MIND THE GAP

ONE YEAR ON

Continuation report on
homelessness amongst newly
recognised refugees
- June 2019 -

CIO no 1162434
Date of publication: June 2019

Author:
Lucy Smith

Acknowledgements: Definitions:
Thanks to everyone who took part in this This report refers to single adults with
report including C4WS Homeless Project, The leave to remain (LTR) including people
Boaz Trust and One Roof Leicester, and the newly recognised as refugees and people
refugees who took the time to be interviewed. with discretionary LTR on other grounds,
Thanks too to the other organisations for instance, humanitarian protection. For
who have provided support around these expediency, both groups are referred to
recommendations. hereafter as ‘refugees’.

Thanks to Rose at Crisp Design for the design

of the report. Image on front cover by Anna
Berdnik/Shutterstock.com

Names may have been changed for

anonymity purposes. Any inaccuracies
identified in the report should be emailed to
[email protected].
Introduction
NACCOM is a network of organisations preventing destitution amongst people who are
refused asylum, other migrants with no recourse to public funds (NRPF) and refugees.
The network, which includes (to date) 59 Full Members (providing accommodation) and
40 Associate Members (in support of NACCOM’s aims), exists to promote good practice,
increase accommodation provision and call for an end to destitution.

Refugees make up a considerable proportion of those supported by NACCOM’s

members; of the 3,471 people accommodated in 2017-18, 1,097 (32%) were refugees.
Members support refugees in different ways, with some providing housing or hosting
schemes and a smaller number providing night shelter accommodation. It is to the work
of the latter that this report turns.1

In 2018 NACCOM published ‘Mind the Gap’, exploring pathways into and out of
homelessness amongst newly recognised refugees after the 28-day move on period.2
Analysis was undertaken with night shelters in Manchester, Leicester and London in
2017-18, in which time 169 people were accommodated, 28% of whom had refugee
status. To identify recurrent or new issues, follow up research was undertaken over
the winter of 2018-19 with the same organisations (Boaz Trust, C4WS and One Roof
Leicester). Interviews were also conducted with refugees facing homelessness, including
but not limited to those accessing night shelters.

4,405 156 23%

nights of people of the guests had
accommodation accommodated refugee status

What is the move on period?

The ‘move on period’ refers to the 28-day timeframe that recently recognised
refugees are given before they are evicted from asylum accommodation and
have support payments stopped. In this timeframe they are expected to access
benefits and/or find employment and secure accommodation.

1
For more information about NACCOM’s aims and accommodation schemes, visit www.naccom.org.uk.
2
NACCOM, Mind the Gap (May 2018); https://naccom.org.uk/wp-content/uploads/2018/10/NACCOM-Homelessnesss-
Report_2018-10-24.pdf

01
 The Home Office needs to give people more than one month. I tried
to arrange everything in 28 days but everywhere takes time. You can’t
sort anything out in 28 days. - Dariush

Summary of recommendations
• The move on period should be extended to at least 56 days alongside improvements
to support, so no refugees face homelessness and destitution after leaving asylum
accommodation.

• To help with this, the Home Office should pilot an extension of asylum support for
a period of at least 56 days, including additional support, with the findings made
publicly available.

• The Government should publish the findings from the Post Grant Appointment
Service without delay, so learning from it can be embedded in future advice and
support services.

• There should be robust monitoring in place to show the impact of changes to

support for newly recognised refugees and this should be made public.

• The Government should publish an assessment of the appropriateness of Universal

Credit advance payments for newly recognised refugees.

• Integration loans should be increased to reflect the cost of entering the private rental
market and more information should be made available about them.

• Clear guidance should be given to Local Authorities about the obligations of asylum
contract providers so that non-compliance can be quickly identified, published and
rectified.

• The Home Office should monitor and report on referrals from accommodation/
advice providers to Local Authorities, so the impact can be monitored and if
necessary the ‘duty to refer’ extended to include the providers.

• The Right to Rent scheme should be abolished.

02
Key Events In The Last Year
In the last twelve months, there has been some positive progress on the move on
issue. Whilst it is clear that much more needs to be done, key changes and events are
summarised below:

June 2018
• Ministry of Housing, Communities and Local Government (MHCLG) launched
the Local Authority Asylum Support Liaison Officers (LAASLO) scheme in 19
Local Authorities (LAs) in England.3

July 2018
• Parliamentary debate on ‘Homelessness amongst refugees’ highlighted
support for policy change.4
• All Party Parliamentary Group on Ending Homelessness (APPGEH) launched
report into ‘Rapid Responses to Homelessness’ which included calls for an
extension to the move on period.5

August 2018
• MHCLG scrapped planned changes to funding for supported housing.6
• Integration National Asylum Stakeholder Forum (NASF) sub-group launched.

September 2018
• NACCOM published its 2017-18 annual report featuring data on housing needs
of refugees.7

October 2018
• APPGEH identified refugee homelessness as one of its campaign goals for the
year ahead.8

3
https://www.gov.uk/government/news/19-million-funding-for-councils-to-boost-integration
4
For the transcript see https://hansard.parliament.uk/Commons/2018-07-17/debates/6DDAB279-15B3-409B-9F76-BF978821450D/
HomelessnessAmongRefugees
5
APPG Ending Homelessness, ‘Rapid Responses to Homelessness; a look at migrant homelessness, youth homelessness and rapid
rehousing models’ (July 2018); https://www.crisis.org.uk/media/239050/appg-for-ending-homelessness-report_final.pdf
6
https://www.gov.uk/government/news/all-supported-housing-funding-to-be-retained-in-welfare-system
7
NACCOM Annual report (Sept 2018); https://naccom.org.uk/wp-content/uploads/2018/09/NACCOM-AnnualReport_2017-09-19_final-
EMAIL.pdf
8
APPG on Ending Homelessness, AGM Minutes (Oct 2018); https://www.crisis.org.uk/media/239625/agm-2018-minutes.pdf

03
 November 2018
• Independent Chief Inspector of Immigration (ICIBI) launched a report on
asylum accommodation.9
• Home Office responded with Asylum Assurance Plan10 including details around
consulting stakeholders on the evaluation of the Post Grant Appointment
Service (PGAS), and launch of a ‘Move-on Board’ and working group with the
Department of Work and Pensions (DWP).

December 2018
• British Red Cross published ‘Still an Ordeal’, calling for an extension of the
move on period, improved support, quicker payments of Universal Credit, and
quick and easy access to bank accounts for all newly recognised refugees.11

January 2019
• Advice, Issue Reporting and Eligibility Support (AIRE) and Asylum
Accommodation and Support Services (AASC) contracts awarded.12

February 2019
• MHCLG launched the Integrated Communities Strategy Response13 and
Action Plan14, featuring plans for government departments to learn from the
Controlling Migration Fund, LAASLO scheme and PGAS.

March 2019
• House of Lords debate took place based on Baroness Lister’s question: ‘To
ask Her Majesty’s Government what steps they are taking to prevent destitution
among newly recognised refugees in the light of the British Red Cross Report
Still an ordeal, published in December 2018?’15

9
ICIBI, ‘An inspection of the Home Office’s management of asylum accommodation provision’ (Nov 2018); https://www.gov.uk/
government/publications/an-inspection-of-the-home-offices-management-of-asylum-accommodation-provision
10
Asylum Assurance Plan (Nov 2018); https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_
data/file/757724/Action_Plan.pdf
11
British Red Cross, ‘Still An Ordeal’ (Dec 2018); https://www.redcross.org.uk/-/media/documents/about-us/research-publications/
refugee-support/still-an-ordeal-move-on-period-report.pdf
12
https://www.gov.uk/government/news/new-asylum-accommodation-contracts-awarded.
13
Integrated Communities Strategy: Response (Feb 2019); https://assets.publishing.service.gov.uk/government/uploads/system/
uploads/attachment_data/file/777160/Integrated_Communities_Strategy_Government_Response.pdf
14
Integrated Communities Strategy: Action Plan (Feb 2019); https://assets.publishing.service.gov.uk/government/uploads/system/
uploads/attachment_data/file/778045/Integrated_Communities_Strategy_Govt_Action_Plan.pdf
15
For the transcript see https://hansard.parliament.uk/Lords/2019-03-20/debates/207980D9-3B31-4C4B-86B6-26F3539777EC/
Refugees#contribution-50CAA4DC-8ABD-4E3E-BFFB-1F3A0279A4F3

04
‘Mind the Gap’- One Year On
Night Shelter Provision (Oct 2018-April 2019)

4,405 156 36
nights of guests were refugees were
accommodation accommodated accommodated
over 6 months (23% of total guests)

Despite the slightly lower proportion of refugee guests in shelters this year (23% in
2018-19 compared to 28% in 2017-18), of those who did access the shelters, 13 (36%)
were known to have left asylum accommodation in the last six months. This is higher
than last year, when 10 of the 48 (21%) refugee guests were known to have left asylum
accommodation in the last six months. Meanwhile, the number of refugee guests known
to come to shelters after leaving asylum support 1-4 weeks previously has increased
proportionally (in 2017-18, 5 guests were known to have moved on in the previous 1-4
weeks and this year it was 6 guests).

Whilst there is an element of improved reporting procedures this year amongst the
members involved, the overall point is still that refugees are becoming homeless after
moving on from asylum support. The breakdown of the figures are shared on the
following page.

Photo credit Roman Bodnarchuk /Shutterstock.com

05
The Boaz Trust
From October 2018 - March 2019, the Boaz Trust night shelter in Manchester received
201 referrals and provided 1,556 nights of accommodation. The shelter accommodated
53 people, 22 of whom were refugees. Of these;

4
had left their asylum
7
had left asylum
9
had left more than 6
1
came on a Family
accommodation accommodation in months before Reunion visa and
within the previous the previous therefore did not
1-4 weeks 1-6 months access asylum
accommodation
Details about the date of leaving asylum accommodation was unknown for 1 guest.

15 of the refugee guests were known to have presented at the council as homeless prior
to coming to the shelter, 12 of whom were granted LTR outside of Manchester.

C4WS
From November 2018 - April 2019, the C4WS night shelter in Camden
received 378 referrals and provided 1,978 nights of accommodation. The
shelter accommodated 78 people, 10 of whom were refugees. Of these;

1
had left their asylum
5
had left more than
3
were granted refugee status
accommodation within 6 months before before turning 18, and of these, 2 were
the previous 1-4 weeks known to have moved on from care
(not asylum accommodation)
Details about the date of leaving asylum accommodation was unknown for 1 guest.

One Roof Leicester

From December 2018 - March 2019, One Roof Leicester’s night shelter
received 46 referrals and provided 871 nights of accommodation. The
shelter accommodated 25 people, 4 of whom were refugees. Of these;

1
had left their asylum
1
had left more than
1
had been granted status before
accommodation within 6 months before turning 18, so moved on from care
the previous 1-4 weeks (not asylum accommodation).

Details about the date of leaving asylum accommodation was unknown for 1 guest.

All 4 of the guests were known to have presented as homeless before coming to One
Roof Leicester.

06
Key Issues And Recommendations
1. Continued gaps in advice and support for housing options
In the last year, much of the Home Office activity around refugee move on has focused
on the Post Grant Appointment Service (PGAS), a joint initiative with DWP, where
refugees receive a phone call inviting them to a Job Centre appointment to set up access
to mainstream services. This was rolled out in 2017 after a pilot in the North East and
Yorkshire and Humberside, with the Immigration Minister describing it as ‘designed
to ensure that the refugees receive the first payment of any benefit they are entitled to
before their Home Office support ends’16,17 Yet despite calls for evidence of the scheme’s
success to be made public, to date this information has not been shared.

However, as housing advice has not (to date) been part of the PGAS, refugees have
continued to receive limited information via the Home Office and asylum housing
provider about their accommodation options after move on. This is clearly not good
enough, with a lack of understanding about the UK housing market and/or statutory
services alongside the short timeframe before eviction leading to a high risk of
homelessness.

As such, changes in the new AIRE (asylum advice) contract are welcomed. These include
more advice for refugees on accommodation and signposting to housing services during
the 28 day period.18 Yet given that this service builds on the work of the PGAS, without
a full understanding of the impact of the PGAS itself it is unclear how effective the
changes will be when they are rolled out later this year. Robust monitoring and evaluation
is therefore essential, alongside a public evaluation of the PGAS and the warm handover
that preceded it.

In recent months, some refugees have been offered advice and support with housing via
the implementation of 35 Local Authority Asylum Support Liaison Officers (LAASLOs)
across 19 Local Authorities (LAs) in England. Whilst these posts play a key role in the
government’s response to homelessness amongst refugees,19 it is still too early to tell
the impact- or long-term prospects- of the pilot scheme, with the MHCLG evaluation not
due until 2020.20

16
Caroline Nokes, Written Question no. 122424, 7th March 2018: https://www.theyworkforyou.com/wrans/?id=2018-02-01.126096.h&s
=refugee+speaker%3A24943#g126096.q0
17
For more on the PGAS, see Caroline Nokes’ answer to Written Question no. 129976, 5th March 2018; https://www.parliament.uk/
business/publications/written-questions-answers-statements/written-question/Commons/2018-02-27/129976/
18
AIRE Contract Schedule 2- Statement of Requirements (4.9.12), pp. 70-72.

07
 Tekie is a 34 year old Eritrean refugee. He reported how he received
some information about his housing options when he got his papers,
but because of his limited English skills his brother, who has refugee
status in Germany, had to translate the letter for him over the phone.
He then went to the Job Centre to apply for benefits and at the same
time asked the council for help with housing, but was advised there
Tekie’s was nothing available for him. He then experienced a one month gap
Story after getting his papers before his benefits started. In this time, he
went to a homelessness support service, where he was supported
with food and shelter until the One Roof night shelter opened in
December 2018.

‘I have had many refusals so when I read the letter from the Home
Office I just saw that I had been granted my leave to remain, I didn’t
read anything else. The way the Home Office writes is very voluminous.
There was other information in the letter about work, benefits and
loans but I didn’t know what to do next. I didn’t have a phone call from
the Home Office. If someone had phoned and explained about it that
would have been very helpful. My mental health was really struggling at Phillippe’s
that time. I was panicking. I didn’t know how to go about accessing the Story
support.

Whilst changes that have been implemented this year to improve advice for refugees
around housing are cautiously welcomed, it remains unclear how they will reduce
homelessness in many instances. As such, alongside the continued recommendation
to extend the move on period to at least 56 days, in response to claims that there is
not enough evidence of both the need for, and impact of, a longer time frame, the
implementation of a pilot is recommended. Such a scheme could extend the move
on period to at least 56 days for a group of at least 300 refugees, and be tracked to
show the effects and cost-savings that an extension to both time and accommodation
could bring. If implemented alongside other procedural changes, with findings made
publicly available, the pilot could both ensure a robust assessment of the benefits of an
extension, whilst improving understanding about any additional support that might be
needed.

19
Caroline Nokes, Written Question no. 181330, 26th Oct 2018; https://www.parliament.uk/business/publications/written-questions-
answers-statements/written-question/Commons/2018-10-18/181330/
20
Integrated Communities Strategy: Response, p. 12 and Integrated Communities Strategy; Action Plan, p.10

08
 Recommendations
The move on period should be extended to at least 56 days, alongside
clearly defined procedural improvements to the support and advice offered,
so no refugees face homelessness and destitution after leaving asylum
accommodation.

The Home Office should pilot an extension of asylum support for a period of
at least 56 days for at least 300 refugees, which can be tracked to conclusively
show the effect and cost-savings of an extension of time and accommodation
alongside improved support. These findings should be made publicly available.

The Government should publish the findings from the PGAS without delay, so
learning from it can be embedded in future advice and support services.

There should be robust monitoring in place to show the impact of changes to

support for newly recognised refugees (through LAASLO scheme and asylum
contracts) and this should be made public.

2. Ongoing delays with receiving benefits for those recently

granted status
In NACCOM’s 2017-18 annual survey, of the 3,471 people accommodated, 401 (12%)
were refugees who did not have access to benefits or housing when they approached
organisations for support.21 This is reiterated by evidence from shelters involved in this
report, who all supported refugee guests who were not in receipt of benefits when they
came to their services. In one instance, a refugee got LTR in August 2018, but despite
getting his National Insurance number (NINo) in good time, was still not in receipt of
benefits when he came to the shelter five months later.

With the roll out of Universal Credit (UC) for all new applicants since December 2018,
problems are likely to worsen. With its in-built delay of five weeks, all new refugees
applying for support will experience a period of destitution for at least one week (most
likely more) before their first payment. Further difficulties are incurred by refugees in
receipt of Section 4 support at the time of their decision, because they do not have any
cash to carry over in the interim period.22

21
NACCOM Annual report (Sept 2018); https://naccom.org.uk/wp-content/uploads/2018/09/NACCOM-AnnualReport_2017-09-19_final-
EMAIL.pdf
22
Section 4 (2) support is offered to people who have been refused asylum and meet certain criteria. Cash payments are not provided.
See https://www.gov.uk/government/publications/asylum-support-section-42-policy for details.

09
 I went to the Job Centre and got an appointment one week after my
decision letter. They said they would start my Universal Credit one week
after my asylum support ended. That was on the 9th April, and my
Universal Credit started on 17th April. I had one week where I had no
benefits, and because I have been on Section 4 I haven’t got any cash.
I asked them what I was to do, and they said that this was the process
Dariush’s and they couldn’t do anything about it.
Story

The Government’s response to criticism around UC delays has been to point to the
availability of advance payments.23 Yet the British Red Cross highlight barriers around
this, including a lack of awareness amongst refugees, or issues getting bank accounts,24
whilst those refugees who do know about them may feel uncomfortable about taking on
debt. In January 2019, a parliamentary question confirmed that the government had not
made any specific assessment around access to advance payments for refugees.25

I was offered an advance payment and told there would be a five week
wait for my first Universal Credit instalment. Usually I have a bad feeling
about loans, but I took the offer of £250 to cover my costs. The main
challenge I faced was from my Job Coach, who was pushing me to
apply for jobs. Even though I wanted to work, there were expenses
to pay during that time. I had to pay for DBS checks and travel for
interviews, and I needed to eat. I had to do all that on £250 which was Phillippe’s
very frustrating. They didn’t tell me about integration loans which could Story
have been very helpful.

Recommendations
The move on period should be extended to at least 56 days so refugees do not
face destitution whilst awaiting their first Universal Credit payment.

The Government should publish an assessment of the appropriateness of

Universal Credit advance payments for newly recognised refugees.

23
Alok Sharma, Written Question no. 203324, 28th December 2018, https://www.parliament.uk/business/publications/written-
questions-answers-statements/written-question/Commons/2018-12-18/203324/
24
British Red Cross, Still An Ordeal, p.23
25
Baroness Buscombe, Written Question, 3rd January 2019, https://www.theyworkforyou.com/wrans/?id=2018-12-17.
HL12360.h&s=speaker%3A25058#gHL12360.q0

10
3. Reliance on charities for support due to a lack of social
and private housing options

I got my decision letter and I went to Housing Options soon after. I told
them I would be homeless and would have nowhere to live. They said
‘You are not suitable for a council house. You need to find somewhere
privately to rent.’ They said they would help me find a shared room in a
privately rented house. I went back on the day that I became homeless
and Housing Options said they hadn’t managed to find me anything.
They said I had to go to a hostel. The hostel was a terrible place. I spoke
Dariush’s
to the manager and they told me it would not be safe for me to leave
Story
my luggage here and also I would not be able to study here. I went back
to Housing Options, and they contacted me with a room in a shared house. I chose a room,
but after waiting for more than a month to move in, I have just been told that this room is
not suitable. I went back [to the charity that had supported me when I was destitute] and
said I had nowhere to stay. They let me stay with a host family, where I am still staying now.

With only 3 refugee guests known to move on to hostels or long term social housing
from shelters this year, and 4 into the private rental sector (PRS), the most common
move on option (taken up by 12 of the guests) was charity accommodation. Yet, whilst
this can be positive, it is not always long-term (for instance, some people moved on
to other night shelters or hosting schemes) and there remains the issue of capacity
amongst services, which may have a time limit or other limitations on availability. This
year, 5 refugee guests were known to return to the streets or sofa surfing after accessing
shelters. If such outcomes are to be avoided, alongside improvements to the support
offered during the move on period, barriers to accessing the housing market need to be
overcome as well.

Barriers in the Private Rental Sector (PRS)

Within the PRS, a major barrier is payment for upfront costs, closely linked with levels
of financial support that refugees have access to in the early weeks and months after
getting status. Getting a PRS tenancy requires people to have a deposit and usually at
least a month of advance rent payments.26 One refugee trying to get a tenancy whilst
starting out on UC reported a ‘Catch 22’ scenario, where he was unable to secure a
tenancy without the funds to pay the upfront costs required, but was unable to receive
the housing element of UC without a tenancy agreement.

See Crisis, Home. No less will do: improving access to private renting for single homeless people (Feb 2018), https://www.crisis.org.
26

uk/media/237168/home_no_less_will_do_access_crisis.pdf

11
Integration loans could provide much needed support to bridge this gap, yet the amount
offered does not reflect the cost of securing a PRS tenancy. In 2017 a parliamentary
question revealed the average amount offered for an Integration Loan was less than
£500,27 whilst figures cited by Crisis indicated the average tenancy deposit stood at
£1197.73 (as far back as 2014).28 To date, no amendments to this loan scheme have
been introduced but it seems to be an opportunity not to be missed.

To receive a housing payment, I needed a signed contract with a

housing provider in place. All the private landlords I approached
required references, deposits and at least one month’s rent up front, so
I went back [to the charity that had supported me when I was destitute]
and they came to my rescue.
Phillippe’s
Story

It can also be extremely difficult to get a tenancy because of a shortage of landlords

willing to take on UC tenants. Alternative payment arrangements (APA) can be made
through which housing payments are paid direct to landlords.29 This can help encourage
a landlord to accept a tenant who is on UC, but one shelter reported that they did not
know how to advocate for this on behalf of their guests.

A further barrier is created by discrimination towards non-British tenants via the Right to
Rent scheme. This legislation, which was recently ruled discriminatory by the High Court,
obliges landlords to undertake checks which prohibit certain groups of people from
accessing accommodation. Despite the landmark judgement handed down in March
2019, the scheme remains in place whilst the Home Office appeals the decision.30 Whilst
the research for this report did not focus on this issue directly, the evidence from others
in the sector of the barriers created by the scheme is stark.31

27
APPG on Refugees, ‘Refugees Welcome?’ (April 2017), pp.21-22; https://www.refugeecouncil.org.uk/wp-content/uploads/2019/03/
APPG_on_Refugees_-_Refugees_Welcome_report.pdf
28
My Deposits (August 2014), ‘Tenancy deposits rise by a third since 2007’, cited in Crisis, ‘Home. No less will do’, p.6.
29
https://www.gov.uk/government/publications/universal-credit-and-rented-housing--2/alternative-payment-arrangements
30
Home Office statement: https://homeofficemedia.blog.gov.uk/2019/03/01/home-office/. For the judgement, see https://www.bailii.
org/ew/cases/EWHC/Admin/2019/452.html
31
See JCWI, ‘No Passport, No Home’ (Sept 2015) and ‘Passport Please’ (Feb 2017); https://www.jcwi.org.uk

12
 Recommendations
Integration loans should be increased to reflect the cost of entering the private
rental market and more information should be made available about them.

The Right to Rent scheme should be abolished.

Barriers To Accessing Statutory Support And Social Housing

With regards to statutory support, whilst many refugees are either not eligible for,
or remain in the lowest priority banding for, social housing (for instance if they have
relocated from another area, or do not meet the requirement for priority need), there
is still a lot that can - and should - be done. Indeed, as a result of the Homelessness
Reduction Act (HRA) anyone who is not in priority need is still entitled to statutory
support to help prevent and relieve homelessness. But to benefit from this, people have
to know their entitlements and feel supported to access them.

To help, the ‘Duty to Refer’ (which gives certain public bodies a responsibility to refer
vulnerable people onto LAs) was introduced in October 2018.32 The premise is that
by ensuring referral pathways, groups at risk of homelessness can be assured of
appropriate advice in a timely manner, and it is key to ensuring both the prevention
and relief of homelessness.33 Yet the exclusion of asylum accommodation and advice
providers from the list of public bodies who hold this duty means that vulnerable
refugees may be missing out on vital support. The clearest way to address this risk
would be to bring these providers under the same referral pathway system.

However, the Home Office argues that it is sufficient that providers have a contractual
obligation to refer refugees on to LAs,34 and have strengthened the wording on the
process in the new contracts which come into place from September 2019.35 As with
other contractual amendments, it remains to be seen if the changes will be effective.
To this end the Home Office should commit to making LAs aware of the changes (and
routes for reporting non-compliance) alongside publishing the impact of their own
approach to referrals and reviewing it as evidence of the benefits of ‘Duty to Refer’
gathers over time.

32
https://www.gov.uk/government/publications/homelessness-duty-to-refer/a-guide-to-the-duty-to-refer
33
Crisis, ‘Preventing Homelessness: It’s Everybody’s Business’ (Oct 2018), https://www.crisis.org.uk/media/239551/preventing_
homelessness_its_everybodys_buisness_2018.pdf
34
Caroline Nokes, Written Question, 25th February 2018, https://www.theyworkforyou.com/wrans/?id=2019-02-
19.223186.h&s=Refugees#g223186.r0
35
AASC Schedule 2: Statement of Requirements (4.4.7), p.75, AIRE Contract Schedule 2- Statement of Requirements (4.9.12), p.72

13
 Recommendations
Clear guidance should be given to LAs about the obligations of the asylum
contract providers so that non-compliance can be quickly identified, published
and rectified.

The Home Office should monitor and report on referrals from accommodation/
advice providers to LAs, so the impact can be monitored and if necessary the
‘duty to refer’ extended to include the providers.

What Is Not In This Report

This report focuses on the needs of newly recognised refugees, largely because it is
understood that simple changes in the approach to the move on period could drastically
improve lives at this critical juncture. Yet it is clear from the evidence provided by
shelters, both this year and last, that refugees are requiring support at other points as
well. Examples include after arriving on Family Reunion visas, when they leave the care
system, when they find themselves unemployed and in rent arrears, or after relationship
breakdowns.

Justice to such a range of issues cannot be done in this short report, but there is strong
evidence that people who have experienced homelessness at one point in their lives are
likely to face it again.36 Therefore, alongside standing with others to call for a society in
which no one faces homelessness, it is hoped that this report can stand as a warning for
the future if action is not taken quickly.

A Note on Homelessness Charters

Two of the cities where evidence was gathered for this report, Manchester
and Leicester, have established Homelessness Charters in recent years. Both
documents set out a vision for tackling homelessness by calling on public bodies,
charities, faith groups, businesses and local government to work together.37 Such
an approach is welcomed by projects working locally, and it is hoped that learning
from them can disseminate nationally as well.

See Crisis, ’Nations Apart’ (Dec 2014), pp.26-28; https://www.crisis.org.uk/media/20608/crisis_nations_apart_2014.pdf

36

Leicester’s Homelessness Charter: https://www.leicester.anglican.org/download/16531/ and Manchester’s Homeless Charter:

37

https://charter.streetsupport.net/manchester-homelessness-charter.pdf

14
 Update on Supported Housing
Supported housing is intensive support and tenancy management and
accommodation for vulnerable groups, with some schemes receiving a higher
rate of housing benefit for tenants (known as ‘exempt accommodation’). Within
NACCOM, several members provide this, primarily for newly recognised refugees
who have begun to receive benefits.

In October 2017, changes were proposed to funding for certain types of supported
housing, but there were concerns that such changes ran the risk of excluding or limiting
existing service provision, which could have resulted in rising homelessness. When
Mind the Gap was published last May the government response was unclear, so a
recommendation about it was included. In August 2018, MHCLG announced they would
not implement the changes, a response which NACCOM welcomed.38

38
https://naccom.org.uk/naccoms-response-to-the-governments-u-turn-on-supported-housing/

15
Conclusion
Whilst actions that government departments have implemented to support refugees in
the last year are cautiously welcomed, there remains a disconnect between public policy
and the experiences of homeless refugees. Some of this has to do with the pace of
learning around government initiatives, but it is also clear that 28 days is simply not long
enough to definitively prevent homelessness.

With a longer move on period, alongside more joined up support, refugees who are
not eligible for social housing would have more time to find PRS alternatives whilst
not having to go into debt to get their first payment of Universal Credit. There would be
less panic and more chance of genuine integration. Of course, there would be a cost to
extending the move on period, but there is currently a cost, both human and economic,
by failing to do so. It is for this reason that the report’s leading recommendation is for the
Home Office to implement a move on pilot and make public its findings. Without such a
practical step towards change, there is a real concern that tinkering will continue around
the edges of the system that never goes far enough to make a lasting difference.

Homelessness is a scandal and all avenues to end it must be explored. Every refugee
who becomes homeless after finally receiving recognition of their need for protection,
every refugee who has to worry about finding a place to sleep rather than putting in
place positive and hopeful plans for their future, represents a failure on the part of this
government to learn from the past and make changes for the future. More must be done,
and quickly. There is no time to waste.

16
NACCOM Board of Trustees
Registered CIO No: 1162434 (as of June 2019)
0161 7060185
[email protected] Julian Prior (Chair)
www.naccom.org.uk Rachael Bee
@naccomnetwork Caron Boulghassoul
@NACCOMNetwork Jonny Darling
NACCOM, c/o Youth Resource Centre, Catherine Houlcroft
Oxford Street, Whitley Bay, NE26 1AD Jochen Kortlaender
Abed Moubayed