The study and methodology

Data underpinning this article are drawn from a Welsh Government commissioned longitudinal post-implementation evaluation of the processes and impacts of the Act which began in April 2016 with the final report being published in July 2018. The evaluation itself involved qualitative and quantitative research methodologies encompassing the following: quantitative analysis of secondary data (taken from the publicly available Stats Wales website (Stats Wales, 2017) encompassing 2015–16 and 2016–17; a survey and review of twenty-two local authorities [in June–August 2016 and again: August–October 2017]; consultation with fifteen national stakeholders [October–November 2016]; six case study local authority areas were then identified and semi-structured interviews with 148 service providers from local authorities, Registered Social Landlords and the third sector were undertaken [March-June, 2017]; two waves of interviews were undertaken with service users [first wave: October 2016–January 2017; n = 154/second wave: June–July 2017; n = 57] and finally, a focus group was undertaken with the Welsh Local Authority Homelessness Network to ‘sense check’ the recommendations for the final report [January 2018].

Defining homelessness in an international context

Before discussing the paradigm shift to preventing homelessness (Shinn et al., Reference Shinn, Baumohl and Hopper2001) it is important to clarify what is understood by homelessness. When defining homelessness, in a European context the categories identified by the European Federation of National Organisations working with the Homeless (FEANTSA), contained in the European Typology of Homelessness and Housing Exclusion (ETHOS) (Amore et al., Reference Amore, Baker and Howden-Chapman2011) are the ones most often deployed (see Busch-Geertsema and Fitzpatrick, Reference Busch-Geertsema and Fitzpatrick2008; Mackie, Reference Mackie2015). Although these are contested (Amore et al., Reference Amore, Baker and Howden-Chapman2011) we adopt them here and throughout the articles included in this themed section. These categories encompass a continuum of experiences of homelessness ranging from: rooflessness; houselessness; insecure housing; to inadequate housing. It should be noted, however, that in the US a narrower definition of homelessness is adopted, and this relates specifically to rooflessness.

Homelessness has been constructed as an analytical category outside of inequality (Farrugia and Gerrard, 2015). It is a complex issue but is often explained as a housing/welfare problem attributed to structural and/or individual causes (Neale, Reference Neale1997). Simply put, the causes include: poverty and unemployment; a shortage of affordable housing; the effects of recession; reductions in housing and other benefits; mental health issues; relationship breakdown; alcohol and substance misuse; time served in prison; traumatic individual events such as bereavement and societal wide events such as war and displacement (Fitzpatrick et al., Reference Fitzpatrick, Kemp and Klinker2000). However, although the causes are well-documented, they are difficult to properly quantify since definitions are not consistent and difficult to monitor and the relationship between them is not always clear (see Fitzpatrick et al., Reference Fitzpatrick, Kemp and Klinker2000). Further, they can play out differently in different contexts (Somerville, Reference Somerville2013). A structural explanation of homelessness locates the reasons for homelessness beyond the scope or agency of an individual, while an agency or ‘victim-blaming’ approach focuses on personal failure or ‘inadequacy’. This also raises issues around who is ‘deserving’ and ‘undeserving’ with regard to homelessness assistance, with the risk that only those households affected by structural causes, rather than their own volition or agency are deemed to be deserving (Neale, Reference Neale1997). In addition, issues of entitlement arise with greater force where a neo-liberal prevailing political economy represents social circumstances as a consequence of the decisions people have made (agency) rather than on structural preconditions (Farrugia and Gerrard, Reference Farrugia and Gerrard2016). A ‘new orthodoxy’ of homelessness research encompasses structural and individual explanations of homelessness. In the face of the complexities involved homelessness legislation has historically operationalised the ETHOS definition of homelessness as a rationing device (Clapham et al., Reference Clapham, Kemp and Smith1990; Neale, Reference Neale1997).

Prevention in an international context

Prevention involves any action or intervention which results in a person avoiding becoming homeless and this captures a range of interventions and policies (Mackie, Reference Mackie2015). The thinking behind contemporary international homelessness policy is that homelessness can and should be prevented (Shinn et al., Reference Shinn, Baumohl and Hopper2001). Whereas previous intervention models involved ‘warehousing’ people who were already homeless in temporary accommodation, it is now widely accepted that preventing homelessness is better than attempting to ‘cure’ it (Mackie, Reference Mackie2014). Where prevention activity is favoured it is construed as ‘shutting the front’ door to homelessness and may be part of a broader strategy to end it (National Alliance to End Homelessness, 2000). It is generally agreed that homelessness should be prevented as it reflects badly on a society that allows it; it is damaging to individuals and communities; and it is also expensive (Mackie, Reference Mackie2014). A shift in global policy, towards a focus on prevention-based initiatives to address homelessness has been evident for some time and is well-documented in Australia (Parsell and Marston, Reference Parsell and Marston2012), the US (Culhane et al., Reference Culhane, Metraux and Byrne2011; Shelton et al., Reference Shelton, Mackie, van den Bree, Taylor and Evans2012), the UK (Clapham et al., Reference Clapham, Mackie, Pritchard, Fitzpatrick, Quilgars and Pleace2009; Wilcox et al., Reference Wilcox, Fitzpatrick, Stephens, Pleace, Wallace and Rhodes2010), Canada (Crane et al., Reference Crane, Warnes and Fu2006), Ireland (Maher and Allen, Reference Maher and Allen2014) and Germany (Busch-Geertsema and Fitzpatrick, Reference Busch-Geertsema and Fitzpatrick2008). In 2008 and in the face of structural challenges associated with poverty and unemployment in Germany and high housing costs in the UK, Busch-Geertsema and Fitzpatrick reported a decline in homelessness levels in these countries and attributed this in part to prevention. There are broadly understood to be three elements to homelessness prevention (Busch-Geertsema and Fitzpatrick, Reference Busch-Geertsema and Fitzpatrick2008):

1. 1. Primary prevention measures – involve activities which may directly or indirectly seek to reduce the risk of homelessness among the general population and prevent new cases of homelessness.

2. 2. Secondary prevention measures – activities which are focused on those most at risk of homelessness (due to a crisis or their ‘characteristics’) and which seek to address homelessness at its earliest stages. They provide for more extended interventions for people with more complex needs (for example, people with mental health issues).

3. 3. Tertiary prevention measures – target those households experiencing homelessness but also entrenched homelessness – in other words, those who are already affected by homelessness (to reduce long term/repeat homelessness) – and to mitigate established conditions.

The three levels of prevention – primary, secondary and tertiary – cover the range of international prevention interventions; but importantly, homelessness prevention must be placed and understood within the specific context in which it occurs (for example, rough sleeping is the definition of homelessness in the US; while the broader definition operates in the UK). Most authors use this three-tier framework to understand prevention strategies but there is no consensus about which activities take place at each level, and in secondary and tertiary levels in particular (Maher and Allen, Reference Maher and Allen2014) (see Shinn et al., Reference Shinn, Baumohl and Hopper2001; Culhane et al., Reference Culhane, Metraux and Byrne2011). Shinn et al. (Reference Shinn, Baumohl and Hopper2001) also suggest that the primary stage of prevention (preceding the loss of accommodation) can be split into three types: first, universal – for the entire population; second, selected – aimed at people in an at-risk group; and third, indicated – individual characteristics (determined by individual level screening).

Shinn et al. (Reference Shinn, Baumohl and Hopper2001) also suggest that universal prevention strategies operate specifically at the primary level and selected (targeting an at-risk group to minimise the risk/duration of homelessness; and targeting people with particular characteristics) can operate at both secondary and tertiary prevention levels. Addressing structural issues such as affordability, substance abuse, poverty and low income are widely considered to be activities that can fall into the ‘primary prevention’ category, as are direct interventions to avoid eviction which could include housing subsidies, financial support and mediation. Secondary prevention measures could involve some of the former activities, but also precautionary activities such as tenancy sustainment support or multi-agency working to support individuals at high risk of homelessness. Tertiary prevention could include rapid rehousing in the US and resettlement in the UK. The European approach to homelessness prevention focuses on all three categories of activities, whereas in the US it is long term homelessness and tertiary prevention measures which are more commonly the object of activity (Busch-Geertsema and Fitzpatrick, Reference Busch-Geertsema and Fitzpatrick2008). A structural explanation of homelessness locates the reasons for homelessness beyond the scope or agency of an individual, so primary prevention measures – the provision of more housing and addressing socio-economic inequalities – would be the solution. For agency explanations, focusing on personal behaviour, secondary or tertiary targeted provision would be the solution or intervention.

An important element of preventing homelessness is to increase the availability of affordable housing (Maher and Allen, Reference Maher and Allen2014) since genuinely effective prevention would ideally occur at the first level (Parsell and Marston, Reference Parsell and Marston2012). For prevention policies to be successful, however, they need to be sensitive to and target the triggers for homelessness and be underpinned by appropriate resources and an effective governance framework (Busch-Geertsema and Fitzpatrick, Reference Busch-Geertsema and Fitzpatrick2008). A focus only on individual risk factors and prevention could leave the structural causes of homelessness unaddressed (Parsell and Marston, Reference Parsell and Marston2012). This is not least because it may be unclear what is meant by ‘at risk’ of homelessness and therefore who is in need of services (Batterham, Reference Batterham2019). Linked to this, a significant challenge in applying prevention policies is how to do so effectively when individuals traditionally present themselves as being in need at crisis point (Crane et al., Reference Crane, Warnes and Fu2006).

There are challenges in developing effective prevention strategies (Burt et al., Reference Burt, Pearson and Montgomery2007). Culhane et al. (Reference Culhane, Metraux and Byrne2011) argue that investment in prevention (unlike Housing FirstFootnote ³ ) may be pursued without an adequate empirical and conceptual basis. There are also issues in defining and measuring the efficiency and effectiveness of homelessness prevention activities. Efficiency relates to how to target those households which are the most at risk of becoming homeless. However, it can be difficult to determine whether households which receive an intervention would have become homeless without it. Effectiveness refers to the success of prevention activities. Here there are significant gaps in knowledge about what works in practice and what constitutes appropriate assistance (Maher and Allen, Reference Maher and Allen2014). Critiques of how prevention strategies have traditionally operated identify that they may be selective about who they assist (Maher and Allen, Reference Maher and Allen2014); they may emphasise individual rather than structural causes of homelessness; and there is a possibility that the most vulnerable households might be omitted as households who can easily be assisted might be targeted or prioritised. Further, prevention could lead to gatekeeping (Pawson and Davidson, Reference Pawson and Davidson2008) so that some people who might be owed a statutory duty in a UK context could be denied this.

Housing systems (encompassing housing markets and policy) have largely been absent from welfare regime analysis (apart from Kemeny, Reference Kemeny2001, also see Fitzpatrick and Stephens, Reference Fitzpatrick and Stephens2014). Although it is beyond the scope of this article to address this, it is useful to establish that the UK has a liberal welfare system with legally enforceable rights to housing and, since 1977, a historical focus on (selective) prevention. It should also be noted that the UK as a whole has been significantly affected by the Global Financial Crisis, the introduction of austerity (both in terms of funding for public services and levels of benefit payments) and that inequality and poverty have been increasing. Prior to the introduction of the 2014 Act in Wales, in their review of international homelessness policy to identify countries with promising approaches to addressing homelessness, Fitzpatrick et al. (Reference Fitzpatrick, Johnsen and Watts2012) highlighted England, France, Finland, Germany, Ireland, Scotland and the US. In terms of an increased focus on prevention, Germany and Finland were considered to be the most promising. However, since enforceable rights to settled housing do not exist outside of the UK, Fitzpatrick et al. (Reference Fitzpatrick, Johnsen and Watts2012) concluded that lessons for Wales would most likely come from England and Scotland where a duty is conferred on local authorities to address homelessness, although historically only for those households deemed to meet certain criteria: being in priority need, unintentionally homeless and with a local connection.

Although it is accepted that welfare regimes impact on the nature, scale and causes of homelessness (see Stephens et al., Reference Stephens, Fitzpatrick, Elsinga, van Steen and Chzhen2010; Bramley and Fitzpatrick, 2017), it should be noted that international comparisons are difficult due to differences in contexts: for example, social values embedded in political cultures (Fitzpatrick and Stephens, Reference Fitzpatrick and Stephens2014) and different causes and types of homelessness (Fitzpatrick et al., Reference Fitzpatrick, Johnsen and Watts2012). There are therefore limits to conventional welfare regime analysis when attempting to explain/understand national responses to homelessness among marginalised groups – an issue addressed further in Wilding et al. (Reference Wilding, Madoc-Jones, Ahmed, Jones, Gibbons and Rogers2019).

The previous legislative framework in Wales

Prior to the introduction of the Housing Act (Wales) 2014, homelessness legislation in Wales was based on the UK Housing (Homeless Persons) Act 1977, later amended by the Housing Act 1996 and later still by the Homeless Persons (Priority Need) (Wales) Order 2001. The 1977 legislation – which replaced the 1948 National Assistance Act – reconceptualised homelessness as a housing rather than welfare ‘problem’ and gave local authorities statutory responsibility to address the homelessness of people who met specific criteria.

First, they would need to be deemed as homeless or threatened with homelessness in the next twenty-eight days. Under the 1977 legislation the FEANTSA ‘homelessness’ categories were adopted: the statutory definition of homelessness as designated by the 1977 legislation being that there is no accommodation for an applicant (for assistance) to occupy or it is unreasonable for them to occupy it (due to poor conditions). Second, the applicant would need to be considered eligible for rehousing, meaning they met certain conditions to receive publicly funded assistance – for example, they would need to be a British citizen or have indefinite leave to remain (refugee) status rather than seeking asylum – and be ‘habitually resident’. The third criterion relates to whether they were deemed to be in priority need for rehousing. Priority need categories include the following: a pregnant woman; dependent children; someone vulnerable as a result of old age, mental illness, handicap or physical disability or other special reason; as well as those made homeless or threatened with homelessness as a result of an emergency such as flood, fire or other disaster.

If not deemed to be in priority need then the applicant would only receive advice and assistance. If accepted as being in priority need, the local authority would then determine whether or not the applicant is unintentionally homeless (i.e. whether they became homeless through no fault of their own). An applicant would be deemed to be intentionally homeless if they had done anything or failed to do anything deliberately, which results in them losing their home: for example, eviction due to anti-social behaviour or non-payment of rent. If the applicant was considered to be intentionally homeless the local authority did not have a permanent rehousing duty, but instead had to provide temporary accommodation for twenty-eight days. Finally, the applicant would need to demonstrate a local connection to the authority area in which the application for rehousing was made. Households could have a local connection with a particular local authority because of normal residence, employment or family associations, or because of special circumstances. If a household has no local connection with the authority to which they have applied, the duty to secure settled accommodation for them could be transferred to another UK authority with which they do have such a connection (except if they are at risk of violence in that other authority). If an applicant passes all the tests, then the local authority has a duty to rehouse them in ‘settled accommodation’. Only with their permission could this duty be discharged in the private rented sector.

The homelessness duties in the 1977 Act were consolidated into the Housing Act (1996) (for England and Wales) which extended the priority needs categories to include vulnerability; however, a single person had to persuade the local authority that they were ‘vulnerable’ in order to be deemed in priority need. A homeless person may be ‘vulnerable’, in the words of s189 Housing Act 1996, as a result of: old age; mental illness; physical disability; having been in care (and now twenty-one or over); having been in the armed forces; having been in custody; having fled actual or threatened violence; or other ‘special reasons’ (for example, being a refugee).

The Homeless Persons (Priority Need) (Wales) Order 2001 extended the groups of people considered to be in priority need in Wales to include: a care leaver or person at particular risk of sexual or financial exploitation, eighteen years or over but under the age of twenty-one; a sixteen or seventeen year old; a person fleeing domestic violence or threatened domestic violence; a person homeless after leaving the armed forces; a former prisoner homeless after being released from custody. Arguably, the gradual increase in numbers of applicants being owed a rehousing duty and the associated increase in the use of temporary accommodation, the costs involved and the negative associations of increasing levels of homelessness led to the preventative turn in England and Wales (Mackie, Reference Mackie2015). Prevention services in the UK were arranged under the ‘Housing Options’ model (known as Housing Solutions in Wales), while in Scotland, amendments to the Homelessness etc. (Scotland) Act 2003 abolished the priority needs criteria with effect from 31^st December 2012. As a result of this local authorities in Scotland have a duty to provide permanent accommodation for all applicants who are deemed to be unintentionally homeless.

Until the 2014 Act, in Wales, any homelessness prevention related activity took place outside of the legislation (Ahmed et al., Reference Ahmed, Jones, Gibbons, Rogers, Wilding and Madoc-Jones2018) and was targeted at preventing homeless households from accessing the statutory duty to permanent housing (Mackie, Reference Mackie2014). Specific criticisms of how the previous legislation operated in Wales include (Mackie, Reference Mackie2014):

1. 1. Provision was selective: in other words, only those who passed the tests were rehoused, and applicants not in priority need did not receive anything.

2. 2. The system was inflexible: those who were in priority need and unintentionally homeless had to spend time in temporary accommodation before they were able to be rehoused and this was not considered to be beneficial to the household; the solutions to homelessness were limited to housing; and wider issues that may have given rise to homelessness in the first place were not considered. This is particularly significant since homelessness is multi-dimensional, not just about shelter (Somerville, Reference Somerville2013); and where the focus is only on housing, people may have support needs which go unaddressed.

3. 3. There was ambiguity regarding the role of homelessness prevention since this agenda developed decades after the original legislation (Mackie, Reference Mackie2014).

4. 4. There was variable application of legislation across Wales.

5. 5. A whole system approach underpinning, and legitimising, prevention activities was required (Mackie, Reference Mackie2015).

Conclusion: a review of progress since the Act’s implementation

The Welsh homelessness legislation, with its focus on prevention and the alleviation of homelessness, is seen as ‘desirable and replicable’ and the changes that Part 2 of the Housing Act (Wales) 2014 introduced in relation to prevention are becoming well-documented (see Mackie, Reference Mackie2014, Reference Mackie2015; Shelter Cymru, 2016; Ahmed et al., Reference Ahmed, Jones, Gibbons, Rogers, Wilding and Madoc-Jones2017; Connell et al., Reference Connell, Martin and St Denny2017; Mackie et al., Reference Mackie, Thomas and Bibbings2017; Welsh Audit Office, 2018; Ahmed et al., Reference Ahmed, Jones, Gibbons, Rogers, Wilding and Madoc-Jones2018). Drawing from data gathered during the post-implementation evaluation, the following discussion centres on the progress made since the implementation of the Act and addresses three of the criticisms levelled at the previous legislation. First, that there was a lack of whole systems approach to addressing homelessness, gatekeeping operated and there was variability in application; second, there was selectivity in provision with particular groups being underserved by the previous legislation; and third, the previous legislation individualised homelessness (Mackie, Reference Mackie2015).

Evidence from the post-implementation evaluation of the Housing Act (Wales) 2014 (Ahmed et al., Reference Ahmed, Jones, Gibbons, Rogers, Wilding and Madoc-Jones2018) indicates that the overwhelming consensus from a range of service providers is that the new statutory homelessness framework ushered in by the Act has had an array of positive impacts. The findings from the local authority survey demonstrate that a clear majority felt that their local authority was undertaking more preventative work and that this is more inclusive and effective. Feedback from service providers in the third sector and Registered Social Landlords supports this.

The Act has helped to shift the culture of local authorities towards a more preventative, person-centred and outcome-focused approach, which has meant a much-improved service response to tacking homelessness. The official statistical returns bear this out, with almost two-thirds of households threatened with homelessness having it prevented across Wales: the proportion of prevention cases that were successful was 62 per cent in 2015-16. As expected, the number of priority need households assisted under the new ‘duty to secure accommodation’, activated only after prevention and/or relief efforts have failed, is much lower than statutory homeless ‘acceptance’ levels under the pre-2015 system.

In addition, the whole systems change introduced by the Act means that the Act has fundamentally changed the way that Housing Solutions Teams work with people who are homeless/threatened with homelessness. Previously, outside of the legislation, prevention is now at the core of the Act, and there is now increased flexibility in how local authorities can intervene to address the causes of homelessness. However, there remains significant variation across Wales and also within local authority areas regarding the extent to which the ethos of the new Act has been adopted and the effectiveness of prevention and reasonable steps – this is a concern. There is also evidence of variation in the interpretation of intentionality and local connection. Intentional homelessness was seen by a minority of service providers as a means of gatekeeping access to services; however, the majority felt it to be counter to the ethos of the Act and detrimental to achieving positive outcomes.

It is important to highlight, however, that most local authorities reported significant challenges in implementing the Act. Such challenges include an increased administrative burden; more bureaucratic working arrangements; and higher and more complex workloads for Housing Solutions staff. The issue of resources is also considered a significant challenge for the successful future implementation of the Act (this is discussed in Ahmed et al., Reference Ahmed, Madoc-Jones, Gibbons, Jones, Rogers and Wilding2019).

It is evident that there is strategic support for partnership working among local authorities across Wales. There is also evidence that partnership working has increased between and within local authorities, and with RSLs and third sector service providers. However, again, there is much variation within and between local authorities and in relation to certain groups e.g. prison leavers (see Madoc-Jones et al., Reference Madoc-Jones, Ahmed, Hughes, Dubberley, Gorden, Washington-Dyer, Lockwood and Wilding2019)

It was also apparent that ‘reasonable steps’ have been strategically embraced by local authorities and this has also resulted in better outcomes for people presenting as homeless/threatened with homelessness. The Act, therefore, provides a framework within which it is possible to prevent and relieve homelessness for a wide range of people who would not have been included under the previous arrangements.

Of the ninety service user interviewees whose housing situation could be verified during the second wave of fieldwork, fifty had been successfully rehoused (thirty-three in social housing, seventeen in the private rented sector). However, a significant number remained in insecure housing six months after they presented as homeless (twenty-one) and nine people were rough sleeping. Additionally, although twenty-one out of twenty-two local authorities confirm that they take steps to maintain contact with service users who miss appointments with Housing Solutions staff, a further concern is the sixty-four people whose housing circumstances could not be verified. In most instances cases had been closed by local authorities – often cited as ‘failure to cooperate’ – but the reasons for this were not always clear.

Single people experienced poor outcomes under the previous legislation. It is important to note however, that under the new Act, the outcomes for single people are still poor, as they often remain without a solution after all stages. This can partly be attributed to a lack of affordable appropriate accommodation and the increasing complexity of people’s needs. Poor mental health affected the majority of service users who participated in the study. Significantly, securing accommodation for people with mental health problems was reported as the biggest challenge facing service providers (see Rogers et al., Reference Rogers, Ahmed, Madoc-Jones, Gibbons, Jones and Wilding2019).

Importantly, rough sleeping is rising in Wales and it is universally recognised across local authorities and among service providers that rough sleepers have benefited least from the recent legislative changes. In stark terms, people who are rough sleeping cannot have their homelessness prevented and often do not meet the vulnerability threshold to be considered as being in priority need. Therefore, they do not receive a rehousing duty at the final stage of the legislation. Additionally, often people have entrenched problems (mental health issues, substance misuse, offending behaviour). Again, shortage of suitable accommodation compounds these issues. There are a number of significant structural challenges which will impact on the successful implementation of the Act (see Rogers et al., Reference Rogers, Ahmed, Madoc-Jones, Gibbons, Jones and Wilding2019; Ahmed et al., Reference Ahmed, Madoc-Jones, Gibbons, Jones, Rogers and Wilding2019).

Personal Housing Plans (PHP) developed between Housing Solutions Staff and applicants appear to be instrumental in promoting person-centred practice, and service providers were overwhelmingly positive about using them, despite the increased paperwork involved. However, PHPs do not seem to be benefiting service users, many of who report not finding them particularly useful (Ahmed et al., Reference Ahmed, Jones, Gibbons, Rogers, Wilding and Madoc-Jones2018). Navigating new systems introduced by the Act also poses challenges for some service users and receiving multiple letters throughout the process can be confusing rather than helpful. Arguably, through the use of PHPs, homeless prevention activities focus on finding solutions to the problems of individuals, therefore reinforcing the individualisation of the causes of homelessness. Service providers identified specific prevention activities that they routinely engaged in as: budgeting and managing debt; rent arrears and rent deposits/bonds; welfare benefits advice and reviews; general housing advice; signposting to Housing Solutions; referral to floating support workers; referral to pre-tenancy workers; mediation with landlords (particularly in the private rented sector); mediation with members of informal networks (family and friends). These activities can be broadly categorised in terms of: general advice and assistance; financial advice and support; and signposting to other support agencies. A focus on individual risk factors and solutions, however, as stated, avoids addressing the structural causes of homelessness (Parsell and Marston, Reference Parsell and Marston2012).

An important feature of homelessness prevention is to increase the availability of affordable housing (Maher and Allen, Reference Maher and Allen2014) since truly effective prevention operates at the primary level (Parsell and Marston, Reference Parsell and Marston2012). Local authority respondents and service provider participants expressed concerns about the lack of available social housing and also raised issues regarding the use of the private rented sector: there were significant misgivings about how this operates in practice (Ahmed et al., Reference Ahmed, Jones, Gibbons, Rogers, Wilding and Madoc-Jones2018). Concerns centred on the lack of available affordable accommodation – one bed properties in particular; insecurity of tenure; the poor condition of some properties; and the unwillingness of some private landlords to rehouse people in receipt of welfare benefits (discussed in Ahmed et al., Reference Ahmed, Madoc-Jones, Gibbons, Jones, Rogers and Wilding2019).

An ideal homelessness system is underpinned by prevention, a strong safety net and robust assessment measures to reduce perverse outcomes (Wilcox et al., Reference Wilcox, Fitzpatrick, Stephens, Pleace, Wallace and Rhodes2010). The future successful implementation of the Act will be contingent on a number of factors: the skills, expertise and behaviour of staff delivering the service (particularly frontline, first point of contact staff); and also upon structural factors: for example, the availability and affordability of housing in a particular area.