Policy Paper: Reforming marginal renting

01/07/2011

Most renters in New South Wales are covered by residential tenancies legislation. Some renters, however, are not.

These 'marginal renters' come from different walks of life, and live in a wide variety of different forms of accommodation, including boarding houses, lodgements in private residences, share houses, and supported accommodation.

What marginal renters have in common is that they are excluded from mainstream residential tenancies legislation, and they are often disadvantaged in other ways too.

Marginal rental accommodation is a small but important part of the housing system in New South Wales. Despite the important roles it plays, the marginal rental sector is in bad shape.

Legal relations between marginal renters and landlords are governed by unregulated common law contracts, with no fair mechanism for resolving disputes.

Existing measures to encourage the operation of boarding houses have not delivered satisfactory outcomes for investors or the community generally.

Renters in boarding houses are often socially isolated, and so are some landlords.

The accommodation and support provided to people with disability by licensed residential centres is generally unsatisfactory, and at its worst is abusive and exploitative.

Marginal renters deserve better. The marginal rental sector needs reform. In this paper, the TU draws on the experiences and positions of the leading organisations in the community sector to propose a comprehensive four-point plan for reforming marginal renting.

A four-point plan for reforming marginal renting

1. Law reform to create 'occupancy agreements'

2. Measures for more viable boarding houses

3. Services to promote social inclusion

4. Appropriate housing and support for people with disability

What is marginal rental accommodation?

For the purposes of this paper, marginal rental accommodation comprises a variety of forms of residential accommodation that are exempt from residential tenancies legislation. Many of these forms of accommodation operate differently from mainstream residential tenancies, and from each other; most provide accommodation particularly to disadvantaged persons. Marginal rental accommodation includes:

boarding houses;
licensed boarding houses (or licensed residential centres (LRCs));
lodgements in private residences;
residential accommodation in hotels, motels, backpacker hostels, serviced apartments, and pubs and clubs;
educational institutions and residential colleges;
refuges, crisis accommodation and supported accommodation;
caravans in residential parks (where excluded from the Residential Parks Act 1998 (NSW) by cl 4 of the Residential Parks Regulation 2006);
share houses (where the occupants do not have written residential tenancy agreements, per s 10 of theResidential Tenancies Act 2010).

As these examples indicate, the persons and organisations that provide marginal rental accommodation vary widely. Some are relatively large institutions; some are community organisations; some are small businesses and some are individual persons. Some operate on an enduring basis; some operate on an informal, impermanent or ad hoc basis. Some are strictly commercial operations; some are not-for-profit; some operate on a subsistence basis.

The marginal rental sector is small relative to the mainstream residential tenancy sector. Table 1 gives an indication of the size of the marginal rental sector and the various types of accommodation that comprise it.

Table 1. NSW marginal and mainstream rental sectors at the Census of Population and Housing, 2006

Accommodation type	Premises	Persons
Marginal rental accommodation
'Boarding house, private hotel'	465	6,093
'Hostel for the disabled'	236	3,621
'Residential college, hall of residence'	122	13,841
'Hostel for the homeless, night shelter, refuge'	164	1,468
Total	987	25,023
Mainstream residential tenancies
Private rental plus social housing	687,431	1,622,486

Source: Australian Bureau of Statistics

It should be noted, however, that it is difficult to say accurately how many persons live in marginal rental accommodation, because measures such as the Census tend to undercount marginal rental properties and the persons residing in them. In particular, some boarding houses – particularly those outside inner city area – are not counted because their external appearance is the same as other suburban houses. Similarly, the Census undercounts persons residing in supported accommodation. In the same year as the Census, the Supported Accommodation Assistance Program database recorded 5110 residents – the Census recorded only 1468 residents in the equivalent category.

Who are marginal renters?

The following case studies from the files of the TU and the Tenants Advice and Advocacy Services illustrate typically the people who live in marginal rental accommodation, and the issues and problems they face.

B is a homeowner, but she and her children have left the home to escape B's violent partner. B cannot afford private rental, so now shares a room with her children in a small private hotel. B has raised concerns about the cleanliness of the shared bathroom and kitchen, and been told by the caretaker that if she does not like it, she and her children can leave.

C moved into a farming property as a lodger, on the understanding that he could have the room for $40 per week and doing some work on the property, and that most of the time he would have the place to himself. Subsequently C found that the landlord was always at the property, and the landlord, complaining that C did not do enough work, increased the rent to $90 per week. Tensions escalated; C and the landlord each applied for Apprehended Violence Orders; C suffered a recurrence of mental illness and was hospitalised. C now lives in his car.

D has lived in a boarding house in inner Sydney for 30 years, and is happy to call it home. The caretaker, however, has given D and the 14 other residents seven days notice to vacate, because the premises have been sold and the purchaser requires vacant possession (he intends to renovate and move in). Some of the residents, including D, are elderly, and some have a mental illness. With the help of an advocate they negotiate for 30 days in which to find alternative accommodation.

E is an international student who rents a room in a house with four other international students. Each has an 'accommodation agreement' with the landlord, the terms of which include:

a fee of $10 for each day rent is paid late;
a fee of $10 each week if the student uses a heater;
a fee of $20 if the student does not keep the premises clean;
a requirement that students vacating during November and December give two months notice; and
a provision that the rent may be adjusted 'from time to time' and 'at the accommodation provider's discretion.'

E's landlord advises, 'that's the way it's done here in Australia.'

F lives in a licensed boarding house for people with disability. The rent is 85 per cent of F's disability support pension, and after other service charges are subtracted F is left with $12.50 per week to spend as he wishes. F is concerned that the boarding house manager is not forwarding mail to residents, but is too scared to raise the matter personally. As he explained in a letter to an advocate, 'if they find out I wrote to you they could make things very hard for me and I'm in the process of leaving here… and they could try to find a reason to keep me here.'

1. Law reform to create 'occupancy agreements'

Because marginal renters are not covered by residential tenancies legislation, they instead have only common law contracts with their landlords.

For marginal renters, the common law is an unsatisfactory regime. The common law does not oblige landlords to provide standardised contracts for marginal rental accommodation, nor compel them to do even the most basic things – such as providing a receipt when rent is paid. Many marginal rental contracts contain no terms relating to the landlord's obligations and many marginal renters do not receive a written copy of their contract. Confusion as to parties' contractual rights and obligations often leads to disputes between marginal renters and landlords.

The common law also fails to provide a fair or realistic mechanism for dispute resolution. Some marginal renters may be able to initiate proceedings against their landlords under the Consumer Claims Act 1993 (NSW) in the General Division of the Consumer, Trader and Tenancy Tribunal. However, this course of action is only available to marginal renters whose landlords fit the legal definition of being 'in business'; otherwise, they have to initiate proceedings in the courts, which is not a realistic option. Marginal landlords, on the other hand, have no access to the Tribunal, and the courts are not a realistic option for them either. All too often, disputes end with landlords summarily evicting marginal renters.

Most other Australian states and territories have enacted legislation that covers some categories of marginal rental accommodation. The approach taken in Queensland, South Australia, Tasmania and Victoria has been to legislate on a relatively narrow and prescriptive basis: that is, their legislation applies narrowly to boarding houses (or rooming houses, or boarding premises – the language varies from State to State) of a certain size (where there is room for three residents or more, or four residents or more – the threshold varies from State to State), and the legislation prescribes in detail the terms of agreements and any notice periods for rent increases and terminations.

The shortcoming of this approach is that many categories of marginal renters – notably lodgers in private residences, students in residential colleges, residents of small boarding houses and residents of crisis accommodation – remain uncovered. Furthermore, if this sort of legislation was extended to cover other categories of marginal rental accommodation, the details prescribed may not be suitable to the very different living arrangements they provide.

The TU believes that the better model of legislation is the 'occupancy agreements' model implemented by the Australian Capital Territory (Part 5 A of the Residential Tenancies Act 1997 (ACT)). The key features of the ACT model of legislation are:

Broad coverage. All rental contracts for residential purposes not otherwise covered by residential tenancies legislation are covered. These contracts are known as 'occupancy agreements'; marginal renters are known as 'occupants' and their landlords as 'grantors'.
Occupancy principles. Occupancy agreements are required to comply with certain 'occupancy principles'. These principles are very basic and non-prescriptive, and so accommodate the different ways in which different types of marginal rental accommodation operate. The TU's proposed occupancy principles are reproduced below.
Provision for standard terms by regulation. Standard terms would be more prescriptive than the occupancy principles, but they would not apply to all occupancy agreements – just the specific types to which they are tailored. Standard terms would not be in the legislation itself, and would instead be prescribed in regulations developed in consultation with stakeholders.
Dispute resolution through the Tribunal. Both landlords and occupants may apply to the tribunal for resolution of a dispute arising from an occupancy agreement. The Tribunal is required to apply the occupancy principles when it determines disputes. Landlords are not required to apply to the Tribunal for termination of an occupancy agreement, but an occupant who disputes a termination may apply.

We propose the following 12 occupancy principles, based closely on the nine principles in the ACT legislation:

An occupant is entitled to live in premises that are—
a. reasonably clean; and
b. in a reasonable state of repair; and
c. reasonably secure.
A grantor is entitled to set reasonable rules of the premises, and an occupant is entitled to know the rules of the premises before moving in.
An occupant is entitled to have the occupancy agreement, and receipts for payment of any monies, in writing.
An occupant is entitled to quiet enjoyment of the premises.
A grantor is entitled to enter the premises at a reasonable time on reasonable grounds to carry out inspections or repairs and for other reasonable purposes.
An occupant is entitled to reasonable notice before the grantor increases the amount to be paid for the right to occupy the premises, and to know before moving in how much notice will be given.
An occupant is not liable to pay a penalty or fee for breach of any term of the agreement or any of the rules of the premises.
A grantor is entitled to charge for use of a utility, provided that the amount charged is determined according to the cost to the grantor of providing the utility and a reasonable measure or estimate of the occupant's use of the utility.
A grantor is entitled to require the payment of a bond equivalent to not more than two weeks' rent, and must lodge any bond monies with the Rental Bond Board.
An occupant is entitled to know why and how the occupancy may be terminated, including how much notice will be given before eviction.
An occupant must not be evicted without reasonable notice.
A grantor and occupant should try to resolve disputes using reasonable dispute resolution processes.

Recommendation

Enact legislation for occupancy agreements on the ACT model, incorporating the TU's proposed occupancy principles.

Further information

TU (2011) 'Occupancy agreements: a briefing paper'
TU (2011) 'Occupancy principles: a briefing paper'

2. Measures for more viable boarding houses

Boarding houses (in particular, 'unlicensed' boarding houses, as distinct from Licensed Residential Centres, which are discussed at Point 4) are a major provider of marginal rental accommodation. Boarding houses are important primarily because they provide accessible temporary accommodation, but for some marginal renters, boarding houses provide relatively affordable permanent accommodation.

Over a long period, the supply of boarding house accommodation in New South Wales has been in decline. Many traditional boarding house landlords have retired from the industry and boarding house properties have been converted to other uses, notably tourist accommodation and private residences.

Boarding houses can, however, operate as profitable businesses. According to modelling conducted by Hill PDA for its 2007 report, 'NSW DoH Boarding Accommodation Study' (the Hill PDA Report), this is particularly so where a boarding house is of sufficient scale and the operator takes advantage of a combination of the incentives available to existing and prospective investors in boarding houses. These incentives currently include:

Land tax exemption. Boarding houses are eligible for exemption from land tax if more than 80 per cent of the accommodation provided is for long-term residents and rents are below certain thresholds.
Boarding House Financial Assistance Program (BHFAP). This program, administered by Housing NSW, provides grants to boarding house landlords for fire safety work and, under an expansion of the program announced in November 2010, for the construction of new boarding houses or the addition of rooms to existing boarding houses.
Council rate concessions. Under the Local Government Act 1993, boarding houses may be rated as residential, rather than commercial premises, if their tariffs are less than certain prescribed amounts, and councils may provide for further reductions in rates.
Affordable Rental Housing State Environmental Planning Policy (ARHSEPP). This new SEPP was implemented in 2009 and provides, amongst other things, floor-space ratio bonuses for boarding house developments.

There appear, however, to be problems with the take-up of at least some of these incentives. Boarding house landlords surveyed in the Hill PDA report said the land tax exemption was the most important subsidy available to them but, strangely, only two-thirds said they claimed the exemption, complaining that the application process is difficult. Only 10 per cent of boarding house landlords in the Hill PDA report said they had used the BHFAP for fire safety upgrades – perhaps because of the narrow purpose of the program (that is, prior to its 2010 expansion) and the payment of grants as reimbursements in instalments over five years. In relation to council rate concessions, at present only Waverley Council further reduces rates for boarding houses.

Accordingly, the Hill PDA report recommends simplifying the land tax exemption; extending the BHFAP to include a suite of grants, loans and subsidies and reducing its administrative burdens; and providing more council rate rebates. It also recommends that the NSW State Government more pro-actively promote incentives to boarding house landlords, and to that end it recommends the establishment of a Register of boarding houses, and the appointment of a 'Boarding House Champion' to promote awareness of boarding house issues within government.

The TU generally supports these recommendations, and propose that they might be further developed and strengthened in the following ways.

As noted, the BHFAP has recently been expanded to allow grants for new rooms and buildings. We support this expansion, and propose that there should be a five-year, $15 million boost to the BHFAP to pilot further expansions to the program. Under the BHFAP Boost, grants might be made to boarding house operators and other organisations for the following purposes:

Grants to boarding house operators to help pay for upgrades that improve (non-fire) safety and accessibility; recurrent costs associated with fire and other safety upgrades, such as the cost of running checks on safety systems; and training courses for boarding house operators and employees, such as in first aid, mental health awareness and business management.
Grants to local councils to reimburse rate reductions afforded to boarding house operators as part of a strategy by the council to retain strategically significant boarding houses.
Grants to community housing organisations to purchase or headlease strategically significant boarding houses.
Grants to community organisations to provide capacity-building programs or resources to boarding house operators, employees and residents.

Each of the expanded purposes of the BHFAP Boost should be reviewed and considered for inclusion in the BHFAP on a permanent basis.

We also propose that a Boarding Houses Register should be established, and its chief officer ('the Boarding Houses Registrar') should also be responsible for 'championing' the boarding house sector. In this role the Registrar would liaise with stakeholders in the boarding house sector to better inform the State Government and local councils as to the present state of the sector, and allow them to better plan and more readily promote incentives, services and other opportunities directly to boarding house landlords.

We also propose that, over time, the registration process should be developed into an accreditation process that requires registered boarding house landlords to show that their practices are sound (for example, they provide written occupancy agreements, per Point 1) and that they are maintaining relevant professional skills and qualifications (for example, current first aid certificates). Accreditation would be a measure of consumer protection for boarding house residents and an aid to viability: for example, accreditation may help decrease the cost of insurance for boarding house landlords. Responsibility for monitoring compliance with health and safety standards for boarding houses might also be transferred from local councils to the Registrar.

We also submit that the NSW State Government may need to work with boarding house landlords to get them sufficiently organised to take advantage of these incentives. We propose that the NSW State Government should provide business mentoring to boarding house landlords through Industry and Investment NSW's business mentoring program.

Finally, recognising that from time to time boarding house operators will seek to exit the sector, the NSW State Government should plan to provide a co-ordinated response to pending boarding house closures. We propose that there should be an 'Assistance Protocol for Boarding House Closures', along the lines of Housing NSW's 'Assistance Protocol for Residential Parks Closures', to co-ordinate the provision of information and assistance to boarding house residents who must find alternative accommodation because of a pending closure. The Protocol should also direct relevant agencies to consider whether a boarding house that is proposed to be closed might be suitable for acquisition by a community housing organisation under the BHFAP Boost.

Recommendations

Expand the BHFAP with a five year, $15 million BHFAP Boost to make grants for additional purposes, including the recurrent costs of safety systems, reductions in rates by local councils for strategic significant boarding houses; and acquisitions of strategically significant boarding houses by community housing organisations.
Establish a Boarding Houses Register to better plan and actively promote incentives and services.
Develop the registration process into an accreditation process.
Provide business mentoring for boarding house landlords.
Establish an Assistance Protocol for Boarding House Closures, including a process for considering the possibility of acquisition under the BHFAP Boost.

Further information

Hill PDA (2007) 'NSW DoH boarding accommodation study'

3. Services to promote social inclusion in boarding houses

Many boarding house residents are socially isolated and excluded, because of unemployment, old age, lack of mobility, disability, mental illness, or institutionalisation. Many boarding house landlords, too, are at risk of isolation and exclusion: some are aged and need support themselves; some others have taken over the operation of a boarding house from an aged or deceased family member, have limited experience or knowledge of the sector and its clientele, and also need support.

There is currently no State-level program to promote social inclusion in 'unlicensed' boarding houses (as distinct from Licensed Residential Centres, as discussed at Point 4 of this paper). The Boarding House Outreach Program, which opened for tenders in November 2010, proposes to do this sort of work, but only in the City of Sydney, Canterbury, Leichhardt and Marrickville local government areas. Otherwise, when this work is done at all it is usually by community workers in local non-government organisations, such as community centres, in the course of their general operations or in an ad hoc way.

The benefits of providing services with a specific focus on boarding houses is demonstrated by Newtown Neighbourhood Centre's Boarding House Project. This project supports frail-aged and young persons with disability who live in unlicensed boarding houses in the Marrickville Local Government Area, connecting these persons with home care, health and other services. The project also provides opportunities for residents to participate in sport, music and art. An important factor in its success is the project's employment of dedicated boarding house workers and volunteers who know the local boarding houses and have come to be trusted by residents and landlords as a welcome source of support.

An important part of the Boarding House Project's work is convening the Boarding House Assistance Group (BHAG), an interagency group of local non-government social service providers. As well as helping to inform and co-ordinate members' delivery of services to boarding houses, BHAG organises regular forums for boarding house residents and landlords respectively.

BHAG's boarding house landlords' forums, in particular, are a real innovation, providing landlords with the opportunity to discuss ways to improve their own practices. The forums have also encouraged the establishment of helpful connections between landlords and local service providers.

At the State level, the NSW State Government should also conduct a review of programs for the provision of subsidies, rebates and other assistance to reduce the cost of living or hardship for eligible persons, and where possible ensure that boarding house residents are able to access assistance. For example, the Energy Accounts Payment Assistance (EAPA) scheme provides vouchers to persons in hardship to help pay energy bills – but they are not available to boarding house residents who pay their landlords for energy and do not have accounts with the energy suppliers in the scheme.

Recommendations

Establish a Boarding Houses Social Inclusion Program to fund, in several locations throughout the State, local community organisations to employ community workers for dedicated work in boarding houses.
Convene, as part of work under the program, local boarding house interagency groups, to facilitate communication and delivery of services.
Review, and where possible ensure that boarding house residents are included in, programs for subsidies, rebates and other assistance that reduce the cost of living or hardship.

Further information

Newtown Neighbourhood Centre (2003) 'Opening these doors: Boarders and lodgers project report'
Leigh Connell & Carolyn Frost (2009) 'BHAG of support', Parity, vol 22 no 5

4. Appropriate housing and support for people with disability

The boarding house sector includes a small subsector of licensed residential centres (LRCs, sometimes called 'licensed boarding houses') that specifically house people with disability. Licensed residential centres are privately owned and operated for profit, and are licensed by NSW Ageing, Disability and Home Care (ADHC) under the Youth and Community Services Act 1973.

The LRC subsector first grew in response to the early phases of deinstitutionalisation in the 1970s and 1980s, which saw people with disability relocated from accommodation in asylums and hospitals – and, in many cases, the staff of these institutions re-employed as owners and staff of LRCs. For some years now, the LRC subsector has been in decline. There are presently just 31 LRCs in operation, and in total they provide accommodation for just under 700 persons.

In addition to ADHC's licensing regime, LRCs are also the subject of ADHC's Boarding House Reform Program (BHRP), which since 1998 has attempted to divert and relocate persons with high support needs away from LRCs to residential disability and aged care facilities, and to connect LRC residents to the wider community through the activities of NGOs funded under the Active Linking Initiative.

Despite the licensing regime and the BHRP, longstanding concerns about the quality of services provided by LRCs remain. Disability advocates report that many LRC residents pay more than 80 per cent of their incomes in rent and other charges to their landlords, and some residents are left with just $5 per week as 'comfort' money. Many LRCs provide shared bedrooms only, and some residents share 4-6 persons to a bedroom. The BHRP has not relocated all high-needs residents away from LRCs, and assessment of current residents' needs has not been repeated (so some residents initially assessed as having low needs might now have high needs). In the last 10 years, the NSW Ombudsman has twice investigated ADHC's licensing and monitoring of LRCs and found them deficient in numerous respects.

The recent implementation of a new Youth and Community Services Regulation 2010 has improved the legal enforceability of licence conditions, but fundamental problems remain. The licence conditions still do not adequately ensure that LRC residents may access support and advocacy services without retribution, and People With Disability (PWD), which delivers the Boarding House Advocacy Program under the BHRP, reports that its advocates have been prevented by some LRC managers from associating with residents. There also remains a conflict of interest in the licensing regime, because ADHC is responsible both for prosecuting breaches and cancelling licences, and for the cost of providing accommodation and services to residents where such action results in the closure of an LRC.

The TU believes that boarding house accommodation should be available to people with disability, like any other citizens, should they want or need it. However, LRCs, particularly where they house large numbers of people with disability, may end up like other congregated residential institutions for people with disability – segregated, isolating, and all too often abusive and exploitative. We also believe that people with disability in need of support or care should receive it as a matter of right – and that this right is compromised where the support or care is paid for from the pensions of low-income people with disability and delivered by private, for-profit landlords operating on an institutional model.

For these reasons, we believe that private, for-profit LRCs should not have a long-term place in strategies for the provision of appropriate housing and support for people with disability. We propose that the BHRP should be amended with the express objective of closing private, for-profit LRCs by attrition, and providing accommodation and support for current LRC residents through funded, not-for-profit service providers.

While they continue to operate, LRCs should continue to be licensed and monitored for compliance, but under a reformed regime. As recommended by PWD in its 2010 report 'Rights Denied: towards a national policy agenda about abuse, neglect and exploitation of persons with cognitive impairment', an Independent Quality Assurance Agency for Disability Services should be established to develop quality assurance resources, monitor compliance, prosecute breaches and cancel licences. There should also be provision for LRC residents and other stakeholders to seek review of licensing decisions, including by application to the Administrative Decisions Tribunal. Access to advocates without retribution should be ensured. Occupancy agreements in LRCs should include prescribed standard terms (see point 1) that are consistent with this regime.

As LRCs close, high-needs residents should be accommodated in ADHC-funded group homes, and other LRC residents accommodated in social housing with funded support, as provided by the Housing and Accommodation Support Initiative (HASI) of Housing NSW, NSW Health and their NGO partners. In some cases – in particular, where the closing LRC is a small property that does not congregate a large number of people of disability – it may be appropriate for a community housing organisation to acquire the property under the Boarding House Financial Assistance Program Boost (proposed at point 2), and for the residents to remain in place, with support delivered by funded service providers.

Recommendations

Establish an Independent Quality Assurance Agency for Disability Services with responsibility for LRC licences.
Allow LRC residents and other stakeholders to seek review of licensing decisions.
Ensure LRC residents have access to advocates without retribution.
Prescribe standard terms for LRC occupancy agreements.
Plan for private, for-profit LRCs to close by attrition.
Accommodate and support LRC residents in ADHC-funded group homes, or in social housing with support delivered by funded service providers – including in appropriately small ex-LRC properties acquired by community housing organisations under the BHFAP Boost.

Further information

PWD (2010) 'Rights denied: Towards a national policy agenda about abuse, neglect and exploitation of persons with cognitive impairment'
NSW Ombudsman (2006) 'DADHC: Monitoring standards in boarding houses'
NSW Ombudsman (2004) 'DADHC: Investigation of the monitoring and enforcement of licensing conditions for residential centres for handicapped persons'
Allen Consulting Group (2003) 'Shared accommodation for people with a disability'

Four-point plan for reforming marginal renting: Summary of recommendations

1. Law reform to create 'occupancy agreements'

Enact legislation for occupancy agreements on the ACT model, incorporating the TU's proposed occupancy principles.

2. Measures for more viable boarding houses

Expand the BHFAP with a five year, $15 million BHFAP Boost to make grants for additional purposes, including the recurrent costs of safety systems, reductions in rates by local councils for strategic significant boarding houses; and acquisitions of strategically significant boarding houses by community housing organisations.
Establish a Boarding Houses Register to better plan and actively promote incentives and services.
Develop the registration process into an accreditation process.
Provide business mentoring for boarding house landlords.
Establish an Assistance Protocol for Boarding House Closures, including a process for considering the possibility of acquisition under the BHFAP Boost.

3. Services to promote social inclusion

Establish a Boarding Houses Social Inclusion Program to fund, in several locations throughout the State, local community organisations to employ community workers for dedicated work in boarding houses.
Convene, as part of work under the program, local boarding house interagency groups, to facilitate communication and delivery of services.
Review, and where possible ensure that boarding house residents are included in, programs for subsidies, rebates and other assistance that reduce the cost of living or hardship.

4. Appropriate housing and support for people with disability

Establish an Independent Quality Assurance Agency for Disability Services with responsibility for LRC licences.
Allow LRC residents and other stakeholders to seek review of licensing decisions.
Ensure LRC residents have access to advocates without retribution.
Prescribe standard terms for LRC occupancy agreements.
Plan for private, for-profit LRCs to close by attrition.
Accommodate and support LRC residents in ADHC-funded group homes, or in social housing with support delivered by funded service providers – including in appropriately small ex-LRC properties acquired by community housing organisations under the BHFAP Boost.