Recent International and National Approaches to Homelessness 

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Executive summary 

This report was commissioned by the Australian Government Department of Family and Community Services (FACS) on behalf of the Supported Accommodation Assistance Program (SAAP) National Coordination and Development Committee (CAD). It provides an overview of international and national approaches to homelessness and updates the literature review undertaken by the SAAP III Evaluation consultants (SERC and AHURI), presented as 'National Evaluation of the Supported Accommodation Assistance Program (SAAP III) Technical Paper 1 Review of Homelessness: International and Australian Perspectives' (Manicaros and Lanyon 1999).

The aim of this project is to identify, assess and compare the range of current definitions, legislation, planning and policies that address homeless and inadequate housing in Australia, the United States (US), the United Kingdom (UK) and the European Union (EU) countries.

The research questions for the review are:

  • What are the current definitions and concepts of homelessness and how have they developed since 1998?
  • What changes have occurred in legislation, policy and programs since 1998?
  • What is considered to be good practice in alleviating homelessness, including locating examples?
  • How can international good practice progress Australian national policy approaches to homelessness?

Since 1998, there has been only modest international advancement in relation to homelessness policies and programs. In those instances where definitions of homelessness exist, the majority are inadequate and narrow. Many international definitions do not recognise the myriad of issues preceding and accompanying homelessness or that homelessness is a dynamic process that may include sleeping rough, insecure tenure, chronic homelessness and, at times, being housed. For most European countries, homelessness does not extend beyond the highly visible but simplistic concept of rough sleeping.

The inability to robustly define homelessness impacts on the quality and quantity of statistics on homeless people. There are substantial gaps, with some countries unable to provide the most rudimentary estimates of homelessness at a national level (Germany, Greece, Netherlands, Belgium, Spain, Portugal and France). There are differing collection methods, time frames and measures that make it impossible to fully appreciate homelessness. Many of the statistics are based on those who are 'accepted' as being homeless by a service provider. This makes it difficult to fully appreciate who is homelessness when a number of groups are excluded from accessing homeless services. These excluded groups include many of those now identified as the 'new homeless'.

Another barrier to effective responses relates to direction of financial resources to homelessness and the lack of statutory responsibility for homelessness. For example, some countries in the EU have a statutory responsibility for housing, but not for homelessness. Housing is but one of the responses to alleviating homelessness. Also, homelessness is not a primary policy area; it is located at the periphery of housing and social policy, thus responses may not be targeted or appropriate. This has major implications for developing adequate and appropriate responses to homelessness, as the integration of social, housing and education initiatives is central to developing good practice policies and programs.

There are a number of responses to homelessness in the international arena that are not consistent or compatible with Australian approaches. There is an increasing use of punitive measures against homeless people. Examples include categorising homeless people as 'deserving' of homelessness because their experience is seen as a 'choice' or 'tradition' (for example, gypsies or asylum seekers) – in some countries it is illegal for services to assist anyone who does not have appropriate identification or residency status. There is a trend toward denying access to housing as a punishment for anti-social behaviour and the use of 'priority need' to promote discrimination. The criminalisation of homelessness through the development of anti-panhandling and anti-sleeping laws in the United States is another example of a punitive approach. These responses directly contradict the social inclusion frameworks that are espoused to underpin many policies and programs particularly in the UK and EU.

Australia is arguably at the forefront of advances in the definition, enumeration and response to homelessness. The definition of homelessness in Australia has not substantially changed in the past five years, and takes into account homeless pathways, age and culture. There are some modifications to existing definitions that have been developed only recently and it remains to be seen whether service delivery responds to these changes. Australia's enumeration of the homeless population, while having some constraints provides useful and relatively comprehensive statistics on homeless people who are both service and non-service users. The SAAP National Data Collection is reported nationally and annually, which is significantly more advanced than the majority of the other countries in this review. The provision of relatively comprehensive statistics in Australia enables both government and non-government agencies to strategically respond to homeless.

Internationally, there are very few strategic approaches to homelessness. In fact, homelessness is often not considered as worthy of a policy response in its own right and is frequently relegated to the periphery of housing and social policy. The development of strategic approaches in Australia to policy and programs, such as the National Homelessness Strategy and various state homelessness strategies, is also another significant advance. Each strategy has relied on strong community consultation and evidenced based research and will be evaluated to determine its effectiveness. This then provides a clear reference point from which to develop further strategies and responses to homelessness. It is in this field of providing strategic and cohesive approaches to homelessness that Australia can become a leader in 'good practice' internationally.

Since the SAAP III Technical Paper there has been a significant increase in the recognition of the diversity and complexities of homelessness, particularly in the EU and the UK. However, this has not always translated into a service delivery response. The majority of the countries covered are developing strategies and responses (such as the National Action Plans (NAPs)) but it remains to be seen whether they are effective. There have been a number of broad issues impacting on homelessness legislation, policies and programs. For example, the devolving of policy responsibility in the United Kingdom has resulted in new legislation in Scotland, Wales and Northern Ireland. It has also resulted in the establishment of new commissions and the formulating of new strategies. There is also a growing reliance on non-government agencies, particularly, in the United States to respond to homelessness.

Good (and best) practice in policy responses is something that is widely encouraged but poorly defined. The idea of 'best practice' is closely associated with the idea of continuous improvement in a quality framework. It assumes identified benchmarks or performance indicators. There are no widely agreed benchmarks or performance indicators for homelessness policies. For the purposes of this report, an attempt was made to identify good practice through using a combination of the criteria used by FEANTSA for the European Union and those associated with 'innovation' in the report by Jerome et al (2003). There were also insufficient evaluative data available to quantify good practice and it was necessary to contextualise good practice in relation to the following identified qualitative criteria. A good practice policy response will:

  • Use a clear definition of 'homelessness', one that can easily be incorporated into legislation and on-going statistics are available to enable on-going assessment and monitoring;
  • Rest on a solid regulatory basis to ensure the effectiveness of political measures and enable their operation to be monitored;
  • Particularly target the homeless in order to respond adequately to problems of the homeless (i.e. that they are not just adjuncts to other policies);
  • Consider homelessness in all its multidimensional aspects and provide solutions for each problem in the lives of the homeless, such as housing, health, work, mental illness, education etc. In Jerome et al (2002) this was described as explicitly incorporating integration and collaboration across wider issues in the wider context, and as addressing both social and housing needs of clients;
  • Recognise the variety of kinds of current homelessness captured by the term the 'new homeless'. They do not focus on just, for example, those who are sleeping rough, or older males;
  • Deal with the problem both before it develops and while it is being dealt with (i.e. introduce measures aimed at preventing homelessness, improve the facilities for helping the homeless and create reintegration programmes adapted to the homeless); and
  • Implement strategies for increasing independence through capacity building.

There was a paucity of policies that could clearly be identified as good practice against all of these criteria. Many policies and programs achieved some of the criteria very well but did not perform well against them all. But clearly good practice policies and programs should be aimed at achieving good performance against all of the criteria.

This review on international and national perspectives on homelessness provides an information base to compare the extent and nature of homeless between Europe, the United Kingdom, the United States and Australia. It has shown that responses to homelessness vary considerably across countries. The review also illustrates that Australia's approaches to homelessness are progressive and well informed, demonstrating a detailed understanding of who is homeless and sophisticated program and policy responses to homelessness that are fair, equitable and supportive of diverse and complex needs.


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