Y Pwyllgor Cyfrifon Cyhoeddus / Public Accounts Committee

Response to the Report of the National Assembly for Wales Public Accounts Committee Report on: Housing Adaptations

Provided by: Rebecca Evans, Minister for Housing and Regeneration.

Date: 12 September 2018

The Welsh Government welcomes the findings of the report and offer the following response to the six recommendations contained within it.

Recommendation 1. We recommend that the Welsh Government publishes the performance data it has collated under the ENABLE review by November 2018. In publishing this information the Welsh Government should clearly set out any deficiencies in the first round of performance information it collected – for example, organisations not providing returns – and how it intends to address these gaps.

Accept – The Welsh Government is committed to improving the provision of aids and adaptations and recognises the role of good quality data in helping to drive improvement. Data collected under the ENABLE review is currently being analysed by researchers and will be published in November 2018. Alongside the published data, we will identify shortfalls in the data in terms of quality and coverage. We will work directly with those organisations that have not provided data returns to ensure they have systems in place to meet our expectations. We have also amended terms and conditions of grant where applicable to make clear the requirements for data to be captured and submitted to Welsh Government.

A task and finish group has been established under the Aids and Adaptations steering Group. The group is tasked with identifying how we can ensure our data collection is robust and consistent across organisations. The group has already met once and made a number of recommendations which are reflected in our response to recommendation 6 below.

Recommendation 2. We recommend that the Welsh Government prioritise the establishment of national minimum standards for all adaptations to ensure disabled and older people receive the same standard of service irrespective of where they live, who their landlord is and whether they own their own home. In particular, they should ensure that the data underpinning this exercise is robust and comprehensive. In their response to the Auditor General’s Report, Welsh Government stated a completion date of December 2019. Given slow progress in the past, the Committee believes this needs greater urgency from Welsh Government and should be completed by July 2019. The Committee will monitor delivery to ensure the minimum standards have been established and disseminated by July 2019.

Accept – We accept the need to work with pace in this area and we have revisited our timeline for action. Work has already commenced to develop initial draft service standards, with the assistance of members of the Aids and Adaptations Steering Group. The draft service standards will be published for consultation in October 2018 and the consultation will run for a 12 week period.

The Service Standards will set the expected levels of service for the installation of a Housing Adaptation and will help to ensure adaptations are delivered in a consistent manner, regardless of a Service Users location and tenure.

The consultation will be an important opportunity to engage with a wide range of organisations whose support will be essential to drive service improvement. Subject to the outcome of the consultation, our intention is to publish a set of standards for use in the sector from April 2019.

Monitoring of delivery against the service standards will be achieved via the revised ENABLE data monitoring arrangements. Any changes to data requirements necessitated by the standards will be considered as part of the consultation process. We will review the standards periodically and strengthen the standards if necessary to ensure further improvement in service quality and consistency.

Recommendation 3. We recommend that the Welsh Government sets clear standards for means testing DFGs. Welsh Government accepted that it is possible to undertake small and medium scale adaptations without creating complex and overly bureaucratic approval processes, but the variation in local authority approaches had resulted in a post-code lottery for applicants. We therefore recommend that Welsh Government reviews current approaches and produces guidance that clearly set out the minimum value and type of adaptations works where the means test should be applied and minimum approval standards required. The Committee will monitor progress that this work has been done, no later than July 2019.

Accept – The 1996 Housing Grants, Construction and Regeneration Act set the legislative basis for the provision of DFGs. The Housing Renewal Grants Regulations 1996 sets out the criteria used to test financial resources and the maximum level of grant that local authorities can pay for an adaptation, which is currently £36,000 in Wales. The Housing Renewal Grants (Amendment) (Wales) Regulations 2005 amended the definition of a ‘relevant person’ to remove the means testing of those responsible for a disabled child or young person.

In addition, local authorities have discretionary powers to provide funding for adaptations, repairs and improvements under the Regulatory Reform (Housing Assistance) (England and Wales) Order 2002. Local authorities can provide assistance under the Order in the form of a grant, but it is often a loan. Local authorities have their own policies on the level of and form of the discretionary assistance they offer and the conditions a person must meet to qualify.

We have begun the work of reviewing the means test for DFGs and officials are working with local authorities to establish what additional funding they provide for smaller adaptations outside the DFG process. This work will serve to clarify which local authorities have adopted changes under the discretion afforded them under the Regulatory Reform Order 2002 to allow smaller and/or medium adaptations to be undertaken without the need for a means test. We will publish the outcome of this work by December 2018, followed by guidance on DFGs and the use of means tests aimed at improving consistency and streamlining processes within the allowable scope of the current legislative framework.

We are building a more fundamental review of means testing into the wider Systems Review of the adaptations process. The review will explore a wide range of complex issues and as such will not report in full until December 2019.

Recommendation 4. We recommend that the Welsh Government provide support and guidance for delivery organisations to improve integration of services, for example through integrated delivery teams. We note that there appears to be a strong relationship between the presence of integrated delivery teams, and good practice in delivering adaptations. We therefore recommend that, as part of its ENABLE work, the Welsh Government identifies the nature of this relationship and how this has supported better outcomes. We will require the Welsh Government to demonstrate to the Committee that this work has been done, no later than July 2019.

Accept – To support and promote greater integrated working, we have already amended grant terms and conditions (details can be seen under recommendation 6) to promote greater join up between Care and Repair agencies and Regional Partnership Boards.  We will support Care and Repair Cymru and work with the sector more widely to raise awareness of the contribution of Aids and Adaptations to supporting independence and keeping people out of hospital. Improved guidance for the ENABLE programme officials will be published by April 2019. It will promote and support integration of services, including integrated delivery teams. We will aim to provide this guidance by April 2019.

As part of the Systems Review of the adaptations process we will specifically examine the benefits of integrated service delivery, this work is due to report in December 2019. In considering the findings of the review and any more substantive changes to the aids and adaptations system that follow from it the Welsh Government will seek to develop a single, overarching suite of guidance covering all aids and adaptations.                                                                                               

Recommendation 5. We recommend that the Welsh Government, through the new “Enhanced Adaptations Development Group” seeks assurance that delivery organisations are taking the necessary steps to discharge the Auditor General’s recommendations. Given witnesses, including Welsh Government, accepted the findings of the Auditor General and the need for change, the Committee believe it is appropriate for the Welsh Government to take a lead in ensuring these long-standing weakness are addressed. We will require the Welsh Government to demonstrate to the Committee that this work is progressing, no later than December 2019.

Accept – We will work with the Aids and Adaptations Steering Group to build monitoring of the Auditor General’s recommendations in to their work plan, which can be monitored and updated at future meetings. We will report back to the Committee no later than December 2019, and sooner if appropriate.

Recommendation 6. We recommend that the Welsh Government revises its national performance indicators for data collection in 2019-20. The indicators should be designed to allow delivery organisations to evaluate their performance, inform their strategy and improve service delivery. The Welsh Government should ensure the revised measures:

·         Reflect the minimum standards developed for adaptations to allow an evaluation of the impact, wellbeing, and wider benefits of investment in adaptations;

·         Address the deficiencies identified in the Auditor General’s report (paragraph 4.13); and

·         Address any gaps identified from the first year monitoring and evaluation of ENABLE.

The Committee will monitor progress that this recommendation has been completed, no later than December 2019.

Accept – We agree the sector would benefit from being able to better evaluate their performance and identify best practice to inform their strategy and service delivery.  To clarify, the ENABLE data monitoring includes all provider organisations including Large Scale Voluntary Transfer (LSVT) organisations and local authority housing and has done from the outset.

As set out above, we are working with the Aids and Adaptations Steering Group to improve the quality, consistency and coverage of future data collected under the ENABLE data monitoring programme. This will include considering any changes required to ensure it reflects the new service standards on which we will shortly consult. The task and finish group meeting on 16 August 2018 looked at the ENABLE monitoring requirements and guidance. The group has proposed a number of changes to ensure data is collected in a more robust and consistent manner and captures data on service delivery. The revised ENABLE monitoring requirements will record the time involved in processing adaptation requests, allowing us to evidence and identify key pinch points and support action to tackle any delays. The revised monitoring guidance will be presented to the next Aids and Adaptations Steering Group Meeting in September for comment. Subject to the group’s agreement the monitoring guidance will be published shortly afterwards for immediate application.

We have made explicit in terms and conditions relating to Care and Repair, Rapid Response Adaptations Programme and Enable funding that all organisations are required to provide ENABLE data and to collect relevant equalities monitoring data.  We will seek out opportunities to make these requirements explicit for all other grants and programmes as we work to improve data quality and consistency. We have also already addressed the issue of incomplete equalities data by amending terms and conditions to make explicit the requirements for individual organisations to meet their statutory duties in this regard.

We recognise consistent monitoring of all adaptations is needed as it will provide everyone with greater insight into the services. It will provide opportunities to investigate and make improvements where there are discrepancies from the service standards, for example, around delivery times as a result of delays by planning or utility companies.

The deadline set by the Committee is noted and agreed.