Temporary Accommodation Placement and Procurement Policy

Outline of the Temporary Accommodation Placement and Procurement Policy 
Temporary Accommodation Placement 
Legal Framework
Key Principles 
Suitability of Accommodation 
Refusals of accommodation by the household 
Service Intervention and Temporary Exclusions 
Temporary Accommodation Procurement 
Estimating and meeting need for homeless households 
Procurement Principles 
Appendix One - WFDC Bed and Breakfast Reduction plan 2024 - 25 
Appendix Two - Suitability Checklist 

Outline of the Temporary Accommodation Placement and Procurement Policy

The purpose of this policy is to outline the council’s approach to managing and procuring Temporary Accommodation (TA).

TA describes a range of different types and tenures of residential unit but is solely used in connection with the prevention of homelessness. The accommodation can be used to fulfil the council's homelessness duties in line with the legislation as well as a discretionary duty to accommodate or accommodation provided under a government scheme such as the Homes for Ukraine or the Afghan Citizens Resettlement Scheme.

The first part of the policy considers the legal framework around the placement of households in TA including recent case law and how we make decisions around suitability and making placements including under the discretionary duty. The policy also considers what is a reasonable period of time when ending a placement and the use of immediate temporary and permanent exclusions.

The second part of the policy considers how we procure TA and some of challenges and principles around this.

Temporary Accommodation Placement

Introduction

This section sets out Wyre Forest District Council’s policy towards the placement of homeless households in temporary accommodation. It covers all offers of temporary accommodation made under any of the provisions of the homelessness legislation, which are set out in Part VII of the Housing Act 1996 (as amended) and the HRA 2017 and is guided by the Homelessness Code of Guidance 2024. This policy does not apply to final offers of accommodation to discharge the main homelessness duty made under either Part VI or part VII of the Housing Act 1996 (as amended) or the HRA 2017.

Background

Local authorities have a statutory duty to provide temporary accommodation in their own area so far as is reasonably practicable (para 17.52 Code of Guidance 2024 (Homelessness code of guidance (publishing.service.gov.uk)) and statutory guidance requires councils where possible to try and secure accommodation as close as possible to where an applicant was previously living although not being constrained by the preference of the applicant. The council is also required to consider the suitability of any accommodation offered (Chapter 17 Code of Guidance 2024).

There has been a steady increase in homelessness applications over recent years and since the implementation of the HRA 2017 (which came into effect in April 2018).  In 2022/23 the number of homeless enquiries was 988 but subsequently rose 15% to 1143 in 2023/24.  This has created pressures on providing sufficient suitable accommodation in the district to households owed an accommodation duty.

The graph below shows the number of presentations of homeless or potentially homeless households over two financial years (2022/23 & 2023/24). Although overall homeless numbers (where we owe a duty) remain stable (2023-24 there were 2225 approaches and 2022-23 there were 2232 approaches) the length of stay for households placed in temporary accommodation has increased. There has also been a greater percentage of single people households being accommodated since the Homelessness Reduction Act 2017.

Homeless approaches 2022/23 and 2023/24

Temporary Accommodation Usage (2022-23 and 2023-24)

Average Number of Days in Bed and Breakfast (B&B)

The council currently has access to the following range of options for Temporary Accommodation (TA):

• Properties leased by the council from private landlords through our Private Sector Leasing Scheme (6 units – mix of 1 and 2 bedrooms)
• Properties the council own outright (12 units – mix of ensuite bedrooms and 2 bed flats).
• A small number of units of accommodation owned and managed by Registered Providers (RPs) (12 bedspaces in four shared houses)
• Spot-purchased and procured private B&B rooms with some shared facilities (i.e. kitchens)
• Spot purchased ensuite rooms in hotels
• Specialist Domestic Abuse housing including women’s refuges (11 bedspaces) and “safe” accommodation in 3 self-contained properties owned by an RP
• Crash pad in RP accommodation for young people or rough sleepers (3 bedspaces in two schemes)
• Council owned property for Afghan households that can also be used as TA if no demand (1 x 4 bed house)
• RP owned properties for Afghan / Ukrainian households that can also be used for TA if no demand (5 properties, mix of 2 and 3 bed)

Legal Framework

We are bound by the legislative framework in the operation of the homelessness service at Wyre Forest District Council. This policy has been developed in accordance with the relevant sections of the following legal and statutory guidance material:

• S188 Housing Act 1996 (As Amended)
• S193 Housing Act 1996 (As Amended)
• S208 Housing Act 1996 (As Amended)
• Equality Act 2010
• Homelessness Reduction Act 2017
• The Homelessness (Suitability Of Accommodation) (England) Order 2003
• The Homelessness (Suitability Of Accommodation) Order 2012
• Localism Act 2011
• S11 Children Act 2004
• Homelessness Code Of Guidance For Local Authorities 2024
• Care Act 2014
• Associated Case Law

Wyre Forest District has a duty to provide temporary accommodation for households who approach the council as homeless and who meet the criteria as set out in Part VII of the Housing Act 1996 (as amended by the Homelessness Reduction Act 2017). Under certain sections of the Acts, councils have a duty to provide short-term accommodation placements whilst homelessness enquires are undertaken. The legislation also sets out duties to provide longer-term temporary accommodation placements for certain households depending on their circumstances. Within this document placements under all the above provisions will be referred to as temporary accommodation placements.

Supplementary guidance to the homelessness changes introduced by the Localism Act 2011 and the Homelessness (Suitability of Accommodation) Order 2012 (DCLG November 2012) states the following:

“Where it is not possible to secure accommodation within the district, and an authority has secured accommodation outside their district, the authority is required to take account of the distance of that accommodation from the district of the authority. Where accommodation which is otherwise suitable and affordable is available nearer to the authority’s district than the accommodation which it has secured, the accommodation which it has secured is unlikely to be suitable unless the authority has a justifiable reason, or the applicant has expressed a preference.”

Nzolameso v Westminster City Council – This is the key piece of case law regarding TA procurement and placements. It sets out a range of issues that councils need to consider when allocating temporary accommodation to homeless households and makes certain requirements of councils. These include;

• A requirement that local authorities need to explain their decisions as to the location of the properties offered.
• Each local authority should have, and keep up to date, a policy for allocating temporary accommodation to homeless households.
• The policy should reflect the authority’s statutory obligations under both the Housing Act 1996 (as amended) and the Children’s Act 2004.
• Where there is an anticipated shortfall of accommodation in the district, the policy should explain the factors to be considered when making decisions on where a household is placed.
• The Supreme Court also proposed that each local authority should have a policy for procuring sufficient units of temporary accommodation to meet anticipated demand for the coming year.

Additional case law in relation to this matter is R (G) v Southwark LBC [2009] UKHL26 with reference to S.20 of the Children’s Act 2004. Case law supports the precedence of the Children’s Act over the Housing Act for 16- and 17-year-olds.

All the Worcestershire councils operate a joint protocol regarding this client group that fall under the Housing Act and the Children’s Act, ensuring that in the first instance any 16 or 17-year-old presenting as homeless alone and not as part of a household is jointly assessed in the initial instance by Children’s services and housing. A local authority can only accept a homeless duty towards a 16–17-year-old once care by children’s services has been rejected, as that is the proper primary agency for that age group. In certain circumstances, a 16 or 17-year-old will go on to make a homeless application and the council will take on responsibility for providing the young person with accommodation, such as pending a joint assessment and if a young person is in need but does not accept care by children’s services.

In Worcestershire this is achieved through co-operation and joint working between the county council and the districts, to ensure that young people do not ‘fall through the gaps’ and are not passed back and forth between agencies.  Any 16 or 17-year-old presenting as homeless alone and not as part of a household will have a joint assessment arranged between housing and children's services. The local authority can only accept a duty towards a 16–17-year-old once they have rejected section 20, as that is the proper primary agency for that age group.

Birmingham City Council v Ali, Moran v Manchester City Council [2009] – In this case the court observed that ‘what is regarded as suitable for discharging the interim duty may be rather different from what is regarded as suitable for discharging the more open-ended duty in section 193(2).’ This confirms the Code of Guidance’s approach that accommodation which would not be considered to be suitable for a household in the long term may be suitable for that same household in the short term.

Key Principles

Initially the council will try to extend the length of time a household can remain in their current home, find them an alternative suitable home or explore whether family and friends can also provide short term or longer term accommodation.

Wyre Forest District Council transferred their housing stock some 24 years ago, whilst the council does have agreed nomination rights with Community Housing Group within the transfer document and other Registered Providers through s106 agreements this has still meant some limitations on available options to address move on accommodation. This situation has presented an opportunity for the council to seek other solutions for move on accommodation including schemes and incentives for clients to move to the Private Rented Sector.

Whilst the council is using these opportunities to deliver medium to long term accommodation options for homeless households, the pressure on short-term solutions remains, the council seeks to use procured B&B and nightly paid placements for the minimum period possible due to the costs attached and the lack of security and longevity for the households accommodated.   As such this type of accommodation is primarily used when it is required for outside of normal office hours or at very short notice, households accommodated under ‘No First Night Out, Severe Weather Emergency Protocol (SWEP) or households who have recently made an application as homeless whilst enquiries are carried out into what, if any, ongoing duty may be owed to them.   It is regrettable that we have only limited access to ‘out of hours’ accommodation (usually only B&B and nightly paid placements), and in certain circumstances this may lead to out of district offers being made due to lack of accommodation within district being available.

The Housing Advice Team seeks to move all households placed in this type of accommodation into more settled temporary accommodation as soon as possible and uses a combination of council owned and RP owned managed temporary accommodation which deliver some level of support, the council also leases private properties that the council manage for this purpose.  It should however be noted that there will be exceptions to this based on the specific needs of the applicant and the availability of accommodation.

For young people approaching as homeless that have no family or friends they can stay with, they are most likely to be offered some form of supported accommodation including the ‘crash pad’ at St Basils Foyer supported accommodation or shared housing. For Care Leavers Worcestershire has a Joint Protocol.  The lead authority for 16 and 17-year-olds who present as homeless is the Children’s Social Care Authority in line with the Southwark judgement (R(G) v Southwark LBC in May 2009). However, if the local housing authority is under a duty to provide a 16 and 17-year-old with accommodation, any accommodation provided must be suitable. The Secretary of State considers that Bed and Breakfast or shared accommodation is never suitable under any circumstances for this category of applicants as set out in the statutory guidance (Prevention of homelessness and provision of accommodation for 16- and 17-year-old young people who may be homeless and/or require accommodation 2018). As such, the council works closely with Worcestershire County Council with the aim of avoiding the need for any such placements.

Victims of Domestic Abuse are very unlikely to be offered Bed and Breakfasts or HMOs as this accommodation is insecure and unsupported and would therefore be deemed unsuitable, the Domestic Abuse Act 2021 along with the Homeless Code of Guidance clearly states what the council need to provide in terms of safe and secure temporary accommodation Wyre Forest District Council have a number of ‘safe accommodation’ units including a Refuge and accommodation procured via Community Housing and utilised by the council, that are supported by a dedicated Domestic Abuse Housing Officer.  

In some exceptional circumstances households may also be housed into self-contained temporary accommodation (privately leased by the council or RP owned) prior to a decision being made if this accommodation is deemed to be most suitable due to the circumstances of the household.

In accordance with legislation, case law and statutory guidance, the council seeks to accommodate homeless households within the district as far as is reasonably practicable, and as close to where they were previously living as possible, unless the applicant’s choice is to move further afield. However, as there is a shortfall of temporary accommodation to meet housing need, it will not always be practicable to provide accommodation to homeless households close to where they were previously living. There will be a need to use accommodation outside the district.

There are occasions where demand for temporary accommodation exceeds the number of available self-contained units, or there are other constraints in finding suitable self-contained accommodation. In these circumstances, if there is a duty to accommodate a household, the council will, as a last resort, place a household in accommodation with shared facilities such as B&B / hotel / guest-house accommodation but in compliance with the Code of Guidance 2024 (recognising the 6 week requirement in such accommodation for pregnant women and households with dependent children).

The Housing Advice Service will assess the suitability of every offer of accommodation that is made to individual homeless households, in line with legal requirements including legislation, associated case law and statutory guidance (such as the Suitability of Accommodation Order 2012). We will take account of all relevant factors when assessing the suitability of temporary accommodation regarding size, location,

accessibility and facilities. When assessing the suitability of location for temporary accommodation regard must be had to the Homelessness Code of Guidance 2024. This states that the Temporary Accommodation must be suitable in relation to the applicant and to all members of their household who normally reside with them, or who might reasonably be expected to reside with them. The guidance sets out the factors that should be considered when deciding whether the accommodation is suitable or not. Households have the right of review on the suitability of accommodation if they are owed the ‘full’ homelessness duty. (See Appendix Two – Suitability Checklist).

If it is not possible to provide temporary accommodation within the district, accommodation will be offered in a neighbouring housing authority area wherever possible, considering the distance of that accommodation from where the applicant was previously living. The council will only look beyond a neighbouring housing authority area if it is not possible to provide anything suitable and/or the applicant has very specific needs which cannot be met within Wyre Forest District or a neighbouring housing authority area. If this should prove necessary, the council will endeavour to provide accommodation with good transport links to the area where the applicant was previously living if essential for employment, education or support needs. Households placed outside the district may be considered for temporary accommodation within the district once a suitable unit becomes available, subject to their needs being assessed alongside the needs of other households who are owed a duty at the same time.

For interim and temporary accommodation placements, where there are multiple households with a priority for being placed inside the district but are accommodated outside the district (due to a lack of accommodation) or conversely if there is sufficient capacity to move households without a priority for accommodation in the district into the local area, priority for moving households back to the district will be for WFDC officers responsible for placing to determine based on: -

• The needs of the households
• The length of time that the households have been placed outside of the district.
• The suitability of the household’s current accommodation
• The effect of the placements upon the households
• Whether a duty is likely to be accepted to the households based on the evidence available
• If a duty has been accepted, the length of time expected for households to be made a permanent offer of accommodation (factors such as whether the applicant has a reduced preference on Home Choice Plus or is being skipped by RPs or is otherwise difficult to rehouse and how long they have held their banding)

The criteria for prioritising include: -

• Households with one child (or more) in secondary school at ‘key stages’ of education e.g. in GCSE exam year
• Households containing one child (or more) who has a statement of special educational needs who are receiving education or educational support at a local school int the district and where a change to another school or learning establishment would be detrimental to their continuing development.
• Where a child has been assessed as being a Child in Need under Section 17 of the Children Act 1989 by Children’s Social Care and where that need is in additional to their need of accommodation and where it can only be met through the provision of accommodation in the district.
• Households with significant disabilities or medical needs, including mental health, where their health or welfare may be significantly adversely affected by moving out of the local area, as assessed by the responsible housing officer. This may include:
  • The applicant needs to live in a particular area to receive care.
  • The applicant is in receipt of a significant care package or receiving specialist healthcare that cannot be transferred elsewhere.
  • The applicant has a severe and enduring mental health problem where a transfer would severely impact on the ability to engage with treatment.
• Households where one person (or more) is in permanent and settled employment for at least 6 months prior to the homeless application and they would not be able to reasonably continue their employment if placed outside the area.
• Households where a member of the household is providing a significant amount of care for another person in the district who falls into one of the following categories: -
  • Over 75 years old and living alone or with no other member of the household under 75 or
  • In receipt of medium or higher rate of the care component or mobility component of the Disability Living Allowance, Personal Independence Payment, Attendance Allowance or War Disablement Pension
  • And the household would be unable to provide care, or unable to provide care to a sufficient degree if placed out of the area considering transport links and the care cannot be provided by another person or agency.
• Any household, which for any other special reason, needs to be placed within the district as its needs cannot be met or transferred to another area and the effect of a placement outside of the district would be significant and detrimental.

Applicants will be made one offer of suitable temporary accommodation which will comply with all of the considerations set out within this policy. There is no obligation to enable applicants to view the accommodation prior to acceptance, and in most cases, this will not be practically feasible, but the council will facilitate this in exceptional circumstances where there is a special need to do so. In making the offer of accommodation, the household’s individual circumstances will be considered, as well as demand and our criteria on out of district placements.

Suitability of Accommodation

Due to increasing pressures of homelessness, it will not always be possible to place households in ideal accommodation. WFDC will take all reasonable steps to ensure that the accommodation it offers is suitable. However, there will be occasions where WFDC is able to satisfy some of the below criteria, but not others. In such circumstances, it is for the WFDC’s housing officer responsible for placing the household to decide, based on the individual merits of the case, which factors should hold more weight whilst ensuring they comply with the council’s statutory duties.

The following must be considered; the Housing Act 1996 as amended by the Homeless Act 2002, Homelessness (Suitability of Accommodation) (England) Order 2012 (SI 2012/2601), Homelessness Reduction Act 2017, Localism Act 2011, Section 1 of the Children’s Act 1989, Section 11(2) of the Children’s Act 2004, The Local Code of Guidance for Local Authorities 2006, Supplementary guidance on the homelessness changes in the Localism Act 2011 and on the Homelessness (Suitability of Accommodation) (England) Order 2012  and any subsequent guidance, relevant statutes and case law.

Factors to be considered when making placements (suitability)

The council has a discretionary duty to accommodate in a number of circumstances, including but not limited to, when an applicant requests a review of a negative decision.

Factors to be considered when deciding to offer Discretionary Accommodation

Factors to be considered when determining reasonable period of time

The council has a duty to provide interim accommodation when conducting homeless investigations. Where the council decides that applicants placed in temporary accommodation whilst enquiries are being carried out are not owed an ongoing housing duty (because of a non-priority or intentional decision), they will be asked to leave and will be given reasonable notice to vacate the property to enable them to secure their own accommodation. The length of that reasonable notice period will be determined on a case-by-case basis and will take account of the circumstances of the household.

Refusals of accommodation by the household

If an applicant rejects any offer of temporary accommodation provided under any duty, they will be asked to provide their reasons for refusal. This applies to new applicants, as well as those seeking a transfer from existing temporary accommodation, and those in temporary accommodation who are required by the council to move. The reasons given will be considered and any and further enquiries undertaken as necessary. 

If the reasons for refusal are accepted, the offer will be withdrawn and a further offer will be made if a suitable alternative unit of accommodation is available. In some circumstances there may be only one unit of accommodation available on a given day and so no alternative will be offered until something suitable becomes available.

Any placement made whilst enquiries are being undertaken (under s.188 of Part VII of the Housing Act 1996 (as amended)) provides no security of tenure to the applicant and the placement can be terminated with immediate effect. There is no right of appeal against the suitability of accommodation offered to applicants under this section (although they can apply for judicial review through the courts).

Where a household is owed the ‘full’ homelessness duty, which is an ongoing accommodation duty, and the household refuses a suitable offer of temporary accommodation, if the council does not accept their reasons for refusal, applicants will not be offered further accommodation and will be required to make their own arrangements. However, applicants owed this duty may ask for a review of the decision that the accommodation offered to them is suitable.

An applicant may request a review as to suitability regardless of whether or not they accept the accommodation. This applies equally to offers of accommodation made to discharge the ‘full’ homelessness duty and to offers of an allocation of private or social rented accommodation that would bring that duty to an end. There are four possible scenarios if a review is requested:

1. The applicant accepts the offer and requests a review, and the review is successful. In this situation an alternative offer of accommodation will be made.
2. The applicant accepts the accommodation and requests a review, and the review is not successful. In this case no further offer of accommodation will be made but the applicant will be able to continue to occupy the accommodation.
3. The applicant refuses the offer of accommodation (i.e., they do not move into it) and requests a review, and the review is successful. In this situation a further offer of accommodation will be made.
4. The applicant refuses the offer of accommodation (i.e., they do not move into it) and requests a review, and the review is not successful. In this case, no further offer of accommodation will be made.

It is important to note that in either in scenario 3 and 4 above, accommodation pending the outcome of the review may or may not be provided. Each case will be assessed on its merits and in line with the principles set out in the primary case law in this area, which is Camden vs Mohammed (R. Camden L.B.C., ex p. Mohammed. 30 H.L.R) which include the overall merits of the review request, any new information or evidence that may affect the original decision, the personal circumstances of the applicant and the potential impact of the loss of accommodation. Should the outcome of the review determine that the original offer was suitable, the homelessness duty will be discharged.

It is important to note that units of accommodation cannot be held empty for applicants pending review due to the overall demand for temporary accommodation compared to supply. As such, if an offer is refused, the unit will be offered to another household and not held over.

Service Intervention and Temporary Exclusions

Introduction

The purpose of this policy is to give guidance to officers dealing with residents of temporary accommodation who are not complying with the responsibilities of occupation. This can be used to help someone manage their emotions and behaviour and is used when an individual feels unsafe to the community they are part of or that community is being is being disrupted. 

The process must always include an explanation as to why the intervention is necessary, what happened and what is required to prevent an escalation or a repeat of the behaviour.  Whenever possible, this must be done face- to- face in a safe environment and the resident to be given details of the intervention in writing which where possible they will sign.  Any meetings must be followed up with full record keeping, including a copy of any paperwork, stored on Home Choice Plus with an incident report completed if required. 

There are four service interventions, and they are hierarchical.  Escalation from lower to higher interventions is preferable, however it is acknowledged that this is not always possible or necessary.

The four interventions are:

Verbal Warnings

A verbal warning is the lowest intervention available. It requires discussion with the Senior Housing Advice or Senior Housing Project Officer before it is given.  There are no preset numbers of verbal warning that are necessary to be given before execution to a higher intervention.  Details of any verbal warnings must be noted on Home Choice Plus including the outcome and if an incident form was completed. 

Written Warnings

A written warning is the second level of intervention. It can be used for a number of more serious circumstances where a written record is needed for the benefit of the resident or WFDC.  The important aspect of a written warning is they are always discussed with the resident and an explanation is given and help and support from staff is given to enable the resident to identify triggers to enable them to control their emotions and behaviour.

Written warnings must be signed by the resident to say they have received it unless there is a compelling reason why this is not possible, a copy must be stored on Home Choice Plus with a note to include the outcome and an incident form if completed. Before a written warning is issued it must be reviewed and agreed by a senior officer//line manager as this could lead to the service of a formal notice if behaviour continues.

Immediate Temporary Exclusion (reviewed within a 12-hour working window)

This intervention is likely to be used where there is an incident that requires an immediate response.   Often used where there has been, or there is likely to be, a menace to other residents, staff, or wider community.  Immediate service suspensions are always subject to a review within 12 hours, this review will be completed by a senior officer/ /line manager and the officer who served the suspension.

When using the time-based suspension approach above, staff need to consider the implications for the resident, if in other respects the resident is doing well in temporary accommodation, for example attending appointments, reducing, or ceasing to misuse substances/alcohol etc. then excluding them from accommodation may encourage them to return to rough sleeping/sofa surfing and substance misuse.  Suspensions should be for as short a period as possible and isnt a permanent ending of the license or the s188 duty to accommodate. However, staff may feel that a short accommodation suspension will work to allow the resident to reflect on their behaviour and manage their emotions. Officers will need to consider implications of following this course of action on any Housing Benefit or service charges and whether alternative discretionary accommodation should be provided while the matter is reviewed.

Permanent Exclusion

Permanent exclusion is the highest sanction and differs from temporary suspension in that the resident is not allowed to re-access the service.  This decision should only be made with the agreement of a senior officer//line manager and the officer who will serve the notice to quit. 

Before issuing a notice to quit it is important that we have a clear understanding of the reason for the exclusion and all facts and information are gathered and captured in a clear and accurate manner, ensuring a senior officer//line manager are part of the process will allow this report to be reviewed and checked for accuracy.

This report must be part of the decision process and added to as events, facts and information come to light.  This is very important as it will form the basis for any evidence in case of a complaint, right to review the decision (if accommodated under the s193, Housing Act 1996 duty) or judicial review.  Consideration should be given and clearly noted in the report that the officer has given regard to both the Equality Act 2010 and the Human Rights legislation where they action denies the person a home. The manager or senior should consult with legal regarding the legality of serving the notice.

Temporary Accommodation Procurement

Introduction and Scope

This part of the policy sets out:

• The challenges facing the council in procuring accommodation for homeless households to discharge the council’s homelessness duties
• An estimate of the number of properties that are needed for these purposes
• The general principles that will be followed when procuring private accommodation for homeless households.

Temporary Accommodation takes the form of two types of accommodation:

1. Shorter-term accommodation for use during the relief stage of homelessness and whilst a household’s homelessness application is being assessed. This could be self-contained or shared accommodation, either through a private landlord arrangement, through a Registered Provider, or within the council’s owned and managed stock.
2. Longer-term accommodation for households where the council has accepted an ongoing accommodation duty. This accommodation is provided until a suitable offer to discharge that duty can be made.

Types of Accommodation

The council’s approach has been to reduce the number of units procured in Bed and Breakfast, Guest House or Hotel style accommodation as this is recognised as having impacts of the households health and wellbeing as well as being the most expensive form of provision. The council has developed an action plan aimed at reducing the use of Bed and Breakfast and this is included at Appendix One.

Procurement Challenges

As part of the council's Bed and Breakfast Reduction Plan and Worcestershire Homeless and Rough Sleepers we are working to reduce the demand for temporary accommodation through increasing the number of households prevented from becoming homeless. However there will always be a requirement to place some households.

The council’s temporary accommodation portfolio comprises a range of provision including procured and spot-purchased ‘nightly paid’ accommodation from Bed and Breakfasts providers. Spot purchasing accommodation does make it more difficult to get a reduced nightly rate for accommodation and doesn’t guarantee vacancies being available when required. Bed and Breakfast providers have these types of arrangements with a number of councils meaning there is no way of controlling who else is in the accommodation. The cost to the council of this type of accommodation in 2023/24 was £134,335.

The council works with private sector landlords to provide accommodation through leasing arrangements. The council offers landlords two year leases and guarantees the rental payment in return for a self contained property on a repairing lease. We council negotiates as low a rental payment as possible but can only charge rent at the 2011 homeless accommodation level less 10% or loses subsidy. This arrangement also means the council pays the rent even when the property is vacant. The costs to the council of this type of accommodation in 2023/24 was £20,455.

The council also utilises accommodation provided by Registered Providers (RP), which aren’t formerly leased but the council secures nomination rights through offering the RP grant funding or service level agreements where the rent is guaranteed. Grant funding has previously been between £30 – 40k although recent funding through the Local Authority Housing Fund covered 40% of the open market value plus £20k. The costs to the council of this type of accommodation in 2023/24 was £660.

All local authorities are generally finding temporary accommodation increasingly difficult to procure to meet a growing demand. Landlords and Bed & Breakfast providers are becoming reluctant to let to households on benefits or low incomes and added to this a number of other agencies are now pursuing the same landlords and Bed & Breakfast providers for the same accommodation to house their cohort of clients and normally these agencies are able to offer much better terms and finance packages such as accommodation for asylum seeker dispersed accommodation and CAS3 accommodation for prison leavers. This is combined with a very competitive open market, due to the difficulty and cost in purchasing a home and it is clear to see how difficult it is becoming to procure good quality temporary accommodation.

Estimating and meeting need for homeless households

Demand for all forms of temporary accommodation remains high. The results below compare Quarter 4, 22-23 and Quarter 4, 23-24, in terms of the number of people accommodated in Temporary Accommodation, No First Night Out (NFNO) and Shared Houses (ESD’s).

The graph shows that the council have increased their use of TA compared to the same quarter last year by 32%. NFNO has increased by 8%. Shared houses (ESD’s) have seen an increase in use by 20%.

In recent years temporary accommodation demand has risen considerably and as such the council have a number of initiatives to address this whilst working to drive up standards and offers, these include the introduction of a Housing Officer who specialises in prevention working with households and single people when they are threatened with homelessness to prevent them having to leave their existing accommodation or if that is not possible to move them into sustainable accommodation before they are homeless.

The council operates a well-established Rent Bond Scheme which works with landlords and letting agents to prevent and relieve homelessness and source sustainable accommodation for households and single people, this work is helping to increase the number of households and single people who are prevented from becoming homeless. 

The council will work to manage the throughput of temporary accommodation more effectively working to ensure the reduction of need and keep length of stay and ensure voids periods for procured units are reduced.

The council has developed a Bed and Breakfast Reduction Plan to reduce the demand through prevention, increasing the supply of alternatives to Bed and Breakfast provision by recruiting more landlords and letting agents to our Rent Bond scheme and growing our Social Letting agency and developing our own temporary accommodation provision at Castle Road, Millpond House, and well as supported move on accommodation in Kidderminster. 

The average number of households requiring temporary accommodation is approximately forty. The council’s direct provision and procured accommodation should aim to meet this requirement with the ability to draw down additional accommodation in the most cost effective way.

Procurement Principles

The council will follow the key principles outlined below when seeking to procure accommodation within the district.  Areas further afield will only be considered if it is necessary to meet a specific need for out of area placement or because there is nothing available closer to home on the day when it is required.

The following principles will apply when procuring properties for both temporary accommodation:

1. The council will act to ensure the property complies with all relevant legal obligations and have regard to all relevant legal guidance.
2. Properties should be affordable and sustainable in the longer term to the households that occupy them, including to benefit dependent households in receipt of Housing Benefit or Universal Credit, and subject to the benefit cap.
3. Each property offered to a homeless household will be suitable for that household, compliant with health and safety requirements and in a decent condition.
4. Landlords may on occasion be offered incentives to procure properties to prevent homelessness and to discharge our homelessness duties, and where the practice will help secure longer-term savings.

Appendix One - WFDC Bed and Breakfast Reduction plan 2024 - 25

Action: Reduce the demand for temporary accommodation through increasing the number of households prevented from becoming homeless

Action: Increase the supply of alternatives to Bed and Breakfast

Action: Ensuring appropriate use of Temporary Accommodation

Appendix Two - Suitability Checklist