Analysis | A Fundamental Review of Allocations or Gatekeeping Finite Resources? Interim points and 'no detriment' | PPR

A Fundamental Review of Allocations or Gatekeeping Finite Resources? Interim points and 'no detriment'

Planned changes for homeless applicants include removing recognition of the impact of extended exposure in 'temporary' accommodation will do nothing to reduce the level of housing need. Paige Jennings  |  Mon Dec 01 2025
Throughout its 20+ years, the Housing Selection Scheme has been implemented with an unwritten ‘no detriment’ practice for FDA homeless households.

The impact of housing stress and homelessness is cumulative. In the words of some participants in PPR housing clinics:

“we have been homeless for nearly 10 years. As a mother, I feel such shame and embarrassment that I have no place that my children can call their home. We are crammed into one single room like sardines … My family and I are at breaking point. We do not know what more we must do.” (complaint letter, July 2025)

“this has now been ongoing for a prolonged period of time, I am not sure how much longer I am able to cope with this situation, I am becoming increasingly worried, and my health is deteriorating.” (complaint letter, Sep 2025)

Throughout its 20+ years, the Housing Selection Scheme has been implemented with an unwritten ‘no detriment’ practice for FDA homeless households. While others on the waiting list could have points added or taken away during a reassessment, homeless people’s points would either stay the same or increase. According to the DFC’s 2017 consultation,

“the rationale for this was to recognise the applicant’s housing/homelessness journey, and to assist in discharging the statutory duty in a reasonable period of time.” (p. 63)

PPR’s objections… that tinkering with people’s points diverted attention away from building social homes and allocating them in line with objective need -- were not taken on board

The DFC recommended stopping this practice and making the points of every applicant on the waiting list – including long term homeless households –reflect only their current circumstances. The claim was that this was ‘fairer’.

PPR’s objections – not least, that tinkering with people’s points diverted attention away from building social homes and allocating them in line with objective need (para. 5) -- were not taken on board. The DFC’s 2020 EQIA finding that some applicants would be adversely affected by this change, and that that they were more likely than other waiting list applicants to be young, non-white and families, was not reflected in the 2020 consultation outcomes report, which seemed more concerned with the administrative workload around the change rather than the impact of withdrawing recognition of homelessness’s cumulative impact on affected people:

“this change represents a significant body of work given the major reassessment exercise that will be required and the significant system and IT changes” (p. 51).

‘No detriment’ will reportedly begin to be withheld from newly recognised FDA households by autumn 2026. According to the information received, those already holding FDA status would retain their current points, at least until they refuse a ‘reasonable offer’, at which time their points would be reassessed.

Similarly the DFC is planning to remove the mechanism for awarding 20 ‘interim accommodation points’ to people placed in temporary accommodation by the Housing Executive for six months or longer. The points had been in recognition of the harm caused by long periods in temporary housing (DFC’s 2017 consultation p. 66). The 2011 Housing Selection Scheme Preliminary Consultation Paper (obtained by Freedom of Information) looked at – and got “overwhelming support” for, according to its August 2011 report of responses (p. 7) -- expanding the points provided after further periods of time in temporary accommodation and amongst a wider group.

PPR’s response to the DFC’s 2017 consultation recommendation to remove this was:

“the proposal to remove interim accommodation points from the selection scheme merely reduces the appearance of housing need and contravenes state commitments to significantly increase the social housing stock and prioritise meeting housing need. Proposal 9 does not actually alleviate the root of NI’s housing crisis which is the shortage of decent accommodation needed to support Northern Ireland’s growing population.” (para. 12)

In November 2020 the sitting Communities Minister (Carál Ní Chuilín (SF)), speaking to the NI Assembly, expressed support for a return to the 2011 ‘expansionist’ approach to interim accommodation points:

“I believe that people who find themselves in any form of temporary accommodation should be awarded points to recognise the additional stress associated with being insecurely housed in whatever form that takes, whether in hostel accommodation or sofa surfing with friends or family. That would involve extending interim points to a wider range of people who are homeless.”

The 2020 Outcomes Report accordingly envisaged “an alternative proposal … whereby points may be awarded to those applicants who find themselves in any form of temporary accommodation” (p. 55).

Under Communities Minister Lyons (DUP) however, the DFC has reversed its position and reportedly forged ahead with plans to remove access to interim accommodation points from newly-qualified applicants by autumn 2026.

As with ‘no detriment’, removing the mechanisms that used to recognise the impact of long-term homelessness and temporary accommodation won’t take those impacts away. Nor will they fundamentally change the waiting list. In the absence of the Independent Scrutiny Panel recommended in the initial 2013 academic research underpinning the Fundamental Review – which the DFC failed to progress – it is unclear what recourse people who feel harmed by the change will have.

That said, the DFC may surprise us all and produce a system for ‘banding’ the waiting list (soon-to-be-implemented FRA proposal 10) that incorporates particular weighting in recognition of the harm caused by being homeless and in temporary accommodation. Given the prevailing FRA emphasis on making the system easier to administer regardless of impact, this may be more hope than expectation.

PPR’s full analysis of the impact of the DFC’s Fundamental Review of Allocations to date is here.