MD3241 Life off the Streets grant funding 2024-25

1.    Introduction and background
1.1.    A total of 10,053 people were seen sleeping rough in London during 2022-23. This is a 21 per cent increase compared to 2021-22. Of these, 64 per cent were new to the streets; 16 per cent were returning to rough sleeping after not being seen in the previous year; and 51 per cent were non-UK nationals. Additionally, 71 per cent had support needs, of which 51 per cent related to mental health; 31 per cent to alcohol; and 32 per cent to drugs.
1.2.    In his 2018 London Housing Strategy, the Mayor set out his aim for a sustainable route off the streets for every rough sleeper in London. In June 2018 he published his Rough Sleeping Plan of Action, which outlines the steps that must be taken by City Hall, government and others to achieve this aim. In 2021, the Mayor refreshed his Rough Sleeping Commissioning Framework, which sets out the overarching and cross-cutting priorities underpinning the GLA’s commissioning activities from 2021 to 2024. 
1.3.    Since taking office, the Mayor has been expanding the pan-London rough sleeping services that the GLA funds and commissions. These services – collectively forming the GLA Rough Sleeping programme – are for people with experience, or at risk, of sleeping rough. They are initiatives to tackle rough sleeping that cannot or would not be provided at a London-borough level, as they either meet a very specific need or deliver at the pan-London/multi-borough level. Since 2016, the GLA Rough Sleeping programme has supported over 16,000 people to leave the streets for good.
1.4.    The GLA Rough Sleeping programme is funded from core GLA budget, supplemented by various government grants, such as DLUHC’s Rough Sleeping Initiative (RSI). The following Mayoral Decisions (MDs) pertain to this programme: 
•    MD2559 (March 2020) approved receipt and expenditure of £4.67m in government funding to expand various core services and to develop initiatives for non-UK national rough sleepers. 
•    MD2789 (March 2021) approved expenditure of £13.69m of GLA Rough Sleeping programme budget to extend various core services up to March 2025; and £1.36m to continue to grant-fund various projects. It also approved receipt and expenditure of £6.66m in government funding, which included the continuation of several RSI projects. 
•    MD2853 (August 2021) approved receipt and expenditure of £24.55m in government funding, and expenditure of £0.17m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD2957 (March 2022) approved receipt and expenditure of £3.65m in government funding, and expenditure of £3.85m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD2993 (June 2022) approved the receipt and expenditure of £30.38m from DLUHC’s RSI. 
•    MD3043 (December 2022) approved the receipt and expenditure of £0.54m in government funding and expenditure of £1.25m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD3089 (March 2023) approved the receipt and expenditure of £0.2m from DLUHC’s RSI, and expenditure of £0.1m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD3135 (June 2023) approved the receipt and expenditure of £3.61m from DLUHC’s RSI, £0.05m from DLUHC’s Controlling Migration Fund, and expenditure of £16.36m from the GLA’s Rough Sleeping Programme Budget, to fund core services and various projects.
•    MD3161 (August 2023) approved the receipt and expenditure of £1.16m from DLUHC’s RSI, £0.14m from London Councils, and expenditure of £0.1m from the GLA Rough Sleeping programme budget, to fund various projects.
•    MD3204 (December 2023) approved receipt and expenditure of £0.33m from the Royal Borough of Greenwich and London Borough of Redbridge, to fund various projects.
1.5.    Some of the services and interventions that are the subject of this decision form part of the GLA Rough Sleeping programme, and are extensions, expansion or continuations of services previously approved by the above MDs.
Activity and funding profile
1.6.    This decision approves funding for multiple elements of the GLA Rough Sleeping programme.
1.7.    The newly approved expenditure will be as follows:

2.1.    The GLA Rough Sleeping programme focuses on achieving the Mayor’s vision for everyone sleeping rough to have a sustainable route away from the streets. The programme is underpinned by the overarching priorities, set out in the pan-London Rough Sleeping Commissioning Framework 2021, and to be achieved by working with boroughs and partners. These priorities are: 
•    to prevent people from sleeping rough 
•    to provide an immediate route off the streets 
•    to deliver sustainable accommodation and solutions for those leaving rough sleeping, to ensure people have the support they need to rebuild their lives. 
2.2.    Further details of individual services and projects for which approval is sought under this decision are set out below.
DLUHC Winter Pressures-funded services – new grants
2.3.    The Mayor has been successful in securing an additional grant of £1.5m revenue from DLUHC to meet new and increased pressures on rough sleeping services in London.
2.4.    GLA was notified of this funding allocation on 14 February 2024 and is in the process of engaging with delivery partners to deploy the resource at pace. Additionally, GLA officers are in the process of agreeing a MoU with DLUHC concerning this funding.
2.5.    This decision seeks approval for expenditure of up to £1.5m of DLUHC Winter Pressures funding between 1 March 2024 and 31 March 2024 to projects that meet the conditions of the funding allocation.
2.6.    The decision seeks delegation of authority to the Executive Director of Housing and Land to approve specific funding allocations in-line with the conditions of the funding allocation and totalling up to £1.5m.
Core Life off the Streets services – new grants

Welfare to Wellbeing
2.7.    Veterans Aid Welfare to Wellbeing service offers an immediate route off the streets to every UK veteran in need; and a bespoke, structured pathway into immediate living. It specifically targets UK veterans who are homeless or at risk of becoming homeless. 
2.8.    In financial year 2023-24, the GLA provided £0.08m of grant funding to Veterans Aid to support its Welfare to Wellbeing project. During this period Veterans Aid’s service supported over 150 ex-servicemen and women. 
2.9.    Veterans’ homelessness remains a concern for the Mayor and it has been deemed that funding the Welfare to Wellbeing service in 2024-25 is the best way to support the specific needs and experiences of veterans. 
2.10.    This decision seeks approval for expenditure of £0.08m from the core GLA Rough Sleeping programme budget, to grant fund Veteran’s Aid’s project from 1 April 2024 to 31 March 2025. 
Homeless Health Peer Advocacy
2.11.    The Homeless Health Peer Advocacy (HHPA) service, provided by Groundswell, enables people who are homeless, or have experienced homelessness, to address health issues by making services more accessible through the support of volunteers with experience of homelessness. 
2.12.    In 2023-24, as part of the HHPA, Groundswell began work on its Health Promotion in-reach programme that aims to offer health information and relevant services to people in person and onsite at their hostel or day centre. By this method, Groundswell reaches more people who need support; increases awareness of health issues and the availability of services and encourages people to identify their own health priorities.
2.13.    Meeting the health needs of those rough sleeping is a priority for the Mayor. People who are experiencing homelessness are disproportionately affected by health inequalities and often lack access to suitable information that could help them manage their health and wellbeing. Funding the HHPA is a good way for the GLA to use the Rough Sleeping programme budget to address this need. 
2.14.    This decision seeks approval for expenditure of £0.06m from the core GLA Rough Sleeping programme budget, to grant fund Groundswell to deliver this project from 1 April 2024 to 31 March 2025. 
StreetLink London
2.15.    Since 2013, St Mungo’s has run the StreetLink service; a digital and phone service for England and Wales. StreetLink enables people to send an alert when they see someone sleeping rough. This alert will connect that person to local support services that can help to end their homelessness.
2.16.    The Mayor has been contributing grant funding to St Mungo’s for its national StreetLink service since 2016 (MD1532), in recognition of the additional and high-volume work to which the StreetLink service is required to respond in London, given the high levels of rough sleeping compared to other parts of the country. Historically, St Mungo’s has provided service under grant from the Department for Levelling Up, Housing and Communities (DLUHC). Other funders have included the Welsh government, Homeless Link, London Councils and Bloomberg Associates. 
2.17.    In December 2022, the DLUHC announced it was procuring a contract for a new national StreetLink service, with a revised service model that reduced functionality to triage referrals and removed the phoneline – aspects of the service that were critical to outreach in London. The new national StreetLink service commenced in September 2023. To retain the enhanced service required in London to triage referrals, operate a phoneline and respond to self-referrals, the GLA increased its grant funding to St Mungo’s to create a separate ‘StreetLink London’ service. This was approved in MD3135.
2.18.    As part of the transition to the government’s new StreetLink service, data that was previously captured by StreetLink pertaining to outreach activity in London, and which was integrated with the GLA-funded Combined Homelessness and Information (CHAIN) system, will begin to be captured on a separate system with limited connectivity with CHAIN. To maintain CHAIN’s objectives and to ensure that data on outreach activity continue to be captured consistently and coherently in a singular, reportable database, DD2686 approved the expansion of the CHAIN database to make provision for additional data to be recorded by St Mungo’s on its StreetLink London service.
2.19.    The new St Mungo’s StreetLink London service will continue to operate a self-referral phoneline, and will implement a new focus on ‘brief intervention’ to assess needs and risks of people contacting them for assistance and provide an immediate response. This response could be a referral to street outreach teams, but in many cases support will be offered to direct people away from rough sleeping altogether. In order to retain the enhanced service required in London to operate the StreetLink London phone line and respond to self-referrals, it is necessary for the GLA to grant-fund StreetLink London in 2024-25.
2.20.    This decision seeks approval for expenditure of £0.28m from the core GLA Rough Sleeping programme budget to grant fund St Mungo’s to deliver the StreetLink London service from 1 April 2024 to 31 March 2025. 
Mental Health Assessment and Support
2.21.    In London, 51 per cent of people seen sleeping rough (according to CHAIN 2022-23) have a mental health support need. However, their circumstances, and the uneven distribution of specialist mental health services across the capital, mean it can be challenging for outreach workers to access appropriate mental health support for the people they work with. The Enabling Assessment Service London (EASL) has experienced mental health practitioners, working in conjunction with outreach teams, to help people with mental health needs, who are sleeping rough, to access the support, treatment and accommodation they need. This grant would enable EASL to continue its work in the four boroughs (Barnet, Enfield, Lewisham and Islington), which do not have a specialist mental health team. 
2.22.    EASL’s project received £207,966.93 of GLA funding (originating from RSI 2022-25) from April 2022 until September 2023 (approved by MD2993). MD3135 then approved expenditure from the GLA Rough Sleeping programme budget to grant fund EASL £93,750 from October 2023 to September 2024 to continue to provide support in the remaining boroughs that don’t have a specialist mental health team. 
2.23.    This decision seeks approval for expenditure of £0.1m from the core GLA Rough Sleeping programme budget to grant fund EASL between 1 October 2024 and 31 March 2025 to provide mental health assessments and facilitate access to local services in London. 
London Homelessness Awards
2.24.    The London Housing Federation coordinates and delivers an annual awards ceremony, the London Homelessness Awards (LHAs), to recognise and highlight innovative practice in the homelessness sector.
2.25.    The LHAs are open to all projects in London working in the field of homelessness. This includes registered social landlords, local councils, NHS and health related organisations, voluntary organisations, or a partnership of any of these.
2.26.    The prizes for first, second and third place are £30,000, £20,000 and £10,000 respectively. Sponsors for the awards include the Mayor of London, London Councils, London Housing Foundation, Crisis and Shelter.
2.27.    The award ceremony takes place in Autumn each year, and in recent years they have been presented by Tom Copley, Deputy Mayor for Housing and Residential Development.
2.28.    This decision seeks approval for expenditure of £10,000 from the core GLA Rough Sleeping programme budget, to grant fund the LHF to contribute towards costs of delivering the LHAs in 2024.
The Outside Project - Anira House
2.29.    Since February 2023, the Outside Project has provided Anira House, a seven-bed house in multiple occupation for members of the LGBTIQA+ community who are experiencing homelessness. The Outside Project receives grant funding for revenue support costs to accommodate 20 people each year. Residents will receive specialist identity-responsive support during their stay of three to six months, and be supported to move on to independent housing.
2.30.    The Outside Project was initially grant funded £0.05m in the second round of the Mayor’s Rough Sleeping Innovation Fund. It was subsequently awarded grant funding of £0.1m in 2020-21 (DD2381) and 2021-22 (MD2789) for its work in partnership with Stonewall Housing. The Outside Project has been delivered independently of Stonewall Housing by LGBTIQ+ Outside CIC since 2022-23, when it received £0.1m (MD2957). A further £0.1m grant (MD3135) was awarded in 2022-23 to open Anira House. 
2.31.    This decision seeks approval for expenditure of £0.1m from the core GLA Rough Sleeping programme budget, to grant fund the Outside Project to deliver this project between 1 April 2024 and 31 March 2025. 
 

3.1.    Under section 149 of the Equality Act 2010, as public authorities, the Mayor and the GLA are subject to the Public Sector Equality Duty, and must have “due regard” of the need to:
•    eliminate unlawful discrimination, harassment and victimisation
•    advance equality of opportunity between people who share a relevant protected characteristic and those who do not
•    foster good relations between people who share a relevant protected characteristic and those who do not.
3.2.    Protected characteristics under section 149 of the Equality Act are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage or civil partnership status (all except the last being “relevant” protected characteristics). 
3.3.    The funding referenced in this decision will help to tackle the inequalities experienced by certain groups of Londoners most affected by homelessness and rough sleeping. Of those seen sleeping rough in 2022-23: 
•    51 per cent were non-UK nationals 
•    19 per cent were Black or Black British 
•    51 per cent had a mental health need 
•    17 per cent were female 
•    58 per cent were aged 26-45 
•    8 per cent were under 26 
•    12 per cent were over 55 years old.

3.4.    Homelessness in London, and specifically rough sleeping, disproportionately affects people with certain protected characteristics. Increasing the provision of preventative homelessness interventions will help to achieve positive impacts in line with the need to eliminate discrimination, harassment and victimisation.
3.5.    Several of the interventions for which this decision seeks approval will specifically benefit particular marginalised or disadvantaged groups, such as ‘Welfare to Wellbeing’ which supports homeless veterans, and ‘Anira House’ which is run by and for the homeless LGBTQ+ community. Other interventions, such as ‘HHPA’ and ‘Mental Health Assessment and support’ address specific needs that are more likely to be experienced (and unmet) by those experiencing homelessness. 
 

Key risks and issues
4.1.    The key risks associated with the decisions in this MD are outlined in the table below:

Links to Mayoral strategies and priorities
4.2.    The projects and services for which this MD seeks approval will help meet Policy 7.2, “Supporting Rough Sleepers off the Streets”, of the Mayor’s London Housing Strategy. This will occur through a range of actions to help meet the stated central aim of the Mayor “to ensure there is a route off the streets for every single rough sleeper in London”. The GLA Rough Sleeping team works closely with partners in local authorities, London Councils, DLUHC and the charity sector to support rough sleepers off the streets; and provides pan-London leadership and coordination. The services and projects funded form part of proposal B of the same policy, which states: 
“The Mayor will fund and commission a range of pan-London services and other initiatives to complement those provided by local councils. These will focus on identifying rough sleepers and intervening rapidly to support them off the streets, providing specialist support for particular groups, and helping rough sleepers stay off the street.” 
4.3.    The projects and services funded through this MD will also help meet the objectives of the London Health Inequalities Strategy. Addressing homelessness and rough sleeping is one of the seven objectives set by the Mayor to achieve the aim that all Londoners benefit from an environment and an economy that together promote good mental and physical health.
Conflicts of interest
4.4.    There are no known conflicts of interest for those involved in the drafting or clearance of this report.
Subsidy control
4.5.    GLA officers have carried out an analysis of the proposal against the Statutory Guidance for the UK Subsidy Control Regime. They have assessed that the Subsidy Control Regime is non-applicable in these circumstances because the proposed financial assistance does not constitute a subsidy.
4.6.    In particular, the proposed financial assistance fails to satisfy Limb B of the four-limbed test set out in the Subsidy Control Act 2022, as the beneficiaries of the funding are not classed as enterprises.
4.7.    This proposal is consistent with the example set out in the Statutory Guidance in section 2.17. This example states that “a ringfenced grant to a charity for its non-economic activities (even if the charity also provides some goods or services on the market)” is unlikely to meet the four-limbed test.
4.8.    Furthermore, as regards the seven subsidy control principles, there is an equity rationale for each of the grants proposed in decision 3. Taken together, they will mean hundreds of people are supported to find a longer-term solution to their homelessness and to address other support needs, rather than remaining on or returning to the streets, as would otherwise have been the case. The funding to be granted is specifically to achieve these objectives and is commensurate with the resources they require for this purpose. Without this subsidy, it is clear that the policy objectives would not be achieved, as these projects would not otherwise be funded. It is only with this additional funding that the providers can deliver these projects. The GLA will closely monitor the grants to ensure that they are spent as agreed; and that they deliver the stated policy objectives of supporting people to secure a longer-term route away from rough sleeping and to address mental and physical health issues. 
4.9.    It is not considered possible for any less distortive means to achieve these policy objectives. It would not be feasible to achieve the same outcome through introducing ex ante competition for contracted services or via a different funding mechanism (e.g. a loan). The people accommodated or supported by these services are homeless Londoners, who would not otherwise be able to pay, on a market basis, for the services provided by the project. The low risk of any impact on competition is far outweighed by the benefits of supporting these people (many of whom will have been sleeping rough for long periods) to find a longer-term solution to their homelessness and to address mental and physical health issues. 

5.1.    Mayoral Approval is sought for receipt of £1,500,000 from DLUHC as ‘Winter Pressures’ revenue funding in 2023-24. Approval is also requested for expenditure for various projects, which will be funded from the DLUHC ‘Winter Pressures’ funding (£1,500,000) in 2023-24, with delegation of authority to the Executive Director of Housing and Land to approve funding allocations in line with the requirements of the funding allocation letter between DLUHC and GLA.
5.2.    In addition to the above this MD seeks approval for revenue expenditure of £625,983 from the GLA Rough Sleeping 2024-25 revenue programme budget, as detailed under paragraph 1.7 and section 2 above. The 2024-25 budget setting process includes sufficient Rough Sleeping core Programme budget for this however, this will be subject to the final 2024-25 budget approval therefore appropriate break clauses should be in contracts, should budget and funding change.
 

6.1.    The foregoing sections of this report indicate that the decisions requested of the Mayor concern the exercise of the GLA’s general powers and fall within the GLA’s statutory power to do such things considered to further or which are facilitative of, conducive or incidental to the promotion of social development in Greater London and in formulating the proposals in respect of which a decision is sought officers have complied with the GLA’s related statutory duties to:
•    pay due regard to the principle that there should be equality of opportunity for all people
•    consider how the proposals will promote the improvement of health of persons, health inequalities between persons and to contribute towards the achievement of sustainable development in the United Kingdom
•    consult with appropriate bodies.
6.2.    In taking the decisions requested, the Mayor must have due regard to the Public Sector Equality Duty; namely the need to eliminate discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010, and to advance equality of opportunity between persons who share a relevant protected characteristic (age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation) and persons who do not share it and foster good relations between persons who share a relevant protected characteristic and persons who do not share it (section 149 of the Equality Act 2010). To this end, the Mayor should have particular regard to section 3 (above) of this report.
Receipt and expenditure of DLUHC funding
6.3.    Decision one, above, seeks approval for the receipt by the GLA of £1.5m “Winter Pressures” funding from DLUHC. Officers are reminded to comply with any conditions placed upon the use of the funding by DLUHC. 
6.4.    Decision two, above, seeks approval for expenditure of the £1.5m “Winter Pressures” funding for various projects. Officers are reminded that all expenditure – whether for the procurement of services, supplies or works or for the distribution of grant funding – must comply with the requirements of the GLA’s Contracts and Funding Code. Furthermore, officers are reminded to put in place appropriate contracts and grant agreements between the GLA and the relevant service providers and/or recipients prior to the commencement of the services or funded activities.
    Specific grant funding approvals 
6.5.    Decision three, above, seeks approval for the GLA to provide grant funding from the core Rough Sleeping Programme budget in the following amounts to the following recipients: (a) £76,983 to Veteran’s Aid for the Welfare to Wellbeing project; (b) £58,000 to Groundswell for the Homeless Health Peer Advocacy project; (c) £280,000 to St Mungo’s for the StreetLink service; (d) £97,000 to EASL for the Mental Health Assessment and Support project; (e) £10,000 to London Housing Foundation for the London Homelessness Awards 2024; (f) £104,000 to the Outside Project for the Anira House project.
6.6.    Further details of the funding are set out at paragraphs 2.7 to 2.31. In each case, the grant funding may be viewed as a conditional gift rather than a contract for services. Officers are reminded to put in place appropriate funding agreements between the GLA and the relevant recipients, before any of the funding is provided.
    Subsidy Control
6.7.    The Subsidy Control Act 2022 requires that grant funding be assessed in relation to its four-limbed test. Officers have made this assessment at paragraphs 4.5 to 4.7, above, and have concluded that the proposed funding does not amount to an unlawful subsidy. Furthermore, at paragraphs 4.8 and 4.9, above, officers have assessed the proposed grants in light of the seven subsidy control principles and have found that the grants comply with those principles.
    Delegation
6.8.    Decision four, above, requests a delegation of authority to the Executive Director of Housing and Land. Any function exercisable by the Mayor on behalf of the GLA may also be exercised by a member of the GLA’s staff albeit subject to any conditions, which the Mayor sees fit to impose. To this end, the Mayor may make the requested delegation to the Executive Director of Housing and Land, if he so chooses.
 

7.1.    The planned delivery approach for each of the interventions within this MD is set out in the tables below:

Welfare to wellbeing

Homeless Health Peer Advocacy

StreetLink London

Mental Health Assessment and Support

London Homelessness Awards

Anira House

Winter Pressures funding