Inquiry into the provision and regulation of supported accommodation in Queensland

Submission No: 148

Submitted by: 38KPR

Publication: Making the submission and your name public

Attachments: See attachment

Submitter Comments:

38KPR 38 Kedron Park Rd
Wooloowin QLD 4030
2nd February 2024

To: The Community Support and Services Committee

Subject: Submission to the Inquiry into Supported Accommodation in Queensland

Dear Committee

I am writing on behalf of 38KPR to submit our perspective and recommendations to the Inquiry into Supported Accommodation in Queensland.

38KPR is a private, accredited Level 1 residential service under the Residential Services (Accreditation) Act 2002 (QLD). Our service caters exclusively to older men who are at risk of, or experiencing homelessness, with a commitment to providing safe, stable accommodation.

Our submission consists of three key points, along with an 8-page document outlining crucial details about our service. I trust that the committee shares our deep concern for the countless Queenslanders currently experiencing the profound challenges of homelessness. As stewards of change, I am confident that the committee will examine this document with the same diligence that we apply to our mission of reducing the traumatic impact of homelessness.

Point 1 - Regulations and Enforcement:

We firmly believe that the current regulations governing Level 1 residential services are fit for purpose and do not require significant changes. However, our concern lies in the inadequate enforcement of these regulations, which has led to subpar standards among service providers. For instance, the recent closure of Clivedon Mansions, a 75-bed Level 1 residential service, serves as a striking example. I personally inspected the property and witnessed deplorable conditions, including damaged property, graffiti, non-functional toilets, sinks that were filled with purulent debris and uncapped syringes on bathroom floors. Clivedon Mansions had gained notoriety among social service providers and was considered scarcely better than “sleeping rough” by some.

These challenges are not isolated incidents but have been recurrent issues in the sector. Several of our residents who have lived in various boarding houses have shared stories of dismal conditions, including violence, theft, and a lack of basic necessities. These experiences highlight the pressing need for stringent enforcement to ensure the safety, well-being, and dignity of residents in Level 1 residential services.

This said, we would like to emphasise that our dealings with regulatory services have been consistently positive, and we value our relationship with the regulator. However, we acknowledge that the subpar standards among some Service providers may be attributed to various factors, such as:

Resource Constraints: Regulatory services may face resource limitations that hinder their ability to conduct thorough oversight and enforcement.
Lack of Understanding: Some officers may not fully comprehend the devastating impact that low standards can have on the lives of vulnerable individuals, leading to complacency.
Pressure to Address Homelessness Crisis: The overwhelming demand for accommodation amid the homelessness crisis may put pressure on regulatory services to keep services open, even when standards are not met.

In light of these challenges, a possible solution could involve expanding the scope of regulatory services. Rather than solely focusing on compliance reports and box-ticking exercises, regulatory services could be appropriately trained to engage with providers in a more comprehensive manner. This expanded engagement would involve actively supporting providers to ensure that residents receive the appropriate support and care they require. Managing tenancies in a social housing environment is inherently complex, and this complexity could be navigated effectively by equipping regulatory personnel with the necessary training and tools to assist providers in addressing the unique challenges of this sector.

We firmly believe that strict enforcement, coupled with increased resources for regulatory services, can help raise the standards of Level 1 residential services and ensure the safety and dignity of residents.

Point 2 - A Progressive Approach to Funding Existing and Emerging Providers:

Our organisation advocates for a market-based approach to address the challenges within Level 1 residential services. Unlike not-for-profit services such as Community Housing Providers and government funded Specialist Homelessness Services, privately-owned businesses entering this sector have a strong incentive to manage their operations efficiently. Their financial risk encourages commitment and dedication, fostering innovation, accountability, and high standards of service. And while it is true that some privately-run services have fallen short, these have consistently been legacy asset owners with minimal debt. We propose that strict regulatory oversight, as mentioned in Point 1, can deter unethical operators and maintain industry integrity. This approach allows only committed and responsible operators to thrive, ensuring resident well-being.

Regarding recent industry discussion about direct funding to providers of Level 1 residential services, we firmly assert that this is not the best approach. Recent instances of mismanagement and abuse within NDIS providers and supported accommodation providers serve as cautionary tales. They underscore the potential risks of indiscriminately injecting funding into Level 1 residential services, which may attract unscrupulous operators driven solely by financial gain, ultimately compromising service quality. Our model and track record have unequivocally demonstrated the capability of private providers, such as ourselves, to deliver a level of service that not only meets but often surpasses the standards set by government-funded providers—remarkably, without relying on government funding.

A more prudent approach entails identifying private operators who diligently adhere to regulations and consistently achieve positive outcomes for residents. These operators could be supported in addressing barriers to expanding the capacity of their residential services, in particular, the capital-intensive nature of rooming accommodation assets, where banks typically extend only 50% of the required funding. This could be facilitated through mechanisms such as borrowing guarantees or support with access to private lending arrangements. This approach encourages responsible and ethical providers to expand their impact while maintaining the high standards of care and efficiency commensurate with small-to-medium enterprises.

Point 3 - Supporting Good Operators:

To maximise the positive impact of Level 1 residential services, we suggest a focus on supporting good operators more generally. Governments can encourage providers to engage with service providers or community groups who are willing to collaborate in supporting homeless individuals in their neighbourhood. This may include assisting residents to engage in local community events and activities, connecting residents with existing, externally funded service providers or encouraging collaboration between Level 1 residential service providers and public service providers such as health services, community corrections and public housing.

Although this may sound like a utopian outcome, there is already a strong precedent for such initiatives. At our residential service, we have seen an overwhelming appetite from the local community for supporting our residents, including food donations from a local cafe at Christmas, expression of care and support from the local supermarket, and numerous kind gestures from neighbours. We have also engaged with the service integration initiative for our region run by QShelter, which has directly led to positive housing outcomes for a number of residents.

Summary

In conclusion, we firmly believe that the existing regulations, if rigorously enforced and supported by adequate resources, can raise the standards of Level 1 residential services. A free-market approach, without direct funding for Level 1 residential service providers, underpinned by stringent regulatory oversight, can lead to innovation and accountability, ultimately benefiting residents. A focus on supporting compliant operators who demonstrate positive outcomes can lead to better engagement with existing and emerging support initiatives.

We thank the Committee for considering our submission and remain open to any further inquiries or discussions on this matter.

Sincerely,

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Dave Lyons

IF vulnerable Queenslanders

WHO ARE experiencing or at risk of homelessness

HAVE ACCESS to safe, affordable, compliant Level 1 Residential Services

THEY ARE MORE LIKELY to connect and engage with support services

THEREBY addressing barriers to finding and maintaining long-term accommodation.

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WHAT IS 38KPR?

At the heart of our operational model is our capacity to get positive outcomes for our residents by

building a positive culture where residents care for each other and their home
promoting safety and compliance via regular engagement with residents and a transparent, SOP-based approach to daily operations
supporting resident well-being by forging strong, collaborative relationships with other service providers
leveraging those relationships with the ultimate goal of addressing barriers to our residents finding or maintaining long-term accommodation.

“My whole world was at the point that I felt it would be better to be in jail rather than barely surviving sleeping in a car. My job prospects were nil with no residential address. I was at the end of everything. I didn’t want to live.

38KPR gave me hope for something I had lost. They made me feel welcome and most of all useful. I could sleep there even without me having the rent in advance.

The rest of my life is now manageable. I feel like a human being who is worth something.”

Mike is now in full-time employment and remains active supporting other 38KPR residents on their journey.

HOW ARE WE DIFFERENT?

We believe that our model is unique in that we do not rely on grants or subsidies (government, philanthropic, charitable or otherwise) to deliver our core service. Our objective is to provide affordable accommodation in a safe, supportive environment and we achieve this by efficiently operating as a Level 1 Residential Service.

This style of accommodation is regulated by the Department of Communities, Housing and Digital Economy under the Residential Services (Accreditation) Regulation 2018. Over the years, many of these property assets (colloquially known as ‘boarding houses’) have become unfit for purpose and are often unsafe, poorly managed and exist with little operational infrastructure or oversight. We take our obligations under the Regulations seriously, fostering a culture of safety and compliance that is consistently applied in a top-down approach.

The economies of scale provided by this style of dwelling allow us to remain financially sustainable without the need for outside funding. Our residents live together in rooming style accommodation and pay fortnightly rent at an affordable rate, which covers utilities, maintenance and other outgoings. Each resident has a private room with a kitchenette, while other amenities and recreational areas are shared.

TOM (pseudonym)

“A lot of the boarding houses I was staying in weren’t much better than being homeless anyway. I had my gear smashed and stolen a bunch of times. There was a lot of violence.

When you move around like that, it’s not like you’re getting mail, so I didn’t even know whether I was on the waiting list for housing or not. It was miserable.

I’m out the other side now. I’ll still keep coming back here to see the other guys once I have a permanent place.“

After 18 months with 38KPR, Tom has re-engaged with HART4000 and will soon move on to permanent housing. He will be missed.

We encourage 38KPR residents to support each other and foster a sense of community. In turn residents show a strong tendency to bond over a variety of lived experiences and an opportunity to “pay it forward” by supporting fellow residents.

OUTCOME MEASUREMENT

Over the past three years, even in the absence of funding, we have consistently demonstrated positive outcomes for our residents and have gained the attention of industry stakeholders via some remarkable stories. Our overarching difference is our capacity to leverage relationships with external service providers to support our residents with healthcare, mental health support, harm minimisation services, advocacy and other forms of social support that can help to address issues resulting from or leading to homelessness.

Providing safe affordable accommodation

Residents leaving service with better health, well being and employment prospects than when they arrived

MAX

Max Kruger had a distinguished career as one of the world’s leading test cricket statisticians for over 30 years. In 2016, a foot infection contracted while mowing his lawn led to Max undergoing a below-knee amputation. The series of events that followed culminated in Max becoming homeless. In 2022, he was referred to 38KPR via HART4000. Once in stable accommodation, Max was connected with other services and began putting his life back together. With support and advocacy from SUFY, Max was referred to the Under 1 Roof care coordination group and was able to successfully access the NDIS and apply for a DSP. In 2023 HART4000 found Max permanent housing. He still visits 38KPR and uses his story and lived experience to actively support our vision.

“I could not put a price on what this key means to me. The sense of relief was almost like the clouds lifting on a foggy day. I can feel as if I know when I wake up each morning where I’m going to be later that night.”

38KPR - Our Vision Page 4

38KPR STORY

2019

Dave, a pharmacist, moves home to Brisbane with his young family and buys a fixer-upper in Wooloowin. He meets his neighbour, Col, who lives in a local boarding house that has been converted from an old industrial building. They become mates.

2020

Col’s building came up for sale as a potential development site, so Dave convinces his boss, Stuart, an accountant that they should buy it and keep it as a going concern.

2021

COVID lockdowns end. On 10th August 2021, the census is taken and over 120,000 Australians are homeless. Dave begins receiving a lot of calls.

2022

In the four years to 2022, homelessness had risen 22% in Queensland compared with 8% across the rest of Australia (1). The calls became more frequent.

2023

By 2023, Brisbane rents have increased 34% since the beginning of the pandemic and the increase in homelessness in Queensland outpaces all other states and territories (2). Dave meets Nic, a support worker at HART4000. Nic cares about his clients like Dave does about the residents. They collaborate.

Nic and the HART team explain that they do their best work with clients when these clients are out of the acute crisis of homelessness and in some form of stable accommodation. However, this was presenting an increasing challenge with older men who had been forced into homelessness given the lack of suitable short or medium-term accommodation options for this cohort. Dave had also begun to see firsthand the traumatic effect that homelessness had on the lives of those coming into 38KPR. Getting older men out of crisis and connected with services became the 38KPR mission.

38KPR PEOPLE

Dave Lyons

After a successful career as a pharmacy owner, Dave undertook an MBA and has since held corporate roles in healthcare and retail. He is passionate about creative problem solving, with a particular interest in primary health and social entrepreneurship.

Stuart McBrien

Stuart is a chartered accountant and has extensive senior executive experience across healthcare and manufacturing. He holds an MBA, is a MAICD and serves as a non-executive director to several startups.

Col Newton

Col qualified as a tiler in 1959 and subsequently tiled a number of well known sites around Brisbane and the Darling Downs. He then ran a successful swimming pool business in Brisbane before moving north to pursue his passion for boating. He returned to Brisbane in the 90s and retired onto his houseboat which he built and moored on the Brisbane river in Hamilton. After his boat was lost in the 2011 flood, he moved into rooming accommodation.

With capacity for 15 residents, the house offers safe and stable accommodation for older men reliant on social income support and suffering from chronic health conditions.

1 Pawson H (2023) The post COVID crisis: which Queenslanders hardest hit with 100,000 households needing low-cost housing? here’s how it can recover The Conversation. 10 March 2023

2 Pawson H Clarke A Moore J vandenNouland R Ng M (2023) A blueprint to tackle Queensland’s housing crisis Queensland Council of Social Service

38KPR - Our Vision Page 5

WHERE TO NOW?

Over the past three years we have:

Shown anecdotally that our service is capable of generating positive social outcomes, in line with or exceeding those achieved by government-funded housing providers (based on anecdotal feedback supported by network partners)
Created a scalable operational model with measurable social impact outcomes
Confirmed the financial viability of our model over three financial years
Done modelling on other similar assets to demonstrate that this financial sustainability can be replicated in current market conditions.

BUT TO INCREASE OUR IMPACT, WE HAVE A FINAL HURDLE TO OVERCOME …

Lenders view this asset class as high-risk and banks will generally only loan up to 50% of the asset value. So despite our being able to demonstrate the capacity to produce positive cash flow sufficient to service debt, even on highly leveraged assets, traditional bank finance alone is not an option. As such, another lending source is required in order to expand our service.

WHAT ARE WE ASKING?

To partner with institutions, organisations, government entities or others who can help by providing credit, investing in future acquisitions or helping us connect with social impact lenders.

To expand our impact, we need more capacity. We aim to achieve this by:

Acquisition of other currently registered Level 1 Residential Services
Conversion of existing assets to Level 1 Residential Services

To engage with service providers who would like to work with us to support older men at risk of homelessness

We currently connect residents with existing, externally funded service providers. But we are also working with several providers to develop customised services that would require funding for successful execution.

We are open to exploring any collaborative opportunity that may lead to better outcomes for our residents.

38KPR - Our Vision Page 6

WHAT ARE WE OFFERING?

We are not seeking free money. Our model works because it is a social enterprise and we believe that our best chance of making an impact is by adopting a sustainable commercial model that outlives tenders and grants. We believe this approach will keep us efficient and engaged in our goal of reducing the impact of homelessness. As such we can offer:

Return on investment at market or near-market interest rates and a plan for amortisation of initial capital investment
Comprehensive outcome reporting and impact sharing.

PHIL SMITH

Care Coordination Facilitator Brisbane
QShelter

“As part of my role, I facilitate multi-disciplinary care coordination groups working with referrals for households who are homeless, or at risk of homelessness, and have other additional complex needs. Dave from 38KPR was already working closely with Communify’s HART4000 (Homeless Assessment and Referral Team) but in and between care coordination meetings has been able to make links with a broad range of service providers who can provide advice and support to residents at 38KPR. These have included, for example, NDIS and other disability advocacy, AOD support, and mental health support agencies.”

NIC NEVIN

Acting Centre-based Team Leader
HART4000 (Homelessness Assessment Referral Team)

“HART4000 is very grateful to have a partnership with 38KPR whereby Dave lets us know about vacancies and we successfully match rooms to suitable participants who access our service. There have been several great long-term housing outcomes we’ve been able to achieve by working together, respecting each other’s needs and capacity, and using our strengths to work towards ending functional homelessness in the community. When we hope for a future of de-colonised, grassroots community work, it looks a lot like 38KPR’s model.”

ZOE PAGE

A/Senior Case Manager
Brisbane Central Community Corrections

“From a Community Corrections point of view, accommodation can be considered to be a protective factor and adversely, the lack of stability within housing can present as a significant barrier to engagement with intervention, supervision and therefore rehabilitation and successful reintegration. Working with organisations like 38KPR creates opportunities for collaborative case management and this has allowed our office to provide a more holistic approach in this area.”

38KPR - Our Vision Page 7

IF YOU ARE PASSIONATE ABOUT MAKING A GENUINE IMPACT ON HOMELESSNESS, WE WANT TO HEAR FROM YOU!

Or if you would like more information on our financial modelling, outcome measurement framework or any other aspects of our model, please get in touch.

THANK YOU.

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