Draft National Strategy for Housing for Older
People:
A consultation
Response from the Chartered Institute of Housing
Scotland
September 2011
September 2011
www.cihscotland.org
Introduction
The Chartered Institute of Housing Scotland (CIH) welcomes this opportunity to
respond to the Scottish Government’s consultation on the Draft National Strategy for
Housing for Older People.
The Chartered Institute of Housing (CIH) is the professional body for people involved
in housing and communities. We are a registered charity and not-for-profit
organisation. We have a diverse and growing membership of over 22,000 people –
both in the public and private sectors.
CIH Scotland has more than 2,400 members working in local authorities, housing
associations, housing co-operatives, Scottish Government and Government
agencies, voluntary organisations, the private sector, and educational institutions.
The CIH aims to ensure members are equipped to do their job by working to improve
practice and delivery. We also represent the interests of our members in the
development of strategic and national housing policy
For more information on the contents of this paper, please contact the Policy and
Practice Team:
Chartered Institute of Housing Scotland
4th Floor, 125 Princes Street
Edinburgh
EH2 4AD
0131 225 4544
[email protected]
www.cihscotland.org
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Draft National Strategy for housing for older people: A
consultation. Response from the Chartered Institute of Housing
Scotland
Introductory comments
The CIH very much welcomes the development of a strategy that reflects the
particular issues faced by Scotland in providing homes for those in later life. We
have been pleased to play a part in this development through the Wider Planning for
an Ageing Population Working Group and also through our Action Plan for Older
People’s Housing1 and look forward to continuing to work with the Scottish
Government in this important area of work.
There is no doubt there is an ever increasing need for a strategic focus on housing
and ageing. Well rehearsed statistics provide clear evidence of the ageing population
time bomb and that the current approach is unsustainable. Something must be done
to target prevention and support approaches for older people before the crisis hits
and an even greater burden is placed on health and social care budgets. Alongside
this we operate in an ever changing landscape, which is currently one of severe
public spending constraint and fluctuating markets.
It is in this extremely challenging context that the Scottish Government has set itself
the target of developing and delivering a 10 year housing strategy for older people,
and is to be commended for doing so.
In general we agree with the aims and purpose of the draft strategy and our
comments seek to support these and to enhance its robustness where we feel this is
needed.
It is an understatement for us to note that the strategy does not have all the solutions
to the massive challenges of our ageing population. Whilst the document is clear that
traditional service models cannot continue in the current financial climate, at present
there do not seem to be a wide range of alternative options on the table. Over time,
there may need to be a more open recognition that future generations of older
people may not be able to depend of the state for provision of housing and support
or care, though we accept that we are some way from teasing out the implications of
this.
Also, with some reluctance we recognise that in light of the Scottish Government’s
concordat with local government, some aspects of the strategy may now be outwith
the Government’s control and could be especially challenging for local government
to deliver on in the context of competing priorities for limited funding.
We do agree with the comments raised in Age Scotland’s consultation response2
that little attention has been paid to the particular issues faced by older people living
in rural and remote communities. We would add to that appropriate reference should
be made to the particular needs of older people from BME communities, perhaps
especially in relation to the provision of information and advice on housing options.
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2
http://www.cih.org/scotland/policy/AP_OP-June09.pdf
http://www.ageuk.org.uk/PageFiles/17685/110818%20Age,%20Home%20and%20Community%20Ful
l%20Response.pdf?epslanguage=en-GB-SC
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We believe that many of the intended outcomes for achievement by 2021, whilst
laudable in their intention and ambition, may be difficult or even impossible to
measure. We trust that appropriate advice will be sought from Scottish Government
colleagues dealing with analytical services and statistics to ensure that the outcomes
are measurable.
Our comments on the draft strategy
Introduction to the strategy
Achieved outcomes and actions will always be more meaningful than strategies
themselves, important though these are as overall expressions of intent. There is
perhaps a tendency within all governments to take comfort in the aspirations and
bold statements contained within strategies. The reference to the importance of
housing as expressed in the Reshaping Care for Older People strategy contrasts
significantly with the reality that there has been little engagement of housing
organisations in the initial stages of the Change Fund.
Similarly, the document perhaps over-plays the significance of the commitments
made in Homes Fit for the 21st Century: the commitments on the national register of
accessible housing and on simplifying access to adaptations are tangible actions and
very welcome. But a commitment such as “ensuring needs of older and disabled
people are better reflected within national and local planning and housing investment
processes” has a grandness which does not offer the same reassurance that there
will be a clear result or impact.
Commitment 1 – clear strategic leadership
Local Housing Strategies
The document refers to the importance of local housing strategies and the need for
them to be more integrated with local health and social care planning. Again these
are grand aspirations but much needs to be done before this can be achieved. For
much of the past 20 years or more, the housing needs of older people have largely
been defined in the context of the need for specialist housing or housing with care.
With changes in the nature of specialist provision such as sheltered housing, and the
relative lack of new build specialist provision, there is in many senses a gap: what
should local housing strategies now say about the housing and related needs of
older people? This looks like an issue on which guidance might be welcomed,
particularly by local authorities. There are links between this issue and the issue of
the suitability for older people of new mainstream housing, which is addressed under
Commitment 4 (investment in new housing provision).
The Change Fund and the involvement of “housing”
The fact that there is little early evidence of housing related services featuring in bids
to the Change Fund is not a surprise to CIH. We see two issues here. Firstly, the
prominent role of Community Planning Partnerships in the Fund is particularly
problematic in relation to housing. The overall effectiveness of CPPs varies markedly
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from one area to another but we know of few areas of Scotland where the housing
sector feels it is properly engaged with the CPP.
Related to this, the second issue is the broader and long-standing challenge of how
“housing” can engage more meaningfully with health and social care agendas and
processes. CIH believes that a fundamental barrier to this is the disparate nature of
“housing”: whilst the NHS and the local authority social work department are single
corporate bodies, the housing sector (rather like the third sector) is made up of a
range of bodies – primarily the local authority (whether or not it has its own stock)
and housing associations. In many parts of Scotland it has never been easy for the
housing sector to find a collective way of being a meaningful partner: one option
might have been for the local authority, in its strategic housing role, to harness the
voice of the housing sector as a whole. There may be some areas where this has
happened to a degree, but generally, housing remains as a collection of
organisations with whom it is not easy for health and social work to know how to
engage effectively.
What this might mean for the Scottish Government is a greater sense of realism in
what can be expected of housing’s engagement with health and social care agencies
and vice versa. That engagement should of course still be encouraged but perhaps
with a greater recognition of the practical barriers.
Demonstrating the case for housing and support
It is not 100% clear whether the commitment to “identify the case for investment in
housing and related support” is about physical housing provision as well as housing
support provision. We think it is intended to cover both, and very much welcome this
because, as mentioned earlier in this response, the focus on mainstream rather than
specialist housing provision has meant a lack of clarity over what is and is not
suitable for older people.
Commitment 2 – Information and Advice
Housing options approach
We very much welcome the commitment to pilot the housing options approach for
older people. Whilst the wider application of the housing options approach has been
well promoted by the Scottish Government and bodies such as CIH, its origins have
very much been in homelessness prevention, and it is clear that a different approach
would be needed for older people. It will also need local authorities in particular to
feel able to prioritise advice provision for people who are for the most part not in
crisis, and that may be something we cannot take for granted as councils grapple
with the pressures of the current financial climate. For this reason, central funding –
as with the existing housing options hubs – may well be needed as a catalyst.
It should also be recognised within the strategy that the information, advice and
awareness raising of issues affecting older people and the choices they make is not
just a matter for older people. As well as not being a static group, if the prevention
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approach is to be successful, people should be aware of the choices facing them
before reaching old age.
Commitment 3 – Better Use of Existing Housing
Adaptations
We welcome the ongoing work to look at how adaptations are delivered. Looking at
funding of adaptations across the tenures will not be easy, given the very obvious
differences between the arrangements for council and housing association tenants
respectively. Whilst funding issues may be tricky to resolve, what should be more
achievable is to ensure that assessment of individuals’ need for adaptations is
consistent across tenures.
We welcome the development of a Scotland-wide register of accessible housing and
are pleased to be members of the working group overseeing its development.
We do, however, have one caveat in relation to this indicator:

‘By 2021. We expect/aim, to reduce the proportion of people who say that
they need an adaptation in their home’.
In our view this may not be a fair measure and may be counter-intuitive to ‘shifting
the balance of care’. If the provision of information and advice is successful, it is
possible that more older people may say they need an adaptation to their home, and
so measuring a failure here may reflect success elsewhere in the strategy.
Repairs to owner occupied property – trusted trader schemes
The development of “trusted trader” schemes across Scotland was expected to be
one outcome of the Scottish Government’s work related to implementation of the
2006 Act and, in particular, the scheme of assistance. It does not appear that a lot of
progress has been made on this, but it might be helpful if the document made an
explicit reference to the fact that most, if not all, Care and Repair schemes operate a
form of trusted trader information for older people.
Helping older people to move home
We welcome the commitments on facilitating advice and support for older people
wanting to move. However, in encouraging social landlords to introduce packages of
support and assistance to facilitate moving, we would also recommend guidance be
provided to landlords to help minimise ‘packages’ that encourage coercion by others
(such as relatives), an experience some landlords have had when introducing cash
incentives, We would also ask, though, whether the aim “to reduce the proportion of
older people who say they want to move…” is properly measurable.
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Existing sheltered and supported housing
We welcome the commitment to prepare a practical guide to the redevelopment of
existing sheltered housing, and to provide “practical advice” on the development of
supported housing.
Personal resources and investment in housing
We would add a health warning to the otherwise welcome intention of the Scottish
Government to explore whether more attractive equity release products can be
identified. Even discounting recent severe difficulties in the housing and lending
market, pure actuarial arithmetic makes attractive equity release products all but
impossible to develop on a commercial basis. Contrary to what the document says, it
is not just perceptions about equity release products which act as a barrier to takeup: even well reputed products, such as some annuity-based “home income plans”,
offer what many older people consider to be a disappointing return. But as people
are living longer, this is only going to affect such products detrimentally. And if no
attractive products could be developed when lending practices were less regulated,
there seems little chance of more attractive products being developed in the new
climate of “responsible lending” which we assume is here to stay.
The aim “to help more older people use their personal resources to make
improvements to their home and support arrangements” may therefore be overambitious, as well as possibly being difficult to measure.
Commitment 4: New Build Housing
New specialist housing provision
It seems significant that this part of the document says little about the need for
specialist housing for older people. This might partly be addressed by cross-referring
to commitments in the previous section about providing advice on the provision of
new supported housing, but some reference to the issue is needed in this section
too. This should include a statement about where specialist provision sits with the
new funding regime and, in particular, the Innovation and Investment Fund with its
greatly reduced grant rates.
New mainstream housing provision
We are anxious about the suggestion that Housing for Varying Needs standards may
no longer be relevant now that the Scottish Building Standards have been enhanced
further. We do welcome, though, the undertaking to examine the issue in detail, as
we believe a close examination of what HVN standards offer over and above the
Building Standards is an essential precursor to any dismissing of the standards. We
have particular concerns relating to any reduction of the ‘barrier free’ concept that
applies to HVN.
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Commitment 5: Preventative Support
This section chimes clearly with the findings of the Christie Commission in its report
on the Future Delivery of Public Services, which states a key objective of reform
should be to ensure that public service organisations “prioritise prevention, reduce
inequalities and promote equality”3 and focus on preventative spending
There is no doubt that preventative support is key to reducing the need for costly
health and care provision and critical to the success of this strategy. However, we
would argue that the indicators:
 By 2021, we want housing support services to be available in all areas of
Scotland and offered by public, private and third sector organisations
and
 By 2021, social landlords will play a central role in sustaining communities
which support local older people and disabled people
are simply stating the status quo, not challenging or improving on it, and are not
ambitious enough to sit within a 10 year strategy. Perhaps the intention of these is
not clear and need to be rephrased?
Handyperson services
The indicator on the cost of this service and the desire for it not to act as a
disincentive has the potential to cause some difficulties for landlords, particularly at a
time of reduced grant levels and as surpluses are focused on SHQS and contributing
towards new build developments. We would argue that, whilst it is undoubtedly a
challenge, the focus here should be on older people recognising the value of the
service provided and, where they are able to, paying the charge accordingly.
3
http://scotland.gov.uk/Resource/Doc/352649/0118638.pdf
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