Written Statement in response to the Social Justice and Regeneration Committee Policy Review Report’s Recommendations on Housing and Older People

PURPOSE: To present the Welsh Assembly Government’s response to the Social Justice and Regeneration Committee’s Report on housing and older people.

Responses to the Report’s recommendations are set out below.  The recommendations follow the numbering in the report.


Recommendation 1

The Welsh Assembly Government should consider whether, at both local and national levels, the older people’s forums established within the framework of the Strategy for Older People in Wales could also engage in the issue of housing and related services for older people. The Welsh Assembly Government should encourage forums to give priority to enabling older people to engage in and influence the development and subsequent evaluation of housing strategies, structures and services that are intended for their benefits. In particular, the forums should expect to provide a focal point for the development and dissemination of advice, advocacy and information on support services to ensure older people are aware of their rights and options.

Accept. Whilst it is for each local Older Peoples Forum to determine it own agenda, we would certainly encourage active debate about housing issues in the way that is recommended by the Committee. It will also be important for each Forum to re-visit these issues at a later stage to evaluate the local action that has taken place and the change that has been achieved. Advocacy requires specialist support to be effective and this is being considered in the context of the National Service Framework for older people.


Financial Implications
None arising directly from the recommendation though clearly there could be as yet unquantifiable costs where the Forums’ advice is taken up.


Recommendation 2

The Welsh Assembly Government should encourage better joint working between housing, health and social care agencies, building on the new joint planning and funding mechanisms in place at the local level. In particular, by 31 March 2006 each Local Housing Strategy, drawing on the support and guidance suggested in recommendations 3 and 19 should reflect work completed on the following:

 the role to be taken by sheltered housing, including the development of leasehold, commonhold and shared ownership opportunities to older home owners seeking sheltered accommodation, and the level of provision that may be appropriate;
 the local role and provision of enhanced sheltered housing;
 the local role and provision of ”Extracare” housing;
 the local role and provision of residential and nursing care;
 proposals to meet the accommodation needs of people with dementia;
 proposals to meet the accommodation needs of disabled people;
 proposals to meet accommodation needs of disabled people;
 proposals to meet the needs of older people living in general housing.

Accept. The proposed new housing/health/social care officials group will have as its prime remit better joint working at the interface of these sectors. “Preparing Local Housing Strategies”, the guidance issued to local authorities by the Welsh Assembly Government, will need to be revised to take account of the policy areas identified.

Financial Implications
No direct financial implications for the Assembly.

Recommendation 3

The Welsh Assembly Government should establish a task and finish working group to support local authorities in meeting the requirements included in recommendation 2. The group should bring together officials and external experts, and to include representatives of older people The Committee asks that the Minister report on the work of the group and the completion of the tasks by summer 2006.

Accept: This should be considered further by the proposed new housing/health/social care officials group specified under recommendation 2.  The remit and composition of the task and finish group should be clarified and the views of the WLGA and other representative bodies sought.



Financial Implications
As for Recommendation  2.

Recommendation 4

The Welsh Assembly Government should discuss with Care and Repair Cymru how that organisation, in collaboration with partners from statutory, voluntary and commercial sectors and linking with older people’s forums, might lead an initiative to promote the development of an integrated community based support service for older people.

Accept.  This reflects on-going discussions with Care and Repair Cymru. Building on the foundations that already exist with agencies Care & Repair Cymru is holding discussions with health, social care, housing and other key partners to consider how Care & Repair services can be enhanced.  Issues being discussed include: cross tenure options; assisted technology; health and wellbeing initiatives; imaginative use of funding sources; partnership that provide training and workforce development in the building industry; BME and rural focus; maintenance and health promotion; staying put and moving on discussion and pre retirement support.  Underpinning many of these discussion will be the unified assessment approach.

Financial Implications
Yes but these are not quantifiable at this stage and are not envisaged to be substantial.


Recommendation 5

The Welsh Assembly Government should promote a standing review, drawing together representatives of health housing and social care in statutory, commercial and voluntary sectors to keep under review the development of practical applications of new technology and to disseminate information, support implementation and evaluation.

Accept.  The Welsh Assembly Government will draw together appropriate implementation and evaluation interests for the purposes of sharing knowledge and good practice in the application of care technology, linking to as appropriate developments in the health field.

Financial Implications
None arising directly from this recommendation, but there may be initial downstream costs for research and piloting as this strand of work develops.  There are also potential savings from the application of appropriate care technology.

Recommendation 6

The Welsh Assembly Government should continue to support and promote the work of Care and Repair in Wales, particularly in strengthening their links with health and social care agencies in enabling older people to remain in their own homes. In further developing the range of the service it should engage with Care and Repair Cymru in developing initiatives to encourage home maintenance in property occupied by older people.

Accept.  Care & Repair Cymru has recognised that there is an increasing interest and need to develop housing solutions based on the principles of health promotion and prevention rather than crisis intervention.  Experience has demonstrated that for many older people the key to securing a healthy and sustainable future is home maintenance.  This is a particularly difficult area for impoverished pensioners, who may have multiple health needs.  A healthy home programme that focuses on housing solutions that prevent deterioration of health and promotes wellbeing is being developed.  This would include an annual healthy home check and a maintenance service.  Care & Repair Cymru are in the process of developing a pilot model for consideration.

Financial Implications
None over and above current levels of support for Care & Repair.



Recommendation 7

The Welsh Assembly Government should seek solutions to the continuing shortage of occupational therapists. It should seek to establish best practice and provide guidance on ways in which flexible patterns of work that make best use of all available professionals can be implemented; matching skills and experience to the complexity of the case in line with effective good practice.

Accept.  The Welsh Assembly Government will explore with local authorities, the voluntary sector and others the way in which the expertise of existing OTs can be better used and more flexible practices can be adopted.

The current review of disabled facilities grants and adaptations will also be considering this issue and examining ways of overcoming current problems of assessment due to the shortage of occupational therapists. The Regulatory Reform (Housing Assistance) (England and Wales) Order 2002 also allows local authorities to operate more flexibly in this area.  The proposed new housing/health/social care officials group will also consider this issue.

Financial Implications
None envisaged at this stage.


Recommendation 8

The Welsh Assembly Government should extend its current review of Disability Facilities Grants to include the wider process for responding to the needs of disabled people and related services. The extended review should include the adequacy of resource provision;

 making representations to the UK Government on the eradication of means testing and setting  the VAT rate for all works to meet the needs of disabled people, at the lowest possible level;
 support from public funds for adaptations to be made available across all tenures and accommodation types and to ensure equality of outcome regardless of tenure;
 the effectiveness of the grant in promoting independence as opposed to emphasising functional deficit;
 involving recipients and their carers in the design and evaluation of services and
 the protection of house holders against unsuitable or poor quality adaptations by reinforcing the rights of the applicant in ensuring grant claims are validated.

Accept. Several of these issues already fall within the ambit of the review and will be considered in the light of the review’s recommendations.

Financial Implications
None in terms of considering within the context of the adaptations review.  However, there will be resource implications contingent on recommendations arising from the review.




Recommendation 9

The Welsh Assembly Government should review and, if necessary, renew guidance on the Regulatory Reform (Housing Assistance) (England and Wales) Order 2002. The guidance should encourage authorities to take advantage of the opportunities to provide more flexible funding for home improvements, including loans, taking into account sensitivity to local circumstances.

Accept. The Regulatory Reform (Housing Assistance)(England and Wales) Order 2002 came into effect in July 2003. The current extensive guidance already encourages local authorities to take advantage of the resultant new flexibilities and advantages. Seminars will be held with local authorities later this year to explore the effect the RRO has had and consider improvements.

Financial Implications
None.


Recommendation 10

The Welsh Assembly Government should explore the introduction of a funding stream to support innovative projects at the intersection of health and housing concerns.

Accept.  The Welsh Assembly Government already has in place a funding stream - the Flexibilities and Joint Working Grant scheme – that would fulfil this role.  The scheme can be applied to virtually all of the functions of local authorities including not only health and social care but also housing.  The Welsh Assembly Government will however explore as necessary ways of ensuring that the possibilities for the use of the grant are better understood.

The Rapid Response Adaptations Programme introduced in July 2002 is also relevant. One of the proposed themes for funding innovative projects through the Housing Directorate’s 2005-2006 Social Housing Management Grant Programme is helping older people live independently in their own homes through the use of assistive technology.  The proposed new housing/health/social care officials group will also consider this matter.


Financial Implications
Funding already in place.  Additional funding may be required for assistive technology.

Recommendation 11

The Welsh Assembly Government should co-ordinate the provision of schemes that offer advice and practical assistance on security and safety in the home, for instance through an expanded Home Energy Efficiency scheme. It should consider whether, in collaboration with the Home Office and Police Authorities, Crime Reduction partnerships and voluntary sector organisations such as Victim Support, guidance should be given on the arrangements for such schemes.

Accept. The Home Energy Efficiency Scheme offers energy efficiency and heating as main measures to eligible households. The scheme also offers security and safety measures such as smoke alarms, door and window locks and peepholes. Through HEES the Assembly works actively with voluntary sector organisations to offer practical advice and assistance on using energy efficiency, security and safety in the home. Officials will continue to look for further opportunities to work in partnership to provide these services under HEES.

In addition, the Assembly’s community fire safety initiatives provide a range of assistance, from the provision of hard-wired smoke detectors, to the provision of other fire safe equipment (such as electric blankets) and fire safety advice, in the homes of vulnerable people, including older people, to increase their domestic safety.

Financial Implications
Yes but difficult to quantify at present.  Increased co-ordination could inevitably lead to demands for greater financial support.

Recommendation 12

The Welsh Assembly Government should encourage the UK Government to support the proposals made by the Financial Service Agency that equity release loans for home improvement purposes should be removed from the constraints of the Consumer Credit Act 1974 Regulations.

Agree with this in principle if there is a problem in this area but it will require further consideration with the UK Government and other parties to ascertain the degree of difficulty the CCA presents.  We are considering this recommendation further with the UK Government.


Recommendation 13

The Welsh Assembly Government should establish and fund a ‘not for profit’ “Welsh Home Improvement Lending Agency” to address the problems associated with equity release. The purpose of the body will be to draw tranches of money from commercial lenders and make them available to older people in more flexible and appropriate ways, working through local delivery agents. The organisation should be granted charitable status, have its financial activities guaranteed and be supervised by a Board representing a wide range of stakeholders.

Accept that there is a need to look at the issue of loans.  However, investigations have indicated that this would not be feasible on a national organisation basis. The Welsh Assembly Government is already investigating with well-established organisations how loans are being developed in other areas of the UK, which could facilitate equity release. There are several players in the field with which we are in active discussion and we will be working with Welsh local authorities to consider the scope for a pilot or pilots in Wales.

Financial Implications
Yes but not yet quantifiable and unlikely to be substantial.





Recommendation 14

The Welsh Assembly Government should encourage local authorities to estimate levels of equity in properties to assess the feasibility of equity release schemes, as part of Local Housing Strategies. They should evaluate the potential of shared equity schemes that could be offered to older people by Registered Social Landlords. They should identify ways of promoting equity release possibly by encouraging Care and Repair agencies to provide information to home-owners using their established outreach services to build trust and confidence.

Accept.  Consideration will be given as to whether, and how, this could be incorporated into revised guidance on preparing local housing strategies.  Discussions with Registered Social Landlords will ensue.  Care & Repair Cymru is supporting the national discussion around the development of equity release packages and is keeping a watching brief on developments.  Care & Repair agencies are carrying out a limited amount of work with interest only mortgages, as well as some charitable packages.


Financial Implications
None.


Recommendation 15

The Welsh Assembly Government should:

 work with local authorities and local; health boards, using existing mechanisms such as Policy Agreements, to encourage an increase in the level of resources available to fund domiciliary care services to allow more people to remain independently at home and reduce demand for residential care and acute medical care;
 support the expansion of support services for older people with lower levels of need through partnerships between local authorities and the independent sector using the model outlined in recommendation 4;
 encourage, through the Supporting People programme, the development of floating support schemes for older people where they are shown to be relevant and cost effective;
 review the issues surrounding recruitment and retention in providing domiciliary care, the provision of non-nursing care in residential care homes and the requirements of flexible, multi-skilled working.

Accept points 1 and 2.  The thrust of the recommendation is already being addressed, through the Welsh Assembly Government’s response to the Wanless Review of Health & Social Care in Wales. This includes taking forward the recommendations in the Wales Care Strategy Group’s report, which makes similar comments about the value of low level interventions at an early stage.

Ultimately, it needs to be recognised that it is for the local authorities concerned to determine the balance between residential and domiciliary care and other forms of support that they purchase. However anecdotal evidence from work we have undertaken on the residential care sector suggests that significant supply side problems are emerging as a constraint.

Good commissioning practice demands the establishment of strong local partnerships. Only by local authorities and local health boards engaging with the independent sector at the planning stage in a meaningful way can we expect to see improvements in the way in which resources are utilised and services are delivered. The Welsh Assembly Government therefore supports the creation of Local Independent Sector Provider Forums, put forward by Care Forum Wales and would encourage local planners and commissioners to engage with them.

Accept point 3.  The launch of Supporting People in 2003 allowed the provision of accommodation related support in new areas such as the owner occupied sector.  Providers and their local authority strategic partners have already taken the opportunity to develop new forms of provision such as floating support for older people.  As the strategic information becomes more robust and the reviews of existing provision and their effectiveness we would expect more resources to be released for these kinds of developments.

Accept point 4.  The Assembly Government is also already taking account of recruitment and retention issues and workforce remodelling both through the work of the Care Council for Wales and through the requirement on local authorities to produce workforce plans to support service plans in their area.  It is also looking carefully at these issues as part of the Review of Health and Social Care in Wales (Wanless).

Financial Implications
Investment decisions including the balance of commissioning as between different types of care and different care settings and local arrangements to support good commissioning practice are primarily for local authorities and local health boards based on robust local assessments of need.  There are resource implications for Supporting People but they must follow local assessment of need and priority.



Recommendation 16

The Welsh Assembly Government should explore with private sector residential care home owners, the potential for providing domiciliary care to older people in line with local needs and how this may be funded.

Accept that this issue needs to be looked at.  However, a number of residential care providers are already providing domiciliary care services.  At the strategic level the Welsh Assembly Government will continue to hold discussions with care providers about how the market can respond to identified needs. However, at the local level it is for commissioning bodies to identify needs and seek to meet and fund them through their commissioning strategies and appropriate contracting arrangements.


Recommendation 17

The Welsh Assembly Government should lobby the UK Government to introduce building regulations requiring the adoption of Lifetime Homes standards to housing renovations and private sector new-build homes. This would help increase the stock of accessible housing and reduce the need for adaptations in the future.

Accept. The introduction of Lifetime Homes Standards for new general needs houses will make them more flexible. This will allow people to stay in their homes longer.

The introduction of all the standards for houses being renovated will not always be practically or economically possible so it will be difficult to incorporate into the building regulations.

Part M of the Building Regulations for housing is currently under review and the experiences gained in Wales in building social housing to Lifetime Homes Standards will be passed on to the review body.



Financial Implications
The cost of introducing the standard into private sector new build houses will vary but for a typical 3-bedroom house it would be in the region of £1,800.


Recommendation 18

The Welsh Assembly Government should urgently commission a baseline study to provide information on the current provision, category and distribution of sheltered housing and other specialised accommodation for older people in Wales. The study should also examine the capacity of the various categories of sheltered housing (and residential care) to provide support to older people with different levels of need so that a more precise view may be developed of the current and future purpose and role of each style of provision.

Accept.  A research project will be commissioned as part of the Housing Research Programme.


Financial Implications
The cost of a project will covering 18 and 19 will be in the region of £100,000 and will be funded from the Housing Directorate Budget.


Recommendation 19

The Welsh Assembly Government should initiate a strategic review of the provision of sheltered housing and its variants that will support local authorities in undertaking the work envisaged in recommendation 2. The issues to be addressed should include:

 the need to review the role of wardens to reflect the changing needs of tenants:
 the need to engage with Registered Social Landlords and with the private sector;
 the need for flexible and small scale provision, especially in rural areas;
 the need to determine the future role to be fulfilled by “conventional” sheltered housing;
 the need to identify the role and purpose of “enhanced” sheltered housing;
 the needs of Black Minority Ethnic elders;
 the need to develop allocation criteria and protocols that mesh with the unified health and social care assessment process;
 the need to identify  the minimum requirement for accommodation to be regarded as “Extracare”;
 the need to respond to the impact of rising levels of owner occupation on demand for rented sheltered housing accommodation and to consider the provision of leasehold, commonhold and shared ownership options.

Accept.  A research project will be commissioned as part of the Housing Research Programme.

Financial Implications
As for Recommendation 18.


Recommendation 20

The Welsh Assembly Government should issue guidance to local planning authorities on the need to consider the strategic planning implications of new or substantially remodelled sheltered and specialist housing and, in particular, the need to ensure that modernised sheltered and specialist housing meets high standards of accessibility for disabled tenants.

Agree the principle behind this but internal remodelling of sheltered housing does not fall within planning control; although any changes to access to housing which affect external appearance does constitute development, access standards are determined by Building Regulations, made under the Building Act 1984 which is not devolved. Provision for appropriate access standards for new sheltered housing is adequately covered by national planning policy, including Planning Policy Wales (PPW) 2002, and the Design Technical Advice Note (TAN) 12 (Design).  The former outlines the need for local authorities to take account of the needs of the whole community in designing polices and considering proposals.  In particular it states:

“Local planning authorities and developers should consider the issue of ‘accessibility for all’ including the needs of those with visual and hearing impairments and those with limited mobility such as . . .elderly people. . . at an early stage in the design process”. (para 2.9.5)

The Design TAN 12 contains a number of paragraphs on “Inclusive Design” and states that:

“The Assembly Government expects all those involved in the design process to foster a culture of inclusion. . . . Inclusive design is a specific approach to barrier free environments.  Implicit in this is a move away from ‘special needs’ approach to disability which relies on adaptations to buildings and individualised design.  In every area of development earlier and greater attention should be given to the needs of all sectors of society, including elderly people, children and people with disabilities”. (para 5.3 and 5.4)

Allocating land or identifying a general requirement for sheltered housing in UDPs is already feasible where it is based on Local Housing Strategies and housing needs assessment. The Assembly Government will be providing detailed guidance on the provision of extra-care housing and the introduction of variable tenure in the RSL sector later this year.


Recommendation 21

The Welsh Assembly Government should issue specific guidance on the provision of “Extracare” housing. The guidance should include its view of the potential role Housing with Care / “Extracare” housing could play within the overall range of housing and support provision for older people and provide examples of good practice in Wales and elsewhere as models for future development.

Accept. The Assembly is currently consulting on revised Design Quality Requirements which will set standards and provide good practice on the development of extra care schemes from Social Housing Grant (SHG).

The potential role of extra care housing will be informed by the research projects referred to in recommendations 18 and 19. Consideration will then be given to providing further guidance on the potential role of extra care housing.


Financial Implications
The Assembly already provides funding for Extracare  housing schemes which are put forward for inclusion in local authorities Social Housing Grant Programmes. The capital cost of these schemes will vary according to size and location  Average grant will be in the region of £2.5m to £3.5m.


Recommendation 22

The Welsh Assembly Government should undertake a study to document the potential benefits and financial viability together with the support needs of retirement villages developed by both the private and not for profit sectors. It should further look to provide leverage funding for a demonstration programme of perhaps two or three such villages of various sizes to suit various communities.

Accept that this needs further investigation.  The City and county of Swansea is already undertaking a 120 unit retirement village scheme which includes an element of extra care.  The scheme is funded via Social Housing Grant.

The scheme is the first in Wales and officials will carry out an appraisal of this scheme including the way in which support needs are met prior to considering the commission of additional schemes of this nature.  The estimated Social Housing Grant requirement for this scheme is over £8million.  Clearly there is limited scope for many schemes of this size within the current level of funding allocated to the Social Housing Grant Programme.


Recommendation 23

The Welsh Assembly Government should provide guidance on the development of protocols within each local authority concerning the potential closure of a care home. It should convene a working party, drawing upon existing work in other parts of the UK and elsewhere, to develop a voluntary charter of rights for those residents in care homes.

Accept in part. The Welsh Assembly Government’s guidance “Promoting Partnerships in Care” which covers best practice in commissioning, stresses that local authorities should work closely with providers to ensure that they take a medium to long-term view of care needs within their area and that changes are foreseen and managed effectively. Coupled with this is an expectation that where a service has to be withdrawn – for example if a home closes – then commissioners and providers achieve this in a planned way for example by appointing dedicated teams of managers and through close liaison with the Care Standards Inspectorate for Wales.

In terms of private sector homes it has to be recognised that ultimately it is a commercial decision for the homeowners as to whether or not they withdraw their service. In other circumstances it might be appropriate for a home to close, for example where the Care Standards Inspectorate have significant concerns about the safety of vulnerable adults.

Within the existing legal framework, it is difficult to see how a voluntary charter of rights could be any more than an aspiration and would not be enforceable. However the Welsh Assembly Government will give further thought as to what could be achieved through amending the existing commissioning guidance.

Financial Implications
None arising directly from this recommendation.




Recommendation 24

The Welsh Assembly Government should provide guidance to local planning authorities to encourage the development of leasehold, commonhold and shared ownership forms of accommodation designed for older people from conventional sheltered to “extracare2housing” by commercial developers and Registered Social Landlords. Such provision should be set within a strategic framework arising from Recommendation 19.

In planning the provision of new housing, PPW (2002) requires local planning authorities to take account of local housing strategies.  It is the strategies, informed by the housing needs of all sectors of society that could contain such detail as preferred types of tenure to meet differing needs.  However in the light of the Assembly Government’s response to recommendation 19, any suggested improvement in the role of the land use planning system arising from the proposed research would be considered.




Recommendation 25

The Welsh Assembly Government should work with local authorities, using assisting mechanisms such as Policy Agreements to identify the appropriate level of funding that will allow local authorities to commission beds from residential care homes at a level that will enable the sector to meet current and future demand, as established in each area and provide stable services for users.

Accept.  The thrust of this recommendation is already in train.  The Welsh Assembly Government’s statutory commissioning guidance requires local authorities and the NHS, in their commissioning practice, to act in ways which will help provide stability for the sector and allow new providers to enter the marketplace.  The Welsh Assembly Government encourages the active participation of providers in the process of planning for future care.

Financial Implications
Investment decisions are for commissioning bodies who bear the statutory responsibility for responding to individuals’ needs.


Recommendation 26

The Welsh Assembly Government should commission a plan for the delivery to people with dementia and their carers that draws together the local services of health, housing and social care providers in a coherent way. The plan should set out good practice in design and management of both housing and residential care based schemes and provide proposals and leverage funding that will allow two initial model dementia projects to be developed in Wales. This initiative should be supported by the Task and Finish group suggested in Recommendation 3.

Accept. The proposed new housing/health/social care officials group will be able to address this issue with advice from the Carers Panel. Additionally mental health is one of the key issues to address in the Wanless Implementation agenda.  An Age Concern/Mental Health Foundation Inquiry into Mental Health and Well-Being in later life in the UK has just commenced. The Inquiry will seek to extend beyond dementia/depression and to look holistically at Mental Health and Older People - issues which have traditionally been considered separately.  

The older persons National Service Framework which is currently under development will set standards for all elderly mental health services including dementia services. A mechanism already exists to ensure services are produced in a coherent way since each local authority is currently required to produce a Health, Social Care and Well Being Strategy which sets out an integrated approach for services for all its population across the whole range of local government, health, voluntary and business sectors.  Officials will also be considering the design and management aspects of this recommendation in the light of current projects in the field of dementia.

Financial Implications
There will be financial implications but these are difficult to quantify at present.