The Independent Chief Inspector of Borders and Immigration has published a report on “An inspection of contingency asylum accommodation November 2023 – June 2024” highlighting the usual problems around lack of stakeholder engagement and data as well as concerns about the lack of Home Office checks on accommodation providers.

The report looked at the Home Office strategy for dealing with an increased need for contingency accommodation while reducing costs, as well as processes for monitoring performance of the accommodation service providers and the experiences of those in the accommodation. It is 115 pages and covers the use of accommodation including hotels, Wethersfield, the Bibby Stockholm and Napier barracks. I have pulled out some of the main points from the “Key findings” section below.

Costs of ‘large sites’ versus hotels

On whether the larger sites provided value for money compared to the use of hotels, the findings of the inspectorate echoed that of the National Audit Office, namely that the large scale sites (Wethersfield and Bibby Stockholm) were more expensive than using hotels [at 2.2].

Stakeholder engagement

This is such an important point that in addition to its inclusion in the report, the chief inspector highlighted it in the accompanying news story, saying:

I would like to draw particular attention to one long-standing, systemic issue that this inspection has again exposed.

Lack of meaningful engagement with stakeholders and poor communication (“one-way”, telling rather than listening) from the Home Office about policies, practices and plans has been a recurring theme of inspections over many years. It is clear that the Home Office still has a long way to go to build trust and confidence in its willingness to be open and honest about its intentions and performance and any reluctance to share information, whether real or perceived, will be seen as evidence that it is not. Timing is all-important, and while there are risks in engaging early, it must avoid any hint of “too little, too late”.

The attitude of the previous government towards stakeholders can no longer excuse a lack of engagement, so we will see whether the Home Office is actually capable of change on this, which has been a significant problem for far too long.

Organisational learning

The report says that the Home Office “appeared slow to draw on the lessons from the setting-up and operation of” the sites at Napier and Penally barracks “or from the failed plan in 2022 to convert the disused RAF station at Linton-on-Ouse” [at 2.11].

Assurance processes

Asylum accommodation providers are required to report to the Home Office monthly on their performance against a series of key performance indicators. This method of providers self-reporting their performance is obviously not robust and in November 2023 the Home Office’s risk register noted that a provider’s self-reports had failed to include areas of underperformance including “extensive overcrowding, non-compliance with licensing requirement and sharing rules, and questionable maintenance” [at 2.23].

Following the inspectorate’s 2021 report on contingency asylum accommodation, a recommendation was made and accepted by the Home Office for there to be quarterly intelligence-led inspections. This inspection found that “the Home Office’s capacity to carry out assurance activity at hotels was severely limited” and where such visits had taken place, “very few potential non-compliance issues had been followed up”.

Particularly concerning is the fact that the assurance team’s remit did not include Napier, Wethersfield or the Bibby Stockholm and there was no evidence of assurance checks carried out by the Home Office at these sites [at 2.22].

Management information and record keeping

The Home Office’s record keeping on service provision and those people in the accommodation was described as “problematic”. Inspectors were unable to get a figure for capacity (as opposed to occupancy) for the 415 sites [at 2.27]. It was noted that although the accommodation providers are required to keep up to date records of safeguarding concerns “it was unclear how the Home Office was ensuring that any individual vulnerabilities were being identified and actioned appropriately, or how it would know if there were issues for particular cohorts at a given site” [at 2.28].

Allocation of asylum seekers to accommodation

There is a formal allocation of accommodation policy for the Home Office to send people to the sites such as Napier, but there is no formal guidance for accommodation providers on how they should allocate people. Inspectors did not find “evidence of any specific training, policies, procedures, and processes for service provider or subcontractor staff to follow that would enable routing decisions to be robust and assured” [at 2.30].

In relation to the Home Office’s policy, stakeholders raised concerns during the inspection about the use of the policy and its effectiveness in actually identifying and raising any vulnerabilities. As of 8 February 2024 a total of 217 people had been removed from Wethersfield for suitability reasons since its opening in July 2023. 12 people had been removed from Bibby Stockholm since that opened on 8 August 2023 and 50 people had been removed from Napier in the second half of 2023.

That is a strong indicator of a process that is not working and the numbers make more sense in the context of an apparent total lack of interest on the part of the Home Office as to why it was having to remove so many people from these sites. The report notes at 2.32 that:

The Home Office had not attempted to record and analyse the reasons why individuals were being reassessed as ‘unsuitable’ after moving them to one of these sites (or why some people were assessed as unsuitable and not moved there in the first place), so there was no process of learning and feedback to those responsible for making such decisions.

Service user experience

The quality of the accommodation “varied significantly” between sites, with some people living in “spacious rooms with en suite facilities, while others were in dormitory rooms which accommodated a dozen people, with limited storage space and shared showering and toilet facilities” [at 2.35]. The most common complaint was about the quality and variety of the food and inspectors noted that at most sites there were no facilities for people to cook their own meals [at 2.36].

Unsurprisingly, given these were concerns raised by those working with people in the asylum system even before the sites were opened, people at Wethersfield and the Bibby Stockholm barge told inspectors about the detrimental impact the isolation of these sites had on their mental health [at 2.37].

One of the most striking elements of this report is the difference in the mood of people at Wethersfield as opposed to Napier. When people are moved to Napier they are told that they will be moved to dispersal accommodation within 60 to 90 days (introduced, in my view, as a way to manipulate people into staying there without complaint).

Having a set timescale gives people much greater peace of mind, whereas at Wethersfield and the Bibby Stockholm stress and anxiety was heightened as people did not know how long they would have to tolerate those conditions [at 2.41]. One person at Wethersfield told inspectors: “I have done nothing. I cannot learn, develop, or communicate. It is a waste of a life” [at 5.54].

Again, not news to anyone working in the area and the same concept applies to immigration detention which is why implementing a time limit would be both an incredibly basic and humane change that the government should prioritise.  

Safety and security

In 2023 an internal audit identified record keeping relating to health and safety incidents as an area needing improvement. Inspectors found that this was still the case a year on from that audit and that in addition to health and safety records, improvements were also needed with records of safety checks, security incidents and the monitoring of residents’ whereabouts.

The chief inspector points out that “without better records, it is hard to see how the Home Office can identify trends or issues that require attention, and how it can show that it is meeting its responsibilities for the safety and welfare of contingency asylum accommodation service users” [at 2.47].

Recommendations and the Home Office response

Nine detailed recommendations were made, which were in summary:

• the ten year strategy and annual delivery plans should be informed by clearly stated milestones for the expected benefits, and a standardised methodology
• improve stakeholder engagement
• strengthen governance arrangements for the management of asylum accommodation
• overhaul contract compliance and assurance checks, including revisiting the previous reports’ recommendations in this area
• improve record keeping and data quality by agreeing requirements and minimum standards for information and data recorded by both the Home Office and the accommodation providers
• define roles and responsibilities for providing purposeful activities to people in contingency asylum accommodation
• improve the safeguarding of vulnerable people, including by seeking external input and clarifying processes with accommodation providers
• strengthen organisational learning
• improve communication with people in the asylum system. For now, this means providing people in contingency asylum accommodation the likely length of their stay, what to expect next, and giving them at least 48 hours notice when they are being moved along with an explanation of why this is happening. As soon as is practicable, the Home Office should establish means for informing people of the progress of their claim through updates such as “current average waiting times” on GOV.UK, text messages, letters or on request for example via a ‘hotline’.

The Home Office has also published their response and accepted most recommendations in full and the rest were partially accepted. From my own experience, I think it is worth highlighting this part of the Home Office’s response to the final recommendation:

Section 4.2.2 of the AASC Schedule 2 of the Statement of Requirement (SoR) sets out the contractual obligation of Home Office service providers to apprise service users of any moves, which is underpinned by a service level agreement (SLA) of at least five days.

This minimum notice period of five days prior to a move is regularly not complied with by accommodation providers, and so where less notice than this is given people should complain to Migrant Help with reference to this contractual obligation.

Conclusion

Also on asylum accommodation, the Institute for Public Policy Research (IPPR) published a report last week on “Transforming asylum accommodation”. The think tank details the increasing costs and substandard living conditions. They recommend:

• Decentralising asylum accommodation and support services to regional bodies who are better placed to find more affordable dispersal housing
• Immediately closing any remaining failing large sites and strengthening accountability and oversight of private companies to improve standards in the short term – this should include significant penalties for non-compliance
• Providing integration from day one, including services like English lessons, skills training, and community engagement

The institute also recommends that urgent steps are taken so that the contracts with existing providers can be terminated in 2026, using the available break clause. Those at the Home Office should give this report proper consideration and start demonstrating that they are prepared to listen to outside suggestions.

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