By Emily- Rae Foreman

As an American now working in the United Kingdom, I have been struck by something rarely discussed in the homelessness sector: despite serious and ongoing challenges, the UK is doing relatively well. While optimism must not obscure real gaps in services, optimism itself is not frivolous — it is a critical tool in this field that can drive progress. 

Optimism in social care serves as an active shield against burnout, which plagues this field more than many others. In Greek mythology, Sysiphus was condemned to push a boulder up a hill every day, only to watch it roll back down each night. The apparent lack of progress in homelessness reduction can feel like a Sisyphean task: frustrating and disheartening. A sense of futility can be dangerous for both workers and ultimately for those most in need of support. By recognising victories, even partial ones, we can build momentum for the reforms that are still needed. 

The UK’s statutory homelessness safety net: A comparatively progressive approach

Across the UK, the safety net for people facing homelessness stands out internationally for its comparatively progressive approach. With exceptions based on immigration status, all households are entitled to receive advice and support aimed at preventing or resolving housing loss. 

Under England’s current framework, when an individual or household approaches their local authority as experiencing homelessness or at risk of homelessness, this first triggers the Prevention Duty, requiring councils to work actively to help the household avoid homelessness. If prevention fails, the household moves into the Relief Duty stage, where the council must assist in securing accommodation. If homelessness persists after this period and the person meets certain criteria—including being assessed as having a "priority need"—they may qualify for the Main Housing Duty, entitling them to longer-term settled accommodation. The Homelessness Reduction Act 2017, which came into force in 2018, extended prevention duties from 28 to 56 days and introduced new cooperation requirements mandating that certain public bodies, such as prisons and job centres, refer individuals they identify as at risk of homelessness to the relevant housing authority.

The most significant barrier within this structure remains the requirement to demonstrate "priority need" to access the Main Housing Duty. Categories such as households with dependent children, pregnant individuals, and those deemed vulnerable due to disability, age, or other special circumstances are prioritised. However, single adults without specific vulnerabilities often fall through the cracks. However,  Scotland formally abolished the priority need test for homelessness applications in 2012 and as a result, any person in Scotland who is unintentionally homeless—regardless of vulnerability—is entitled to settled accommodation. This bold policy shift demonstrates that removing the priority need barrier is both possible and practical, potentially paving the way for similar reforms throughout the UK. That said, progress comes with its own challenges: Scotland now has higher numbers of people living in Temporary Accommodation per capita than many parts of England, highlighting the need to think carefully about how expanded rights are supported in practice.

By comparison, the legal landscape around homelessness In the United States is far less cohesive. Although federal legislation—most notably the McKinney-Vento Homeless Assistance Act—provides the opportunity for some funding for homelessness prevention and support services including housing vouchers, it does not create an enforceable right to housing assistance. Instead, local and state-level policies vary dramatically. A handful of cities, such as New York City, have established a legally enforceable "right to shelter," requiring that individuals who seek emergency accommodation must be provided with it. However, the majority of US cities lack such guarantees and, instead, often rely on punitive measures: it remains common for municipalities to criminalise activities associated with homelessness, such as sleeping or camping in public spaces. In my own experience living and working across Denver, Boston, and Washington DC, I have seen first-hand how this fragmented system leaves many without meaningful legal protections, even as service networks try to fill the gaps. By comparison, the UK's national legal obligations and particularly the duty-based approach —stand out for offering a far more consistent and preventive framework, even if significant challenges remain.

Evidence of success: Comparative examples

Rough sleeping statistics

The comparative success is clear in rough sleeping figures. In the 2023 New York City rough sleeping snapshot, approximately 50 per 100,000 people (roughly 4,140 individuals) were recorded as experiencing rough sleeping. In London, the comparable figure was approximately 15 per 100,000 people (1,318 individuals). Similarly, statistics from 2021 reveal that while in Berlin there were approximately 55 people per 100,000 sleeping out and in Paris there were approximately 128 people per 100,000 experiencing rough sleeping, in the same year in London there were approximately 13 people per 100,000 experiencing rough sleeping. 

These figures showcase real-world results of policy choices. The UK's prevention-focused approach and legally-mandated council responsibilities create tangible differences in people's lives. While economic and cultural factors certainly play roles, the strength of the UK's legislative safety net has been crucial in achieving these comparatively lower rough sleeping rates.

Temporary Accommodation: Dignity vs. warehousing

Temporary accommodation (TA) is another critical area where stark differences emerge between the US and UK approaches. Coming from the US, I was initially surprised to discover that many people in UK temporary accommodation are provided with private rooms and the default expectation is that individuals will not be required to share a room. While room-sharing does exist, especially for single individuals, there are no "warehouse" style shelters of the type that have proliferated across the US. In some American cities, shelters operate in literal warehouses — cavernous, chaotic spaces that unhoused people may avoid, preferring the dangers of sleeping rough over the dangers inside.

In contrast, in England, families with children must be offered private rooms. Additionally, the Homelessness (Suitability of Accommodation) (England) Order 2003 mandates that Bed and Breakfasts (B&Bs) are unsuitable for families with children or pregnant individuals for periods longer than six weeks. The UK focus on the suitability of accommodation — not just the provision of a bed — represents a significant policy difference. In my professional and personal experiences coming from a US context, the concept that temporary accommodation quality would be a legal standard was almost unthinkable. In my own experience in the US, access to any shelter space is often considered a win for policy makers, regardless of conditions. The UK's approach, codified in law, foregrounds human dignity and safety, not mere survival.

From comparison to action: Using optimism to break inertia

Identifying where systems perform better is essential for resisting the inertia that so often can paralyse frontline work. Social policy work involves bearing witness to deep injustices and human suffering daily. Without hope that improvement is possible—evidence that things are already better in some places—the emotional weight can become unsustainable. While there is still a long way to go in the UK (rough sleeping persists; families still face inadequate accommodation; austerity measures have left local authorities struggling) optimism rooted in evidence—optimism tempered with realism—pushes us to demand more rather than settle for less.

Burnout is a real and dangerous threat in this sector. In a 2022 study, 58% of UK frontline workers reported their job negatively impacting their wellbeing. Workers who lose faith in the possibility of change may leave the field altogether. Worse still, they may disengage emotionally, viewing clients as problems rather than people. Comparative optimism can act as a necessary counterbalance: proof that better is possible, that systems can change, and that collective effort can yield real results. Burnout in this field is not inevitable—it's a response to perceiving the work as futile. When practitioners can see evidence that their efforts contribute to systems that genuinely reduce suffering, they find renewed purpose. Returning to Sisyphus and his boulder, this means more dedicated helpers who believe in the possibility of change and fewer who have abandoned the push, convinced the boulder will always roll back down. Comparative optimism reveals that in some places, on some hills, the boulder moves further up and stays there. Sometimes, with the right policies and sufficient will, we manage to create ledges where progress can rest and be maintained. This knowledge is vital not just for morale but as a necessary mechanism to unlock further advancement.