Organisation details
1. Name of organisation
Name of organisation
(Required)
Scottish Federation of Housing Associations (SFHA)
2. Information about your organisation
Please add information about your organisation in the box below
SFHA is the voice and membership body for housing associations and co-operatives in Scotland. Our ambition is that everyone has a good home in a successful community, with a range of high quality, affordable, safe, and accessible homes that meet people’s changing needs and aspirations throughout their lives.
SFHA has 133 members, representing the interests of every size and type of housing association, from all areas of Scotland. There are around 150 housing associations and co-operatives in Scotland providing more than 280,000 homes and supported accommodation, specialist care and support. Around a fifth of Scotland’s population, approximately 1.2m people, live in social housing. Of those, half live-in housing association homes, and half in council homes.
SFHA has 133 members, representing the interests of every size and type of housing association, from all areas of Scotland. There are around 150 housing associations and co-operatives in Scotland providing more than 280,000 homes and supported accommodation, specialist care and support. Around a fifth of Scotland’s population, approximately 1.2m people, live in social housing. Of those, half live-in housing association homes, and half in council homes.
Other comments
9. Do you have any other comments on the Scottish Government’s proposed draft Stage 2 amendments to the National Care Service Bill?
Please use this text box to provide your answer
Housing associations and co-operatives are central to achieving many of the aspirations of the National Care Service , going way beyond the bricks and mortar with social justice built in and support for people to remain independent in their homes and communities for as long as they can, preventing homelessness and providing care and support. At least nineteen housing associations offer specialist housing with care and support and many others work in partnership with the third sector to deliver housing with care and support to people with a range of care and support needs.
Health, Social Care and Housing
We welcome the opportunity to offer further comments on the proposals for the NCS but remain concerned that the opportunity for improved collaboration with housing has not been addressed through any of the proposed amendments. We and other partners repeatedly called for a clear and explicit relationship between the proposed National Care Service and Housing and Homelessness services throughout stage 1 of the National Care Service bill scrutiny. And yet the amended version of the bill continues to ignore this crucial relationship.
Whilst the overarching aims of the NCS are wide ranging, there remains a gap in how the Scottish government sees housing and housing support aligning with the National Care service at strategic planning and delivery levels. The right to adequate housing is a basic human right and a reorganisation of social care services must consider the role of housing in planning and delivery to improve the wellbeing outcomes of those who require care and support. The proposed changes at stage 2 have again failed to recognise the unique contribution of housing in improving health and wellbeing and supporting independence at home through a range of services including innovative technology solutions, support and care, aids and adaptations as well as providing accessible homes.
The current draft legislation does not make it clear that the National Care Service should collaborate closely with other services such as strategic housing authorities to plan and deliver services. Given the clear interdependence of a range of housing and support services we believe this is a serious omission and was a missed opportunity when Health and Social Care Integration was introduced through the Public Bodies Joint Working (Scotland) Act 2014.
National Outcomes Framework
Scottish Government has also recently presented its revised National Outcomes Framework to parliament for consultation. The revised framework, as part of the objective to “improve the wellbeing of people living in Scotland now and in the future,” includes a new outcome on care and on having a “home that meets our needs.” Given the new focus on this in the proposed National Outcomes Framework, it would seem appropriate to ensure this is built into a new system for the National Care Service.
National Care Service Strategy
We remain concerned, as set out in our response to stage 1 of the Bill, that it is unclear how the cost of the development of the National Care Service will directly impact on frontline service delivery or how addition of a new structure will achieve the sort of improvements envisaged as it is not clear where the responsibility for resourcing NCS services lies. We recognise the need for leadership to drive the focus on prevention, human rights and equality, fairness, and accountability, but in line with the IRASC recommendations believe this should be planned and delivered at a locally accountable level. It is not clear that the current proposals will achieve this, nor do they set out the importance of partnership and collaboration required to plan deliver social care and related services.
While it is positive to see linkages with housing and homelessness services mentioned in the policy memorandum, it is not clear how this will be achieved. References to prevention through early intervention are welcome but evidence highlights the need to align with housing and housing support. Research commissioned by the Housing Support Enabling Unit (HSEU), SFHA and others, Economic-benefits-of-housing-v6.pdf (housingevidence.ac.uk), highlighted that housing support is often the ‘glue that helps make a wider model of care and support work.
A clear duty to collaborate with housing may improve the current position and help build on some of the good practice that does exist.
Housing to 2040
The Scottish government in proposals for the National Care Service and in Housing to 2040 have stated their policy intention to support people to live as independently at home for as long as they can. Housing to 2040 set out clear links with proposals for a shared agenda between housing, health and social car and we would like to see that commitment mirrored in the National Care Service. For example, Housing to 2040 commitments include:
• Ensure that strategic planning is joined up locally across housing and health and social care services.
• Develop and implement a joint accountability and outcomes framework to design and deliver person-centred and integrated services, planning to meet people's future needs.
• Establish mechanisms for shared resources across health and social care in a phased way to ensure best use of health, social care and housing funding and deliver integrated services on the ground.
• Ensure greater connectivity between mental health and addictions service design and local housing support, by continuing to scale up Housing First,
• Act jointly to transform the way health and housing services are delivered to those experiencing addiction and homelessness and to those with severe and multiple disadvantage.
A summary of key points:
SFHA would welcome a clear message on how housing aligns with the National Care Service through amendments to the Bill including:
• An additional principle added to the National Care Service Bill, that services should be designed collaboratively across the system, with all relevant stakeholders, including housing to ensure cross cutting rights like good quality housing and appropriate care and support are upheld. Current principles refer only to people who use services and family carers.
• Proposed membership of the National Care Services Board and the reformed Integrated Joint boards, (NCS Local Boards) to be set out more clearly, recognising the importance of co-design and the strategic importance of the housing sector in achieving the aims of the NCS.
• Representatives from Housing to have a seat on the proposed NCS Local Boards.
• Collaboration with the housing sector to plan and deliver joint responsibilities for homeless people that will be included in the Housing Bill. Proposals from Housing Directorate for the Housing Bill will place duties on Public Bodies to Ask and Act to Prevent Homelessness making it even more important to have an integrated system that includes housing.
• Recognition of the strategic importance of accessible housing, housing support and housing adaptations to ensure that people are supported to live as independently as possible at home.
• The development of ways to ensure the role of housing and housing support as part of the wider prevention agenda is better understood within the National Care Service.
• Greater clarity on ethical commissioning, procurement and fair work. The term ethical commissioning appears to have been removed.
• A reciprocal the commitment set out in Housing to 2040 to establish mechanisms for shared resources across housing, health and social care.
Why is this important?
A safe, secure, affordable home is essential for meeting any care and support needs. We are concerned that proposals have so far failed to recognise the unique contribution of housing in delivering preventative services and supporting independence at home through a range of services including innovative technology solutions, support and care, aids and adaptations as well as providing accessible homes. Despite efforts to improve integration, good joint working with housing, health, and social care (IJBS) across Scotland is not consistent and represents missed opportunities to improve housing, health, and care outcomes for people.
Services provided by housing associations prevent people entering more formal care or hospital services, which have a much greater cost to the public purse. Housing has demonstrated that it offers valuable solutions to national health and wellbeing outcomes. This was recognised in the Scottish Government’s advice note Housing services and integrated health and social care (2015) which required Integrated Joint Boards (IJBs) to
include Housing Contribution Statements as an integral part of the Strategic Commissioning Plan and a statement of how the Integration Authority “intends to work with housing services.”
Collaborative planning will recognise the importance of support for people at home, alongside technology and adaptations together with new housing models such as extra care. We need to recognise that as society ages people’s housing needs will change and new options will need to be developed in partnership to provide choice so that older people can live independently and safely in places that meet their needs.
Extra Care Housing Models
Extra care housing offers an integrated service model with onsite tenancy and housing support and personal care with a local flexible staff team, safety and security and personalised telecare. Eildon’s Wilkie Gardens is one example. Evaluations demonstrate its benefits in terms of cost-effectiveness and quality of life.
People with Learning Disabilities
The Coming Home report (2019) and subsequent SG plans identified the need for new specialist housing with care provision closer to home for people with complex needs currently in unsuitable out of area residential placements, far from their families and support networks. The recommendations in this report can only be achieved when housing, health, and social care plan effectively to deliver good outcomes for this very vulnerable group of people. The slow progress in achieving the recommendations is in part created by challenges in funding and barriers in collaborative joint planning between health, housing, and social care.
Homelessness
The solutions to homelessness for significant numbers of homeless households sit across the housing, health, and care sectors. The introduction of duties for public bodies to “ask and act” in the Housing Bill currently going through parliament make it more important that planning and service delivery in this area is joint. Homelessness, housing support and Housing First services are complementary to social care and need to work together with health and social care for maximum impact.
Housing associations, along with homelessness services, are a key route to services for many people and are well placed to identify early intervention when things go wrong. The National Care Service should be developed with the social housing sector as an equal partner at a strategic and operational level, including community health and social care boards – all aligned with the ambitions of Housing to 2040.
Health, Social Care and Housing
We welcome the opportunity to offer further comments on the proposals for the NCS but remain concerned that the opportunity for improved collaboration with housing has not been addressed through any of the proposed amendments. We and other partners repeatedly called for a clear and explicit relationship between the proposed National Care Service and Housing and Homelessness services throughout stage 1 of the National Care Service bill scrutiny. And yet the amended version of the bill continues to ignore this crucial relationship.
Whilst the overarching aims of the NCS are wide ranging, there remains a gap in how the Scottish government sees housing and housing support aligning with the National Care service at strategic planning and delivery levels. The right to adequate housing is a basic human right and a reorganisation of social care services must consider the role of housing in planning and delivery to improve the wellbeing outcomes of those who require care and support. The proposed changes at stage 2 have again failed to recognise the unique contribution of housing in improving health and wellbeing and supporting independence at home through a range of services including innovative technology solutions, support and care, aids and adaptations as well as providing accessible homes.
The current draft legislation does not make it clear that the National Care Service should collaborate closely with other services such as strategic housing authorities to plan and deliver services. Given the clear interdependence of a range of housing and support services we believe this is a serious omission and was a missed opportunity when Health and Social Care Integration was introduced through the Public Bodies Joint Working (Scotland) Act 2014.
National Outcomes Framework
Scottish Government has also recently presented its revised National Outcomes Framework to parliament for consultation. The revised framework, as part of the objective to “improve the wellbeing of people living in Scotland now and in the future,” includes a new outcome on care and on having a “home that meets our needs.” Given the new focus on this in the proposed National Outcomes Framework, it would seem appropriate to ensure this is built into a new system for the National Care Service.
National Care Service Strategy
We remain concerned, as set out in our response to stage 1 of the Bill, that it is unclear how the cost of the development of the National Care Service will directly impact on frontline service delivery or how addition of a new structure will achieve the sort of improvements envisaged as it is not clear where the responsibility for resourcing NCS services lies. We recognise the need for leadership to drive the focus on prevention, human rights and equality, fairness, and accountability, but in line with the IRASC recommendations believe this should be planned and delivered at a locally accountable level. It is not clear that the current proposals will achieve this, nor do they set out the importance of partnership and collaboration required to plan deliver social care and related services.
While it is positive to see linkages with housing and homelessness services mentioned in the policy memorandum, it is not clear how this will be achieved. References to prevention through early intervention are welcome but evidence highlights the need to align with housing and housing support. Research commissioned by the Housing Support Enabling Unit (HSEU), SFHA and others, Economic-benefits-of-housing-v6.pdf (housingevidence.ac.uk), highlighted that housing support is often the ‘glue that helps make a wider model of care and support work.
A clear duty to collaborate with housing may improve the current position and help build on some of the good practice that does exist.
Housing to 2040
The Scottish government in proposals for the National Care Service and in Housing to 2040 have stated their policy intention to support people to live as independently at home for as long as they can. Housing to 2040 set out clear links with proposals for a shared agenda between housing, health and social car and we would like to see that commitment mirrored in the National Care Service. For example, Housing to 2040 commitments include:
• Ensure that strategic planning is joined up locally across housing and health and social care services.
• Develop and implement a joint accountability and outcomes framework to design and deliver person-centred and integrated services, planning to meet people's future needs.
• Establish mechanisms for shared resources across health and social care in a phased way to ensure best use of health, social care and housing funding and deliver integrated services on the ground.
• Ensure greater connectivity between mental health and addictions service design and local housing support, by continuing to scale up Housing First,
• Act jointly to transform the way health and housing services are delivered to those experiencing addiction and homelessness and to those with severe and multiple disadvantage.
A summary of key points:
SFHA would welcome a clear message on how housing aligns with the National Care Service through amendments to the Bill including:
• An additional principle added to the National Care Service Bill, that services should be designed collaboratively across the system, with all relevant stakeholders, including housing to ensure cross cutting rights like good quality housing and appropriate care and support are upheld. Current principles refer only to people who use services and family carers.
• Proposed membership of the National Care Services Board and the reformed Integrated Joint boards, (NCS Local Boards) to be set out more clearly, recognising the importance of co-design and the strategic importance of the housing sector in achieving the aims of the NCS.
• Representatives from Housing to have a seat on the proposed NCS Local Boards.
• Collaboration with the housing sector to plan and deliver joint responsibilities for homeless people that will be included in the Housing Bill. Proposals from Housing Directorate for the Housing Bill will place duties on Public Bodies to Ask and Act to Prevent Homelessness making it even more important to have an integrated system that includes housing.
• Recognition of the strategic importance of accessible housing, housing support and housing adaptations to ensure that people are supported to live as independently as possible at home.
• The development of ways to ensure the role of housing and housing support as part of the wider prevention agenda is better understood within the National Care Service.
• Greater clarity on ethical commissioning, procurement and fair work. The term ethical commissioning appears to have been removed.
• A reciprocal the commitment set out in Housing to 2040 to establish mechanisms for shared resources across housing, health and social care.
Why is this important?
A safe, secure, affordable home is essential for meeting any care and support needs. We are concerned that proposals have so far failed to recognise the unique contribution of housing in delivering preventative services and supporting independence at home through a range of services including innovative technology solutions, support and care, aids and adaptations as well as providing accessible homes. Despite efforts to improve integration, good joint working with housing, health, and social care (IJBS) across Scotland is not consistent and represents missed opportunities to improve housing, health, and care outcomes for people.
Services provided by housing associations prevent people entering more formal care or hospital services, which have a much greater cost to the public purse. Housing has demonstrated that it offers valuable solutions to national health and wellbeing outcomes. This was recognised in the Scottish Government’s advice note Housing services and integrated health and social care (2015) which required Integrated Joint Boards (IJBs) to
include Housing Contribution Statements as an integral part of the Strategic Commissioning Plan and a statement of how the Integration Authority “intends to work with housing services.”
Collaborative planning will recognise the importance of support for people at home, alongside technology and adaptations together with new housing models such as extra care. We need to recognise that as society ages people’s housing needs will change and new options will need to be developed in partnership to provide choice so that older people can live independently and safely in places that meet their needs.
Extra Care Housing Models
Extra care housing offers an integrated service model with onsite tenancy and housing support and personal care with a local flexible staff team, safety and security and personalised telecare. Eildon’s Wilkie Gardens is one example. Evaluations demonstrate its benefits in terms of cost-effectiveness and quality of life.
People with Learning Disabilities
The Coming Home report (2019) and subsequent SG plans identified the need for new specialist housing with care provision closer to home for people with complex needs currently in unsuitable out of area residential placements, far from their families and support networks. The recommendations in this report can only be achieved when housing, health, and social care plan effectively to deliver good outcomes for this very vulnerable group of people. The slow progress in achieving the recommendations is in part created by challenges in funding and barriers in collaborative joint planning between health, housing, and social care.
Homelessness
The solutions to homelessness for significant numbers of homeless households sit across the housing, health, and care sectors. The introduction of duties for public bodies to “ask and act” in the Housing Bill currently going through parliament make it more important that planning and service delivery in this area is joint. Homelessness, housing support and Housing First services are complementary to social care and need to work together with health and social care for maximum impact.
Housing associations, along with homelessness services, are a key route to services for many people and are well placed to identify early intervention when things go wrong. The National Care Service should be developed with the social housing sector as an equal partner at a strategic and operational level, including community health and social care boards – all aligned with the ambitions of Housing to 2040.