The Social Housing Support – Household Means Policy 2021 (the policy) as it is currently worded it appears to give local authorities little or no scope to allow access to social housing supports for those whose current income is below the income threshold but whose income may have exceeded the threshold when a calculation is made based on their preceding 12 months’ net average.
As a result, the policy is creating a block on individuals and families accessing social housing supports. In particular, it is creating a block for those who may have had a material change to their income over the preceding 12 months, e.g. due to the loss of a job or a change in social welfare entitlements.
MLRC understands that local authorities are not carrying out reviews (under Regulation 28 of the Social Housing Assessment Regulations 2011) where they have become aware of a change in household circumstances. We have a concern that they are citing the rigid nature of the policy’s wording in relation to the 12-month retrospective income assessment as the reason for this. The policy is appearing to have the effect of preventing local authorities from exercising their discretion under the Social Housing Assessment Regulations 2011 to review an application for social housing supports (a function that they are specifically experienced in carrying out).
An additional concern is that the current wording of the policy is preventing or causing an undue delay in individuals and families from accessing emergency accommodation. While we are aware that the Department has publicly stated that a person does not need to be eligible for social housing to access homeless supports, in practice we have seen local authorities insisting that those seeking emergency accommodation are approved for access to social housing supports prior to being placed in emergency accommodation. Typically the rationale employed by local authorities is that having access to social housing supports is the means through which an individual or family will move on from homelessness.
We have asked the Department to amend the policy to allow local authorities to consider a material change in circumstances when assessing or reviewing a household’s application for social housing supports. However, to date, they have not been minded to do so. MLRC is taking a keen interest in developments and is taking on referrals of people adversely affected by the strict application of the policy.