In June 2020, the Fulfilling Lives South East team responded to a call for evidence by the government on the draft Domestic Abuse Bill and published a blog detailing our response and thoughts on the subject. We called for
- a clear definition of multiple complex needs,
- access to appropriate housing options and specialist DA domestic abuse services,
- domestic abuse and complex needs training for non-specialist services, and
- lived experience voices to be included in the Bill.
As the Domestic Abuse Bill achieved Royal Assent in April 2021, the Fulfilling Lives’ team reflects on how far the measures go in meeting the needs of women with multiple complex needs.
Time to reflect, review and re-think
Perhaps the biggest impact that the Act will have on our client group will come from the new duty placed on local authorities to assess the need and commission support to victims of domestic abuse and their children in safe accommodation services in their areas. When the Fulfilling Lives team reviewed the new Act we also considered the corresponding statuatory guidance published by the Department for Levelling Up, Housing and Communities (DLUHC), formerly the Ministry for Housing, Communities and Local Government (MHCLG). This sets out the operation of Part 4 of the Domestic Abuse Act to be delivered by local authorities, and what they should do to fulfil their statutory responsibilities and provides further clarity on how the new duty should be delivered on the ground.
Naming ‘Multiple Complex Needs’
As the Domestic Abuse Bill progressed through parliament last year, Fulfilling Lives South East called for the inclusion of a clear definition of multiple complex needs that expresses the needs of women who experience domestic abuse and complex needs. Whilst we welcome the widening of the statutory definition of domestic abuse to include emotional, coercive and economic abuse, we are disappointed in the lack of inclusion of a clear definition of multiple and complex needs within the Act. Nevertheless, we are pleased to see the direct inclusion of and frequent reference to ‘multiple and complex needs’ as a term, as well as ‘additional and/ or complex needs’, within the DLUHC’s corresponding statutory guidance. We know this is important because women who have multiple and complex needs are disproportionately affected by domestic abuse; In a snapshot in December 2018, 93% of the women on our caseload had experienced domestic abuse (25 out of 27 women), a prevalence that has been consistent throughout the lifetime of this project. Yet this group are often the most challenging to reach in terms of having their voices heard and needs met. So, the recognition of this group within the statuatory guidance is a welcome development in the delivery of support to victims of domestic abuse.
‘’In a snapshot in December 2018, 93% of the women on our caseload had experienced domestic abuse.’’FLSE Manifesto for change
Despite this progress, we still feel there needs to be an explicit definition of multiple and complex needs within the guidance provided by DLUHC. As currently drafted, Local Authorities can use their discretion in defining multiple and complex needs, which creates the risk of fragmented, variable responses nationally and a postcode lottery of appropriate safe accommodation services for those who experience domestic abuse and complex needs. To ensure a cohesive support response to those with multiple and complex needs, where individuals receive the right help when needed, without being judged, stigmatized or unfairly treated or excluded, it is imperative for this group to be distinctly recognised in the form of a comprehensive explanation of their experiences in such statuatory guidance.
‘‘My hope would be that women on the edges of society who face multiple barriers and stigma on a daily basis, will now be seen as a distinct group of people, with distinct needs when experiencing domestic abuse’’Sandra, Systems Change Officer
A spotlight on ‘safe accommodation’
Throughout the Bill consultation, Fulfilling Lives South East continued to advocate for access to appropriate housing options for those experiencing domestic abuse and complex needs. We hoped to see the Bill pave the way for creative forms of accommodation that provide emergency rapid-access accommodation with specialist wrap-around support. As such, it is positive to see a focus on safe accommodation for woman who experience domestic abuse and complex needs in the Act and statutory guidance and we welcome the new statutory duties placed on local authorities to provide safe accommodation for victims and survivors of domestic abuse. We believe that the inclusion of specialist, dispersed, and emergency accommodation that includes wrap around specialist support, including mental health and substance misuse support, in the DLUHC’s categorisation of appropriate safe accommodation to be a sign of considerable progress. We must now ensure that funding allocated to Local Authorities is ringfenced to support the provision of innovative accommodation options that are readily available for women who experience domestic abuse and complex needs.
‘’ I would hope that the complexity of these women will not be missed and do not end up slipping through the net and not receiving the help and support they so desperately need in a crisis”Kate, Engagement and Co-production Worker
Whilst Royal Assent of the Domestic Abuse Act was a pivotal moment for survivors and specialists in the sector, the legislation represents many beginnings as support systems locally and nationally review accommodation and support needs to shape future provision. We look forward to working with local statutory agencies to help shape a new local strategy to translate guidance into action and create the change needed to protect those women at the sharpest end of inequality.
Author: Emily Page
For further information about Fulfilling Lives work in this area, please contact Rebecca, Systems Change Lead: firstname.lastname@example.org