Similarly, under the emergency housing grant initiative, commercial suppliers are not required by MSD to ensure that their accommodation, or a proportion of their accommodation, is physically accessible to meet the needs of disabled people in the emergency housing system. There are no accreditation standards or equivalent accountability mechanisms to ensure that commercial accommodation suppliers receiving payment under the emergency housing grant initiative meet their human rights obligations. The significant inconsistency in funding models between emergency accommodation and transitional housing is also leading to poorer overall delivery on the government’s immediate human rights obligations. Transitional housing providers are almost always required to provide a higher level of service and support to their clients. Residents in emergency accommodation are significantly less likely to have access to the wraparound supports and other services available to transitional housing residents. In contrast, the accreditation requirements for transitional housing providers create a mechanism for assessing whether services meet human rights requirements. Alongside these accreditation standards, many transitional housing providers also operate according to frameworks informed by kaupapa Māori, traumainformed care models, Housing First, and/or other practices that are more likely to result in human rights compliance. This is effectively creating a two-tier system and is a significant equity issue. This has been acknowledged by Government: We are concerned that commercial accommodation suppliers receiving the emergency housing grant are often ill-equipped to meet the needs of people experiencing homelessness in a way that upholds mana, dignity, and human rights. This is particularly clear when we compare the accreditation process for transitional housing providers, and the wraparound services provided to people living in transitional housing. As with decency issues, these inadequacies would be less pressing (although still concerning) if emergency accommodation was always a temporary solution that provided housing for a week or less before people were moved into housing that better met their basic needs. However, it is clear this is not the case. Those living in emergency accommodation are not being moved into more suitable housing for some months, or in the worst cases years. Failure to fund [new supply of public and transitional housing places] will impact those in most housing need, leading to increased levels of homelessness [and] increased [emergency housing grants] at higher cost (and without supports to help people address long term or underlying issues).52 The weekly average cost of [an emergency housing grant] is $1,494 with no support services provided and results in worse outcomes in the short and longer term as underlying issues are not addressed. The weekly average accommodation and support cost for a COVID-19 or Transitional motel place is $1,400 per week.53 We do not find it acceptable that the weekly costs for transitional housing and emergency accommodation are roughly equivalent but provide drastically different services for residents in each initiative. We have heard that some transitional housing providers face funding constraints that make it difficult or impossible to deliver the services their clients need. Our observation is that Government has tried to 47