Policy paper

Home Office response to the ICIBI’s report: An inspection of contingency asylum accommodation

Published 24 October 2024

An inspection of contingency asylum accommodation November 2023 to June 2024.

Introduction

The Home Office thanks the Independent Chief Inspector of Borders and Immigration (ICIBI) for this this report An inspection of contingency asylum accommodation. The Home Office is grateful to the ICIBI for the effort that he and his team has devoted to this inspection to examine any improvements needed to ensure we are fulfilling our statutory obligation to accommodate destitute asylum seekers.

The ICIBI identified several areas for improvement and has made 9 recommendations.

It is important to note that since the inspection there has been a change in government. The Home Office, in accepting and implementing the recommendations or where activity is already underway, demonstrates its commitment to reflect the elected government’s evolving understanding of the challenges and opportunities, and any changes in its strategy and policy to ensure we continue to meet our statutory obligation to accommodate and support destitute asylum seekers.

Recommendation 1

Ensure that the 10-year strategy and annual delivery plans for asylum accommodation are informed by:

a) clearly stated milestones for expected benefits, overall and broken down by type of accommodation (initial, dispersal, contingency) and by site

b) a standardised methodology, for each type of accommodation being provided, including planning assumptions (e.g. occupancy rate, length of stay) to enable clear and consistent costings and value for money assessments for each site.

Recommendation 1(a) Accept in full

Recommendation 1(b) Partially accept

We fully accept the recommendation 1(a) as the 10-year strategy will outline a clear plan to deliver safe and sustainable accommodation, that is not only cost effective but flexible to changing circumstances, in close partnership with local authorities and other stakeholders. This will be underpinned by clear plans to deliver both the accommodation and services needed to reach this goal, with expected demand for each type of accommodation.

We partially accept recommendation 1(b) as we are already exploring cohort requirements and in this regard the approach to the design of accommodation will follow a standard methodology, though outcomes will be different as we consider the needs of the cohort and the design and location of the property.  We will however develop standard methodologies with regards to setting up / sourcing accommodation types. Testing and engagement with local authorities will be required to explore community cohesion and opportunities for joint working, which will create some variation in terms of how larger sites might operate.  This reflects the fact that communities in which accommodation is situated, are diverse.

Recommendation 2

Improve stakeholder engagement in relation to the whole of the asylum accommodation estate (initial, dispersal, contingency) by:

a) Creating stakeholder ‘maps’ identifying who the key stakeholders (overall and broken down as above), their responsibilities, interests and likely concerns (to be kept under review), and the Home Office’s aims and objectives in relation to each (e.g. provision of services, other forms of support, management of expectations)

b) establish a system and schedule for engagement with local and national stakeholders for each contingency asylum accommodation site to exchange information, ideas, and challenges at every stage of the procurement process and throughout the lifetime of its use. This should include consideration of the site’s suitability, contract completion, set up, opening, ‘business as usual’ operation, and withdrawal and closure.

2a Accept in full

2b Accept in full

2a. Asylum Support, Resettlement and (non-detained Accommodation (ASRA) currently hold stakeholder directories at both national and regional level and across various accommodation types. We will develop these to create stakeholder maps that provide a holistic view of all interests and challenges. These will identify key stakeholders across the full accommodation estate and, as per the recommendation, segment stakeholders to ensure we can rapidly identify appropriate stakeholders in relation to issues. We will also utilise Boston matrices to prioritise engagement in relation to specific challenges and keep both the maps and matrices under review. The new engagement strategy aims to pivot to more objective-led engagement and evaluation of outcomes.

2b. The Home Office delivered a new Strategy in Contingency Accommodation that engages with local and national stakeholders prior to standing up a site.  This is implemented on a case-by-case basis and includes assessment of suitability criteria, including feeds from Ministry of Housing, Communities and Local Government (MHCLG) and a wider range of data points.

Recommendation 3

Strengthen governance arrangements for the management of asylum accommodation, including proposed and existing large and medium contingency accommodation sites, by ensuring that:

a) lines of reporting and accountability are clearly documented, and any gaps or ambiguities are resolved: and

b) the skills and experience required by staff responsible for managing contracted providers and large projects are clearly articulated, and where necessary further training is provided, and that a development pathway is identified for Home Office staff who may wish to fill such roles in future.

3a Accept in full

3b Accept in full

3a. There are several governance boards in place for the management of asylum accommodation sites, as well as a formal contract management training programmes for those delivering the contracts. We recognise the need to go further both in relation to current contracts and future arrangements and are therefore fully accepting this recommendation.

3b. The Cabinet Office recognises that the majority of contract management activity sits outside of the commercial function – contract management professional (CMP) standards have therefore been created to set out the capabilities expected of government professionals who are involved in the management of contracts. The Home Office will ensure that all contract managers are adequately accredited at different contract management levels. This will ensure all such individuals are trained to manage contract complexity and risk that reflects the accreditation level requirements, their expertise and responsibilities. We are therefore accepting this recommendation in full.

Recommendation 4

Overhaul contract compliance and assurance checks by revisiting the relevant recommendations from ICIBI’s 2018 and 2021 inspections of asylum accommodation and, in light of these:

a) review the department’s approach to assurance for all types of asylum accommodation and develop a consistent model, including minimum acceptable levels and maximum intervals between assurance checks at each type of accommodation (initial, dispersal, contingency (large and medium sites, hotels, other sites)

b) review the key performance indicators (KPIs) in the asylum support and accommodation contracts (AASC) to ensure that they align with and inform the new assurance regime.

4a. Partially accept

4b. Accept in full

4a. Similar recommendations to review the department’s approach to assurance from ICIBI’s 2018 and 2021 inspections have been addressed and closed with the updates provided to ICIBI, therefore the Home Office does not see the merit in re-visiting these. The Asylum and Support Contract – Assurance (ASC-A) Team is however reviewing the frequency and scope of the inspection activity, and the ASC-Assurance framework is well into development. We do accept that the department needs to develop a consistent approach to assurance across the different accommodation types that sit outside of the asylum accommodation and support (AASC) contracts. The Home Office will look into this further and agree an approach which addresses the spirit of this recommendation which we are partially accepting.

4b. Whilst change control notice (CNN) is the only tool available to undertake contractual amendments to a live contract, the Home Office is committed to completing a full review of the key performance indicators (KPIs). This work was commenced earlier this year and is being driven by the altered asylum accommodation landscape since the asylum accommodation and support contracts (AASC) were awarded in 2019, for 10 years. This review comes in the backdrop of a substantial increase in the volume of those that have claimed asylum, are destitute and require support and accommodation; COVID; Brexit; and uncontrolled inflation.

The purpose of this review is to ensure that the revised KPIs are appropriate, SMART (specific, measurable, achievable, realistic and time bound) and ensure that KPI failures are less punitive / damaging and that service credits are proportionate. This will encourage providers to be more open in reporting performance against KPIs. We therefore accept this recommendation in full.

Recommendation 5

Improve record keeping and data quality by agreeing the requirements and minimum standards for information and data recorded by the Home Office and by the accommodation providers (and subcontractors) relating to asylum accommodation and service users, and:

a) develop a single, interrogatable database of contingency asylum accommodation sites and service users that holds:

1) the current location (site and block or room number) of each service user

2) ‘since date’

3) the current occupancy and availability of bed spaces at each site

b) define a data assurance regime with accommodation providers to ensure that record keeping is in line with the agreed requirements and standards, with the objective that Home Office and contractor records are fully reconcilable at all times.

Accept in full

The Home Office and its accommodation providers recognise the importance of record keeping, data and information technologies and are committed to continuous improvement in this area.

As the inspection noted, the ATLAS immigration casework system is the Home Office’s primary system of record for personal information and addresses for all immigration cases. Enhancements are required to the existing range of additional systems and reporting tools that are used by the Home Office and its providers that manage different aspects of the asylum support and accommodation system. The Home Office continues to progress and invest in improvements to ATLAS and recording of service user vulnerabilities.

Since the inspection a new management information visualisation tool has been implemented offering greater insight to data held on capacity, utilisation and occupancy of provider accommodation sites.

In Autumn 2024, further enhancements to the Home Office strategic management information platform, Vantage, are scheduled to deliver improvements to existing capabilities on reporting on trends and patterns regarding the overall asylum support populations and movement through asylum and support system.

Building on this, we are developing a dedicated property management platform (PMP) for delivery from 2025 onwards, that will bring together property and occupancy data into a single platform in the Home Office. In the first phase, the platform will: improve the data related to accommodation and service user movements; streamline the onboarding of new properties and providers; provide property / address data to the Home Office Atlas system (which is required for casework). 

The next phase, will cover contract assurance and will provide a central location for property assurance information, reducing the manual work required to analyse provider trends, and thereby enhancing the ability to schedule and manage property inspections.

Issues with the availability and quality of data and management information have been identified across multiple ICIBI reports. This impacts the way individuals move through the migration and borders system, affects the service they receive, impacts on efficiency and public confidence.

The department already undertakes thematic reviews of recommendations and will complete a review of those directly or closely related to operational data improvements and management information. This will inform work already underway to support improvements in data governance, data quality and management information.

Recommendation 6

Define roles and responsibilities (Home Office, accommodation providers, others) in respect of providing purposeful activities (e.g. education, recreational activities, volunteering opportunities) for service users in contingency asylum accommodation and establish a means of sharing ideas and ‘best practice’.

Partially accept

Asylum accommodation and support is for those who would otherwise be destitute and is designed to ensure that an individual’s essential living needs are met and maintained to an appropriate standard. Accommodation providers’ responsibilities are made clear in the Asylum Accommodation and Support Contract (AASC) Schedule 2 – Statement of Requirements, and pertain to transport, accommodation procurement and reactive maintenance, provision of appropriate food and beverage services and safeguarding activities to manage the wellbeing of those within being accommodated within those sites, employed by the Home Office, and the wider public.

The provision of ‘purposeful’ activities would not fall within the providers’ remit, however it is accepted that more clarity could be provided to service users on roles and responsibilities of providers, the Home Office and statutory organisations, to facilitate the management of expectations, and signposting to the correct organisations responsible for areas outside of the ASC realm. This would include local authorities, health services, charitable organisations, educational bodies as a minimum, whom we would expect to engage service users on these topics whilst they reside in asylum accommodation.

We do also accept that there could be a more consistent approach across the AASC providers and wider business with regards to engagement with local organisations and the supply of such activities on a voluntary basis (not contractually mandated) to ensure all have the fair opportunity to benefit from provider relationships and engagement in the regions and therefore partially accept this recommendation.

Recommendation 7

Improve the safeguarding of vulnerable asylum accommodation service users by:

a) seeking input regarding its current policies and practices from agencies and organisations with knowledge and experience of dealing with vulnerable at-risk individuals

b) clarifying with accommodation service providers (and subcontractors) the processes for identifying and risk assessing such individuals in contingency asylum accommodation

c) documenting the decision making processes and criteria used to place individuals in or remove them from specific sites

d) ensuring that families with children, are not housed in the same contingency asylum accommodation as single adult males or females.

Partially accept

The Immigration and Asylum Act 1999 sets out that the Home Office is to support and accommodate asylum seekers (including any dependents) who would otherwise be destitute, however the statutory duty for safeguarding does not sit with the Home Office. Therefore, we are working with partners and stakeholders to clarify the role of the Home Office around safeguarding.

To inform this work, we are collaborating with statutory partners to ensure that appropriate information is shared to enable them to carry out their safeguarding responsibilities and that this is fully mapped.

The clarification and mapping of safeguarding responsibilities will support any review, assurance or dialog internally or externally. It will also ensure there is no uncertainty of what actions should be taken to protect at risk adults or children, the data that should be shared within the parameters of GDPR, as well as defining relevant statutory and authority responsibility. As part of this, we will also ensure that service providers are clear on their contractual obligations and fully understand and deliver these roles and responsibilities, accordingly. 

The Home Office accepts that gender-specific accommodation may be necessary in certain circumstances. We take into consideration the suitability and needs of asylum seekers when accommodating across the estate.  Those identified as not suitable for specific accommodation, including co-location with families, will be allocated or placed in alternative accommodation across the estate. It is however crucial to weigh the potential benefits / disadvantages to ensure that such arrangements are implemented in a way that promotes the wellbeing and safety of asylum seekers.

Recommendation 8

Strengthen organisational learning in relation to asylum accommodation by producing a framework, with associated processes and guidelines, for capturing, evaluating and sharing learning (‘best practice’ and pitfalls) from ‘business as usual’ and from new projects, including the findings and recommendations from inspections and reviews.

Accepted in full

We fully agree that strengthening organisational learning is critical for our business’s continued success.  The work undertaken since the establishment of a business delivery unit under Asylum Support and the ASRA Cross-Cutting Operations Team means that we have better oversight of findings from internal and external reviews and audits. The creation of a framework will ensure we have the workable foundations documented, which will foster a culture of continued learning. This new framework will be aligned with the overarching business objectives to ensure that we maintain a sustained and continued effort in applying lessons learned.

Recommendation 9

Improve communication with asylum seekers by:

a) [as soon as is practicable] establishing mechanisms for informing asylum seekers of the progress of their claim through Home Office generated updates (e.g. GOV.UK ‘current average waiting times’, text messages, letters) or on request (e.g. via a hotline)

b) [now] providing service users in contingency asylum accommodation the likely length of their stay, what to expect next, and giving them reasonable notice (at least 48 hours) when they are being moved to alternative accommodation and an explanation of why this is happening.

9a. Partially accept

9b. Partially accept

9a. The Home Office has been working to introduce a service standard to asylum decisions, however this is a complex area that needs to balance operational efficiency, the needs of asylum seekers and the integrity of our asylum system. A project to review these considerations along with scope and potential implementation timescales is being undertaken. Once the project is completed a final decision will be taken on any potential asylum claim service standards.

Additionally, the Home Office is constantly looking to improve our approach to communications. We are building a digital portal for two-way communication between ourselves and our customers. The Manage Asylum Claim (MAC) portal is a new customer-facing digital product that will be used initially by immigration advisors. An early version of a portal was in test with a small group of immigration advisors, and learning from that test we are now developing a new version to help improve customer experience. This will allow the Home Office to deliver new features and requirements expediently. Further information will be provided to claimants and legal representatives / immigration advisers nearer the time of operationalisation of the MAC portal. Details of how to access the portal, once it is operational, will be published on Claim asylum in the UK. 

9b. Section 4.2.2 of the AASC Schedule 2 of the Statement of Requirement (SoR) sets out the contractual obligation of Home Office service providers to apprise service users of any moves, which is underpinned by a service level agreement (SLA) of at least five days. Section 11 of the SoR also sets out provision for quality assurance that the provider requires service users confirm in writing that any information regarding the move is understood. Furthermore, asylum seekers can raise any concerns or complaints via Migrant Help which is a 24 hour service.

As part of regular contract management meetings, service delivery managers will continue to ensure that service providers are meeting these contractual obligations. It would not be practical or realistic for the Home Office to enhance the provisions within the contract however, the Home Office is committed to providing asylum seekers with a positive experience throughout the life of their claim. We therefore partially accept this recommendation and will work with partners and stakeholders to review our processes, ensuring that any identified improvements are implemented as soon as practicably possible.