Bristol Zero Tolerance response to consultation on support for victims of domestic abuse in safe accommodation
The Ministry of Housing, Communities and Local Government (MHCLG) launched a consultation in May 2019 about support for victims of domestic abuse in safe accommodation. Bristol Zero Tolerance’s response to the consultation is below.
We welcome the consultation and agree with the need to ensure that provision of services are consistent nationally and that there are national standards to ensure accountability so that there is not a postcode lottery for survivors in terms of availability of services and standards.
Although this consultation was aimed at a wide audience including survivors it is a long and inaccessible document with a lot of jargon and specialist language used making it hard for survivor’s to meaningfully engage. In particular survivors from diverse backgrounds would find it hard to respond without the consultation available in different languages and accessible formats such as easy read and braille or a spoken/video version.
We support the understanding of the importance of having a safe place to stay and the support for victims and their children to rebuild their lives. Currently due to a lack of adequate funding leading to an inadequate number of supported or emergency accommodation options available, the shortage of social housing as a move on option, and the lack of enough appropriate services to meet demand, this is not currently the case. The lack of affordable and social housing means that even when survivors of domestic abuse are ready to move on from accommodation-based services they are unable to leave as there is no appropriate housing for them, we have found that even if they are moved to the highest band for housing waiting lists it can be over a year before they are re-housed safely.
The Government acknowledges that funding for domestic abuse services comes from a wide range of sources but fail to acknowledge the huge lack of resources and funding available to meet the enormous need for these services. With 10 woman every day still turned away from refuge provision  and women advised to return to abusers or sleep rough with their children  by local authorities, significantly more needs to be done to address this issue.
Defining accommodation-based services and support
Q1. Do you agree with our definition of ‘accommodation-based services’ for victims and their children?
Q2. Are there any other services, other than those listed, that you would define as an accommodation-based service? If ‘Yes’, what is this accommodation-based service?
Keeping the definition of ‘accommodation-based services’ too wide risks the provision of inappropriate and unsafe housing options which do not provide a specialist support service and can be set up without proper scrutiny. This can lead to women/residents having their safety compromised and having no security in their tenancy or access to services and support which can increase their risk. All services which claim to provide safe accommodation for survivors of domestic abuse must be properly monitored and assessed to ensure that they are providing this service appropriately and should have to comply with statutory standards.
Therefore, there needs to be a better definition of this. It is important to recognise that providing local authority emergency accommodation, sanctuary schemes and enhanced security measures on people’s properties, dispersed accommodation and move on accommodation are not the same as specialist refuge provision. Refuge accommodation should be supported by workers from specialist domestic violence and abuse organisations that understand the impact, prevalence, and dynamics of domestic abuse as well as how best to provide holistic support for recovery. It is also important that refuges are effectively managed to ensure health and safety specific to domestic abuse (e.g. CCTV, Premises Risk Assessments, house rules to reflect purpose of the scheme such as for victims with complex needs or family houses). Support staff should also have appropriate supervision and management to ensure they are providing the correct support. Accommodation and services that do not have this cannot be said to be providing a specialist domestic abuse service and may not have the same level of safety for residents.
Properties with sanctuary schemes, emergency accommodation or move on accommodation should not be seen as ‘accommodation-based services’. They would fall under outreach community services, and this is an important distinction as they are not necessarily safe as detailed above, for example being safe from other perpetrators that could target victims and their children; able to provide the level of security needed; providing women-only spaces; offering support within the accommodation; and the control a domestic abuse provider has over providing a psychologically informed environment. Therefore, we would be concerned that local authorities could use other types of accommodation at the expense of specialist refuges, as this may be cheaper but it may not be safer.
It is important to highlight the need to provide women-only refuges as many victims would not come into refuges and would remain at risk if there was not a woman-only option. Similarly, there is a need for different types of accommodation to meet different needs and protected characteristics of all service users, as again many people would not access a refuge where they did not feel comfortable and understood and some refuge options may not be appropriate for their risks or needs.
Q3. Do you agree with our definition of ‘support’?
Q4. Do you define an accommodation-based service not listed here as support? If ‘Yes’, what is this support service?
There should be a clearer definition of the role of support workers in the guidance and definition. For example, refuge workers who provide support to families living in refuge will work alongside the victim following a co-produced support plan that covers housing needs, financial needs, emotional and wellbeing needs, parenting needs, health needs etc. Outreach workers may provide support to families at risk who are living within the community. Some outreach workers also provide support in refuges where they don’t have specific refuge staff. The need for specialist support to be part of accommodation services should be a requirement of provision and ‘support workers’ should have requirements for training and specialism to ensure that they provide an appropriate service.
The proposals do not include Independent Domestic and Sexual Violence Advocates (IDSVAs) which are a key support role locally and can work within a service or refuge, as well as through outreach in the community and be based in a variety of settings e.g. NHS. Housing Workers are also missing, their role is to manage health and safety, maintenance and rents. Peer support and group work facilitators are another work force. Therefore, in order to provide an appropriate specialist service and help after fleeing domestic abuse there is a high level of support needed across a range of roles which must be acknowledged. Where this is not available and included in other accommodation provision that should also be clearly understood and not assumed to be present.
Leadership and responsibilities
Q5. Do you agree with our approach of introducing a statutory duty underpinned by statutory guidance?
Q6. Do you agree with placing the statutory duty on Tier 1 Authorities (County Councils, Metropolitan Councils, Unitary Authorities and the Greater London Authority) as ‘Lead Authorities’?
Q7. Do you agree that a duty to co-operate should be placed on Tier2 Authorities and London Boroughs?
We support the suggestion of implementing a new legal duty on local authorities to deliver support to survivors of domestic abuse and their children in accommodation-based services. We agree to the approach to introduce a statutory duty underpinned by guidance, and that this should be placed with tier 1 authorities with a duty for tier 2 to co-operate.
Local and national accountability
Q8. Do you agree with the proposed representation on Local Partnership Boards?
Q9. Do you believe your local authority has an existing governance structure in place which could meet the proposed role of the Board?
Q10. If you believe your local authority has an existing governance structure in place that could meet the proposed role of the Board a. What is the structure of the Board? b. Who are the Board members?
Q11. Do you agree with a duty to convene a Local Partnership Board?
Q12. Do you agree with the role and remit of Local Partnership Boards?
Q13. Do you agree with Local Partnership Boards assessing need for services?
Q14. Do you agree with Local Partnership Boards developing local strategies?
Q15. Do you agree with Local Partnership Boards commissioning DA services with Tier 2 Authorities?
There should be more individuals who have the authority to make decisions on the Local Partnership Boards, within their organisations but also across the local authority. This will make them more effective and have clearer lines of communication and accountability.
Q16. Local authority/ providers: What would be the practical implications of meeting the proposed requirements of the statutory duty?
Q17. Local Authority: What would be the financial implications of meeting the proposed requirements of the statutory duty?
We agree to the approach to introduce a statutory duty underpinned by guidance. However, this needs to be accompanied by an understanding of the need for specific ring-fenced and adequate resources for this to be implemented which currently many local authorities lack in terms of housing and other social services. The consultation acknowledges the increase in expenditure needed on domestic abuse which recognises the cost impact this has on other services such as health, police, education etc. and to meet increased demand. This funding should match inflation. At present grants are set across a set number of years, which means that domestic abuse providers work with a loss and their services are always under threat. Longer term commissioning would enable services to be sustainable and plan, showing longer term outcomes, trends, and meaning more resources going to longer term strategies rather than short term interventions or constant bid writing.
Q18. Do you think that Government should develop a standardised needs assessment form for local areas to use in assessing need for domestic abuse support services?
Q19. How often should the needs assessment be conducted?
A lot of local authorities implement needs assessments and strategies, but often these are not followed through and fall off the radar or act as tick box exercises. Standardised guidance would help with ensuring that needs assessments are acted upon and these should be done in line with commissioning.
There needs to be an understanding in the statutory duty of how much supported accommodation and housing is ‘adequate’, this should be based on population figures and how many people live in a local area as well as local demographics to ensure that needs are met.
Q20. Do you agree with Local Partnership Boards making commissioning decisions in partnership with Tier 2 Authorities?
Yes, as long as the membership of the Boards reflect an understanding of the needs and requirements to provide appropriate services.
Q21. Do you agree that standardised reporting would promote accountability and transparency?
Q22. Do you agree with the reporting themes suggested?
Standardised reporting needs to reflect the local population and needs, and be in consultation with local domestic abuse providers. It would be helpful to have standardised data brackets to help gather and analyse data (for example age ranges to be set nationally). We feel there is not a lack of data, but a lack of collating and analysing the existing data. Domestic abuse providers provide a lot of data to local authorities, and can access more with live case management systems in place but this is not always utilised and does not feed up into national approaches. We would also like to see more of a representation of qualitative data from survivor’s voices being heard on the ‘overview of the proposed approach’ and to feed in to this work.
Q23. Do you agree with the role and remit of the National Steering Group?
Q24. Do you agree with the proposed representation on National Steering Group?
We support the idea of a National Steering Group for oversight but this must also reflect local needs and there must be a mechanism for feeding in local data and information. There should be a local domestic abuse provider perspective, and a range of small local providers should be represented, not just large national organisations such as Refuge and Women’s Aid or local authorities. Survivors voices should also be represented in this forum.
Q25. Do you agree with the overall approach of the statutory guidance?
Q26. What else would you like to have set out within the Guidance?
Q27. What support would you find most useful to meet the requirements of the statutory duty and guidance?
In terms of guidance there should be a set number of the bed spaces that local authorities are expected to provide based on local population demographics and needs. Also, directions on the requirement of number of workers, for example 1 support worker per 8 bed spaces and 1 outreach worker per 20 victims as an example. This will ensure adequate funding is allocated to meet the need and quality of support.
Providing support to all victims of domestic abuse and their children
Q28. Do you think that the proposed policy will help local areas ensure the needs of all victims and their children can be met?
Q29. What more could the Government do to ensure the needs of victims and their children with protected characteristics are supported?
We are very pleased to see that the proposals consider the specific support needs of those with protected characteristics under the Equality Act 2010 (e.g. disability, LGB&T, older and younger survivors) and to provide a better response to those with complex needs. In particular we are glad to see an understanding of the need for specialist provision for survivors of domestic abuse with no recourse to public funds and insecure immigration status. So far the Domestic Abuse Bill has shown little regard  for these very vulnerable women and has not gone far enough to support their complex needs.
It is important to acknowledge the importance of having support accessible from a range of accommodation-based services and services that meet the needs of different survivors including those with children, those who may be disabled, LGB or trans, whose first language is not English, and who may have other protected characteristics.
Even though the consultation continues to mention children throughout there is a surprising lack of focus on children’s specific support and needs. Child witnesses of domestic abuse are often not recognised and there is little funding for provision of both preventative and recovery focused support. The need for accommodation which meets the needs of parents and those who may have multiple children, including older boys, should also be included in the range of provision expected as moving away from support networks and schools can have a huge impact on families and influence their decision to access refuge accommodation.
Every year gender-based violence providers are seeing a greater demand for support and this needs to be recognised as it affects access to services and the ability to provide high quality support. Nationally the supply doesn’t meet the demand putting a strain on services and increasing thresholds for support so that only those in acute crisis are able to access support rather than a focus on preventative measures and initiatives to avoid abuse escalating.
Services should reflect local demographics, and we feel that the diversity of the workforce is key to enabling access to services and reducing barriers to informing local and national decisions. There should be guidance on workforce diversity on all strategic and operational levels, including workforces that have lived experience of domestic abuse and those with protected characteristics such as trans women, LGB workers, those who speak different languages, disabled staff etc. To help support a wider range of people. Survivors and survivors with protected characteristics should also be part of key decisions alongside decision makers to ensure their voices and needs are heard and understood.