Reply To: Housing Proactive

#285993
Peter Barker
Keymaster

Before answering this, I’ll declare an interest: I do occasional bits of work for Alertacall. So you won’t be surprised that I think it perfectly eligible and shouldn’t really be controversial at all.

The customers who sign up to this are exclusively registered housing associations providing sheltered accommodation.

One of the posts in this thread mentions alarm/warden call. Housing Proactive is NOT in any way integrated with an emergency alarm. Alertacall make alarms as well, and they could have integrated everything into an all-in-one system, but they decided to keep it separate precisely because it maintains a bright line between ineligible alarm systems and eligible activities like repairs and fire safety and so on. They wanted to offer a product that would not raise complicated problems around apportionment of cost between eligible/ineligible activities. It can be integrated with compatible video entry systems if required, but that’s all.

It is a portable Android tablet with a few apps installed to support communication between tenants and housing management staff. These can be messages from staff to tenants (eg meeting reminders), messages from tenants to staff (eg reporting repairs) or two-way communications including video calls. The OK Each Day feature is optional – tenants aren’t obliged to participate but for those who opt in it is a useful way to confirm they are well and not in need of any intervention. If someone doesn’t respond to a prompt during the day that will of course trigger some follow-up work which might then stray into the realms of support, but the Alertcall system isn’t involved in that follow-up work so the charge wouldn’t be funding the home visit, call to social services or whatever they end up having to do.

I did have some doubts/questions at first:

1. Should it not be funded out of the core rent?

The charge is not very much, and if it is marketed as making the job more efficient ought the cost not to be absorbed in the regulated core rent? Well, the regulator’s standards are becoming more rigorous in areas such as tenant engagement, consumer satisfaction, proactively preventing disrepair. You can read all about this on the English social housing regulator’s website and you can read the enhanced legal powers in the Social Housing (Regulation) Act 2003. In simple terms, providers are going to have to do more to maintain compliance with standards and it’s going to cost them more. Something like Housing Proactive can help them to do that more effectively.

I’d be cautious about trespassing on the regulator’s territory: if there was a problem levying a service charge for this, then the regulator would have had something to say about it but it’s not something HB should be policing really. There is a well-established line of case law about core rent items specified as service charges: if it’s something that could just as easily have been funded by core rent, there’s no problem paying it through HB. The important thing is that it’s not an *ineligible* service, which Housing Proactive is not. Regs 12 and 12B say the eligible rent for HB is the aggregate of payments including rent and service charges, minus service charges that are ineligible under Schedule 1. The distinction between core rent and eligible charges is somewhat academic.

2. Is the charge unreasonably high?

It’s not that much and I don’t think anyone is offering a rival product for significantly less. The only other one I’ve seen was developed for challenging environments and has a toughened case – it costs about double the charge for Housing Proactive.

There is a tortuous line of reasoning that if the product has replaced work that staff were previously doing, and if staff roles have become redundant, but there has been no corresponding reduction in core rent, then it is unreasonable to make a service charge. But you would need evidence that those things had actually happened and that there was a causal link. I’m not aware of any providers using this to get rid of existing staff: as I said above, it’s a way of meeting new challenges that would otherwise require even more staff to be recruited.

3. Is the service in any way ineligible?

No it really isn’t. It is not integrated with the alarm and even if the tenant has opted into OK Each Day, the human follow-up to a missed response is not funded by the charge.

I would recommend accepting this as eligible.

I know that LAs are cautious about approving things in principle before they exist. The landlords who are considering ordering Housing proactive obviously want reassurance that HB will cover it. This isn’t like supported accommodation providers asking for approval in advance, when you don’t know whether the individual tenants will all require more than minimal support etc. This is a flat rate charge for the same service across the board – if it’s eligible for one tenant, it’s eligible for all of them.