27.11.2024

We Might Need To Re-think.... Everything... Key Lessons from the Older Persons Housing Taskforce Report

Yesterday, MHCLG published the findings of the Older Person's Housing Taskforce - an independent group set up in May 2023 to explore how to improve the supply and suitability of housing options for older people.

I urge you all to read the report, accompanying research, and written ministerial statement in full. They deserve your attention.

Together, they set out a truly compelling case for a whole-society, cross- governmental, shift in our approach to both aging itself and how we approach our homes as we get older. To quote my own blog title, for a moment, we might need to re-think, well, everything.

That said, it is almost December, and life seems particularly hectic at the moment. So, if you are struggling to find the time to grapple with the whole report, some of the key lessons are set out below*.

As a society, we are ignoring the inevitability of ageing which is leading to short-term and unhelpful decision-making

One of the overwhelming messages of the report is that we are all, individually and collectively, burying our heads in the sand when it comes to ageing. When coupled with current demographic shifts (we are, after all, a rapidly ageing society), this ostrich-like approach to the inevitable has…. well… less than optimal consequences. 

To quote from the report itself:

“Over 11 million people – 18.6% of the total population – are aged 65 years or older, compared with 16.4% at the time of the previous census in 2011. By 2066, there will be a further 8.3 million (26%) projected UK residents aged 65 years – broadly equivalent to the size of the population of London today. The number of people aged 80 and over – the fastest growing segment of the population – is set to more than double to over 6 million. But the proportion of life spent in poor health has not changed, so a longer life means more years spent in ill-health. Nearly half of older households include someone living with a long-term illness or disability and the likelihood of long-term illness or disability and use of a wheelchair increases with age, so the over-stretch of health and social care systems is set to get worse.”

The report argues, convincingly, that we need to make thinking about how we age, and what we will need from our homes as we do, a mainstream issue. All housing should be capable of adaptation to some extent and all communities should be made more inclusive. 

This is not something we can afford to leave until we hit a crisis-point - whether in our own personal lives, or as a society as a whole. 

We need a holistic response to a multi-faceted problem. 

One of the most striking things about the recommendations made by the taskforce is just how wide ranging they are. 

The Report's call to action is addressed to everyone - from MHCLG, DHSC** and the Treasury, to local government, investors, individual future residents and, of course, housebuilders and providers of specialist seniors housing. 

We all need to do more, and do better, if we are to stand a chance of meeting the needs of our rapidly ageing society - and, as a result, build a better society for everyone. 

By way of example, below are the recommendations from just one part of the report - the section aimed at incentivising greater choice for older people when it comes to housing: 

"Central government should drive progress by:

1. Incentivising a range of OPH/LLH options including community-led models and moving towards the overall housing stock being more suitable for people as they age: Recognise the heterogeneity of senior citizens and incentivise a range of OPH/LLH options to be scaled up, in order to meet the needs of individuals, enhance their wellbeing and create inclusive communities.

2. Setting a target of 10% of delivery through the Affordable Homes Programme being for OPH/LLH, in terms of grant funding to support the capital costs of developing affordable age-friendly and inclusive housing in England. This should be accompanied by a review of rent and service charge settlements, and how the revenue operating costs should be best funded, to encourage providers to bring forward schemes.

3. DHSC reviewing support for the Care and Support Specialist Housing Fund to set aside capital and revenue funding for service-led housing providers to bring forward proposals for development of OPH/LLH to meet the needs of senior citizens and adults with disabilities or mental health problems.

4. Developing measures which encourage homeowners to adapt their own homes for later life, such as public campaigns, guidance, changes to value added tax (VAT) on adaptations, or low-cost loans.

5. Radically improving the efficiency of the Disabled Facilities Grant.

6. Recognising those who work in service-led housing care and support roles in all plans to grow the adult social care workforce, and ensuring the roles and skills required in service-led housing are considered in DHSC plans for a Care Workforce Pathway for Adult Social care.

Local systems should work together to:

7. Understand the needs and preferences of senior citizens living in their local community and build housing to suit their varied needs.

The industry should:

8. Work in partnership with relevant stakeholders to come up with creative solutions that enable senior citizens to access the housing choices that best meet their needs.

9. Adopt the Care Workforce Pathway to ensure staff have the opportunities to grow their skills and progress."

One size does not fit all: We need more of everything. 

Another key theme of the report is that there is no one ‘ideal’ way of providing homes for older people. It is a diverse and segmented market. We need more of everything.

The report divides the market into the following broad typologies, and makes a compelling case for dramatically increasing levels of supply in ALL of them: 

Later Living Homes/housing typology

Mainstream housing	Community-led housing	Service-led homes/housing with support Supported living	Service-led homes/housing with care Assisted living	Care homes
e.g., existing, new build and adapted homes, rightsizing homes, bungalows, stacked bungalows with lift.	e.g., Alms houses, Co-housing, collaborative housing, Shared Lives, home share.	e.g., sheltered homes, independent living or retirement apartments and sometimes bungalows.	e.g., extra care, assisted living, integrated retirement communities, retirement villages.	e.g., residential and nursing homes.
Age-friendly, dementia-inclusive, self-contained homes for sale or rent.	Age-friendly, dementia-inclusive, self-contained homes or shared homes for sale, shared-ownership or rent with like-minded people.	Age-friendly, dementia-inclusive, self-contained homes for sale, shared-ownership or rent.	Age-friendly, dementia-inclusive, self-contained homes for sale, shared-ownership or rent.	Age-friendly, dementia-inclusive, communal living with own bedrooms and often en-suite bathroom.
Offers no extra services.	Offers companionship but no extra services.	Offers 5 days a week on-site staff, who provide support (e.g., help to access care and domestic services, if needed). Meaningful activities and emergency call systems.	Offers 24-hour on-site staff with optional on-site care and domestic services. Meaningful activities and technology enabled care.	Offers 24-hour on-site care and support, plus on-site nursing (nursing homes only). Visits from GPs, pharmacists and other health providers. Meaningful activities and safe environment.
No shared facilities	Sometimes have access to a shared lounge, kitchen, laundry facilities, gardens.	Usually have access to a shared lounge, laundry facilities, gardens and a guest room. Sometimes, including a restaurant or café alongside leisure and wellness facilities (e.g., gyms, hairdressers, activity rooms).	Always have access to a shared lounge, laundry facilities, gardens and guest room. Usually, including a restaurant or café, alongside leisure and wellness facilities (e.g., gyms, hairdressers, activity rooms).	Always have access to a shared lounge and gardens. Always, including meals in a dining room alongside leisure and wellness facilities (e.g., gyms, hairdressers, activity rooms).
Single homes	Sizes vary considerably;	Sizes vary considerably, often 40 + units.	Sizes vary considerably, typically 60 + units.	Sizes vary considerably, new care homes are typically built at 60+ units

There is also a point made about ensuring that everyone uses the same terminology when discussing seniors housing and a plea for the above categories to be adopted as more standardised language for discussing the sector moving forward. 

There are specific planning-related changes that can help.

Perhaps unsurprisingly, as planning is a particular pain point for the sector, there are a fairly large number of recommendations for changing the planning system's approach to the sector. 

These include:

• allowing CIL funding to be spent on making communities more age-inclusive
• Introducing a planning policy presumption in favour of seniors housing to scale up appropriate housing for an ageing population.
• Revising the use class definitions guidance to clarify which use class(es) would apply to the various forms of seniors housing with due consideration to the design and operational requirements, including types and levels of service and care.
• Revising the NPPG and developing a new National Development Management Policy (NDMP) to positively profile seniors housing and include specific agreed requirements for LPAs to allocate sufficient land in varied locations (town centre to greenfield) and recognise the nuances of the form and function of the various types of provision.
• Reviewing regulations - and in the interim, revising guidance to LPAs - on planning obligations to recognise that seniors housing schemes face significant viability challenges arising from the higher upfront and ongoing operational costs compared to mainstream housing.
• Introducing a presumption that service-led housing will not be able to contribute to Affordable Housing and should be exempt from Community Infrastructure Levy (CIL) payments. 
• Section 106 contribution requirements for seniors housing should also be reviewed in light of the wider benefits such schemes provide, the profile of residents and their more specific needs.
• Establishing a common standardised methodology for local assessment of minimum need for the various forms of seniors housing. 
• The NPPG should make clear that all forms of housing for senior citizens and health and social care workers contribute towards the overall housing numbers, as well as, having distinct characteristics of benefit.
• Guidance relating to land use should be clear that the overall need cannot be met by over-provision in one subcategory of seniors housing at the expense of others.
• Requiring LPAs to co-produce a Seniors Housing Strategy in consultation with senior citizens with lived experience, local communities including faith groups, public and private sector providers, which is based on a robust local assessment of need and supported by the Integrated Care Board and the local Social Care funding body. 
•  Where a Local Plan is not up to date, the Strategy should be incorporated into the emerging Local Plan and, where there is an up-to-date Local Plan, the Strategy should be adopted as a Supplementary Planning Document.
• Requiring Homes England and local authorities to utilise a sufficient proportion of their own land in suitable locations for Seniors Housing to ensure the ageing population’s needs are being met through public sector investment.
• Requiring LPAs to allocate sufficient land (including town centre locations, greenfield sites and potentially green belt sites) for Seniors Housing to be developed at a scale that enables viable and affordable options for senior citizens to right size. Where an LPA is unable to allocate sufficient land to meet the needs of their ageing population, the local plan should include an exceptions policy.
• Rewarding high performing LPAs.  Where a local authority has a proven track record of planning Seniors Housing with successful delivery, a delivery grant could be considered to reflect the benefits of Seniors Housing reducing burdens on local and NHS infrastructure as well as freeing up family homes.
• Ensure that local plans and local design codes jointly incorporate guidance for local decision-makers to better appreciate the characteristics of Seniors Housing and age-friendly and inclusive placemaking.

Taken together this is a comprehensive package of reforms that could really help to springboard seniors housing into the mainstream and should, as a result, be welcomed…. however, the points made around CIL and s.106 contributions are likely to be met by resistance, given the current state of local government resourcing, unless there is a clear steer on the issue from the central government (and a wider range of financial support for high performing LPAS)

But it is a much broader issue than that….

It is abundantly clear, however, that planning reform alone will not unlock the changes that the taskforce is calling for. The report also urges reforms to:

• review and introduce new tenures or forms of occupying seniors housing, that are better aligned to the needs of residents and operators of seniors housing schemes.
• improve regulation of the sector to increase both consumer and investor confidence in the sector. 
• unlock and support investor appetite for the sector and encourage new entrants into the market.
• amend SDLT and increase the provision of home improvement grants to encourage downsizing and make the adaptation of existing housing easier and more affordable.
• Upskill our care and social services workforce, and providing better, clearer career paths for a much needed and vital workforce. 
• enhancing innovation, research and professional development within the sector. 
• adopt new building standards for accessible housing; and
• move the need for adaptable, accessible, inclusive homes and communities into the very centre of housing policy - in short - to move seniors housing firmly into the mainstream. 

It is a clarion call for a wide-spread systemic shift in our approach to both housing and ageing - across the whole of society. 

The report makes it abundantly clear that this is not just a planning issue. It affects all of us. 

Government response 

So, how did the government respond to this thorough, and well-researched, call to action?

Well, if I am to heavily paraphrase the Housing Minister's Written Ministerial Statement, they said they would think about it. 

To be more exact, they said that they would give “careful consideration to the many recommendations set out in the report”.

They did, however:

• Recognise the importance of older persons housing as a sector; and
• commit to working with PAS to provide more guidance "on how planning use classes apply to specialist Older People’s Housing

Which means that at least one of the recommendations is being taken forward.

If nothing else, that is an encouraging start…. 

 

 

 

*I am unashamedly focussing on the findings relating to planning here. I am a planning lawyer, after all….

** Department of Health and Social Care

We face a looming problem of under provision of OPH/LLH
Developing new OPH/LLH is challenging for many reasons, but it is hampered further due to the complexities in the planning system in England. Analysis for the Taskforce has found that planning consents granted in England for OPH/LLH are low and have fallen from about 180 in 2015 to just 80 in 2023. Worryingly, approval rates were found to be particularly low for applications with more than 120 units, although providing service-led housing (supported living and assisted living) at affordable prices requires higher numbers of units to drive economies of scale.”