Universal Credit Regulations Call for Evidence Introduction Refuge opened the world s first refuge in 1971 and is now the country s largest single provider of specialist domestic violence services. On any one day, around 2,000 women and children access Refuge s services. These services include: Freephone 24 Hour National Domestic Violence Helpline: Run in partnership between Refuge and Women s Aid Refuge accommodation: Refuge runs 45 refuges across 16 local authority areas Floating support: Working with women who are either still living with their abuser and/or those who have left their abuser and require support Community outreach: Refuge supports women from ethnic minority groups, including Vietnamese and East European women from Bulgaria, Poland and Romania Independent advocacy: Refuge s independent domestic violence advocates operate across London and Coventry and Warrington, supporting women through the civil and criminal courts Prevention and education: Refuge works to influence the Government s response to domestic violence and raise public awareness of the issue Two women are killed every week in England and Wales by a partner or ex-partner and one in nine are severely physically abused each year. In 90% of domestic violence incidents, children are in the same or next room. 38% of women calling the 24 Hour National Domestic Violence Helpline (run in partnership with Women s Aid) are in immediate danger and need to escape with their children to emergency accommodation. Victims of domestic abuse are at greatest risk of homicide when they are attempting to separate from a violent partner. They often leave everything behind and arrive with very few possessions. Research by Refuge found that 89% of women accessing its services had experienced financial abuse, and the majority of those women were what the Government considers to be financially excluded 1. Around one-third of women accessing Refuge s services do not have a bank account. A large number of women in refuges will have previously applied for a Crisis Loan, either prior to coming into a refuge or whilst in a refuge. Often, at point of entry into a refuge, women will arrive with no money and few, if any, personal possessions for themselves or their children. 1 http://refuge.org.uk/cms_content_refuge/attachments/what's%20yours%20is%20mine%20exec%20summary %20(Web).pdf 1
Summary Refuge responded to the Department for Work and Pensions consultation on Universal Credit. This response summarises the concerns we raised in relation to the impact of the implementation of Universal Credit on refuges. There has been no reference in the regulations to supported housing or exempt accommodation, which makes it difficult for providers like Refuge to plan for the impact of the changes. Refuges are unique in terms of the specialist support they provide to abused women and children. If the proposed payment arrangements are applied to refuges, their financial viability could be threatened. Delayed payments could leave survivors with no resources for a considerable period of time, and providers with cash flow problems. Refuge does not think Universal Credit will be workable for this type of supported housing. We understand that funding to local authorities for discretionary housing payments will be increased. However, given the number of people affected by the changes, demand is highly likely to exceed the funding available. We are also concerned that some local authorities would apply local connection to discretionary payments, which is not appropriate to women fleeing domestic abuse who must leave their local area in order to stay safe. There has been no information on how vulnerable clients will be identified and how their claims will be processed. Online management of claims must be secure and confidential for this client group. One of the biggest threats to the future sustainability of refuge provision is the proposal to make some service charges, which are essential to the operation of refuges, ineligible. We are extremely concerned that the regulations do not allow for rents to reflect the unique position of refuges providing crisis family accommodation. We would urge that this policy be reconsidered. 2
Information Claims and payments There is a national shortage of refuge provision.. Refuge accommodation is, by its very nature, short-term emergency accommodation. Women and children often flee to our services seeking a place of safety away from the danger area where the abuse has been perpetrated. Refuge understands that a snapshot will be taken of a woman s financial situation on a given day and that this snapshot will be used as the basis for determining her entitlement to housing costs for a whole month. This is clearly unworkable for refuge accommodation, as women and children often arrive and leave at very short notice. Women experience many forms of domestic violence, including physical, emotional, sexual and financial abuse. Perpetrators of abuse exert power and control over their victims. Women who reach our services may have had their every movement controlled, being told when they can leave the house and for how long, what they can wear and how much money they are allowed to spend. It is not unusual for perpetrators to control all of the benefits for a household and to accumulate debt in a woman s name. Very often a woman will arrive at a refuge with no money at all. Refuge is concerned that a woman who moves in to a refuge at the beginning of the month but does not receive payment until 7 days after the end of the month will not have enough money to survive during this period. Likewise, a woman who has been working may lose her job through fleeing domestic violence. She may arrive at the refuge on, for example, the 2 nd of the month but would not get paid until 8 th of the following month. Benefit payment periods If Universal Credit is used to cover housing costs in supported housing, the practice of paying monthly in arrears 7 days after the end of the period (if the payment is on time) will impact greatly on small providers who cannot afford to operate in this way. The level of arrears for refuges will increase if women receive one month s housing benefit payment in arrears and have already left their accommodation. The impact of managing a higher level of rent arrears would be financially disastrous for smaller organisations such as Refuge who may have no means of retrieving those arrears. Payment to landlords It is still not clear exactly how vulnerable clients will be identified. The current plans state that only the individual can request direct payment. We have been assured that claims 3
involving domestic abuse will be classified as vulnerable and therefore payments will go directly to the landlord. However, there has been little information on practical arrangements for identifying vulnerable clients and payment direct to landlords. It is absolutely crucial that any online claims for victims of domestic abuse are secure and confidential. Discretionary payments Refuge welcomes the additional funding to local authorities for discretionary payments. We note that there is a fixed amount for each area and that, although local authorities have discretion to match central government funding, there is no obligation to do so. Refuge believes it is essential that the funds for discretionary payments are ring-fenced. The demands on discretionary payments are likely to be high, particularly when local Housing Benefit departments restrict the amounts payable to some refuge residents, in particular those under the age of 25. This will leave these women in an impossible position: whilst no longer needing the care and support of a refuge, they may not be able to find anywhere safe to live that is affordable, especially in London. (Under 25 s are only entitled to a shared room rate). This will leave under 25 s particularly vulnerable to all sorts of exploitation. 23% of our current service users are under the age of 25 (202 aged 16-24 years old, of whom 46 are 16-19 years old). Discretionary payments are for all categories of vulnerable people. The draft DWP Discretionary Housing Payments Guidance Manual April 2013 acknowledges that demand for discretionary payments will be high: Given the numbers of people affected by changes, awarding DHPs to meet all shortfalls is not going to be a viable option. You will need to consider how best to target the funding within your priority groups, whilst remembering that each case must be considered on its own individual merit. Refuge recommends that local authorities be required to prioritise discretionary payments for women escaping domestic abuse and ensure timely access to funds. Local authorities will need to give careful consideration as to how discretionary payments will be administrated, especially if initial claims for Universal Credit are to be administered centrally, online or on the telephone. We are also concerned that local authorities may introduce local connection as one of the criteria for assessing discretionary payments. Women fleeing domestic abuse very rarely stay in their local area as it is not safe to do so. The DWP should ensure that women fleeing domestic abuse are not discriminated against by local authorities because they do not have a local connection. 4
Rent levels and service charges Refuge is extremely concerned about proposals to make some existing service charges ineligible. Rent levels in our services can be higher than some other client groups. Our client group is extremely vulnerable with a high level of need, requiring intensive support. We support a high number of children at any given time. Refuge accommodation is a short-term emergency service. Throughput is much higher than in some other client groups and therefore a higher level of housing management is required. Due to the nature of our services, refuges are often in more expensive residential areas and need to be close to amenities. The types of housing costs that are typically higher for our client group are: 24-hour call out, 365 days per year Children s equipment, play areas and furniture Heavy wear and tear on the fabric of the buildings Provision of basic requirements for women and children who often arrive with just the clothes they are wearing Provision of furniture, bed linen, towels etc. due to lack of belongings Enhanced security such as CCTV and extra security on all entrances and windows Intensive housing management due to high turnover and the crisis nature of our work Service charges for women escaping domestic abuse are already particularly vulnerable to challenge by local authorities that do not understand the unique and complex nature of a service for vulnerable women and children who often have multiple complex needs. This makes comparison with cost in supported housing difficult, and with ordinary housing impossible. Refuges provide short-term emergency accommodation for women and children. Women in our services often arrive at a point of crisis, bringing with them few, if any, belongings. We have no option other than to provide furniture and fittings and other essential items. In addition, our furniture, carpets, white goods etc. receive heavy wear and tear. Children s play areas and communal gardens are essential in helping children rebuild their lives and recover from the trauma they have experienced. 78% of children in our London refuges are under the age of seven. We are extremely concerned that the regulations do not allow for rents to reflect the unique position of refuges providing crisis accommodation for families. Security in our refuges is also of the utmost importance. Items such as entry phones are integral to the running of the service; Refuge is concerned that these provisions may not be covered. Due to the high turnover of clients and the crisis nature of our work, intensive housing management is a key element of the service we provide to women. We recently carried out 5
a time management survey with our staff which showed that staff working in refuge accommodation spend at least 20% of their time dealing with tenancy issues, collecting rent, ensuring health and safety is carried out to the required standard, working with the residents around communal living etc. Local authorities who fund support will not pay for this element of the service. If we are no longer able to charge intensive housing management we will not be able to fund the level of staffing hours needed to run a refuge. Registered Social Landlords with whom we work will not allow us to move any costs to core rent as this takes rent above the rent convergence level required by the Homes and Communities Agency. Women will not be able to afford to pay the additional costs themselves and will be faced with the option of: 1) Remaining with the perpetrator of the abuse because they cannot afford to move out. 2) At the point of leaving a perpetrator - when they are in most danger and are at their most vulnerable - moving to unsuitable accommodation without additional security and specialist support. Refuge has carried out scenario planning for every single one of our refuges. The impact of the service charge reduction or exclusion measures will mean the closure of all our refuges, resulting in the loss of 297 units of refuge accommodation across the country. We would also have to close our floating support services as they are often run alongside our refuge provision. If this is the case for our refuges, it must be the same for many, many more. If our life-saving services were to close, the cost to the public purse would increase substantially. The Cap Gemini report which researched the financial benefits of the Supporting People programme estimates that, in relation to domestic abuse, the increased costs to the public purse associated with events that might otherwise be prevented or minimized is likely to rise by 24,701 per event. This is broken down as follows: An average 20,702 cost arising from severe incidents of domestic violence, including hospital, ambulance and Criminal Justice System costs. An average 2,665 cost arising from homelessness, including social costs of homelessness and costs of emergency accommodation (e.g. B&B). An average 516 cost from homicides (corresponding to an increase from around one per 1,000 population per annum to around four), including human and emotional costs and costs to the Health Service and Criminal Justice System. An average 213 cost from tenancy failure. An average 199 from being a victim of a minor incident of domestic violence, including hospital, ambulance and Criminal Justice System costs. 6
Additional other, less significant event costs which total to an annual average of 406. Recommendations 1. Refuges should be considered as unique in terms of the specialist support they provide and should be removed from Universal Credit. Survivors accommodated in refuge services should be exempt from the benefit cap. 2. The removal of certain types of eligible service charges should not apply to refuges, as specific elements are essential to the service provision. Housing Benefit and Universal Credit housing element should continue to pay the whole rent including all of the service charges/running costs of the refuge service. 3. Payments should be made directly and immediately to the refuge service for the full period of a survivor s stay. 4. The online management of claims by domestic violence survivors must be secure and confidential. 5. It is essential that funds for discretionary payments are ring-fenced. 6. Every local authority should have policies and procedures in place to ensure that all victims fleeing domestic abuse are able to access discretionary payments quickly and efficiently. 7. Local authorities should not exclude women in refuges from accessing discretionary payments by applying local connection criteria. 7