in 2021bringing together previous guidance alongside recommended best practice.

Consultation about further changes to the DFG was announced at the end of 2021. This includes the DFG amounts allocated to local authorities, the upper limit of the DFG, and the means test. There are also plans to introduce Section 36 of the Equality Act to allow more adaptation of the common parts of dwellings.

Home technology is also becoming increasingly important to enable people to remain independent.

The following sections look at each of these issues in turn.

1. Allocation of DFG Resources

The central government allocation of DFG funding needs to be better aligned with local need. The basis on which it is calculated has not changed since 2011. The 2018 DFG Review assessed how the formula could be updated but did not make a firm recommendation about how housing association use of the DFG should be accounted for in the allocation.

The findings of this report shows that it is very important to include housing association use of the DFG in any amended allocation calculation. In some areas 50% or more of the DFG allocation is going to associations, with little left for owner occupiers or private sector tenants.

A fairer distribution of funding would allow housing association contributions to DFG costs to either be removed entirely or set at a standard level. The current inconsistencies in contribution amounts are confusing and lead to unnecessary conflict between associations and local authorities.

Ideally any changes should be accompanied by an increase in the total national DFG allocation amount. If not, new arrangements for funding would need phasing in to allow local authorities to adjust, because some would gain while others would lose funding.

2. Works over the DFG upper limit

Housing associations are often asked to contribute to the cost of adaptations over the upper limit of the DFG. This is currently set at £30,000, although some authorities have raised the limit as part of their Housing Assistance Policies. Some major adaptations, such as ground floor extensions, can cost £70,000 or more.

Housing association adaptation budgets are usually too limited to cover the additional cost, particularly if there are a cluster of expensive cases in a single year. Prolonged negotiation can lead to long delays for the disabled person and their family who are often struggling with a very inadequate home. These cases are usually better met through capital works budgets.

3. Changing the means test

In relation to social housing, the way the means test currently operates varies. Some authorities do not means test any social housing tenants, others test housing association tenants but not council tenants, while a few test everyone. Some housing associations top up if a tenant must pay a contribution, but others do not. The way the means test currently works is inconsistent and unfair.

If landlord applications are used for DFG adaptations this would remove the need for housing association tenants to be means tested, but local authorities need to be able to afford to cover any increase in costs.

There also needs to be agreement about how means testing would operate in relation to adaptations in the common parts of dwellings once Section 36 is introduced which is discussed below.

Changes to the means test needs much more work by central government.  Aligning the DFG means test with new social care charging arrangements might resolve some the issues.  The aim should be to make the test of resources transparent and fair for all DFG applicants.

4. Adaptations to common parts

Most work to the common parts of dwellings (such as entranceways, hallways, stairs and emergency exits) is usually done by associations themselves.
Section 36 of the Equality Act 2010 is to be brought into force in England and Wales to make it easier for disabled people to enter and leave their homes. The Equality Act allows landlords to ask tenants to pay for the work, but residents on low incomes or with disabled children can apply for a Disabled Facilities Grant.
The 2018 DFG Review tried to put a figure on the costs of introduction, but the lack of detailed property data for most areas made this very difficult. If enacted, it could result in significant pressure on DFG funds, so the introduction needs to be monitored effectively to gauge the impact.

 

Recommendations for central government

  • Update the DFG allocation formula to take account of housing association use of the DFG.
  • Issue guidance to make the level of contribution to the DFG consistent for all housing associations across England.

Recommendation for housing associations

  • Use capital works budgets (not limited adaptation budgets) to contribute to expensive cases above the upper threshold for DFG funding.

Recommendation for central government

  • Resolve issues about the funding of common parts before Section 36 of the Equality Act is enacted and provide guidance to local authorities and landlords.

Several outstanding issues need resolving:

  • A clear definition of common parts.
  • Who applies for a DFG –tenant or landlord? •What happens if there are multiple landlords, especially in leasehold blocks?
  • Does the DFG means test apply?
  • How should costs be apportioned if there are multiple disabled tenants?
  • Should landlords contribute towards costs?
  • A clear definition of what would count as a legitimate objection.
  • How should maintenance be organised and paid for?

Solving the problem - Home Technology

Home technology is becoming an increasingly important aspect of home adaptations and something that housing associations are keen to adopt to keep tenants independent. Covid-19 has hastened its uptake among a wide range of consumers and upended myths about older people not being able to use IT.

Unfortunately, disabled people and those with health conditions are the some of those least likely to use the internet. Lack of skills, low incomes, and inability to pay for subscription costs hamper the uptake of things such as smart plugs, video doorbells, remote heating and lighting controls and other devices to control aspects of the home.

Assistive technology is beginning to be provided as part of home care packages by social care services and can be included as part of a DFG application in some cases, but this will not reach most disabled and older tenants. Housing associations will need to provide their own support.

Although assistive technology can sometimes be provided as part of home care packages and included in some DFG applications, in most cases housing associations will need to provide their own support.

Solving the problem - Contractors

The construction workforce is ageing rapidly and there is national shortage of skilled contractors and tradespeople, especially the sub-contractors that do much of the adaptation work.

If housing associations are to take over more of the management of home adaptations, there needs to be a real focus on ensuring the right contractors are appointed, the process is managed effectively, and the outcomes monitored.

Housing associations and local authorities need to work in partnership to improve contractor training and performance. They must also avoid setting prices too low in what has become a very competitive market.

In interviews, housing association staff mentioned the lack of handyperson support, particularly for older tenants.  The government is planning to fund more of these services.  Associations will need work with local authorities to determine how any new handyperson services might operate.

Housing associations and local authorities need to work in partnership to improve contractor training and performance.  There is also scope to develop handyperson services in partnership with local authorities.

Solving the problem - Better Design

Restricted budgets mean that it is hard to innovate and improve the appearance of adaptations.

Failure to invest in design More attractive, inclusive design
Medical-looking designs deter people from seeking help with their homes. Encourages people to fit adaptations earlier, reducing risk and maximising independence.
Obvious adaptations outside people’s homes make them a target for crime Prevents adaptations being refused by landlords.
Poorly designed products are more likely to be removed at change of tenancy. Reduces the costs of making a house ready for reletting and makes them easier to let.
Poor design and sub-standard fitting by contractors leads to faults and water leakage. Begins to create a more inclusive housing stock.

There has been a lot of innovation in home adaptations and there is now a wide range of well-designed fixtures and fittings that would look good in any home. If these designs were used it would future-proof the housing stock reducing the need for further adaptation.

Some associations are already using Invisible Creations products, and there are other manufacturers and suppliers with attractive ranges suitable for rental properties.

Some associations are also using flexible designs, such as installing shower trays under baths, or fitting the anchor points for grab rails and shower seats, to allow rapid conversion when required.

To ensure that good design is properly embedded requires effective management input and increased adaptation budgets.

In value for money calculations, it is important look at lifetime costs, not just the cost of the fixture or fitting. The labour costs and impact on void times of installing and removing cheaper items needs to be set against the cost of fitting quality items just once. In addition, as more associations get behind improved design their purchasing power will allow better prices to be negotiated.

In a housing sector where 54% of tenants have a long term illness or impairment, creating a more inclusive housing stock should be a central part of overall strategy.

More details about improving the appearance and quality of adaptations are shown in the accompanying online design guide. 

More details about improving the appearance and quality of adaptations are shown in the accompanying online Design Guide: https://www.foundations.uk.com/design/.

Solving the problem - Support to move

Decisions about moving need to be made earlier rather than at the point when someone is ill, has fallen, or in crisis and unable to cope with a move:

  • Routine housing reviews need to include discussion of home adaptations and the potential to move home. This would improve people’s knowledge of the choices available and allow them to plan ahead more effectively.
  • Home MOTs would also identify people who are struggling with their home environment.

These initiatives would provide data for associations to use at a strategic level to understand the needs of their disabled and older tenants and what new homes and services need to be provided.

Accessible Now is an extension of the HomeFinder service being developed with disabled residents and OTs. It includes a comprehensive range of information to make it easier for people to find suitable homes.

The need for specialist support – although people will usually be given a priority banding in bidding for homes, specialist support with moving is more limited. Research shows that, although everyone’s needs are different, most disabled people require help with the application, viewing and moving-in processes.

‘Managed rehousing’ where disabled people are matched to properties works more effectively than the current system of leaving people to deal with the choice based letting or home swap systems on their own. It is best carried out by specialist staff, ideally OTs, who can assess the person and the properties available and take people to look at homes, or use ‘virtual viewings’.

There are some very effective services run by housing associations, often in conjunction with home improvement agencies, such as Bolton at Home’s HOOP service. However, some are restricted to older people when disabled people of all ages require this type of help.

The savings far outweigh the costs. It prevents people dropping out of the process, matches people to properties, frees up larger homes, reduces void times, sustains long-term tenancies, and provides substantial savings to health and social care.

Bringing together home adaptations staff with a managed rehousing team into an ‘inclusive housing’ or ‘customer service improvement’ team would provide a much more streamlined and effective service for older and disabled tenants. It would give people a single point of contact and more choice and control over their housing options.

Recommendations for housing associations

  • Improve home adaptation information on asset management databases.
  • Routine housing reviews to include future housing needs (adaptations/moving).
  • Develop a ‘Managed Rehousing’ process to match people to properties and provide practical support for disabled and older people needing to move.
  • Base the home adaptations and managed rehousing service in an integrated ‘inclusive housing’ or ‘customer service improvement’ team.

Developing inclusive strategies

Leadership and diversity

The 2021 National Housing Federation (NHF) report on Diversity and Inclusion acknowledged that the sector has been talking about diversity for a long time, but it has not resulted in significant change. It is easy to appoint staff members who are the same as those you already have so they will ‘fit in’ and it takes courage to appoint somebody who is different.

Given that 54% of the population has a long term illness or impairment it is vital to appoint more disabled people as staff members, in leadership positions and onto boards. There is potentially a huge pool of talent hidden within the housing association sector given the number of disabled people it houses. As employers, housing associations have an opportunity to do so much to close the disability employment gap.

Inclusive living strategies

There is a need for a far more flexible housing stock that can adapt to people’s changing needs over the lifetime. It is not just about new homes, but about how we can make the existing housing stock work for everyone.

The Scottish Federation of Housing Associations (SFHA) and Stirling University Scottish Federation of Housing Associations have developed an especially useful suite of materials designed to help social housing providers take a more holistic approach to accessibility and inclusive living. Using consultation and co-production techniques the Inclusive Living Toolkit brings staff and residents together from different parts of one association, or within a group, to develop an inclusive living strategy that will work across strategic areas.

It is also important that every housing association has an inclusive housing lead to make sure that disabled people do not get left out of major strategic and policy decisions (e.g. decent homes or energy efficiency initiatives) and that services are joined up more effectively for disabled and older tenants.

It is also important to include adaptations staff and OTs in decisions about new homes and major retrofit schemes. New construction methods are making the fitting of adaptations more time-consuming and expensive. Engineered wooden beams may reduce build costs but make it very hard to fit hoists to ceilings or drop shower trays into bathroom floors. Even the fitting of grabrails and handrails, which should be quick and easy, can become much more complicated and costly if there are non-structural walls in key places such as bathrooms and staircases.

Outcomes

The current fragmentation of adaptation services between housing associations, social care OT services and DFG teams makes it very hard to measure outputs, outcomes and impact and give a clear picture of what is happening in the housing association sector. If housing associations bring together services for disabled people in a more coherent way, it would allow better measurement of outcomes and feedback loops for continued service improvement.

Accountability

In the past the Audit Commission’s Housing Inspectorate, a public spending watchdog, was involved in inspections of housing associations. These had significant impact on housing association adaptations spending and delivery, albeit for a short period of time. Short notice inspections’ (SNIs) focussed on three themes ‘access and customer care’, ‘diversity’, and ‘value for money’ using Key Lines of Enquiry (KLOE).

Each association also had to demonstrate that they were consulting specific groups of residents including older people, people with caring responsibilities and those with disabilities.

Unfortunately, the Audit Commission was discontinued due to the austerity measures introduced in the Spending Review of 2010and inspections ended.

One of the most significant changes promised by the Social Care White Paper is a shift back to regulation of consumer standards with inspections of landlords with more than 1,000 homes every four years.

At the time of writing the Housing Regulator’s Corporate Plan includes nothing on disability. It can only be hoped that the new inspection regime will include similar issues to the earlier Audit Commission inspections.

Recommendations for housing associations

  • Appoint more disabled people in all departments and to leadership positions.
  • Use co-production with disabled and older tenants to drive service improvement.
  • Appoint an Inclusive Housing Lead to ensure that disabled people do not get left out of major strategic and operational policy decisions and that services are joined up more effectively.
  • Use the Inclusive Living Toolkit to develop an approach that will work across strategic areas

 

Recommendation for Homes England and The Housing Regulator

  • Inspection regime to include home adaptation and home move services for disabled people of all ages.

Conclusions

During the Covid-19 pandemic of 2020-22 we all experienced what it is like to be confined inside our homes for long periods.  It allowed an insight into what life is like for many disabled people and highlighted the need for more accessible and better designed homes.

Disabled people and those with a long term illness are not a minority; they are a key customer group making up more than half of all existing tenants and almost a fifth of all new lettings.  The average age of tenants is 52 and demand for adaptations is only going to increase as the population ages.

Disabled tenants of working age and families with disabled children are often very poorly housed and more than half of those who need adaptations do not have them.  Poor health is increasing in younger age groups and levels of obesity are rising.  The need for adaptations is going to rise.

It is no use relying on new housing to solve the problems.  New accessible homes are very important, but nearly all the homes we will be living in in 50 years’ time are already built and most tenants will never live in a brand new property.  We need to address the shortcomings of the existing stock and make it work for everyone.

Housing association landlords need to take more control of the home adaptations process and work in closer partnership with local authorities.  It will involve more investment by associations themselves, and better use of DFG funding.  The DFG is a very rare mandatory grant, a fact which is not sufficiently appreciated.

It is not just about funding.  Perhaps more crucially it requires a change in culture:

  • From assets to people
  • From new build to the existing stock
  • From value for money to investment
  • From reacting at crisis point to prevention
  • From putting up barriers to saying yes

Adaptations have often been seen as a niche issue, but they are fundamental if homes are going to be able to flex to accommodate the changing needs of occupants.  None of us know when we might have an accident or illness that will make us glad of the rail outside, the seat in the shower, or the better lighting in the kitchen.  What is certain is that we will all grow old and need those extra fixtures and fittings that make life safer and more comfortable.

Housing associations have always been innovators and there is so much scope for them to lead the way in developing new inclusive, attractive adaptation designs.

Instead of a decline in the number of adapted homes, the goal over the next decade should be to see a substantial increase in attractive, inclusive homes in the existing stock, regardless of whether they are general needs or specialist properties.

It needs engagement by management, effective partnerships with local authorities and the involvement of disabled people.  Hopefully this summary and the more detailed research report provides the background to allow associations to sit down with disabled tenants and staff and start planning ways to make services work better.

“It is about learning to say ‘yes’ to adapting homes rather than trying to put barriers in the way.”

Speak to our Regional Advisors

Our team of Regional Advisors are at the heart of what we do – providing advice and support to Local Authorities and Home Improvement Agencies. And because we’re funded by the Department of Levelling Up, Housing and Communities our everyday support is free of charge.

Whether it’s a question about the DFG legislation, you need advice on how to commission a HIA or anything in between – we’re here to help.