2020-2021 NRPF Connect data report

Policy changes

• End the imposition of the NRPF condition.
• Enable people with pending EU Settlement Scheme applications (made in time or late) to be eligible for means-tested benefits and mainstream homelessness assistance.
• Enable people with pre-settled status to rely on this as a right to reside in order to be eligible for means-tested benefits and mainstream homelessness assistance.
• Work across local and central government to fully understand the impacts of the use of the NRPF condition on councils and communities  
• Mitigating impacts on local government when immigration-based exclusions to benefits are maintained 

Funding  

• Using the comprehensive spending review process to understand and provide financial reimbursement to councils when people with no recourse to public funds are provided with accommodation and financial support.

• When immigration or other national policies are formed that may increase homelessness and destitution, and therefore the need for local authority support, a new burdens assessment must be undertaken that considers how this will affect existing pressures.

Minimising impacts

Provide policy concessions or more streamlined operational processes across government departments when these give rise to cost-shunts or delays exiting support. For example:

• Reinstating legal aid for immigration matters for particular groups or types of cases. 
• Exempting people receiving local authority support from secondary healthcare charging. 
• Enabling people without National Insurance numbers to be issued these once leave to remain is granted in order to expedite the transition to mainstream benefits when recourse to public funds is obtained.

With a view to taking steps to reduce any negative impacts on children, people with protected characteristics, and integration, conduct a cross-departmental review of the impacts arising from:

• Imposing the NRPF condition.
• Restricting access to benefits for EEA nationals with pre-settled status and people who are applying to the EU Settlement Scheme who cannot meet right to reside requirements.

To undertake a more strategic approach to concluding the immigration claims of households receiving support for over 1000 days, including a policy solution, such as a route to regularisation, when people are unable to return to their country of origin but do not meet the requirements of the Immigration Rules.

Operation of NRPF Connect 

• Increase the current resources put into operating NRPF Connect in order to ensure that the terms of the Service Level Agreement are met and to enable more councils to join and benefit from using the system.
• If the current policy position remains unchanged, increase the resourcing of NRPF Connect so that more targeted casework can be undertaken to ensure that households supported for over 1000 days achieve a final outcome expediently in addition to meeting the Service Level Agreement.

Service planning

• Ensure that a coordinated response is being undertaken to case-resolution across all practice areas to improve outcomes for residents receiving support and reduce expenditure, using NRPF Connect data to identify local trends and understand the needs of supported households.
• Consider ‘invest to save’ arguments for specialist staffing resources and commissioning services to support case-resolution, such as immigration advice.
• If your council is supporting households with no recourse to public funds and is not subscribing to NRPF Connect, consider joining to support local service delivery and contribute to collective regional and national data to understand the needs and make up of people with NRPF in your locality

Operational 

• Work with housing colleagues to expedite the transition between services when recourse has been granted and the household becomes eligible for homelessness assistance (including homelessness prevention).
• Review local data to ensure that this has been accurately reflected in your regions data report. Where inaccuracies are identified, remedial action may need to be undertaken to improve data quality.
• Attend your regional NRPF Network to share practice and learning.
• Contact the NRPF Network for further training and user support with NRPF Connect, as required. 

During the year of the Covid-19 pandemic, it is perhaps unsurprising that councils saw an increase in people with no recourse to public funds requesting support, or that more households were recorded as being provided with accommodation and financial support in comparison to the previous year. This places significant pressures on staffing resources and council budgets. The overall costs to local government will no doubt be higher if these trends are replicated in councils that are not contributing data through NRPF Connect.  

Households receiving support are diverse in terms of their immigration status. The rise in the proportion of adults with EEA nationality who requested or were provided with support could be a consequence of the changes to their residence rights following the end of free movement in the UK.  

The fact that one fifth of families requesting support have leave to remain that is subject to the NRPF condition serves as evidence of the financial hardship experienced by people with this immigration status, who are often on routes to settlement. As it is likely that a council will only be approached once informal or charitable support in the community has been exhausted, this figure can only represent the 'tip of the iceberg' in terms of wider need. The ability for people with leave on the family or private life routes to apply to the Home Office for a change of conditions to request that the NRPF condition is lifted may explain why this group makes up a smaller proportion (5%) of the family households that are provided with support. The change of conditions process offers an opportunity, in some cases, for a family’s situation of destitution to be resolved relatively quickly following their presentation to the Council.  

The fact that a significant proportion of people remain supported, despite having recourse to public funds, demonstrates that there can be delays transferring to mainstream benefits and housing services following a positive Home Office outcome.  

Although it is positive that the average time on support has decreased for both adult and family households, it is concerning that the proportion of adult households who had been receiving support for longer than 1000 days increased from 27% in March 2020 to 35% in March 2021.  

The data also continues to demonstrate that the majority of families (79%) and adults (51%) will exit support due to a grant of leave to remain or change in immigration status granting recourse, with the numbers returning to their country of origin or leaving the UK remaining low. People who are ‘in breach of immigration laws’ are only able to receive support when there is a barrier preventing return to their country of origin (Schedule 3 Nationality, Immigration and Asylum Act 2002). The data demonstrates that for the significant proportion of people provided with local authority support who are without current immigration permission, return to country of origin will only rarely be the solution to their situation of destitution in the UK. 

There has been an increase in the number of looked after children and care leavers added to the database, demonstrating that it is a useful tool to get updates on the progress of immigration and asylum claims, to identify whether a young person requires further immigration advice, and to confirm the status of care leavers age 18+ when the council must consider whether Schedule 3 applies and a human rights assessment is required.  

Councils clearly benefit from working in partnership with the Home Office over the NRPF Connect database in order to obtain essential immigration information to enact statutory safety-net responsibilities and gain prioritisation of immigration claims when households are receiving local authority support. However, with 33% of Home Office responses falling below the targets set out in the Service Level Agreement, this raises the question of how the Home Office will be able to meet an increase in demand for the service arising from existing users and new councils wishing to join.  

Overall, the national data demonstrates that significant cost pressures arise for councils as a result of government policies excluding people from mainstream benefits and housing services. The trends identified in the data inform the recommendations for policy and operational change that are set out in this report. Action is required from the UK Government to reduce destitution in communities and mitigate the impacts that immigration policies have on councils. Councils may also need to consider how they can reduce costs locally by ensuring that services providing essential safety-net support are delivered as efficiently and effectively as possible, including making best use of NRPF Connect to monitor caseloads and trends.