CIH response to adult social care fair pay agreement process consultation

The consultation document, and fair pay agreement proposals cover people wholly or mainly working in connection with social care with adults aged 18 and over. Social care is defined as ‘any form of personal care or other practical assistance provided by individuals who, by reason of age, illness, disability, pregnancy, childbirth, dependence on alcohol or drugs, or any other similar circumstances, are in need of such care or other assistance.’

This is a broad definition that will potentially encompass housing support workers within supported housing services (and any floating support offered within mainstream housing), both those directly supporting residents and managers of such post holders. Many support workers help residents to manage their tenancies and pay rent, ensure they have their full income entitlement, connect to employment, engage with GPs and other medical experts where relevant, reconnect with families, etc.

As such, if this definition is maintained, representation of housing support workers, and of supported housing providers/ landlords must be involved in the negotiating body. Many providers/ landlords are members of the National Housing Federation but not all, and consideration should be given as to how smaller voluntary sector charities are represented as well. It is important that the different elements of the care and support sector are considered equally and that the process delivers an equitable approach to the pay levels, terms and conditions across the sector, to ensure that recruitment and retention is maintained or improved, and value given to all different roles.

This should also be encompassed in the guidance, to support employers to identify and understand what roles/ services are within or outside the scope.

The section ‘the role of local government’ in the consultation document proposes a package of measures to ensure local government has a strong role in the negotiation process. This includes the following:

• Specifying within the remit letter that the ASC Negotiating Body must consult with local government and consider their views
• Building the role of local government into the terms of reference for the ASC Negotiating Body and the roles and responsibilities of the chair
• Local government representatives will be able to provide the Secretary of State with a written assessment of the proposed fair pay agreement, which the Secretary of State must give due regard to when deciding whether to ratify an agreement.

Do you agree or disagree with our proposed approach for involving local government in the fair pay agreements process?

Agree

The role of local authorities in both provision and commissioning of services makes their role critical to consideration and delivery of the fair pay agreement. However, the role of local authorities is pivotal to the wider issue of shifting services to those that support prevention and/ or reduction of dependence on high cost services, as identified in the Care Act 2014. This includes services such as reablement in housing settings, and supported housing more generally.

The value of such services in reducing the dependence and therefore cost of care provision will be a significant factor in helping to maintain a manageable settlement across the adult care sector. Research across different models of supported housing had demonstrated its value in terms of increasing independence and benefits of savings to other public sector services, including health and justice systems.

For example, recent research into supported housing by the NHF estimated that supported housing saved the public purse £3.5 billion every year, which could increase to £6 billion a year by 2040, if the additional 28,400 new supported homes needed every year was delivered. In the process, NHF research shows it would provide 52,000 new jobs and add around £4 billion a year to the national economy.

(CIH has responded with evidence of the importance of decent housing for adult social care in its submission to the Casey Commission, available here: CIH submission to the Casey Commission on Adult Social Care.)

The capacity of local authorities - in finances, skills and expertise - to commission supported housing/ housing related support services must therefore be considered and increased, as part of the broader context to support the sustainability of the wider adult social care sector. As it stands currently, many contracts commissioned for supported housing services are short term and reducing, leading some providers to close services or withdraw from the sector (see more below). The impacts of the fair pay agreement must reflect the reality of costs of providing safe and good quality services, and local authorities should be appropriately funded to deliver this.

Government should also be clear how other departments will be consulted and involved, notably MHCLG and DWP, to ensure costs are covered. Many supported housing providers already pay above minimum wages, and there will also be further costs associated to meet the National Supported Housing Standards once developed, as required in the Supported Housing (Regulatory Oversight) Act.

Currently the supported housing sector is struggling to meet revenue costs, and many services are being lost or at risk.  For example, an NHF survey in 2025 highlighted that 71 per cent of supported housing landlords which responded believed that, without long term sustainable funding, some of their services would close or be decommissioned, and 22 per cent would consider leaving the sector completely. NHF estimate this would potentially mean the loss of 50,000 homes. This came after the 2024 survey that revealed one in three providers had closed schemes in the previous 12 months and three in five planned to close schemes in the future.

We have noted above that the definition set in the consultation document is wide and potentially will include housing support roles in scope as well as staff providing personal care. Most social housing providers are regulated by the Regulator of Social Housing, and there will be requirements to meet a Competence and Conduct Standard that will cover performance and training (and qualifications at senior manager and director level) but not pay levels or terms and conditions. Whilst staff wholly involved in providing support and care are not directly covered by this standard, those whose roles may include an element of support, and particularly managers in setting where support and care is offered may be.

We would encourage government to consider where the responsibility and focus for additional employment matters such as training and development should lie in these cases, and ensure that there is clarity for employers and relevant staff. We would not want to see overlapping regulation but neither it is appropriate that roles should ‘fall through the gaps’ in terms of promoting skills and expertise to help people who need support and care. The guidance mentioned in the consultation proposals could usefully extend to cover such matters and make clear what staff roles, and what issues of employment such as training and development sit for housing support staff and managers.

For details on the consultation visit the government's website.

For more information on our submission please contact Sarah Davis, policy manager: sarah.davis@cih.org.