1. Adult Safeguarding and Housing: the implications of the Care Act 2014 and related statutory guidance
Imogen Parry
Independent Safeguarding Adults Consultant, Researcher and Trainer for the Housing Sector
and
Co-Chair of the Housing and Safeguarding Adults Alliance
SHIP Conference January 2015

2. Learning objectives of this workshop:
Know what you/your organisation needs to do to be ready for implementation of the safeguarding aspects of the Care Act 2014 and related statutory guidance
Understand the lessons for housing providers from Adult Serious Case Reviews
Be better equipped to address difficulties relating to partnership working
Be able to identify how to improve your organisation’s approach to adult safeguarding, operationally and strategically

3. Weak regulatory and legislative responsibilities, contributing to:
Disincentives and barriers for all social housing providers to be involved in adult safeguarding
Weak regulatory and legislative responsibilities, contributing to:
lack of a safeguarding culture
insufficiently trained staff
under-reporting of abuse
limited data on vulnerabilities of tenants
Problems and complexities of partnership working

4. New drivers and incentives for housing providers’ engagement in adult safeguarding (1)
Increasing public, political and media awareness of abuse
Reputational risk for all providers of services for adults at risk
Increasing numbers of adults at risk living in social housing
Safeguarding links to other agendas that housing is (or should be) engaged in: anti-social behaviour; crime reduction; domestic abuse; disability hate crime; health and well-being

5. New drivers and incentives for housing providers’ engagement in adult safeguarding (2)
Evidence through SCRs of failures of housing providers to prevent murder, abuse and neglect of adults at risk, including those living in general needs housing
SCIE guidance on ‘Adult safeguarding for housing staff’
Care Act 2014 and statutory guidance

6. From ‘No Secrets’ to the Care Act
Review of No Secrets 2008/9
Consideration of safeguarding included in the Law Commission review of Adult Social Care Law 2010/11
Care and Support Bill published July 2012
Care Bill published May 2013
Care Act 2014 received Royal Assent May 2014
Statutory guidance consultation June – August 2014
Final statutory guidance published October 2014
Care Act and statutory guidance due for implementation from April 2015 – see

7. The limitations of ‘No Secrets’ 2000
Statutory guidance – not legislation
Preceded the Mental Capacity Act 2005, much case law arising from the Human Rights Act 1998, DoLS
Referred to ‘vulnerable adults’ (not ‘adults at risk’) and ‘adult protection’ (not ‘adult safeguarding’)
Limited list of types of abuse
Focus on process and procedures which contributed to ‘risk aversion’ not ‘outcomes’ (MSP)
Lack of clarity about differences between poor practice, abuse, crime
‘Only’ sheltered and supported housing staff included

8. Statements of Government Policy on Adult Safeguarding
Issued in May 2011 and May 2013; now incorporated into the Care Act statutory guidance 2014
Set out adult safeguarding principles:
Empowerment – presumption of person led decisions and informed consent
Prevention – it is better to take action before harm occurs
Proportionality – proportionate and least intrusive response appropriate to the risk presented
Protection – support and representation for those in greatest need
Partnership – local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting abuse
Accountability – accountability and transparency in delivering safeguarding

9. Who is a ‘vulnerable adult’ or ‘adult at risk’?
Under the Care Act 2014 safeguarding duties apply to an adult who:
(a) has needs for care and support (whether or not the authority is meeting any of those needs)
(b) is experiencing, or is at risk of, abuse or neglect, and
(c) as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it.

10. The Care Act 2014 - safeguarding sections 42 - 45
New duty for local authority to carry out enquiries (or cause others to) where it suspects an adult is at risk of abuse or neglect.
Requirement for all areas to establish a Safeguarding Adults Board (SAB)
SABs to carry out safeguarding adults reviews (SARs)
New ability for SABs to require information sharing from other partners to support SARs or other functions.
Enquiries – can they be delegated? Suggestion that housing may be asked to conduct some. Concerns about training? Term replaces referral and is preceded by concern which replaces alert (AVA consultation doc).
SABs to bring together LA, NHS and police to coordinate activity to protect adults from abuse and neglect.Statutory members are LA, NHS and police but housing is listed in the guidance as a possible additional member if the SAB choose. My survey on this.
SARs – requirement on SABs to conduct SARs into cases where someone who is experiencing abuse or neglect dies or there is concern about how authorities acted, to ensure lessons are learned. Previously called SCRs and will be compulsory to do and to publish, unlike SCRs
Information sharing provisions should go a long way to address some of the significant problems for front-line housing staff. Plus there is lots in the statutory guidance on the need for information sharing eg ‘fear of sharing information must not stand in the way of promoting and protecting the well-being of adults at risk of abuse and neglect’ (para 14.14).

11. The Care Act 2014 – other sections and guidance relevant to safeguarding adults
Well-being
Co-operation
Information sharing
Prevention focus
Advocates
Level of needs not relevant
Wide scope for what constitutes abuse or neglect
Additional types of abuse included
Well-being (includes protecting people from abuse and neglect) (S1(3)(g). The definition of well-being now includes ‘suitability of living accommodation’.
Cooperation between partners The Act sets out five aims of cooperation including protecting adults with care and support needs who are currently experiencing or at risk of abuse or neglect (para 15.16, Chapter 15). RPs are now explicitly listed in the Act as one of the partners a LA must co-operate with when considering and planning a person’s need for care and support. S6(3)(d). Duty on LAs to promote integration with NHS and other services including housing
Prevention focus – (S2 (1) . Three levels: primary to stop/prevent care and support needs from developing from those who do not have them – eg through health promotion (WEAAD?) or action to reduce isolation; secondary prevention, (delay) for people at risk of developing needs – eg housing adaptations, telecare, advice, early intervention to prevent escalation; tertiary prevention (reduce) for people with established needs to help improve independence – eg through reablement/rehab.
Advocates (S68) introduced for first time for people subject to a safeguarding enquiry or a SAR and who would have substantial difficulty in being involved in contributing to the process and where there is no other appropriate adult to assist.
‘Level of needs not relevant and the adult does not need to have eligible needs for care and support, or be receiving any particular service from the local authority, in order for the safeguarding duties to apply’ (para 14.5)
Local authorities should not limit their view of what constitutes abuse or neglect (para 14.17)

12. Main types of abuse (italicised are new)
Physical
Psychological/emotional
Sexual
Financial
Neglect
Discrimination
Organisational abuse
Domestic abuse
Sexual exploitation
Modern slavery
Self-neglect

13. Does the Care Act go far enough to safeguard adults?
The Care Act is a major improvement on ‘No Secrets’
But there:
are resource concerns
is no power of entry or duty to report despite much lobbying and debate
may be insufficient ‘teeth’ for SABs to be effective
may continue to be confusion about thresholds and sometimes an absence of systems for low level concerns
are insufficient references to the need to make links with other issues such as domestic abuse, hate crime and ASB
are continuing contradictions about consent issues
is insufficient emphasis on need for improved practice by all professionals, including attitudes towards partnership working and capacity assessments
No doubt that putting safeguarding adults on a statutory footing will raise its political and professional profile across all sectors and maybe even with the public and the media, and for housing in particular the focus is on ALL housing providers, not just providers of sheltered and supported housing as indicated in No Secrets. My next slides indicate huge changes that will have to be made by housing providers to implement the safeguarding aspects of the Care Act and associated guidance
But there are:
inevitable concerns about resources – there’s lots of talk about this for social services but housing providers need to be budgeting for their new obligations now. Currently lots of controversy about eligibility criteria - piece in Inside Housing 26 June ‘Tenants at risk over Care Act’ …. And recent ADASS figures on underfunding.
Power of entry , duty to report
Although the guidance states that the level of need is irrelevant it is hard to see how councils will function without some kind of threshold to progress an alert to a referral. There is an absence of MASH (or VARM) systems for low level concerns in many areas of the country (encouraged in para 14.29)
Questions remaining over whether self-neglect will be included in the final guidance due in October – there is currently silence on this in both the Act and the guidance but Question 65 is hinting at it I think: ‘Are there any other types of behaviour that should be explicitly stated in the guidance? See SCIE resources on this issue
Insufficient references to overlaps between safeguarding and other issues such as DA and ASB – if you agree, you could submit an answer to question 67 ‘Are there additional aspects of the SAB’s work that we should highlight?’ (MCA?)
The issue of refusal of consent (para 14.55) needs expanding with greater clarity of the circumstances when a referral should NOT be made nor an enquiry undertaken. The recent SCIE guide refers to this issue states that a person’s choice should be respected unless one or more of the following applies: very high risk to the individual, coercion is involved, other people are at risk, the alleged abuse has care and support needs and may also be at risk, the victim lacks the mental capacity to make a decision about their safety, a serious crime has been committed, staff are implicated in the crime. ( SCIE cite Parry.I. (2013) Adult safeguarding and the role of housing, Journal of Adult Protection Vol.15 No

14. The Care Act statutory guidance for adult safeguarding – housing implications (1)
14 references to housing providers, housing support providers
Agencies should identify a senior manager to take a lead role in organisational and inter-agency safeguarding arrangements
Although not a statutory member of SABs, housing providers and housing support providers may be invited
Housing support workers may be asked to ‘make enquiries’
The Care Act draft regulations and guidance were published in June. Responses to any of 84 questions had to be in by 15 August. The final guidance was published in October. Chapter 14 provides guidance on Sections and 68 of the Care Act and includes:
14 references to housing providers and housing support providers
States that a senior manager should take a lead role (para ) ‘Regular face-to-face supervision from skilled managers is essential to enable staff to work confidently and competently with difficult and sensitive situations’ (para and ). Managers have a central role in ensuring high standards of practice and that practitioners are properly equipped and supported (para ). Anyone in contact with the adult must... have access to practical and legal guidance, advice and support... including local inter-agency policies and procedures (para 14.40).
‘SABs may wish to invite additional partners to some meetings depending on the specific focus or to participate in its work more generally. Examples include representatives of housing providers, housing support providers’ (para )
The Act (S42(2)) and guidance (para 14.84) make it clear that an enquiry could be undertaken by people other than the local authority (the lead agency) including ‘a housing support worker’ .

15. The Care Act draft statutory guidance for adult safeguarding – housing implications (2)
All housing providers and housing support providers should have clear operational policies and procedures in adult safeguarding
All housing staff must be:
familiar with the six principles underpinning adult safeguarding
trained in recognising the symptoms of abuse
vigilant and able to respond to adult safeguarding concerns
Policies and procedures (eg para 14.41). Specific to housing, the guidance states that ‘all service providers, including housing and housing support providers, should have clear operational policies and procedures that reflect the framework set by the SABs in consultation with them (para ).
See the Housing and Safeguarding Adults Alliance webpage for examples of good practice policies and procedures by Together Housing Group (Sue Lewis)
All housing staff must be:
familiar with the 6 principles which are: empowerment, prevention, proportionality, protection, partnership, accountability. The six principles that underpin adult safeguarding apply to all sectors and setting including housing providers (para 14.13)
trained..including via multi-agency training set by the SAB (para ) that covers local multi-agency policy, procedures and professional practices (para ) and is at all levels, updated regularly with no staff group excluded (para ). Staff must know: signs and types of abuse, who to report to, how to support adults to think and weigh risks and benefits of different options (para ).
vigilant and able to respond to adult safeguarding concerns, including housing (para 14.29, 14.30).
Do your own organisation’s current adult safeguarding policies, procedures and guidance include all these points?
Recommend that you self assess against the Housing and Safeguarding Adults Alliance checklist against the safeguarding aspects of the Care Act statutory guidance

16. What is ‘Making Safeguarding Personal?’
Combines ‘personalisation’ approach with safeguarding
Intention of MSP is to facilitate person-centred outcome-focused responses to adult safeguarding
Key messages from MSP development project:
Focus on what outcome service user wants, which may not just be about being safe – empowerment and being in control may be as important
Avoid putting them through a process
Work with service users’ networks and strengths

17. Implementation of Care Act and MSP – letter from DH, Nov 2014
Rather than seeking to update existing policies and procedures and ‘bend’ them to fit the aims of the Care Act we urge local authorities to sit down with their partners to agree how their new arrangements will work’
The basis for these discussions should be:
the statutory guidance
MSP values, standards and guides
The diagrams 1A and 1B on pages of the statutory guidance

18. Adult safeguarding self assessment checklist against the Care Act statutory guidance for housing and housing support providers (1)
Question
Para reference in the statutory guidance
Yes No
In progress
Comments/ evidence 1a
Do you have a senior manager with strategic responsibility for safeguarding? OR
14.187
14.109 b
Do you have an operational lead for adult safeguarding? 2a
Have you a safeguarding adults policy and internal procedures that cover ALL staff and are regularly reviewed?
14.29, 14.30, ,14.54, , ,
Do they include the 6 principles?
Do they include guidance on record keeping?
Are staff vigilant about adult safeguarding?
14.13
14.87,
14.29, 14.30 c
Do you have internal systems in place to ensure compliance with policies and procedures?

19. Adult safeguarding self assessment checklist against the Care Act statutory guidance for housing and housing support providers (2) 3
Have you regular safeguarding training for all staff in contact with adults at risk?
14.30, 4
Can staff access regular face to face supervision from skilled managers?
Can staff access practical and legal guidance, advice and support?
14.46,
14.40 5
Are you involved in a Safeguarding Adults Board (SAB) or housing sub group? If you are not directly involved, are you able to get involved via a housing representative on any SABs? Have you worked with other local housing providers to seek housing representation and other engagement with the SAB?
14.117 6
Have you discussed (internally and with the adult social care safeguarding lead) the implications of S42(2) in the Care Act and related para in the guidance of the possibility of being asked to ‘make ’ enquiries?
14.84, 7
Have you sought to engage with the local multi-agency safeguarding hub (MASH) (if one exists?)
14.164

20. Adult safeguarding self assessment checklist against the Care Act statutory guidance for housing and housing support providers (3) 8
Has anyone in your organisation made effective links with Local Authority Safeguarding Leads to ensure cooperation and information sharing, improve joint working, addressing barriers?
Are roles and responsibilities clear and is there collaboration at all levels?
14.53, ,
14.167 9
Do you have arrangements in place to ensure review and learning? 10
Do you engage with all customers regarding safeguarding (eg information, awareness raising).
14.11,

21. Serious Case Reviews
A review of the circumstances of the death of a vulnerable adult if abuse or neglect was suspected
‘The overriding reasons for holding a review must be to learn from past experience, improve future practice and multi-agency working’ (ADASS and LGA, 2013)

22. My research on adult Serious Case Reviews
Half the 21 subjects lived in specialist housing (or received specialist housing services), half lived in general needs housing
All but 2 individuals had either physical health or mental health issues, the other 2 had learning disabilities
3 cases showed between 5-7 features indicating vulnerability
Thematic analysis identified 6 themes/lessons

23. Summary of findings Internal lessons for housing providers:
Poor data base of vulnerabilities (7 cases)
Poor contract/support monitoring (4 cases)
Narrow focus/poor understanding of safeguarding/not referring (10 cases)
External lessons for housing providers:
Exclusion of housing from information sharing/ assessment/ monitoring (11 cases)
Thresholds too high/ failure to capture low level concerns (7 cases)
Problems with Adult Social Care: assessments (including risk, capacity); diagnosis; choice (16 cases)

24. 21 housing related SCRs BANES, 2013: ‘PQ’ Bucks, 2010: Mr B
Bury, 2010: ‘Adult A’
Cornwall, 2007, 2009: Steven Hoskin, JK
Coventry, 2012: Mrs C
Dorset ,2013: JT
Leics, Leics and Rutland, 2008: Fiona Pilkington
Luton, 2011: Michael Gilbert
North Tyneside, 2011: Cynthia Barrass/Adult A
North Yorkshire, 2012: Robert
Sheffield, 2004: Margaret Panting
Southampton, 2012: Mr A
Stockport, 2011: Martin Hyde
Sunderland, 2012: Mrs AM
Surrey, 2010, 2010: ‘CC’, 0001
Tameside, 2011: David Askew
Torbay, 2011: Ms Y
Warwickshire, 2011: Gemma Hayter
Worcestershire, 2010: A1

25. A. Poor data base of vulnerabilities
‘Commissioners cannot organise the improvement of services unless they know quite a lot about the people using them’
(The Information Governance Review, Dame Fiona Caldicott, 2013, p.14).

26. A. Poor data base of vulnerabilities
Failure by landlords to record the vulnerabilities of all tenants was a contributory factor to the eventual death or serious harm of the 7 individuals
The reasons for these poor data bases included:
not understanding the nature of vulnerability
not asking the right questions
not recording the answers
not having an adequate IT system to record vulnerabilities.
In some cases, even where vulnerabilities were recorded, there were problems with the incompatibility of the data with other agencies’ systems.

27. B. Poor support/contract monitoring
Although most SCR discussion on contract monitoring focuses on failures by Adult Social Care (ASC), housing agencies can also be culpable.
The monitoring role of housing staff was often not made clear in the SCRs but this role is recognised in the Quality Assessment Framework of the Supporting People programme

28. C. Narrow focus/ poor understanding/ not referring
Failure by housing staff to refer abuse or hate crime into safeguarding was a contributory factor in the deaths or serious harm of 12 individuals living in social housing

29. ‘All staff need to have a greater curiosity and enquiring approach about what they observe and to be aware when they need to pursue further information either directly with the individual or through other agencies’
(SCR concerning PQ, Bath and North East Somerset, para.24)

30. Reasons for under-reporting of abuse by housing staff include:
A narrow, uninformed focus by the housing provider
Different definitions of vulnerability
Erroneous belief that consent by the victim is always necessary
Incorrect assumption that evidence is needed before making an alert or referral
Inadequate policies regarding service refusal and insufficient understanding of the Mental Capacity Act 2005
Poor practice in offering accommodation to victims rather than addressing the abuse through safeguarding procedures.
Narrow uninformed focus by housing provider: David Askew, Fiona Pilkington, Steven Hoskin, PQ/BANES, Cynthia Barrass, Gemma Hayter, Michael Gilbert, Mr A/Southampton, JK/Cornwall
Different definitions of vulnerability – Robert
Erroneous belief that consent of the victim is always necessary – Margaret Panting
Incorrect assumption that evidence is needed before making an alert or referral – JT, Dorset
Inadequate policies regarding service refusal (Mr A/Southampton) and insufficient understanding of the MCA (David Askew, Michael Gilbert, Mr A/Southampton).
Offering victim new accommodation (David Askew, South Tyneside LGO case)

31. D. Exclusion from information sharing
‘The duty to share information can be as important as the duty to protect patient confidentiality’
(The Information Governance Review, Dame Fiona Caldicott, 2013, principle 7, page 21).

32. Quote from SCR on the exclusion of housing from information sharing
‘Support Officers were not seen as professional by social care colleagues. A support officer made a referral to ASC and was asked to leave the resultant meeting, even though she was an alerter and had a lot of understanding of the situation. Housing is outside the loop at present.’ (Steven Hoskin/Cornwall)
Steven Hoskin was a 39 year old man with learning disabilities, living in housing association general needs accommodation, who terminated support from Adult Social Care. He was tortured and murdered one year later, in July 2006, by teenagers who had for some time been exploiting him and using his house as a base for under-age drinking.

33. E. ASC referral thresholds too high, failure to capture low level concerns
The threshold issues in the 7 cases support the argument in favour of low thresholds that responding to low level concerns (that include harassment and disability hate crime) helps to prevent serious harm or death.

34. F. Quotes from SCRs on problems with Adult Social Care: choice; assessments (including risk, capacity); diagnosis (1)
‘There was a lack of co-ordination of responses as JK’s situation deteriorated and incidences occurred that could have been regarded as safeguarding alerts. Services got confused about choice and risk, they lost the ability to work in anything but a reactive fashion. There was no shared multi-agency assessment about her needs and the risks she faced.’ (JK/Cornwall)
‘Steven’s ‘choice’ to terminate contact with ASC was not investigated or explored with him, or other key agencies involved in his care, even though such choices may compound a person’s vulnerability; may be made on the basis of inadequate or inappropriate information; or result from the exercise of inappropriate coercion from third parties.’ (Steven Hoskin/Cornwall)
JK was a frail, reclusive, self-neglecting 76 year old woman who lived alone in rented housing association property and who was discovered dead at her home in November 2008.
Steven Hoskin was a 39 year old man with learning disabilities, living in housing association general needs accommodation, who terminated support from Adult Social Care. He was tortured and murdered one year later, in July 2006, by teenagers who had for some time been exploiting him and using his house as a base for under-age drinking.

35. F. Quotes from SCRs on problems with Adult Social Care: choice; assessments (including risk, capacity); diagnosis (2)
‘The presumption of capacity under the MCA 2005 does not mean that professionals are exempt from asking challenging and searching questions in relation to individuals who are making choices that are problematic. The presumption of capacity does not exempt authorities and services from making robust assessments where a person’s apparent decision is manifestly contrary to his well-being.’ (Michael Gilbert/Luton AND Adult A/Stockport)
Michael Gilbert (Adult A), age 26, was murdered in early 2009 by a family who had kept him as a slave and to claim his benefits. A care leaver, heavy cannabis user, serially homeless and with possible undiagnosed mental health problems he had been deemed ineligible for Adult Social Care services.
Adult A/Martin Hyde was a 22 year old man who used alcohol and cannabis, a care leaver with a mild learning disability but with no formal diagnosis establishing his vulnerability or capacity and therefore considered ineligible for services. He lived in accommodation run by Stockport ALMO and received floating support. Martin was murdered in November 2009 because ‘he owed £15 to the girlfriend of one of the men convicted of his murder’.

36. F. Quotes from SCRs on problems with Adult Social Care: choice; assessments (including risk, capacity); diagnosis (3)
‘A key finding from this review is how an alcohol dependent individual, with serious health issues and in need of safeguarding was consistently viewed as making lifestyle choices’ (Ms Y/Torbay)
‘The housing agency make repeated attempts to refer Gemma to Adult Social Care but were told that she did not have a learning disability and had capacity to make her own choices’ (Gemma Hayter/ Warwickshire)
Ms Y was a 30 year old woman with alcohol and drug problems and a highly dysfunctional lifestyle which included several periods of homelessness. She received extensive support from the drop in centre of the town’s homeless unit, funded by Supporting People. Just prior to her death she was admitted to a residential care home from which she went missing. She was later found dead of an alcohol related illness in a public place in October 2010.
Gemma Hayter, age 27, was murdered by a group of ‘friends’ in August Although there were changing and conflicting diagnoses over time regarding the nature of her disabilities and behaviour, she had a profoundly chaotic lifestyle and was known to be a vulnerable adult, prone to exploitation and ‘mate crime’. She lived alone in council accommodation and received floating support to help her maintain her tenancy.

37. F. Problems with ASC risk and capacity assessments; diagnosis
Failures of assessment , diagnosis and multi-agency working were contributory factors to the death or serious harm of the individual.
Common themes included:
failures to assess capacity or risk; assumptions rather than assessments
the need for effective multi-agency working that led to holistic assessments (which were focused on the victims, not their families)

38. SCRs regarding deaths in sheltered and supported housing – key issues
Mr B/Bucks – sheltered housing staff not given care plan, not officially able to support tenants (but rang him daily)
Mrs AM/Sunderland – contradiction re monitoring role of housing support agency
Mr A/Southampton – confusion between care, support and health support regarding respective roles
Mr B/Bucks. A 62 year old man, with a recent history of ill-health and alcoholism and living in sheltered housing. He died in January 2009 from possible neglect by care agencies. ‘Housing Support Agency’ provided a sheltered housing officer who did not carry out assessments and was not provided with a copy of the support plan of the care agency. The responsibility of the HSA was 80% housing matters and 20% tenant welfare. The HSA had a limited role in respect of welfare of the tenants and relied on ASC and provider care agencies to meet the tenants’ support needs. BUT the SHO contacted the client by phone daily and saw him regularly in the housing complex. While she was on leave for 3 weeks the task was carried out daily by support officers. The SCR was critical of ASC for not requiring the care agency to liaise with the SHO or to share information. The HSA was of the view that other agencies do not respond to either the SHO or to requests from senior managers in the HSA as though they were competent professionals. This can result in gaps in care management and assessments. Greater partnership between agencies involved with tenants in sheltered housing would lead to improved services to those tenants. There is a systemic failure to deal with the HSA as a partner. BUT why didn’t the SHO ask to/get be more involved?
Mrs AM/Sunderland. Socially isolated, pd older woman, died from physical assault by paid carer in Poor information sharing between housing and care agencies. No requirement on sheltered housing staff to monitor care provided by care agency.
Mr A/Southampton. Aged 49, learning and other disabilities, lived in supported housing. Died of natural causes in Dec 2010 but death was preventable as systems in place to deal with his health were inadequate. Confusion by staff from housing management, care, support and health agencies re their own and others’ roles and remits. Care and support staff didn’t deal properly with Mr A’s refusal of help or summon the police when needed or ensure Mr A’s flat was hygenic. Support staff were poorly trained and supervised. There was too much focus on Mr A’s friend Miss B, treating them as a couple and obscuring his needs.

39. SCRs regarding deaths in sheltered and supported housing – key issues
Mrs C/Coventry – insufficient risk assessment of equipment
0001/Surrey – insufficient information sharing meant risks not appreciated
Margaret Panting/Sheffield - warden’s concerns not responded to
Mrs C/Coventry. Mid 80s. Extra care scheme. Died due to asphyxiation when head became trapped between grab handle rail and the side of her bed. SCR recommended that better information is given on scope and limitations of support and care regime on offer, ensure all equipment has visual inspection, risk assessments are carried out.
0001/Surrey. Was an autistic and learning disabled man with a history of severely challenging behaviour and psychotic episodes. Had lived in a long-stay hospital for many years prior to moving to a care home then supported housing. He stabbed a fellow resident in March 2008 in an apparently unprovoked attack. This man had been a resident in the same hospital and care home and the risks inherent in placing them together in a supported housing setting were not fully appreciated.
Margaret Panting/Sheffield A 78 year old woman from Sheffield died in 2001 after suffering “unbelievable cruelty” while living with relatives. After her death a post mortem found 49 injuries on her body, including cigarette burns and razor cuts. She had moved from sheltered accommodation to her son-in-law’s home and five weeks later she was dead.
Prior to Margaret Panting’s move, there had been indications of self-neglect, depression, falls, debt, poor diet, possible financial abuse and frequent fires. Despite the best efforts of the scheme warden to raise her concerns with housing and social services, a referral to a social services assessment team was not made until April 2001, because Margaret Panting did not want the involvement of social services. Even after this eventual referral, a strategy meeting was still not called.

40. Cynthia Barrass – North Tyneside
Missed opportunities by housing provider:
Rent arrears
Refusal to grant access for gas servicing
Garden maintenance issues
Housing provider was ‘reactive’, not proactive
Failure of systems to ensure follow up of the disconnection of gas, to insist on a home visit and to alert social services

41. Overcoming information sharing problems – tips for housing staff
Know about and use all relevant multi-agency information sharing protocols
Set up multi-agency meetings to improve these protocols and address problems
Draw on law and guidance in:
Care Act and statutory guidance
SCIE guide ‘Adult safeguarding and housing’
SCIE Care Act resource ‘Sharing information’ (due Feb 2015)
Increase awareness and understanding of role of housing staff
Ensure that decisions are being taken at the right level within your organisation and within Adult Social Care

42. Tips to housing staff re thresholds
If told that the alert or referral cannot be accepted (as it doesn’t meet their referral threshold or their definitions of abuse or vulnerable adult/adult at risk), consider:
checking what their policy says on referral criteria and definitions. Is their interpretation open for discussion?
reconsidering the facts of your referral – have you left something out or underestimated/downplayed the risks?
ask if they have a mechanism for gathering information on apparently low level cases, especially where there is an emerging pattern of referrals, eg MASH, VARM (quote Pilkington, Hayter)
asking for advice on how to handle the situation yourself or via other agencies
If the case is not accepted and investigated, refer again if circumstances and risks change
Ensure that decisions are being taken at the right level within your organisation and within Adult Social Care
Do you agree with this list? What would you add/qualify?

43. Tips to housing staff encountering problems re assessment, diagnosis, choice
If you are told ‘it is the person’s choice’ (eg to refuse services/intervention/proceed with prosecution) or that ‘they have capacity and the right to make unwise decisions’ consider:
Was the person coerced?
Is anyone else at risk?
Has there been a proper and recent capacity assessment on this issue? Could a joint visit be arranged of social worker and housing worker?
Could there be an over-riding duty of care?
Applying for an advocate (Section 68 Care Act)
Has the person been accurately and recently diagnosed (eg learning disability or mental health issues) and risk assessed? Particular attention should be paid if:
their circumstances have deteriorated and/or
their needs have increased or are very complex and/or
there is a sudden change in behaviour ie ‘an escalating problem’
Ensure that decisions are being taken at the right level within your organisation and within Adult Social Care

44. Summary of action needed by housing providers to improve adult safeguarding
Ensure effective housing representation on SAB, MAPPA, MARAC, MASH, CSP, VARM etc
Housing providers should:
Improve recording of vulnerability on data bases and IT systems to flag up patterns and warning signs (the ‘Cynthia Barrass test’)
Employ internal safeguarding leads
Ensure robust adult safeguarding policies, procedures, guidance and supervision
Train ALL staff, regularly, in adult safeguarding and the Mental Capacity Act 2005
Seek inclusion in current revisions to local multi-agency safeguarding policies, procedures and processes in the light of the Care Act and the Making Safeguarding Personal approach
Instil staff confidence to challenge other agencies
Improve customer awareness of safeguarding
Self assess against the Housing and Safeguarding Adults Alliance objectives and Care Act checklist

45. Final words......
Legislation alone will not address the many difficult issues around adult safeguarding
Multi-agency working in general and safeguarding in particular raise complex issues, for housing and for all agencies
Housing is often neglected in multi-agency work on safeguarding, despite the contribution that front line staff can make
Adult Social Care and housing staff must meet locally to identify and address barriers and to promote best practice
Identify and acknowledge the good practice already happening

46. For further information:
Housing and Safeguarding Adults Alliance:
SCIE guide on ‘Adult safeguarding for housing staff’:
My research on Serious Case Reviews: lessons for housing providers:
Consultancy, training and research on housing and adult safeguarding:

47. Our objectives:
Increase awareness across the social housing sector, in particular non specialist providers of general needs housing, of the need to engage in adult safeguarding
Improve practice within the sector through sharing learning between members and promoting safeguarding adults training
Increase awareness of the economic and social value that participation by the housing sector brings to safeguarding adults across all sectors
Demonstrate the commitment of the social housing sector to improving engagement in safeguarding adults to a range of partners, particularly adult social care staff

48. Our objectives:
Work with statutory partners to address the barriers to effective partnership working, including those relating to information sharing
Improve the strategic engagement of all housing providers with Safeguarding Adults Boards, addressing the barriers
Increase joint working on safeguarding adults between housing providers in any geographical area
Capture and disseminate positive practice, and celebrate success!