CIH NI response to consultation on homelessness prevention private member's bill

You can read CIH Northern Ireland's response to Colm Gildernew's private member bill on homelessness prevention below.

Do you agree with the proposal to extend the time period of the statutory duty on the NIHE to support those threatened by homelessness from 28 days as it is currently, to at least 60 days?

CIH Northern Ireland strongly supports the proposal to extend the statutory duty on the Northern Ireland Housing Executive (NIHE) to support those threatened by homelessness from 28 days to at least 60 days.

There are a number of reasons why, and this draws on CIH views both regionally and nationally:

In summary, we view this proposal as a positive and necessary step towards a more preventative, effective and person-centred approach to tackling homelessness in Northern Ireland, reflecting good practice seen elsewhere in the UK. 

We would stress, however, that such an extension must be accompanied by adequate funding and resources for the NIHE and its partners to truly deliver on the enhanced duty.

Should the duty to support those threatened by homelessness apply to any other organisations besides NIHE, such as local authorities or housing associations?

CIH Northern Ireland believes that the primary statutory duty to support people threatened by homelessness should remain with NIHE. It holds a unique and vital role as Northern Ireland's single, region-wide housing authority, possessing the comprehensive powers, expertise and infrastructure for social housing provision, allocations and direct homelessness support across the entirety of Northern Ireland. This centralised structure is distinct from other UK nations and is fundamental to the delivery of housing services here.

However, recognising the critical importance of a collaborative and preventative approach, as exemplified by the successes of England’s HRA, we advocate for the introduction of a statutory ‘duty to refer’ for other key statutory organisations. This duty would legally require these bodies to refer people they identify as being homeless or threatened with homelessness to NIHE, with the person’s consent, at the earliest possible opportunity.

This approach aligns with the progressive shift towards early intervention and prevention seen across the UK, while reflecting NI’s distinct housing governance model. It acknowledges that homelessness is a complex issue often stemming from multiple factors, and therefore requires a concerted effort from various statutory partners who routinely interact with vulnerable people.

We propose that this ‘duty to refer’ should apply to specific, statutory organisations that have a key interplay with the homelessness system, including, but not limited to:

• Health and social care trusts: Given their crucial role in public health, mental health and social care, they frequently encounter people whose health or social circumstances place them at risk of homelessness
• The Probation Board for Northern Ireland and NI Prison Service: Supporting people leaving custody who are at high risk of homelessness
• Jobs and benefits offices: Assisting people facing unemployment or financial hardship who may subsequently struggle with housing costs
• Local authorities: While Northern Ireland's local councils do not have direct housing provision duties like those in Great Britain, they play a crucial role in community planning, well-being and local service delivery. Placing a ‘duty to refer’ on relevant council departments (e.g. environmental health, community development) would leverage their local presence and knowledge to identify and connect at-risk individuals to NIHE, without imposing direct housing responsibilities that do not align with their current mandate.

Furthermore, we acknowledge that housing associations in Northern Ireland already play a significant and proactive role in tackling and preventing homelessness. As the primary providers of new social housing and through their vital tenancy sustainment support services (including benefits advice, budgeting, employment support and anti-social behaviour management), they are crucial partners in reducing the housing waiting list and alleviating homelessness. Many housing associations specialise in supported housing for vulnerable people and families, where early intervention is key. While not a statutory ‘duty to refer’ in the same vein as public bodies, their continued collaboration and formalised links with NIHE are essential.

By implementing a statutory ‘duty to refer’, Northern Ireland can empower truly person-centred solutions and make sustainable progress towards addressing homelessness, ensuring that people receive timely support from the specialist housing authority, regardless of which public service they initially interact with.

Do you agree that extending the time period whereby NIHE must support people threatened by homelessness from 28 days to at least 60 days would have a positive impact in reducing the number of people that fall into homelessness?

CIH Northern Ireland believes that extending the time period for the NIHE to support people threatened by homelessness from 28 days to at least 60 days would have a positive impact in reducing the number of people who become homeless.

Prioritising prevention and early intervention is crucial. We champion homelessness prevention as the most effective and humane approach. A 28-day window is often too short to genuinely intervene in complex situations. 

Extending it to 60 days provides crucial additional time for the NIHE and its partners to proactively engage with people and families early, before their housing situation becomes critical.

It also allows for a holistic assessment to be completed, identifying any underlying causes of threatened homelessness (e.g. debt, family breakdown, mental health issues, domestic abuse, loss of private rented accommodation due to landlord sales) and more importantly, drawing up a tailored, person-centred prevention plan. 

With more time, NIHE can explore a broader spectrum of solutions, such as mediation, negotiating with landlords, exploring alternative housing options (social, private rented, supported housing), and connecting people with specialist support services.

Fundamentally, a longer period increases the likelihood of finding sustainable housing solutions, rather than just crisis management, which often leads to repeat homelessness.

Over the past decade, the number of households with homelessness status has steadily increased year on year. Whilst the main solution must be the delivery of social and affordable housing at scale, what if any other interim measures do you feel could be progressed by NIHE to support those on the social housing waiting list?

CIH Northern Ireland highlights the alarming trend of increasing households with homelessness status in Northern Ireland over the last decade, even as the overall social housing waiting list grows. We acknowledge that the main solution is indeed the significant delivery of social and affordable housing at scale. However, we have also proposed several interim measures that NIHE and the wider housing sector could progress to support those on the social housing waiting list while this essential supply is being built.

We feel that as already highlighted, extending the statutory duty from 28 to 60 days is important. This provides NIHE with more time to work with people at risk, explore all options, and prevent the loss of existing housing.

We also call for adequate and stable funding for NIHE's homelessness prevention services and the voluntary sector partners they work with. This includes, critically, the Supporting People programme, which provides essential housing-related support to vulnerable people, enabling them to live independently and prevent homelessness. We emphasise that prevention, particularly through proven programmes like Supporting People, is more cost-effective than crisis management, but these vital services still require necessary funding.

We need to see better inter-agency cooperation. This means improving and formalising collaboration between the NIHE, health and social care trusts, local councils, housing associations, and the voluntary sector to provide holistic, person-centred support that addresses underlying issues contributing to homelessness (e.g. mental health, addiction, domestic abuse).

We also ask the sector to ensure it is maximising the use of existing housing stock. By reducing voids and streamlining repair and re-letting processes, more people could be allocated homes more quickly.
We also believe that strengthening the private rented sector could alleviate some of the stresses on the social housing waiting list. This can be achieved by empowering landlords to provide tenants with more robust advice and support, including comprehensive information on their rights, responsibilities, and available financial assistance to prevent evictions. Furthermore, promoting tenancy security is crucial, which can be significantly advanced by removing fiscal disincentives that currently lead to property sales in the sector. By making the private rented sector a more stable and viable option, we can better meet diverse housing needs.

We also advocate for the expansion of ‘Housing First’ solutions. It is a highly effective model for supporting people with complex needs who are experiencing chronic homelessness. This approach prioritises immediate access to stable housing, coupled with intensive, flexible support, rather than requiring people to be ‘housing ready’. 

And finally, we advocate for strategic policy changes. This includes addressing the issue of water infrastructure capacity hindering new housing developments, and providing realistic, multi-year funding commitments to support the social housebuilding ambitions of the Programme for Government and Housing Supply Strategy, providing certainty for the entire housing sector.

Do you believe that extending the time period whereby NIHE must support people who are threatened by homelessness from 28 days to at least 60 days would have any significant financial implications?

Although we agree the move to extending the time period from 28 to at least 60 days is a positive and necessary development, there may be several anticipated impacts on the NIHE's operations.

A positive financial implication for NIHE is that shifting focus to preventing homelessness is more cost-effective than managing it once it occurs. By investing more in upstream prevention, NIHE can potentially reduce its significant expenditure on temporary accommodation (which has soared in recent years) and the associated administrative costs. This aligns with the NIHE's own strategic objective of prioritising homelessness prevention for long-term savings.

There are however, other financial implications that need to be considered. We would emphasise that this extension must be accompanied by not only adequate additional funding but additional staffing for NIHE's homelessness prevention teams. Without this, the extended duty could become an unfunded mandate, leading to increased pressure on already stretched resources and potentially undermining the intent of the policy.

Do you think that extending the time period whereby NIHE must support people who are threatened by homelessness from 28 days to at least 60 days would create administrative or logistical challenges?

It is likely that extending the period for NIHE to support people threatened by homelessness from 28 days to at least 60 days would create administrative and logistical challenges for the NIHE, particularly in the short to medium term.

Undoubtedly, there would be increased caseload management for NIHE staff. For each threatened homelessness case, NIHE staff will be engaging with people and families for a longer duration. This means potentially more appointments, more follow-ups, and more sustained case management per person. This will put pressure on people and teams if the staffing levels aren’t addressed.

With new staff will come increased training costs. Staff may need additional training in advanced prevention techniques, complex needs assessment and sustained client support to make the most of the extended period.

Another administrative consideration is the impact this will have on NIHE data management and IT systems. The NIHE's current methods may need to be reviewed to effectively track longer-term prevention cases, monitor outcomes over 60+ days, and gather the necessary evidence to demonstrate the effectiveness of the extended duty.

NIHE would need to manage public expectations. While the extended duty aims to prevent homelessness, it doesn't guarantee a social housing allocation, particularly given the severe shortage of supply. Communicating realistic outcomes and change in policy will require time, efforts and administrative costs to ensure the correct message is communicated to the public.

We believe that these are manageable and necessary costs for achieving a more effective and preventative homelessness system.