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Submission: Draft Revised Working Protocol between Tusla and the Housing Authority

EPIC make this submission on behalf of the children and young people with whom we work due to the significant deterioration of the housing and accommodation options available for care leavers over the past decade.

It is EPIC’s position that in light of the State’s duty of care as a corporate parent, care leavers must be prioritised as a specific category of young people in relation to housing needs.

Care leavers should not face the uncertainty of where they will live when they turn 18, or fear of becoming homeless. With careful planning, early flagging of young people who may be at risk of homelessness, and interagency supports, better outcomes for the housing needs of young people leaving care can be achieved. 

Recommendations:

To ensure a greater inter-agency collaboration, a more consistent and standardised approach across housing authorities is required to ensure effective planning for the allocation of housing for care leavers.
Given the variation in ASC processes and HA  allocations, the protocol should set out mandated mechanisms and procedures, rather than suggested ways of working, to ensure greater consistency in the application of Housing Authorities’ Allocation Schemes for young people leaving care. Roles and responsibilities of agencies who are members of Steering Committees must be clearly defined.
Tusla should be required to send detailed and accurate information in relation to young people leaving care for whom no accommodation has been identified and are therefore at-risk of homelessness.
It should be a requirement that a young person’s application for social housing is commenced one year in advance of turning 18. This requirement should be consistently implemented across all Housing Authorities nationally.
Priority applications (such as Exceptional Social Grounds in Dublin City Council) should be available for all young people with care experience who require safe and secure housing or are facing homelessness. A prioritisation system of this kind should be implemented as a formal and consistent mechanism in every local authority.
Each Local Authority should have a designated representative who oversees all housing applications for young people leaving care. This representative should be mandated to attend local interagency steering committees to ensure collaboration plan for the provision of adequate housing for care leavers at risk of homelessness.
Provision for data in relation to unaccompanied minors entering the country should be provided to the local authorities. This must then lead to planning and provision of adequate accommodation that takes account of their vulnerabilities when these young people turn 18.
To ensure continuum of care, all Local Authorities should provide semi-independent housing which would cater for young people needing support and which they can access even when moved from one county to another.
In line with good practice the protocol should include a mechanism to strengthen the voice of the young person and encourage their active participation in the process, including a forum to raise concerns where the protocol is not being applied in practice.
The Protocol should not be limited to young people who meet the statutory criteria for aftercare and should include young people who have care experience but are outside of the statutory threshold for statutory aftercare eligibility.  Young people who have entered care in the year before turning 18 or are accommodated under section 5 of the Child Care Act 1991, including unaccompanied minors, should not be excluded from the application of this protocol.
The application of this protocol should be regularly reviewed, and the findings published, to ensure transparency and accountability.