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Universal Credit Early learning from the North West Pathfinders

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Universal Credit

Early learning from the North West Pathfinders

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Contents

1 Introduction 3

2 Preparations by housing associations 9

3 Making the claim 11

4 Personal Budgeting Support and identifying vulnerability 14

5 The Local Services Support Framework 18

6 Universal Credit Advances 20

7 Alternative Payment Arrangements 23

8 Discretionary Housing Payments 27

9 Data sharing 28

10 Relationships 30

11 Landlords as partners of choice, and recommendations 35

Appendix A: Glossary 42

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1. Introduction1.1 The design of Universal Credit“For too long, we have discouraged people from taking up their responsibilities as the Welfare State has pushed in to fill the gap where family and society used to function far more effectively.1”

In 2010, Iain Duncan Smith launched a white paper, 21st Century Welfare2, which set out two main objectives – streamlining the benefit system, and making work pay.

It described how those reliant on benefits can find it very difficult to return to work. When returning to work, many have all or most of their earnings deducted from their benefits. There is no significant financial advantage from work, and this has been compounded by having separate systems for in work and out-of-work benefits, meaning the two systems have become disconnected, trapping people on benefits.

In a subsequent document from the same year, Universal Credit: welfare that works3, it was also noted that the current system has further consequences, in addition to poor work incentives. The complexity of the system also acts as a barrier to work and means that people do not know what benefits and Tax Credits they can get. This undermines trust in the system and stops people focusing on getting back to work.

There is also an administrative cost to having a complex system. The document reports the high numbers of incorrect contacts DWP had – either to the wrong agency or the wrong office. This means, again, that take-up of benefits is lower than entitlement suggests. Fraud and error may also result from this.

In addition, the cost of welfare dependency and poverty is rising. There are huge social and economic costs for individuals, families, households and society more widely. Consequently, spending on welfare must have a positive, rather than a negative, effect, in order to encourage people back into work.

Universal Credit is therefore designed to make work pay. It places no limit on the number of hours an individual can work in a week. The benefit is tapered, so it reduces the more an individual works, but ensures that a person on a low income is better off in work.

1.2 Composition and delivery of Universal CreditUniversal Credit (UC) is underpinned by a number of concepts:

• It is paid monthly, in arrears, to mimic a monthly wage.• It is “digital by design” – all claims (where possible) must be made online, getting claimants used to

undertaking jobsearches and applications online.• It places the onus on an individual to pay things such as their rent; there is no choice for the claimant of

payment direct to a landlord, for example.• It is responsive – as people on low incomes move in and out of work, UC will be adjusted but not

cancelled, giving people more incentive to work for any period of time that is available.• For most people, support with housing costs will go direct to the claimant as part of their monthly

payment.

1 Speech by Rt Hon Ian Duncan-Smith, 27 May 20102 http://www.official-documents.gov.uk/document/cm79/7913/7913.pdf3 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/48897/universal-credit-full-document.pdf

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UC is paid to people in work and out of work, monthly in arrears. It replaces a number of benefits:

• Working Tax Credit• Child Tax Credit• Housing Benefit• Income Support• Income-based Jobseeker’s Allowance• Income-related Employment and Support Allowance.

It does not include:

• Disability Living Allowance/Personal Independence Payments• Child Benefit• Carer’s Allowance• Help with Council Tax.

The Federation has a range of resources around Universal Credit, available from the welfare reform section of our website.

Different organisations have different roles in delivering Universal Credit. The following summarises how this is organised in the Pathfinder areas:

Online Most people will claim Universal Credit online. In limited circumstances. claims will can be made over the phone or face-to-face.• Universal Credit claim: www.gov.uk/apply-universal-credit

There are online resources and advice available to both claimants and partner organisations.

• Universal Credit Personal Planner: https://secureonline.dwp.gov.uk/universal-credit-preparation/

• Universal Credit toolkit for partner organisations: www.gov.uk/universal-credit-toolkit-for-partner-organisations

• Advice for claimants from the Money Advice Service: www.moneyadviceservice.org.uk/en/categories/universal-credit

Jobcentre Plus (JCP)

After submitting their online claim, claimants will be invited to an interview at their local jobcentre.

At this interview claimants will discuss and be asked to accept their claimant commitment. JCP advisers are ultimately responsible for creating, changing and enforcing the claimant commitment, as well as facilitating claimants’ ability to satisfy the conditions set out.

The claimant may be required to bring evidence to the interview to be verified for their claim, eg a rent statement.

They should also be asked questions about their ability to manage money and any support they may need. Any issues identified will trigger the UC helpline to phone the claimant to assess their needs in more detail.

If necessary, the claimant should also be offered an advance payment of UC.

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UC helpline There is one number to contact the UC helpline which should be used by both claimants and housing associations – 0845 600 0723

The UC helpline can support claimants when they are filling out their claim. It should also be the first point of call for any questions a claimant may have once their claim has been processed.

If a claimant experiences a change of circumstance, which will affect their claim, they should report it to the UC helpline.

The UC helpline will make outbound calls to claimants identified during their face-to-face interview at JCP as potentially needing personal budgeting support or an Alternative Payment Arrangement (APA). The helpline will further assess each individual claimant’s needs.

Housing associations can also contact the helpline to highlight any issues they think might affect an individual’s ability to manage their UC payment. The UC helpline cannot confirm whether or not an individual tenant is claiming Universal Credit.

Housing associations should contact the UC helpline to request an APA when the arrears trigger has been reached. The helpline provides details of the information the housing association needs to provide (by post) to process the APA request.

Local authority In the Pathfinder areas, local authorities have overseen the provision of support services, either providing services in-house or working with local partners such as the Citizen’s Advice Bureau.

Claimants can contact the local authority about accessing personal budgeting support. The local authority may also be able to assist with providing claimants with online access.

The local authority is not able to answer questions about individual UC claims. Questions should be directed to the UC helpline.

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1.3 Introduction of Universal Credit via the PathfindersThe introduction of UC commenced in April 2013. The Pathfinders began a staged roll-out in four areas of Greater Manchester and Cheshire from 29 April 2013. Initially confined to Tameside, it was gradually extended to certain areas of Warrington, Wigan and Oldham during the summer. By the end of July 2013, Universal Credit was operational in the following postcodes:

• Oldham postcodes – OL1, OL2, OL3, OL4, OL6, OL7, OL8, OL9 • Manchester postcodes – M35, M43 • Stockport postcodes – SK16 • Warrington postcodes – WA1, WA2, WA3, WA4, WA5, WA13 • Wigan postcodes – WN1, WN2, WN3, WN5, WN6 UC is currently limited to new claims made by newly unemployed people of working age who are single, without children and who are not home owners. Once on UC, a claimant will stay on it. This is the case even if he or she moves out of the Pathfinder areas or there is another change of circumstances.

The national rollout will commence from October 2013 and continue through to 2017. Between October 2013 and March 2014, the rollout will cover new, single claimants of working age who are not home owners in six areas:

• Bath• Hammersmith• Harrogate• Inverness• Rugby• Shotton.

The precise timetable beyond this is, as yet, unknown, except that the current aim is for the process to have been completed by the end of 2017. It is unlikely that any large scale rollout will commence before 2015. DWP expect that any additional groups will be added to the existing Pathfinders in a controlled and managed way.

1.4 Purpose of the reportThis report has been designed to share learning from the North West Pathfinders with the wider National Housing Federation membership. As UC is currently being tested in a small, controlled way, it is likely that when rolled out more widely some of the issues highlighted in this report will have been resolved. The Federation supports the DWP’s ambition to “prove before you move”, recognising that learning from the Pathfinder underpins this ambition.

The report therefore has a second ambition, and that is to provide learning to the DWP and other interested Government parties around how social housing landlords are finding the rollout of UC in the Pathfinder areas. While the Federation and its members are feeding into the DWP’s own evaluation, it is important to gather evidence from a different perspective, one which provides a more detailed view from the social housing sector.

The Federation therefore hopes that this report will be used to inform the rollout of UC to more complex groups within and outside the Pathfinder, and the wider rollout more generally. The feedback from housing associations is already having a major impact on the design of systems, and the Federation hopes this will continue over the coming months.

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1.5 Scope of this evaluationThe evaluation has been completed by the National Housing Federation. It looks solely at evidence from housing association landlords and the tenants they know are claiming UC. The learning and messaging in this document is drawn from a small subset of the larger UC claimant group. Anecdotally, it has been suggested that the majority of claimants are those young adults still living with their parents, rather than tenants of housing associations. Nonetheless, the overall UC claimant group is still small; the National Audit Commission4 reported that at the end of July there were around 1,000 claimants in the Pathfinder areas.

This evaluation is also necessarily anecdotal. The report relies on:

• Claimant information, as reported to the landlord – this may be different to the information the claimant gave to Jobcentre Plus, and indeed may be an interpretation of what the claimant was told by Jobcentre Plus.

• The experiences as reported by landlords – because they are unaware of who is claiming UC, it is possible they are only finding out about those cases where UC is not working optimally.

The learning in this report has been drawn from a number of sources. The main period of research was undertaken between July and October 2013. The Federation has been working closely with the housing associations operating in the Pathfinder areas. We have held monthly meetings with associations since March 2013 to allow them to meet and discuss their concerns with representatives of DWP and CLG. The meetings have also allowed associations to share the stories of their tenant claimants. We have been particularly pleased with the level and depth of engagement both the Federation and the associations have had with DWP staff. The DWP have been incredibly receptive to feedback as the Pathfinder has evolved, and this has been one of the great strengths of the process so far. We very much hope that the learning from these meetings, and this report, will be taken forward into the design of UC as it is rolled out more widely over the next four years. Learning from these meetings has been incorporated into this report.

In addition, we have also undertaken a number of structured interviews with housing association staff. These have allowed us to go into more depth about particular issues, allowing us to understand how solutions have emerged, or how the process could be better designed to incorporate those solutions or stop the issues emerging in the first place. Material from these interviews has been central to the writing of this report.

We also held a study day in Tameside with housing associations, and representatives of DWP and CLG, as well as tenants. This was a particularly fruitful exercise as it allowed DWP and CLG to hear first-hand from tenants about the issues they faced when accessing UC and operating their claims. Evidence presented at this study day has also been incorporated into this report.

We are therefore very grateful to a number of organisations and individuals for contributing to this report. We would like to thank them and encourage them to continue sharing learning with us, with the DWP and CLG, and among themselves as the rollout of UC continues. We would also encourage associations in other areas where the national rollout continues from October 2013 to consider establishing regular meetings amongst themselves and with local DWP staff, to enable experiences to be shared and problems to be solved. Similarly, as the wider rollout timetable becomes clear, we would urge the same arrangements to be developed in other local areas.

4 http://www.nao.org.uk/wp-content/uploads/2013/09/10132-001-Universal-credit.pdf

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1.6 Structure of the remainder of this reportThis document is concerned with the claimant journey, summarising evidence of how the journey of the claimant through UC is impacting on both tenants and their social housing landlords. Below is a diagram, adapted from the DWP document UC: your claimant journey5.

Figure 1: UC claimant journey

Using this claimant journey, the remainder of the document is structured as follows:

• Preparations by associations• Making the claim• Personal Budgeting Support and identifying vulnerability• The Local Services Support Framework• Short Term Benefit Advances• Alternative Payment Arrangements• Discretionary Housing Payments• Data sharing• Relationships• Where could landlords add value as a partner of choice?• Recommendations

Throughout this document there are a number of consistent elements. The blue boxes contain real-life claimant stories, taken at various points over the Pathfinder process between April and September. These are positioned at various points in the document to provide examples of how the system is operating. The burgundy boxes contain the housing association sector’s offer to DWP to ensure UC can run smoothly; these are at the end of each section. At the end of most sections we also present a number of recommendations around how UC could be improved to provide a better service to both tenants and their landlords.

5 https://www.gov.uk/government/publications/universal-credit-your-claim-journey

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2 Preparations by associations2.1 IntroductionHousing associations have responded to the challenges of welfare reform in the round, to mitigate against the impact of any combination of the following:

• Benefit cap• Size criteria or ‘bedroom tax’• Wider welfare reform

During the research we asked associations to describe what they had been doing to prepare for welfare reform,with this section highlighting some of the activities that associations have been undertaking. Often these preparations have been the result of senior management having the foresight to see what the impact of welfare reform might be on their organisation.

2.2 Working with staffMany associations have reassigned staff to work on welfare reform, or have created new posts. New Charter Housing Trust has, for example, created four new posts, and may well look at creating new posts to deliver more money advice services. Many housing associations, such as Ashton Pioneer Homes, have been looking at the skills of existing staff and providing training where available. This may include financial inclusion training or telephone skills. Wigan and Leigh Housing has taken on additional staff such as digital inclusion officers and rent officers, to deal with specific issues and also to provide more general operational support.

The introduction of UC in the four Pathfinder authorities has resulted in a great deal of additional work for associations. Many associations have dedicated specific resources to monitoring UC claims made by their tenants. This work is often resource-intensive, and is diverting staff from other activities. In some cases (eg Ashton Pioneer Homes) this is without additional resources.

Many associations have also spent a great deal of time communicating with their staff, and developing training programmes where appropriate. New Charter Housing Trust, for example, has created a project called “Thinking Big”, which is their staff-facing awareness project involving the whole company. This led to the development of SWAT (Specialist Welfare Reform Advice Team). Contour Homes has undertaken training sessions and awareness-raising drop-in sessions, in order to involve many departments. It has presented on welfare reform at its annual staff conference, and produces a Word on Welfare newsletter, as well as creating a welfare reform group which includes people from across the organisation. Golden Gates Housing has undertaken money advice sessions with staff, and also provided two-hour welfare reform overview sessions to relevant individuals as needed. Overall it has provided 416 hours of training to 400 staff, including board members and senior staff – using a mix of internal and external training. Further training is planned.

2.3 Working with tenantsHousing associations have also carried out a lot of work to understand their customers even better, in order to better support them. New Charter Housing Trust carried out a financial inclusion survey, the results of which are now being used for business planning. Contour Homes has undertaken an insight/profiling exercise to increase its knowledge of its customers.A tenant census was carried out to collect information on tenants, receiving a seventy percent response rate. This has allowed the organisation to target advice and support at those who need it – for example targeting visits to those affected by the size criteria reduction in housing benefit. Golden Gates Housing has also undertaken customer profiling. Ashton

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Pioneer Homes has also profiled 95% of its residents through surveys and door-to-door interviews. This has allowed them to understand their needs, aspirations and income.

One of the key elements of housing associations’ preparations has been communication with their tenants. New Charter Housing Trust has been travelling around its neighbourhoods with a welfare reform bus. Golden Gates Housing has had a presence in local shopping centres to provide advice to tenants. Ashton Pioneer Homes has visited each tenant that may be affected by welfare reforms, including UC. It has also held two large welfare reform events with various local partners, which were attended by a quarter of its tenants. It has also provided free internet access and computer access to all tenants via a computer hub it funds, which tenant volunteers support.

Some associations have provided training for residents. Wigan and Leigh Housing has offered digital inclusion training and provided “Made of Money” courses, aimed at raising awareness of debt and credit. This additional training and support has in some cases informed recruitment.

Because tenants claiming UC are now being paid once a month, housing associations are looking at ways to find out when they are being paid, and the way in which they want to pay their rent. Tenants are paying their rent over the phone, in offices in cash and via high street pay outlets. Housing associations want to maintain their rent collection levels and are looking at means to expedite this, to ensure they are “first in the queue” for payment when UC is paid to tenants. They are therefore developing new products for their tenants. Contour Homes is looking at a range of financial products including bank accounts. It is also looking at digital inclusion, trying to map provision, and is establishing a digital inclusion team. Golden Gates Housing has developed a digital inclusion pilot to assist 450 households to get online. New Charter Housing Trust is developing its digital inclusion strategy and is beginning to contact all potential UC claimants to assess their situation in readiness for the rollout.

2.4 Reviewing internal processesInternal processes are also being revised or reworked. Contour Homes is looking at its allocations process, as well as processes to deal with rent free weeks and the current 53 week financial year. Wigan and Leigh Housing is considering changing its policies around arrears. Previously, the association had automatically generated letters to tenants after arrears of two or three weeks, telling them they are in arrears and requesting rent payment. As UC is paid monthly, this means arrears letters may be unnecessarily generated. It has changed the level of arrears at which it serves a notice to seek possession (or serves it after a certain period of time, if the amount is greater). It does not issue a summons to the tenant until arrears are much higher. It is also looking at its allocations policy with regard to the under-occupation charges.

Wigan and Leigh Housing is also looking at modifying its Northgate system, the IT system this and other associations use for housing management, in response to UC. This allows the association to record information about their tenants’ claims (as supplied by the tenant), including when they are offered or access debt advice, budgeting support, the length of time it took to process a claim or whether they accessed advance payments. Similarly, New Charter Housing Trust has updated its Northgate system to include a notification of ‘expected payment’. This allows staff to monitor arrears for each case and provides a daily update.

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3 Making the claim3.1 IntroductionUC is a ‘digital by design’ service. It is expected that applications are made online in the majority of cases. This section looks at the experience of tenants, as reported to their landlords, when making the claim.

3.2 Making the claim onlineSome claimants have reported finding the online form difficult or time consuming to complete. Others have suggested it is relatively straightforward. This will probably be a function of an individual’s computer experience and ability. Housing associations have stated that claimants need more help to get online, and more access to IT kit. The time slots made available by libraries, for example, may not be enough to complete a UC application form. Time slots available in libraries may only be an hour, whilst some tenants have reported the form taking ninety minutes or more to complete. The assistance being offered by library staff may be over-estimated by Department for Work and Pensions (DWP) staff. Staff from libraries and other partners may themselves not be able to offer the support a claimant needs. In addition, the claim form needs to be completed in one sitting, which means claimants cannot save and return to their claim. However it is anticipated that in the wider rollout this will not be an issue as a “save” function will be built into the process.

Claimant journey – as reported to the housing associationBecause of fluctuating hours and earnings, this particular claimant applied for Universal Credit. The claim was made in early August. Personal Budgeting Support (PBS) and advance payments were not offered. The claimant made the application on their own with no assistance. The claimant has arrears but is making efforts to pay them off.

Claimant journey – as reported to the housing association• This claimant made a claim at their parents’ home, with no help, at the end of July. They found the claim moderately difficult. • The claimant was not offered PBS, nor was PBS requested. At the point of the claim the arrears stood at £300. By mid-September this had risen to £420. • The claimant has a bank account, and wants to set up a direct debit. The claimant is also interested in the credit union. • The claimant declined an advance payment at the start of the process, but is now in need of one. The claimant has been referred onwards to the local authority for employment support.• They reported finding the UC experience frustrating.

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There have been a number of cases where claimants have been incorrectly routed onto UC or Jobseekers’ Allowance, when their circumstances or eligibility would indicate they should be on the other benefit. As the system is new, this is perhaps to be expected. But it may also be symptomatic of a wider lack of understanding of the UC system itself amongst Jobcentre Plus staff. Similarly, it might be a failure on behalf of claimants to provide the information required of them at the time it is needed. Or it may also be due to the assumptions that Jobcentre Plus or DWP staff may have about the level of understanding amongst the claimant population about their entitlement to different benefits.

Whatever the cause, there is a need for streamlining the process to route claimants back onto the correct benefit. One claimant in Tameside remained on UC, even though they should have been on Housing Benefit. Routing them back to Housing Benefit proved difficult for DWP and Jobcentre Plus staff.

Having made a claim, we are aware that there is no confirmation sent regarding safe receipt of the claim. We would urge DWP to look at this in the future – for example, sending out an automated email confirming safe receipt, notifying of next steps and possibly including the indicative amount of the award. This confirmation could be required as proof of a benefit claim if claimants are trying to access a new tenancy. Some associations will not be able to confirm an offer of a tenancy until they have confirmation of the means by which the rent can be paid.

Claimant journey – as reported to the housing associationThis claimant thought they had made a claim at the start of July. Their first claim was not recognised by the system, so a second claim had to be raised in mid-July. The claimant had to ask for budgeting support as this was not offered. The claimant was not asked about existing debts (which stood at £1,000). The claimant asked for a direct payment to be made to the landlord, but this was refused, despite existing debt. The landlord served a notice to seek possession given the debt and arrears issues, and has attended court. The claimant also asked the judge for payment to be made direct to the landlord, but was told by the judge of the ‘eight week rule’, in that this would only be considered after two months. By the time the claimant’s first payment was due in early August, a total of £1,500 was owed to the landlord. The first payment was made a day late. The breakdown letter, detailing the elements of the claim, was received in mid-September.

The claimant has attempted to do two training courses:

• She wanted to do a four day a week air hostess course, but didn’t do it because she was told by advisors it would affect her Universal Credit claim

• She has begun a two-hour college course, which she does in the evening. However again she was given contradictory advice as to whether it would affect her claim. She asked four advisors, but was ultimately referred to telephone advice. She has started the course, but is still waiting for it to be formally signed off.

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3.3 Jobcentre interviewsFollowing the initial online application, the aim is for claimants to be interviewed in person at a Jobcentre. This includes the ‘triage’ process, whereby any issues of vulnerability may be uncovered. We will return to this in subsequent sections. However, it should be noted that face-to-face contact is reported by tenants as being more beneficial than telephone contact. The DWP expects that subsequent contact, aside from the regular meetings between the claimant and the Jobcentre, will be managed online or by telephone.

Housing associations report a mixed picture regarding the receipt of award letters. New Charter Housing Trust, for example, reported that of seven cases, only two claimants had received an award letter. Very few claimants have reported to their landlords that they subsequently received a breakdown letter detailing the different elements of the award.

3.4 Recommendations around making the claim• The claimant should receive an automatic confirmation that their claim has been submitted. This should

include the indicative award amount and could be sent by either email or text. This confirmation should be in addition to the information given on the final screen of the UC claim. This would mirror similar processes, eg for online purchases. It would mean the claimant could be certain that their claim had been submitted, and if needed for accessing a new tenancy, this could be used as proof of a benefit claim.

• A “save” function should be added to the online claim form as soon as possible. The inability to save information in a claim has caused problems, particularly where claimants are accessing the form on a public computer. Some access points, including libraries, have time limits for internet usage which may be less than the time taken to complete a claim.

• During the interview at JobCentre Plus, social housing tenants should be encouraged to talk to their landlord to let them know they are claiming UC.

• Greater clarity and consistency in the messages given to claimants is needed. Some claimants have reported confusion as to what counts as work search activity or what actions may lead to a benefit sanction. There has also been confusion over how activity on Universal Jobmatch relates to a UC claim.

What housing associations can offerHousing associations have a social ethos to support their tenants. Many associations in the Pathfinder area have already provided access and support to claimants in completing applications, and this support will undoubtedly continue as Universal Credit is rolled out. They are able to signpost claimants to services they provide, and services provided by local partners, to create a holistic “offer”. However, there remains a question about what level of support can be provided and on what scale as the UC programme is rolled out and millions of claims are transferred from the old system to UC.

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4 Personal Budgeting Support and identifying vulnerability 4.1 IntroductionDWP has recognised that some people will find the new payment arrangements for UC difficult and has set up a system to identify the need for and provide personal budgeting support. This support could range from signposting to information on the internet to a face-to-face interview with an advisor from an advice agency. The specific pathway for this more personal support will be determined locally.

This support should be offered during the initial face-to-face interview following the claim being raised online. The route map for Personal Budgeting Support (PBS) is as follows

Figure 2: The PBS High Level Design in the Pathfinder Areas

Within the Pathfinder, the process for identifying and providing support is as follows. Once an online claim has been raised, the claimant will then be invited to a ten to fifteen minute interview a few days later. During this high level “triage” interview, debt and arrears issues should be uncovered. A more in-depth interview is then carried out by a more senior member of Jobcentre Plus a few days later, which looks further into debt and arrears issues, alongside any other vulnerabilities. Appropriate support is then offered. The following box summarises the groups which the DWP guidance has identified as likely to need budgeting support.

DWP has identified a list of tier one and tier two factors which may suggest either a probable or possible need for an alternative payment arrangement6.

6 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/181400/personal-budgeting-support-guidance.

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Tier one factors are those where it is highly likely or probable that there will be need for an Alternative Payment Arrangement. The factors are:

• Drug/alcohol and/or other addiction problems eg gambling

• Learning difficulties including problems with literacy and/or numeracy

• In temporary and/or supported accommodation• Homeless• Domestic violence/abuse• Mental health condition• Currently in rent arrears/threat of eviction/

repossession• Claimant is young (either a 16/17 year old) and/

or a care leaver• Families with multiple and complex

needs

Tier two factors are those where it is less likely or possible that there will be need for an Alternative Payment Arrangement. The factors are:

• No bank account• Third party deductions in place (eg for fines,

utility arrears etc)• Claimant is a refugee/asylum seeker• History of rent arrears• Previously homeless and/or in supported

accommodation• Other disability (eg physical disability, sensory

impairment etc)• Claimant has just left prison• Claimant has just left hospital• Recently bereaved• Language skills (eg English not spoken as a

‘first language’)• Ex-service personnel• NEET – Not in Education, Employment or

Training

As the Pathfinders are accepting claims from newly unemployed single people, who aren’t home owners and have no dependants, it might be expected that the above factors are quite unlikely to apply to the initial claimant group.

4.2 Claimant evidence as reported to landlordsVery few of the tenant claimants reported to their landlord that they were offered budgeting support. This is despite many of them already having debts and/or arrears, which is one of the “tier one” vulnerability criteria above. Consequently very few have taken up the offer of the DWP’s own support. There may be several reasons for this:

• Claimant was asked the questions in a way that he or she did not understand what was being offered to them (eg they may not understand terms such as “personal budgeting support”).

• The questioning did not uncover historical debt/rent arrears, so the offer was not made to the claimant.• The tenant has forgotten or misunderstood what was offered, and has therefore reported to their

landlord that budgeting support was not offered.• The tenant chose not to reveal financial circumstances to DWP staff beyond what is required to make a

claim for benefit.• The tenant fears the sanction regime and has therefore not reported debt issues because of this, or

because of other reasons.• The tenant was offered budgeting support, but despite not choosing to access it, has reported that it

wasn’t offered to the landlord.

pdf

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Housing associations would welcome the opportunity to shadow Jobcentre Plus advisors during the claim interview to understand how this process works and offer practical solutions to the issue of the low take-up for PBS. Housing associations are often well placed in terms of the knowledge they have about their tenants, and would be able to provide details around vulnerability and debt issues.

The triage process has scripted guidelines. As such the questions may not uncover debt issues in enough detail. This may mean there is a training issue which needs to be addressed with Jobcentre Plus staff. To mitigate against this, associations such as Ashton Pioneer Homes have taken the decision to ask claimants to refer themselves to budgeting support where appropriate.

The introduction of UC in the four Pathfinder areas was limited to “simple” cases of single people with no dependants, who were recently unemployed, had no legacy benefits, and were non-home owners. Evidence from housing associations suggests that none of the claimants known to them presented “simple” claims. Many were already in debt. We have received a number of case studies of claimants, some of which we relay throughout this report.

Housing associations have raised the issue that vulnerability can change over time. As such processes under UC need to be able to capture this. Given that this initial Pathfinder has focused on “simple” cases, and yet many are financially vulnerable, the initial triage and interview needs to be looked at in more detail.

Claimant journey – as reported to the housing associationThis claimant made a claim without help, and was due a first payment at the end of September. The claimant had £150 arrears at the time of the claim. The claimant set up a bank account with the help of the association and established a monthly direct debit. In early September the claimant made contact with DWP to notify them of a change of circumstances.

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4.3 Recommendations around identifying vulnerability and Personal Budgeting Support (PBS)• The triage process for personal budgeting support needs to be reviewed to understand why there

has been a low take up of the support on offer in the Pathfinder. We are particularly concerned that claimants with existing rent arrears have not been identified as needing PBS or an Alternative Payment Arrangement (APA).

• Further work is needed to identify and streamline the process for housing associations and other partners to feed into the triage and PBS decision-making processes. Housing associations may have information about a tenant claimant’s ability to manage their money which is not picked up through the existing processes.

• Job Centre Plus should offer the opportunity for housing association staff to shadow their advisors – this would help build understanding of the processes in place and how the different organisations can work together to identify needs for PBS.

• Clarity is needed as to how the need for PBS or an APA can be identified outside of the initial UC claims process. For example, if a claimant undergoes a change of circumstance or experiences a situation such as a bereavement which may have a temporary effect on their ability to manage their money.

What housing associations can offerMany housing associations have a long history in helping verify Housing Benefit claims. This experience should not go to waste. Given the complexity of the Universal Credit system, many housing associations have reported to the National Housing Federation that they would be willing to continue verifying documentation to support the applications made by their tenants to access Universal Credit. This is an offer that should be seriously considered, given that most associations have existing close relationships with their tenants and some have the experience of verifying documentation. This would have a number of positive outcomes. Tenants would be able to work with staff they already know. Associations would be able to advise of the documentation needed. Because of existing good relationships with authorities, as well as long-standing experience, housing associations can turn around Housing Benefit claims very quickly; this quick turnaround could be applied to Universal Credit.

In addition, housing associations could be part of the solution around reducing benefit fraud.

Housing association staff can help smooth the claimant journey through Universal Credit and ensuring that appropriate arrangements are made for example:• Referrals for PBS• Helping identify where an Alternative Payment Arrangement is needed

Housing associations would like the same opportunity to be afforded to local authorities, in terms of being able to shadow Jobcentre Plus staff during an initial claim interview. This would be useful for a number of reasons:• It would develop the understanding of association staff, allowing them to better advise

tenants • It would allow associations to gain an insight into the personal budgeting “triage” system.• It would give Jobcentre Plus staff an insight into housing associations’ work.

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5 The Local Services Support Framework5.1 IntroductionUC is a large-scale change to the welfare system and DWP and local authorities have recognised the need for local partnerships to support new claimants and people migrating from the existing system. The high level approach to setting up local delivery partnerships between DWP, local authorities and other local partners is set out in the Local Services Support Framework7 (LSSF). The Local Support Services Framework is still under development and DWP will include evidence from the existing experience of the Pathfinder areas to inform further testing as UC is rolled out. The availability locally of Personal Budgeting Support is a key element of the LSSF.

5.2 Local Support Services in the PathfinderHousing associations have found the process around providing local support services complex, fragmented and confusing in the Pathfinder areas. Many housing associations are unclear as to how the LSSF is operating in their areas, with little or no understanding of which organisations are providing services.

Associations reported that they are continuing to offer all of their tenants budgeting and money advice. The degree to which these services are accessed has increased. This may reflect an increase in need, or it may reflect greater provision and/or publicity. As the number of UC claims amongst tenants is low, this increase is not due to UC.

Contour Homes, for example, has increased its money advice services. Last year services were provided to 57 cases, whereas this year 290 cases have been supported, and Contour Homes now has a waiting list for its services, despite having taken on more staff. However Contour signposts more complex cases to

7 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/181395/uc-local-service-support-framework.pdf

Claimant journey – as reported to the housing associationThis claimant made their claim at the end of July via a family computer. Making the claim was straightforward. They were not offered nor requested personal budgeting support. They were also not offered an advance payment. As the claimant was a new tenant, there were no arrears at the point of claim. The association supported the claimant during August to apply for a local authority scheme to support people needing help. The association also gave the claimant two food vouchers. The claimant was also referred to employment initiatives, a credit union, and a low-cost energy supplier. The claimant attended a workshop to learn about jamjar accounts.

In early September the first payment was due, but this did not appear. The claimant was told it would be the next day. Again there was no payment. The claimant went to the Jobcentre; despite his presence there he was told he had to call the UC helpline, which he did and was advised of a three hour callback. This callback was not received, so the claimant attended the housing office and rang UC, and was given an emergency call back. Late that afternoon the claimant received a payment and then paid rent to the association. In mid-September the claimant was due to start a college course.

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external money advice services. Wigan and Leigh Housing holds a surgery with Citizens Advice Bureau staff once a week to provide money advice.

5.3 Recommendations around the Local Support Services Framework• The Federation urges local authorities to begin scoping the form of support that will be required in their

area for UC claimants. This should map the services that already exist, and position these alongside the requirements of UC. Where gaps exist, local authorities should consider commissioning new services from those who may be best placed to deliver them. This may include housing associations.

• Local authorities should consult housing associations with stock in their area about the design of the support services.

• Housing associations should contact local authorities in which they operate and ensure that they are involved in discussions about the LSSF.

What housing associations can offerAlmost all housing associations in England provide a range of services other than just housing. There are a number of services they offer which have relevance to Universal Credit. Many associations offer employment-related services. Others also offer money advice services. It seems sensible that this experience could be used, not only for tenants, but also the wider community. This could be formally, as part of the Local Services Support Framework, or informally. Such services could be rolled out, with funding, to other Universal Credit claimants thereby providing economies of scale.

Housing associations can be significant partners within the delivery of the LSSF – both as service providers and as strategic partners with an overview of the needs within an area. Financial inclusion work must be part of the LSSF. The DWP and local authorities should consult local housing associations and associations may wish to bid to deliver aspects of the LSSF.

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6 Universal Credit Advances6.1 IntroductionUC is paid monthly in arrears and for a new claim there is an additional seven-day wait to process the claim. If a claimant is struggling financially, he or she can access a UC Advance. This is a loan given to a claimant to help bridge the gap between raising a claim and the first payment coming through.

There are two types of advances of benefit available in the Pathfinder – UC Advance (New Claim) and UC Advance (Change of Circumstances): • A Univeral Credit Advance (New Claim) may be payable at the start of a new claim – at the point of

making the claim or before the first benefit payment.• A UC Advance (Change of Circumstances) may be payable when or after the claimant reports a change

of circumstances which significantly increases the amount of benefit they may be entitled to e.g. a rent increase.8

These advances are subject to eligibility criteria being satisfied with the decision maker feeling that the claimant has demonstrated that: • it is likely that they satisfy the conditions of entitlement for benefit• they can afford to repay an advance within six months• they are in financial need• they are without access to any other source of funds or support.

8 http://www.legislation.gov.uk/uksi/2013/386/regulation/19/made

Claimant journey – as reported to the housing associationThis claimant made a claim at the end of April. Their payment was due in early June. The claimant owed £200 in rent before going onto Universal Credit. The claimant told the landlord that the DWP had not offered budgeting advice. An interim payment was offered, but the claimant was told they had to pay this back within three months, rather than the six stated in the rules. By early August, the claimant ‘s arrears were just under £1,000. The association believes this claimant is particularly vulnerable because of substance misuse issues, although the claimant may not see themself as vulnerable.

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6.2 Claimant evidence as reported to landlordsTake up of a UC Advances has been patchy. In some cases claimants have stated to their landlord that they are not being offered an advance, despite pre-existing debts/arrears.

For some claimants who were able to access UC Advances in Tameside, the repayment conditions were different to those expected. UC rules state that UC Advances should be paid back over six months (although the DWP’s initial guidance9 incorrectly stated until recently that repayment was due over three months). Yet in Tameside some claimants were told they had to pay them back over three months. The need to pay back money over a shorter period of time would have reduced the money available to claimants to pay for things such as rent and other essential outgoings, including food.

Some tenants do not take up the offer of a Universal Credit Advance soon after they raise a claim. However some claimants have reported struggling subsequently and then decide to access advance payments.

9 http://webarchive.nationalarchives.gov.uk/+/http://www.dwp.gov.uk/docs/budgeting-short-term-advances-guidance-las.pdf

Claimant journey – as reported to the housing associationThis claimant was helped by an association money advice worker to make a claim in mid August, as the claimant had no home internet access. The claimant’s expected payment date was in late September. An advance payment was not offered. The claimant reported that they did not get offered personal budgeting support. At the point of claim the claimant’s arrears stood at £1,000. By mid-September the arrears had grown to £1,300.

In late August the association emailed DWP advising of the claimant’s arrears and asking how to apply for an Alternative Payment Arrangement. Further emails followed voicing the landlord’s concern regarding the arrears and the APA. The claimant then applied for an advance payment (having not been offered one during the initial claim process), but this was refused and the claimant was advised to try again at their Jobcentre Plus appointment. The claimant attended a workshop regarding jamjar accounts.

In a conversation with the claimant, the association was told the claimant felt that Jobcentre Plus were telling them off about their council tax arrears. In early September confirmation was received about the APA, and a referral was made by the council to PBS. The APA was received by the association, using the National Insurance Number as an identifier, rather than the UC claim number. (Given the association may not know a claimant’s National Insurance Number, it may be difficult to match money coming in against a specific rent account.) In late September the claimant attended the PBS appointment. The claimant then received a letter from DWP saying they had missed a Jobcentre appointment, and was threatened with sanctions. The local Jobcentre did not have any evidence of the missed appointment, instead having in their diary an appointment which was in the future.

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6.3 Recommendations on UC Advances• Housing associations have reported that their tenants have told them there has been little consistency

in the way UC Advances have been offered. Given that the claimant receives their first UC payment one month and seven days after they make their claim. The process for identifying need should be more tightly developed. In partiuclar, the claimant should be asked how he/she will manage the next rent payment

• The correct information needs to be given to claimants regarding the repayment of the advance. Some claimants have been incorrectly informed that it needs to be repaid over 3 months, rather than 6 months.

• UC Advances need to be easily accessible at any point between the initial claim and the first UC payment. A claimant who initially turns down an advance may subsequently find that they need one before their payment date.

What housing associations can offerHousing associations know their tenants and could be ideally placed to help identify those tenants who might be in most need for a Universal Credit advance. In tandem with this they would be able to offer budgeting support services to these claimants. Such services could be rolled out, with funding, to other claimants, thereby providing economies of scale.

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7 Alternative Payment Arrangements7.1 IntroductionIf DWP decides that a claimant may not be able to manage a standard UC payment (ie monthly full payment paid into a single account) then an Alternative Payment Arrangement (APA) can be made. These are:

• making payment more frequently than monthly• splitting payment between members of a couple• paying the rent element of benefit direct to the landlord.

DWP has agreed that in the Pathfinder area10 landlords can apply for a direct rent payment to themselves if arrears of rent have reached two months. The process is set out below.

The arrears trigger has the following process:

• Decisions about whether tenants should receive direct payments will be made in collaboration with social landlords

• If arrears build up to the equivalent of one month’s rent the decision to make direct payments can be reviewed

• If arrears reach the equivalent of two months’ rent, the claimant will have housing payments switched to the landlord, or managed payments

More details can be obtained from the DWP website11 12.

7.2 The APA process under PathfinderFrom the position of housing associations in the Pathfinder, the new regime of money being paid to the claimant will increase their own costs. One association, New Charter Housing Trust, in the Pathfinder estimates:

• Cashier costs will increase by £20,000• The cost of increasing the number of arrears/support staff will be around £197,000• There will be an increase in the court, eviction and void costs of around £325,000

The process for applying for an APA is clearly laid out by DWP, but the actuality for housing associations seems to differ. When arrears reach two months, associations can contact the DWP. This should be done by contacting the UC helpline (0845 6000 723), where an agent should tell the association what to do next. The association should then provide a letter with the information required by DWP (the name of the claimant, the address, the National Insurance number if known, a reference number, and details of where they want the money sending). It should be noted that DWP is attempting to get a proforma in place to ensure the right information is supplied. This will hopefully be in place by the time UC is more widely rolled out. The letter gets opened at a mail opening centre (currently Wolverhampton), scanned in and an urgent task is then raised for action by agents in Bolton or Glasgow. A decision should be made within two days, and notification sent to the claimant and landlord. The claimant is then routed to PBS.

10 http://www.housing.org.uk/policy/policy-news/universal-credit-direct-payment-arrears-trigger-announced11 https://www.gov.uk/government/news/freud-universal-credit-protection-for-tenants-and-landlords12 https://www.gov.uk/government/publications/hb-circular-a132013-universal-credit-change-of-circumstances-affecting-hous-ing-benefit

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Despite this route map for granting an APA, associations have raised a number of issues and concerns with the process:

• The DWP does not acknowledge receipt of the APA request letter. Whilst this should not cause problems, it does when the process for making an APA decision is delayed, as associations will not know whether to wait for a decision or raise another request. If associations call the DWP about the APA request, the service centre is unable to confirm whether they have received the letter, and cannot make any comment at all.

• Associations indicate that the process for an APA decision can take at least three or four weeks, rather than the two days noted above. During this time, associations note that tenants will continue to be paid UC, but are unlikely to make any payment of rent or against arrears. It is also possible that during this time associations have begun threatening tenants with court action.

• Associations have reported that, until recently, they have not been receiving letters confirming the granting of an APA. Those who have received a letter have noted that it gives a time-frame (usually a few days) during which they should receive payment. Letters issued in September also make reference to the issue of recovering historical arrears (in that they will be dealt with at a later date), whereas letters issued in October have not mentioned this. The DWP processing centre has told at least one association that it does not deal with deductions from benefit to pay off arrears.

• When payment is received, the transaction identifier is the claimant’s National Insurance number. The association may not know this detail. Associations who are expecting APAs have been looking through their accounts on a daily basis for payments, given that some of them have not been receiving confirmation letters.

• The processes dealing with current arrears (which lead to the APA) and deductions from benefit to pay off arrears are separate. The Federation would urge DWP to look at joining these two processes to ensure a more seamless service.

Individual associations have reported that some tenants were reluctant to disclose information to DWP which might have influenced a decision about an Alternative Payment Arrangement. This included information about rent arrears and substance misuse.

At present in the Pathfinder areas, the system for identifying the need for an APA rests on JCP staff and the interview with the claimant. Many of the tenant claimants had arrears before they accessed UC, and these arrears have increased in the first few months of their claim. Given that debt is one of DWP’s criteria, such issues should be picked up. It may be that, by sharing information with housing associations, a more streamlined approach can be taken to identifying the need for an APA. Further work therefore needs to

Claimant journey – as reported to the housing associationThis claimant made the claim online at their mother’s house in late August, and found the process straightforward. The claimant reported that the subsequent interview process was hard work, and they didn’t understand it. The interview was completed quickly, and the claimant thoughtJobcentre Plus staff were only concerned about processing claims speedily. Personal budgeting support was neither offered nor requested, nor was an advance payment. In mid-July the claimant’s arrears stood at £400. By mid-September this had risen to over £1,000. The claimant has received money advice in the past, and has another appointment. The claimant wants to pay their rent via Allpay. The claimant has subsequently requested an APA via the helpline.

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be done to work out the best way of identifying the need for an APA and how information held by other agencies can be used.

If an APA is forthcoming, associations also feel that the process for getting arrears paid directly to them should be further streamlined. Currently, the process for requesting an APA is separate from the process of getting linked arrears paid back through direct deduction from the benefit. These two processes should be joined. The decision to introduce the APA when two months of arrears has developed is welcome, but it still means there is a period during which an association may start proceedings, yet is unaware of whether an APA will be granted by DWP. This may mean tenants are being put under greater financial pressure, and ultimately the security of their home may be put under threat. Knowing which tenants are claiming UC would help social landlords to concentrate their efforts in supporting people and not waste time on unnecessary legal action. DWP has stated it is looking at the regulations regarding the APA and the process for deductions to pay back arrears.

7.3 Supported housingSupported housing includes hostels, refuges and sheltered housing for older people. Tenants in supported housing which meet the definition of ‘exempt accommodation’ cannot claim housing costs through UC and can currently claim Housing Benefit instead. At present, if someone already in receipt of UC moves into supported ‘exempt accommodation’ then he or she should apply to the local authority to claim Housing Benefit to cover the rent. The tenant can choose to have the Housing Benefit paid direct to the landlord of the supported housing.

Claimant journey – as reported to the housing associationThis claimant owed £429 in rent when the claim for UC was made. The claimant made a payment against this when the first Universal Credit payment was made. However a second payment was not made. By early August the claimant owed £992.

What housing associations can offerHousing associations want Universal Credit to work for their tenants and for systems to be efficient and streamlined. Whilst they recognise the drive to make claimants responsible for their own actions, there are occasions when people will not pay their rent and arrears will build up to the trigger level or where an Alternative Payment Arrangement is appropriate from the start of the claim. In these cases, associations should be able to share this information with the DWP. However, without knowing which tenants are on Universal Credit, associations are unable to provide information as effectively as they would like.

As noted above, associations also already provide a range of services to tenants, which will help them to manage their money more effectively, and also help them to move back into employment.

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The regulations13 governing the payment of UC in the Pathfinder areas exclude homeless people, which means that the numbers of people in receipt of UC and living in supported housing are likely to be very small at this stage. However a claimant may become homeless after the start of the UC claim. One association had experience of the interaction between the UC system and supported housing when a claimant in receipt of UC moved into a supported scheme. The claimant, housing association, local JCP staff and the UC helpline staff were unsure of the correct process and initially the claimant was advised to claim housing costs through UC and to request an APA so the money would be paid direct to the landlord. Subsequently, the claimant had to make a separate claim Housing Benefit and arrears of rent accrued.

The Federation therefore makes a number of recommendations. To ensure that UC works effectively for people living in supported housing it is important that:

• tt is clear to residents how they can apply for help with housing costs• there is data sharing between supported housing providers, local authorities and the DWP so that

exempt schemes are clearly identified• staff in supported housing schemes, DWP and within the local authority are aware of how the system

should work and can advise people appropriately.

7.4 Recommendations around Alternative Payment Arrangements• The process for applying Alternative Payment Arrangements (APA), whether identified through the PBS

assessment or because a claimant has reached the trigger of two months’ rent arrears needs to be better communicated to landlords and claimants.

• Housing associations should be able to contribute information to be taken into account during the PBS assessment (see section 4).

• The process for switching to managed payments (housing costs paid to the landlord) after the arrears trigger has been reached needs to be streamlined. The current process of phoning the helpline, sending information to the service centre and waiting to see if a payment is made is too long and labour intensive.

• An email or letter confirming the safe receipt of an APA request should be sent to the landlord.

• Both the claimant and the landlord should be notified whether or not an APA has been granted. The landlord should be told when to expect the rent payment and an appropriate identifier should be agreed to allow the payments to be tracked.

• Decisions on APAs need to be made quickly and before the next UC payment is made to the claimant. If there is a delay in processing an APA request, the rent money should be held and only paid to either the claimant or the landlord after the APA decision has been taken. This should be communicated to both landlord and claimant.

• Landlords should be able to apply for a direct deduction from UC to repay existing rent arrears at the same time as requesting a managed payment due to rent arrears. These processes need to be closely linked.

13 UC Pathfinder regulations

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8 Discretionary Housing Payments

8.1 IntroductionDiscretionary Housing Payments (DHPs)14 are awarded by a local authority from a fund given to them by central government, which they themselves may enhance with their own funding. DHPs are given to claimants that require further financial assistance towards housing costs, and are awarded in addition to existing welfare benefits. Devolved powers allow local authorities to define their own rules for the administration of the fund within broad rules set nationally.

8.2 DHPs in the PathfindersIn the experience of the housing associations interviewed DHPs are not being accessed by claimants of UC. The reasons for this are unknown. Most DHPs are applied for as a result of the social sector size criteria or the benefit cap. Because this is a locally administered fund, the process for awarding DHPs varies between local authorities, with different award amounts and durations offered. Most associations involved in the Pathfinder promote DHPs to their tenants. Some associations report having good relationships with local authorities, and therefore are able to find out in detail about claims made.

With specific reference to UC, there is an issue of whether tenants will understand if there is a shortfall in the housing element of their benefit because a ‘spare room’ has been identified. There is no data sharing protocol in place between housing associations in the Pathfinder and the DWP, the DWP may be accessing details about the size of property from the tenant themselves on their claim form, or from secondary evidence such as the tenancy agreement if this includes such a detail.

Recommendations• Local authorities and social landlords should promote the availability of DHP to UC claimants so that

tenants know that they can apply for support.• Jobcentre Plus and DWP staff should eb aware of DHP scheme locally and signpost UC claimants for

help.

14 http://www.dwp.gov.uk/docs/discretionary-housing-payments-guide.pdf

What housing associations can offerAssociations are already supporting claimants to make DHP claims. Elsewhere in the country some associations are managing all or part of the DHP fund on behalf of their local authority. Associations are well placed to know which of their tenants are in financial difficulty, and are happy to work with relevant agencies to ensure the fund is administered effectively.

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9 Data sharing9.1 IntroductionThere are examples through this report of where relationships between the tenant, the landlord and the DWP could have worked better if agencies had been able to share data.

9.2 Knowing a tenant is a UC claimantIn the Pathfinder areas housing associations do not know which of their tenants are claiming UC. They find out:

• as a result of investigating why arrears are rising• when a tenant hits the arrears trigger and receiving an APA• because the tenant asks for help or advice – for example help filling in the UC application form• when a tenant volunteers the information.

9.3 Benefits of data sharingThe lack of data sharing in the Pathfinder areas has caused a number of problems for housing associations. Firstly, it means that housing associations are unable to support tenants as well as they traditionally can do under other benefit regimes. Secondly, it means that they are not acting with the full information; they may serve a notice to seek possession, for example, without knowing that a claimant will be receiving UC. Thirdly, it prevents associations offering tenants early intervention to prevent arrears building up.

By the open sharing of information, the administrative burden felt by DWP would be reduced, and claims would run more smoothly. For example:

• Housing associations could send across automatically data around rent increases, to avoid the prospect of millions of tenants individually making DWP aware of their change in circumstances. In the Pathfinder area, at least two landlords have increased their rents during the first few months of UC. As numbers are currently small, it is likely that such volumes can be managed, though this will increasingly not be the case as the volume of claims grows.

• Associations could also send across automatically data around eligible service charges. This would reduce error, and speed up the process for tenants.

• By having the right information, DWP would avoid over/underpayments, and possible fraud. This would mean a fewer number of cases of benefit “clawback”.

• Associations may already be working intensively with tenant claimants who are in arrears or have debts. UC has the possibility of duplicating this effort through its own personal budgeting support via the Local Support Services Framework, thereby wasting resource at a time when money is tight.

• Early intervention can prevent eviction and homelessness, and reduce costs to the wider public purse (eg through having to provide temporary accommodation).

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9.4 Where housing associations can helpHousing associations would like DWP to share information with them that allows them to better support their tenants, and take swift action to remedy problems. Associations may know the vulnerability issues that their tenants are facing, whether these are caused by debt or other issues. The triage system as it stands at the moment is not necessarily picking these issues up, resulting in problems further down the line with tenants reaching the arrears trigger after two months of non-payment of rent. Whilst associations are able to contact DWP directly about tenants they think might be vulnerable, because they don’t know which tenants are claiming UC, they could be providing information about non-claimant tenants. This system needs to work better for tenant claimants.

9.5 Next stepsWe welcome that DWP has established an internal working group to look at data sharing, and look forward to working with this group. DWP has established a memorandum of understanding with the local authorities in the Pathfinder area to facilitate the sharing of data and allow personal budgeting support. It should be the case that this agreement is extended to other key partners, including housing associations, to facilitate better support for claimants.

9.6 Recommendations around data sharingThe issue of data sharing seems to be at the heart of UC, and the relationship between DWP and housing associations. It underpins many of the recommendations highlighted above. For example:

• Streamlining the process for applying APAs and the operation of the arrears trigger• Identifying needs for personal budgeting support• Housing associations’ ability to support tenants with the claims process

The Federation welcomes the importance that this issue now has within DWP and looks forward to working further on this issue to create a mutually beneficial solution. The Federation is producing a separate paper containing recommendations on data sharing and UC.

What housing associations can offerData sharing seems to be at the heart of many of the issues tenants and associations are experiencing with Universal Credit. There would be real benefit to claimants, the DWP and associations themselves if some details of claims could be shared. This would allow associations to provide a better service and potentially cut the costs of administration for DWP and reduce fraud. It would allow associations to continue to play a role in verifying claims and the secure transfer of data on rents, property size, direct deductions of benefit to pay arrears and direct payments of housing costs to the landlord. It would allow associations to offer support to deal with monthly budgeting at an early stage rather than after a tenant had got into difficulty with arrears of rent. It would also allow the effective application of the arrears trigger where a tenant in arrears has the housing costs element of UC paid direct to the landlord.

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10 Relationships10.1 IntroductionOne of the key solutions to smoothing the introduction of UC (and indeed wider welfare reform) is having effective relationships with the right people locally. This allows mutual understanding to develop and issues to be dealt with swiftly and efficiently. However, relationships, by their very nature, work better in some areas than others. This is often down to individuals.

During this research we have seen that some relationships are key. Sometimes relationships between senior people are of greatest importance. In other cases, it is the relationships between operational staff that are most vital. Our research has looked at the relationships between:

• The tenant and their association• The tenant and Jobcentre Plus• The association and Jobcentre Plus• The association and DWP• The association and the local authority• The association and other local service providers (eg money advice services).

We look at evidence below from our evaluation relating to each of these. It should be remembered that this evidence is a snapshot from the first few months of UC’s operation in the four Pathfinder authorities.

10.2 The tenant and their housing associationGiven the challenge of wider welfare reform, housing associations are looking at how they work and communicate with tenants to ensure regular rent payments, and to ensure tenants receive the support and help they need to maintain their tenancy. UC brings additional challenges, though many associations believe they generally have very good relationships with their tenants, with the exception of those who refuse to engage with them. It is these positive relationships that mean housing associations find out which tenants are claiming UC. Many associations have increased their knowledge base of their tenants through profiling work and other research.

However, it is easier for associations to support a tenant that asks for help. Some tenants are harder to engage and associations have to use a range of methods and approaches to stress to tenants the importance of paying rent.

Associations are also doing a great deal of work to support tenants around employment and skills. Where possible they are increasing resources in this area, and joining with relevant local partners to increase delivery. Because of their knowledge of and work in local neighbourhoods, associations are often best placed to provide or signpost to work or training opportunities. The Federation produced a report on housing, employment and skills in June 2013, and more details of their work can be found on the our website15.

15 http://www.housing.org.uk/publications/browse/housing-employment-and-skills

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10.3 The tenant and Jobcentre Plus/DWPThe relationships between tenants and Jobcentre Plus seem to be inconsistent, both between cases and even for individual cases. Housing associations report that claimants have to make contact through the UC helpline, even if they are visiting a Jobcentre in person. There is also a three hour call back in operation, whereby claimants make contact with DWP and are then called back three hours later.

There is a need for greater consistency within and between Jobcentre Plus staff and UC helpline staff. Tenants reported to their housing associations that they received different answers to the same query at different times from different staff. This leaves them confused and unsure of which advice to follow.

Claimants reported to their landlords that the language used by Jobcentre Plus can feel threatening and complicated. Claimants reported a focus on sanctions, with claimants told that if they do not complete certain things, they will be sanctioned. Tenants have reported being threatened with sanctions for undertaking training courses, or for not attending meetings with Jobcentre Plus staff, despite having mitigating circumstances (eg health issues or because they have been undertaking volunteering). Rules are therefore sometimes unclear for claimants.

Several tenant claimants have reported that they need a CV to upload to the Universal Job Match site before they will receive their UC payment. In response DWP has stated that this shouldn’t be the case. However,, there is clearly a need for IT access to allow tenants to create their CV, and support for claimants to create a CV and perform job searches.

Tenant claimants are also reporting being told by Jobcentre staff that they need a bank account to access UC. DWP has stated in response that this was not entirely true. Tenants need access to a bank account, which may or may not be in their name.

This evidence suggests therefore that:• Tenants are interpreting what they are being told in different ways, and reporting this to their landlords• Tenants are not being given consistent messages by different staff within Jobcentre Plus or DWP• There is a need for greater consistency in messaging and the information being relayed to tenants, as

well as greater clarity, in order to avoid confusion.

10.4 The housing association and Jobcentre PlusLocal relationships between housing associations and local Jobcentre Plus branches are variable, but generally positive. New Charter Housing Trust, for example, has informal relationships with their local Jobcentres. It also runs six of the ten Job Clubs in Tameside for Jobcentre Plus. Golden Gates Housing is looking to co-locate their own staff with Jobcentre Plus staff, although there are no formal agreements. The association noted that welfare reform has provided the impetus for better joint working between associations and Jobcentre Plus in particular around supporting people back to work, and that it is very useful to establish a mutual understanding of the different roles of the different organisations.

10.5 The housing association and DWPSome housing associations report they have good relationships with their local DWP representatives. Contour Homes has good relationships with its local DWP staff and attend regular stakeholder forums. However because Contour operates over a number of different authorities, it notes that relationships vary between places – for example between Contour and DWP regional managers. While some of this may be down to personalities, it may also be a factor of the association having less presence in some areas compared to others. Conversely, First Choice Homes Oldham has reported meeting regularly with DWP staff. This is the same for providers in Warrington, where regular formal meetings and informal communications take place.

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Another association reports its relationship with DWP can be hit and miss. Some elements of communication with DWP works well and can be very effective. However, it feels it doesn’t work enough with DWP. DWP is working closely with the local authority, and the association therefore sometimes feels out of the loop.

Others indicate that relationships with DWP do not exist, or if they do, they are not very positive. However many associations noted that these relationships will undoubtedly improve over time as it is still currently very early days.

The Federation would urge DWP to consider having a dedicated telephone number/email address for landlords. This would enable them to have a direct route into DWP. It would result in problems being raised more effectively and dealt with more quickly.

10.6 The housing association and the local authorityHistorical links are often important in terms of the quality of the relationship between the housing association and their local authority. Some associations have been created from the local authority as stock transfers, taking on their housing role. Because of these historical links, the association and authority may work together better and more closely. For example, New Charter Housing Trust works well with Tameside because of historical links. The authority is willing to share data with New Charter Housing Trust, particularly around Housing Benefit and Discretionary Housing Payments.

One association reported a good relationship with its authority, both in terms of data sharing (relating to under-occupation and housing benefit) and reporting (the association writes management reports on behalf of the authority on a number of issues).

Another association also reported a good relationship with its authority because of historical links. These links have been useful when promoting budgeting and IT skills. However it was noted that these activities have potentially had less impact than hoped because they were commenced too early in relation to the rollout of welfare reform. Golden Gates Housing noted that developing relationships with the right people in the housing association was vital. It may be that relationships with senior people may not be the most appropriate and rather relationships between those at an operational level may be key.

10.7 The association and other local service providersRelationships between housing associations and other local service providers vary. One association reported having a very good relationship with its local Citizens Advice Bureau (CAB), but noted that relationships do vary. CAB locally feed back to the association on the service they provide and the money they help the tenant save. The association is proposing to cement the relationship further by having embedded debt advisors sitting within local CAB offices. Another reported a concern regarding money advice services, highlighting the tension that will exist between independent advisors and a landlord over debt priorities.

A number of housing associations reported working well with private sector organisations. Both First Choice Homes Oldham and Golden Gates Housing have good relationships with banks. This helps to overcome financial exclusion, and allows tenants to access bank accounts to facilitate the payment of UC.

Golden Gates Housing also reported having good relationships with the local credit union, local schools (where they have given presentations on welfare reform), the YMCA and tenant associations.

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10.8 Housing association activity during the wider roll-outAs a summary to this section, we consider some of the evidence from the housing associations operating in the Pathfinder areas and how this translates into positive action to mitigate against some of the challenges of UC.

Associations should start preparations and building relationships now. It is better to have something in place before UC arrives in your area, than be left having to manage UC and create relationships from scratch. Once relationships exist, it will be easier for all parties to share experiences and information, and to find solutions to issues more quickly.

It is vital that associations map key local contacts within the Jobcentre and the DWP. Once these have been mapped it will then be possible to make contact and begin joint planning for the introduction of UC. It is likely that both Jobcentre and DWP staff will welcome the input of housing associations, given the housing element of UC will be newly under their remit.

Housing associations should also press their local authority/authorities for their plans around the Local Support Services Framework. This will allow associations to understand how supply and demand for support is being assessed. It will also allow associations to meet with local authorities to describe the services that they offer, and could continue to offer under the framework. Some authorities are beginning to work on their response to the framework now, whilst others are waiting to see the funding available. However, in either scenario, the sooner housing associations position themselves, the better the outcomes will be for all parties and those needing the support.

Even during the wider rollout, the systems of UC may still not work optimally, or work in such a way that affects housing associations. Where possible, it is better for associations to offer solutions to problems, which may result in system change. Such changes may be small within the wider context of UC, but may have a profound impact on the outcomes for associations and their tenants.

Finally, working together with associations in your area will be vital. This allows associations to share experiences and crucially to share solutions to problems. This model has worked effectively in the North West Pathfinder, where associations have met with relevant people from the DWP, CLG and Jobcentres.

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10.9 Recommendations around relationships• There should be a specific phone line for landlords to use to contact the UC service centre.

• Housing associations should begin to map and develop relationships with key contacts within Jobcentre Plus, the DWP and other partners. These relationships will be vital to resolving issues as UC rolls out to new areas.

• Housing associations may want to consider identifying key contacts within their own organisation (e.g. for welfare reform, financial inclusion, employment and skills) and ensure that local partners such as the council and JCP have access to these contacts.

• There is a need for consistency in the messages and language used to talk about UC claims between all agencies that a claimant may contact about their claim.

• Local partners should decide whether there is a need for joint training sessions for front line staff (from the local authority, JCP, housing associations and PBS providers) on UC. This will help to develop these relationships and ensure that claimants receive consistent messages regardless of who they contact about UC.

• Housing associations may wish to develop their relationships with other local associations. Pathfinder associations have benefited from learning from other associations’ experiences of UC.

What housing associations can offerRelationships are key. Hosing associations, both within, but also outside the Pathfinder, are willing to make contact with the key stakeholders (in particular their local DWP and Jobcentre Plus staff), as these are the relationships which will be vital when Universal Credit is rolled out more widely. Finding the right person may be tricky to begin with but it will pay dividends.

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What housing associations can offer

Many housing associations are able to support tenants make or manage their claim. They have a social ethos to support their tenants and help them to achieve their goals and aims. Many associations in the Pathfinder area have already provided access and support to claimants in completing applications, and this support will undoubtedly continue as Universal Credit is rolled out. They are able to signpost claimants to services they provide, and services provided by local partners, to create a holistic “offer”. However there remains a question about what level of support can be provided and on what scale as the UC programme is rolled out and millions of claims are transferred from the old system to UC.

11 Landlords as partners of choice, and recommendationsThroughout this report we have presented areas where housing associations could be seen as partners of choice in helping to deliver Universal Credit. This is in terms of offers which associations are prepared to make to DWP to facilitate the delivery of Universal Credit, and ultimately provide a smooth, seamless service to their tenants. We have also provided recommendations based on our learning from the Pathfinder. Recommendations cover how Universal Credit needs to develop to improve the experience for tenants and landlords and how housing associations can start to prepare for Universal Credit.

Recommendations

The claimant should receive an automatic confirmation that their claim has been submitted. This should include the indicative award amount and could be sent by either email or text. This confirmation should be in addition to the information given on the final screen of the UC claim. This would mirror similar processes e.g. for online purchases. It would mean the claimant could be certain that their claim had been submitted, and if needed for. accessing a new tenancy, could be used as proof of a benefit claim.

A “save” function should be added to the online claim form as soon as possible. The inability to save information in a claim has caused problems, particularly where claimants are accessing the form on a public computer. Some access points, including libraries have time limits for internet usage which may be less than the time taken to complete a claim.

During the interview at JCP, social housing tenants should be encouraged to talk to their landlord to let them know they are claiming Universal Credit.

Greater clarity and consistency in the messages given to claimants is needed. Some claimants have reported confusion as to what counts as work search activity or what actions may lead to a benefit sanction. There has also been confusion over how activity on Universal Jobmatch relates to a UC claim.

Making the claim

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Recommendations

The triage process for personal budgeting support needs to be reviewed to understand why there has been a low take up of the support on offer in the Pathfinder. We are particularly concerned that claimants with existing rent arrears have not been identified as needing PBS or an Alternative Payment Arrangement.

Further work is needed to identify and streamline the process for housing associations and other partners to feed into the triage and PBS decision making processes. Housing associations may have information about a tenant claimant’s ability to manage their money which is not picked up through the existing processes.

JCP should offer the opportunity for housing association staff to shadow their advisors – this would help build understanding of the processes in place and how the different organisations can work together to identify needs for PBS.

Clarity is needed as to how the need for PBS or an APA can be identified outside of the initial UC claims process. For example, if a claimant undergoes a change of circumstance or experiences a situation such as a bereavement which may have a temporary effect on their ability to manage their money.

What housing associations can offer

Many housing associations have a long history in helping verify Housing Benefit claims. This experience should not go to waste. Given the complexity of the Universal Credit system, many housing associations have reported to the National Housing Federation that they would be willing to continue verifying documentation to support the applications made by their tenants to access Universal Credit. This is an offer that should be seriously considered, given that most associations have existing close relationships with their tenants and some have the experience of verifying documentation. This would have a number of positive outcomes. Tenants would be able to work with staff they already know. Associations would be able to advise of the documentation needed. Because of existing good relationships with authorities, as well as long-standing experience, housing associations can turn around Housing Benefit claims very quickly; this quick turnaround could be applied to Universal Credit.

In addition, housing associations could be part of the solution around reducing benefit fraud.

Personal Budgeting Support and identifying vulnerability

What housing associations can offer

Housing association staff can help smooth the claimant journey through Universal Credit and ensuring that appropriate arrangements are made for example:

• Referrals for Personal Budgeting Support• Helping identify where an Alternative Payment Arrangement is needed

Housing associations would like the same opportunity being afforded to local authorities, in terms of being able to shadow Jobcentre Plus staff during an initial claim interview. This would be useful for a number of reasons:

• It would develop the understanding of association staff allowing them to better advise tenants • It would allow associations to gain an insight into the personal budgeting “triage” system

Individual Jobcentres would be encouraged to invite local housing associations to participate as part of the local partnership process.

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What housing associations can offer

Almost all housing associations in England provide a range of services other than just housing. There are a number of services they offer which have relevance to Universal Credit. Many associations offer employment related services. Others also offer money advice services. It seems sensible that this experience could be used, not only for tenants, but also the wider community. This could be formally, as part of the Local Services Support Framework, or informally. Such services could be rolled out, with funding, to other Universal Credit claimants thereby providing economies of scale.

Housing associations can be significant partners within the delivery of the LSSF – both as service providers and as strategic partners with an overview of the needs within an area. Financial inclusion work must be part of the LSSF. The DWP and local authorities must have a duty to consult local housing associations, given that associations may wish to bid to deliver aspects of the LSSF.

Recommendations

The Federation urges local authorities to begin scoping the form of support that will be required in their area for Universal Credit claimants. This should map the services that already exist, and position these alongside the requirements of Universal Credit. Where gaps exist, local authorities should consider commissioning new services from those who may be best placed to deliver them. This may include housing associations.

Local authorities should consult with housing associations with stock in their area about the design of the support services.

Housing associations should contact local authorities in which they operate and ensure that they are involved in discussions about the LSSF.

The Local Services Support Framework

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Recommendations

Housing associations have reported that their tenants have told them there has been little consistency in the way Universal Credit Advances have been offered. Given that the claimant receives their first UC payment a month and seven days after they make their claim, advance payments should be offered as a matter of course. In particular this should apply where the claim includes housing costs. If this is not possible, then the process for identifying need should be more tightly developed.

The correct information needs to be given to claimants regarding the repayment of the advance. Some claimants have been incorrectly informed that it needs to be repaid over three months, rather than six months.

Universal Credit Advances need to be easily accessible at any point between the initial claim and the first UC payment. A claimant who initially turns down an advance may subsequently find that they need one before their payment date.

What housing associations can offer

Housing associations know their tenants and would be ideally placed to help identify those tenants who might be in most need for a short term benefit advance. In tandem with this they would be able to offer budgeting support services to these claimants. Such services could be rolled out, with funding, to other claimants thereby providing economies of scale.

Universal Credit Advances

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What housing associations can offer

Housing associations want Universal Credit to work for their tenants and for systems to be efficient and streamlined. Whilst they recognise the drive to make claimants responsible for their own actions, there are occasions when people will not pay their rent and arrears will build up to the trigger level or where an Alternative Payment Arrangement is appropriate from the start of the claim. In these cases, associations should be able to share this information with the DWP. However, without knowing which tenants are on Universal Credit, associations are unable to provide information as effectively as they would like.

As noted above, associations also already provide a range of services to tenants, which will help them to manage their money more effectively, and also help them to move back into employment.

Recommendations

The process for applying Alternative Payment Arrangements, whether identified through the PBS assessment or because a claimant has reached the trigger of two months’ rent arrears needs to be better communicated to landlords and claimants.

Housing associations should be able to contribute information to be taken into account during the PBS assessment.

The process for switching to managed payments (housing costs paid to the landlord) after the arrears trigger has been reached needs to be streamlined. The current process of phoning the helpline, sending information to the service centre and waiting to see if a payment it made is too long and labour intensive.

An email or letter confirming the safe receipt of an APA request should be sent to the landlord.

Both the claimant and the landlord should be notified whether or not an APA has been granted. The landlord should be told when to expect the rent payment an appropriate identifier should be agreed to allow the payments to be tracked.

Decisions on APAs need to be made quickly and before the next UC payment is made to the claimant. If there is a delay in processing an APA request, the rent money should be held and only paid to either the claimant or the landlord after the APA decision has been taken. This should be communicated to both landlord and claimant.

Landlords should be able to apply for a direct deduction from Universal Credit to repay existing rent arrears at the same time as requesting a managed payment due to rent arrears. These processes need to be closely linked.

Alternative Payment Arrangements

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Recommendations

The issue of data sharing seems to be at the heart of Universal Credit, and the relationship between DWP and housing associations. It underpins many of the recommendations highlighted above. For example:Streamlining the process for applying APAs and the operation of the arrears triggerIdentifying needs for personal budgeting supportHousing associations’ ability to support tenants with the claims process

The Federation welcomes the importance that this issue now has within DWP and looks forward to working further on this issue to create a mutually beneficial solution. The Federation is producing a separate paper containing recommendations on data sharing and Universal Credit.

What housing associations can offer

Data sharing seems to be at the heart of many of the issues tenants and associations are experiencing with Universal Credit. , there would be real benefit to claimants, the DWP and associations themselves if some details of claims could be shared. This would allow associations to provide a better service and potentially cut the costs of administration for DWP and reduce fraud. It would allow associations to continue to play a role in verifying claims and the secure transfer of data on rents, property size, direct deductions of benefit to pay arrears and direct payments of housing costs to the landlord. It would allow associations to offer support to deal with monthly budgeting at an early stage rather than after a tenant had got into difficulty with arrears of rent. It would allow the effective application of the arrears trigger where a tenant in arrears has the housing costs element of UC paid direct to the landlord.

Data sharing

Discretionary Housing Payments

What housing associations can offer

Associations are already supporting claimants to make DHP claims. Some are also “sifting out” those claimants which are unlikely to have their claim approved. Elsewhere in the country some associations are managing all or part of the DHP fund on behalf of their local authority. Associations are well placed to know which of their tenants are in financial difficulty, and are happy to work with relevant agencies to ensure the fund is administered effectively.

Recommendations

Local authorities and social landlords should promote the availability of DHP to UC claimants so that tenants know that they can apply for support.

Jobcentre Plus and DWP staff should eb aware of DHP scheme locally and signpost UC claimants for help.

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Recommendations

There is a need for consistency in the messages and language used to talk about Universal Credit claims between all agencies that a claimant may contact about their claim. There has been inconsistency in the messages given to claimants by different members of staff, from different agencies.

Local partners should decide whether there is a need for joint training sessions for front line staff (from the local authority, JCP, housing associations and PBS providers) on Universal Credit. This will help to develop these relationships and ensure that claimants receive consistent messages regardless of who they contact about UC.

Housing associations may wish to develop their relationships with other local associations. Pathfinder associations have benefited from learning from other associations’ experiences of UC.

Recommendations

There should be a specific phone line for landlords to use to contact the UC service centre.

Housing associations should begin to map and develop relationships with key contacts within Jobcentre Plus, the DWP and other partners. These relationships will be vital to resolving issues as Universal Credit rolls out to new areas.

Housing associations may want to consider identifying key contacts within their own organisation (e.g. for welfare reform, financial inclusion, employment and skills) and ensure that local partners such as the council and JCP have access to these contacts.

What housing associations can offer

Relationships are key. Associations (both within, but also outside the Pathfinder) are willing to make contact with the key stakeholders (in particular their local DWP and Jobcentre Plus staff), as these are the relationships which will be vital when Universal Credit is rolled out more widely. Finding the right person may be tricky to begin with but it will pay dividends.

Relationships

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Appendix A: GlossaryAPA – Alternative Payment Arrangement: Universal Credit is paid monthly into a single account. Any deviation from this (eg a “split” payment between members of a couple, more frequent payments or payments direct to landlords of housing costs) is called an Alternative Payment Arrangement.

CAB – Citizens Advice Bureau: provides free impartial advice to the general public, and may be one of the key partners delivering local services under the Local Support Services Framework.

CLG – Department for Communities and Local Government.

DHP – Discretionary Housing Payments: this is a locally-administered government fund (potentially matched by local authority money) to provide extra benefit to people struggling to afford housing costs.

DLA – Disability Living Allowance. This benefit will be replaced by Personal Independence Payment.

DWP – Department for Work and Pensions

HB – Housing Benefit

HMRC – Her Majesty’s Revenue and Customs

LSSF – Local Support Services Framework: this covers the local support and advice services that may be delivered by local partners under Universal Credit.

JSA – Jobseeker’s Allowance

PBS – Personal Budgeting Support: the support offered to claimants if they are recognised as struggling, or potentially struggling, to manage a monthly benefit payment.

PIP – Personal Independence Payment. New non means tested benefit to help with the costs of disability. It will gradually replace Disability Living Allowance.

STBA – Short Term Benefit Advance: this payment may be offered to claimants to bridge the gap between their claim and their first payment. This is in effect a “loan” that must then be paid back over the next six months, and is deducted from the benefit. To be eligible for an advance the claimant must demonstrate that they are in financial need.

UC – Universal Credit

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The National Housing Federation is the voice of affordable housing in England. We believe that everyone should have the home they need at a price they can afford. That’s why we represent the work of housing associations and campaign for better housing.

Our members provide two and a half million homes for more than five million people. And each year they invest in a diverse range of neighbourhood projects that help create strong, vibrant communities.

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National Housing Federation Welfare Reform

National Housing Federation25 Procter Street, London WC1V 6NYTel: 020 7067 1010 Email: [email protected]