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Housing Benefit and Health Impact Assessments

July 6, 2011

The review of the Governments approach to Health Impact Assessments carried out by the Centre for Health Impact Assessment (which is part of the Institute for Occupational Medicine) supports my superficial investigation into health impact assessments that I described in my earlier blog.

Their review “Putting Health into the Policy Picture” looked at over 300 government impact assessments – all of which had been commissioned as part of the process of developing policy or piece of legislation.

The study discovers significant variation in quality; a small number of impact assessments do have a good health focus but a lot show little evidence of systematic consideration of health impact positive or negative.

The report also expresses concern about the capability that exists within government to ensure that high quality health impact assessments are consistently carried out.

I do think that one area that the review does not address properly is the relationship between the impact assessment and those outside of government. There seems to be an assumption that impact assessments are primarily an internal process – through which technically astute, professionally trained ‘experts’ can bring their technology to bear to stress test policy change.

We need to challenge this assumption.

Territory to fight over

Impact Assessments should provide an important place for stakeholders outside government – local authorities, the voluntary sector etc to challenge and debate with government – this is territory to fight over. I do not get any impression that Government – in particular the Department of Health – pro-actively encourages key stakeholders to use the material in impact assessments to have a public debate about policy impact. Similarly I am not aware of  public lobbying using impact assessments as a mechanism to challenge and influence policy makers.

I think that this is because Impact Assessments and Health Impact Assessments in particular remain obscure and rather technical documents – rather than a key lever to improve policy through widening and strengthening democratic engagement.

What can be done.

While it would be great if Government were to improve the way it does impact assessments – we can’t wait – action needs to be taken outside government – national voluntary organisations, local government and academia all need to become more proactive in challenging impact assessments that relate to their areas of special interest.

Engagement must not just be through formal government channels – but publicly through the media. That way we will have better informed debate and will empower those civil servants within government who want to deliver better policy that improves wellbeing.

Housing Benefit cap

Is this such all such a big deal? Well – the government is pursuing an aggressive set of policies which have the potential to hit the poorest hardest. The proposals in the Welfare Reform Bill to cap Housing Benefit – which could lead to a large number of people having to leave their homes has hit the press recently. If you look at the relevant Impact Statement linked to the cap on Housing Benefit – it says that there are NO impacts on Health and Wellbeing.

As we now know on the 2nd of July the Observer published a leaked letter by Nico Heslop  (private secretary to Eric Pickles Secretary of State for Communities and Local Government) where he writes to the Prime Minister and says

“……our modelling indicates that we could see an additional 20,000 homelessness acceptances as a result of the total benefit cap. This on top of the of the 20,000 additional acceptances already anticipated as a result of other changes to Housing Benefit. We are already seeing increased pressures on homelessness services. I understand that there may be a suggestion around requiring families to divert a percentage of their non-housing (benefit) income to cover housing costs. It is important not to underestimate the level of controversy that this would generate (likely to dwarf anything already seen on the HB only caps) and the difficulty of justifying this in policy terms as well as implementation.”

No impact on health and wellbeing? You’re having a laugh!

4 Comments leave one →
  1. Chimeme egbutah permalink
    July 8, 2011 17:13

    Mark, I couldn’t agree more! I’m always curious as to why locally there is such a myth amongst policy writers that “HIA Practioners” (which I consider myself – never an expert as there doesn’t seem to be any framework to prove such a claim) come along with a magic bullet and yet there seems very little policy influence around tackling health inequalities.

    Within the local authority I work in, we have worked hard (over 7 years of slow but consistent chipping) we have managed to combine the equalities, environmental and health impact paradigms finally to come up with something that may work – with the focus on reducing the inequalities gap based on financial changes within the Council. It’s yet to be tested and as the process for HIA has been to parachute an HIA ‘expert’ to undertake the assessment. I’m looking forward to seeing the differences it will make in policy decisions – particuarly with elected members and thier local communities.

    I feel I need Government to make it explicit and express this to those of us working at the sharper end.

    • July 10, 2011 08:36

      Hmm – I had a look at the work you are doing in Luton – great case study on the LGID web site by the way. I agree with your point about ‘consistent chipping’ I think we are talking about cultural change in organisations. 10 years ago most local authority councillors would not have been able to describe the gap in life expectancy between the worst off and best off areas in an area – now most can – I am sure this is the case in Luton. I think Impact Assessments are part of the portfolio of tools that help us strengthen the capability of systems and individuals to take action to address health inequality. The bit I am not so sure about is what the role of government should be. I certainly think that it needs to get its act together and use HIA more consistently and better. I also think that it should ensure that funding is available to sector owned improvers such as LGID to support good practice – and that similar funding should be available to the voluntary sector. I am not sure whether more prescription would be appropriate – i.e. consistent with the spirit of localism.

      Interesting that you say the council has involved an outside expert.

  2. Debbie Fox permalink
    July 11, 2011 11:40

    Hi Mark and Chimeme

    I agree with your comments. Ive been involved in HIA since 2000 and have become increasingly frustrated with the increase in technobureacratic approaches, and a litle dissilussioned about the abilty of HIA to affect change. Im not saying technical approaches dont have a place but if the purpose of IA is to learn something and transform actions to promote social (SJ) and environmental justice (EJ) (which I think it is) – then public spaces for dialogue are essential. These, I think seem to have a tendency to be limited and/or controled tightly.

    Like EIA, HIA has its roots in social movements in response to injustices – local and global. HIA makes explicit its aspiration for SJ – less so EJ but is increasingly being used, particularly in the US, as a means to address environmental distribution of benefits and burdens experienced by marginalised peoples.

    Im currently writing up my phd which is evaluating the role of impact assessment in promoting social and environmental justice by piloting a framework on 3 HIAs – a community strategy, a neighbourhood managment Initiative and a housing market renewal stratgey. all 3 invovled outside expertise but in different ways.

    In the first instance the expert facilitated an LSP cross-sector workshop and took an ‘action learning’ approach, people volunteerd to follow through actions then reported back on changes and oucomes; the second parachuted experts in, included interviews then nothing else happend until a one day conference about the findings and what could be done about them took place almost a year later. This is what made the difference in terms of actions but also generated local conflict as the health stats were grim, and the language used to describe ‘locals’ seen as stigmatising. The third HIa was done as part of an ALS but also commissioned experts to do the bulk of the HIA . again in a participatory way – local public discussions have not yet happened as far as I know but there were intentions to do this. However restructuring of LA (staff cuts) and changes in funding have had considerable impact on the direction of change and use of the HIA findings and recommendations in the latter 2 cases. Im still working on these stories so will report on them at a later date. Certanly the second HIA provided a territory to fight over.

    Re ‘Territories to fight over’ – My learning (and experience) is that IA is a higly politicised process that can be used as a way of mediating /avoiding conflict / used to attract resources – moslty funding but also partnership working. I agree the content of HIA as ‘Territory to fight over’ is important. Creating arenas for reflection,action and change should be part and parcel of IA. My personal experience has taught me that sometimes conflict is a good thing as it makes people think through the moral/ethical dimensions of their actions – something missing in IA literature on the whole. It can also bring in to sharp focus the subservience of social values to economic values – again something missing across IA generally.

    Re in the ‘spirit of localism’ – In Liverpool some years (2003) ago we pioneered a ‘learning by doing’ appoach to HIA, then following the canadians CHIA approach, piloted a community led approach in partnership with Croxteth Community University in 2005/6 – but the money dryed up and subsequent bids to role out this approach have been unsuccessful. It is time to rethink the role and purpose of HIA technology in a more radical way ie assessing their own health and environment by devloping thier own tools with the experts on tap rather than on top (apologies for that oldie but still appropraite phrase). Once the phd finished this is something I will be pursuing.

    Re governments role – Youre right to be cautious of governments role in IA – see the paper by Kat Smith and colleagues on the role of BAT on EU IA content and form – I note there is a new publication on a proposed social impact framework using a ‘capitals’ model.

    Theres lot of issues including the ‘uniqueness of place’ in the formulation, interpretation and modification of HIA technologies; the issue of futurity; and the danger of IA (and I include HIa in this) becoming complicit rather than critical, and subsequently perpetuating power inqualities through compromise and deals; whether the HIA practitioner should work from a critical distance or from within is one of personal values –

    What I would add, is that all the HIa people I know and have met – demonstrate an ethic of care- they care about challenging injustices and at conferences, we challenge each others assumptions and methods. Unsurprisingly we dont all agree! Not sure how much challenging goes on with HIA commissioners…?

    Apologies for such a long response (rant) but I was inspired by your blog. and apologies if you dont hear from me again until end of september when my thesis is submitted.

    • July 11, 2011 15:06


      Really helpful comments – not a rant at all! I do think that at their heart HIA are about the setting out the space – territory – where we can have a more equal dialogue – because we have some clarity about terms, information etc and have invested to ensure that all of those engaged in the dialogue have the capability to engage – I do think your community examples are really interesting. As I move forward on the wider Equity Action work I think these comments are really helpful – in trying to ensure that practice stays grounded in ensuring community engagement – so keep in touch!


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