• Sufficient facilities for the number of people living in the house, and bedrooms adequately sized for the number of people sleeping in them • Approved forms of heating in living rooms. 61 Residential Tenancies Amendment Bill: Officials’ Report to the Social Services and Community Committee, at paragraph 517. 62 At paragraph 529. 63 Sam Olley, “Emergency housing: Government warned of human rights risks years ago, documents reveal”, rnz.co.nz, October 5, 2022. https://www.rnz.co.nz/news/political/476085/emergency-housing-government-warned-of-human-rights-risks-years-agodocuments-reveal. 64 Residential Tenancies Amendment Bill: Officials’ Report to the Social Services and Community Committee, at paragraphs 519 and 520. 65 At paragraph 522. 66 At paragraph 523. 67 As we have acknowledged, residents can complain to the Human Rights Commission if they consider they have experienced unlawful discrimination, including in housing. 68 The Code will be enforceable through being referenced or incorporated in a contractual agreement or through a court referring to it in a judicial review proceeding. However this enforcement will not apply until at least sometime in 2023 as it will need to be incorporated into new contractual agreements as they come up for renewal. 69 Operational Guidelines for Providers of Transitional Housing. 70 Operational Guidelines for Providers of Transitional Housing. 71 We note that in some cases, MSD have determined that particular moteliers will no longer qualify for emergency housing grant payments, but this is an exception rather than a standard accountability review. 72 Controller and Auditor-General, “Inquiry into the Ministry of Social Development’s funding of private rental properties for emergency housing”, oag.parliament.nz, December 2021. https://oag.parliament.nz/2021/inquiry-emergency-housing/docs/emergencyhousing.pdf. 73 RNZ Checkpoint, “No deadline for phasing out motel emergency accommodation”. In that interview, the Minister was asked whether the Ministry was ensuring it ‘contracts’ safe accommodation services, but we note that MSD does not contract accommodation through the housing grant. 74 Report: Emergency and Transitional Housing, at page 1. 75 At paragraph 6a. 76 At paragraph 6c and d. 77 At paragraphs 5 and 6. 78 At paragraph 32. 79 At paragraph 5. 80 These include but are not limited to: • The design of government service delivery. Some standard service design and ways of working in government services, such as contact only by phone and the expectation that clients will be able to always answer calls from case managers, are not appropriate for the needs of those they are intended to serve. • The importance of connections between agencies and the possibility for a ‘one door’ approach with clear responsibility. Gaps in both information and responsibilities are causing problems for those navigating the emergency housing system. These problems include a lack of coordination between MSD case managers, housing providers, KO, and other agencies involved, and difficulty understanding who the ‘key person’ should be in terms of directing a person through the system and ensuring they receive correct support and entitlements. • The operation of the emergency housing grant in relation to its approval and renewal timeframes. • The operation and processes related to the housing register. These include the way that needs assessments are carried out (both the amount of sensitive information being asked for and how this can be collected more appropriately), a review of the way priority ratings are determined, and more transparency about movement in ratings. 70 81 Report: Emergency and Transitional Housing, at paragraph 30. 82 Supporting the reset and redesign of the emergency housing system, at page 5. 83 RNZ Checkpoint, “No deadline for phasing out motel emergency accommodation”. 84 Strengthening Accountability and Participation in the Housing System, at page 17. 85 Report: Emergency and Transitional Housing, at paragraph 30: “Demand drives funding: EH SNG [housing grant] is a NonDepartmental Benefit or Related Expense (BORE), with funding allocated annually based on estimates, and adjusted every six months in response to how many grants are made. This means [the housing grant] is not set up or managed like a programme.” 86 Kelly Makiha, “Homelessness won’t go away if contracted motel consent bids fail, ministry says”, nzherald.co.nz, October 19, 2022. https://www.nzherald.co.nz/rotorua-daily-post/news/homelessness-wont-go-away-if-contracted-motel-consent-bids-fail-ministrysays/6YEDICUP3TIXR54HFWPSWZSK5I/. Human Rights Commission