Regulatory Judgements 18th January 2021

The Regulator of Social Housing (RSH) has published 25 Regulatory Judgements (RJs), all of which confirmed existing grades. Although less than in December, the number of RJs published again reflect that this is annual stability check season for the RSH, with all of this week’s RJs resulting from stability checks.

22 of the registered providers (RPs) received the highest G1 grade for Governance with three – The Abbeyfield Society, Southern Housing Group and Wandle Housing Association – being graded at G2, meaning that whilst they are compliant with the RSH’s expectations on Governance, they need to make some improvements to maintain compliance.

18 of the RPs received V1 grades for Viability with 15 (including The Abbeyfield Society, Southern Housing Group and Wandle Housing Association) being graded at V2, meaning that whilst they are compliant with the RSH’s expectations on Viability, they need to manage material risks to maintain compliance.

The full list of 25 RJs is set out below.

Registered provider Governance Viability
Abbeyfield Society (The) G2 V2
Advance Housing and Support Limited G1 V1
Anchor Hanover Group G1 V1
Broadacres Housing Association Limited G1 V1
Broadland Housing Association Limited G1 V2
Castles & Coasts Housing Association Limited G1 V1
English Rural Housing Association Limited G1 V1
Gloucester City Homes Limited G1 V2
LiveWest Homes Limited G1 V1
Longhurst Group Limited G1 V1
Magna Housing Limited G1 V1
NSAH (Alliance Homes) Limited G1 V1
Origin Housing Limited G1 V2
Plymouth Community Homes Limited G1 V1
Poplar Housing and Regeneration Community Association Limited G1 V2
Silva Homes Limited G1 V1
South Lakes Housing G1 V1
South Liverpool Homes Limited G1 V1
Southern Housing Group Limited G2 V2
Sovereign Housing Association Limited G1 V1
Unity Housing Association Limited G1 V1
Vivid Housing Limited G1 V1
Wandle Housing Association Limited G2 V2
West Kent Housing Association Limited G1 V1
Westward Housing Group Limited G1 V1

 

Sector Risk Profile

Introduction

The Regulator of Social Housing (RSH) has published its Sector Risk Profile (SRP) 2020 which encompasses strategic risks, operational risks in relation to service delivery, existing stock and development, and finance and treasury management risks.  The RSH recognises the focus which providers have quite rightly placed on dealing with the coronavirus pandemic in recent months, but stresses the importance of remaining vigilant on other areas of risk.  The RSH notes the changing nature of the operating environment, referencing the Social Housing White Paper, the Planning White Paper, the Building Safety Bill, a new shared ownership model and the launch of the latest Affordable Homes Programme, as well as the ongoing uncertainty arising from the pandemic and Brexit.  The RSH also notes the competing demands which RPs face in agreeing purpose and strategic direction (for example balancing meeting the needs of existing tenants with the delivery of new homes, and meeting the evolving expectations of a wide range of stakeholders), and that effective decision making requires robust data and advice, and skilled Boards able to understand and challenge the information that is presented to them.

In the SRP the RSH confirms that it remains committed to co-regulation.  That commitment chimes with the Social Housing White Paper which proposes retaining the co-regulatory approach, putting the onus on the boards of providers (and councillors in the case of local authorities) to comply with Regulatory Standards.  The White Paper proposes significant changes to regulation of the Consumer Standards including removing the serious detriment test, a review of the Standards themselves and introducing a pro-active approach to regulating against the Standards including regular investigations of compliance by the RSH on providers with 1,000 or more homes.

 

Strategic risks

The RSH identifies four key strategic risks:

  • Reputational risk – in making strategic choices, providers should consider the impact on the range of their stakeholders, failure to do so can cause reputational damage. Relevant areas in recent cases where providers have been criticised include executive pay and payoffs, rent setting, data breaches, handling of complaints, building safety and stock quality
  • Complaints – providers should have clear standards for complaints handling and dealing with instances of whistleblowing, ensuring they learn any lessons from events which have occurred
  • Diversification – providers should be aware that involvement in diverse activities, e.g. market sales, specialist care, student housing and commercial property, introduces different risks into the business which ultimately could put social housing assets at risk
  • Value for Money – in making (and reviewing) decisions about the optimal use of their resources to achieve their objectives, providers should take account of changes in the operating environment and competing stakeholder expectations.
The Housing Ombudsman Service introduced its Complaint Handling Code in July 2020.  Landlords should self-assess themselves against the Code and publish the results of that assessment by 31 December 2020.   From 1 January 2021, non-compliance could result in the Ombudsman issuing a landlord with a complaint handling failure order.

 

Operational risks – service delivery

The operational service delivery risks identified in the SRP relate to:

  • Delivering services to tenants – building on their work since the start of the pandemic, providers need to keep their service delivery arrangements under review so they can manage future periods of restrictions, including considering how specific groups of tenants are affected
  • Health and safety risk – it is important that providers understand the legislative requirements in relation to health and safety, act on any shortcomings that come to light and have robust arrangements for collecting, managing and reporting data about their homes.
In September 2020 the RSH published its eighth annual Consumer Regulation Review, which summarises the RSH’s consumer regulation work for 2019-20, and details the 15 cases in the year where the RSH found a breach of the serious detriment test.  Six lessons for providers from the 15 breaches are outlined in the report: (1) ensuring tenants are safe in their own homes, (2) treating tenants with respect and fairness, (3) responding swiftly and effectively to complaints, (4) complying and being able to evidence compliance with the Consumer Standards, as well as understanding the requirements and responsibilities which providers are subject to, (5) maintaining good quality data management and effective systems, and (6) operating transparently with the RSH, tenants and other stakeholders.

 

Operational risks – existing stock

Operational risks in terms of existing stock which the RSH has identified are in terms of:

  • Existing stock quality – providers need to ensure that stock continues to meet changes in stakeholder expectations, e.g. in relation to building safety, energy efficiency and the proposed review of the Decent Homes Standard, and also to ensure necessary works are undertaken to deal with any remaining unsafe cladding and any backlogs as a result of the pandemic
  • Counterparty risk – entering into arrangements with third parties exposes providers to counterparty risk and possibly concentration risk. Outsourcing services does not negate the responsibility of landlords for the provision of those services and due diligence should be undertaken on third parties as appropriate
  • Supported housing – supported housing may offer only low financial returns allied to a vulnerability to adverse income and cost fluctuations. Providers of social housing will need to manage those risks together with risks relating to the pandemic, potential staffing issues caused by Brexit and the implications of the government’s review of how support services are funded
  • Rent setting and rental market exposure – providers should ensure that they have assurance on internal controls relating to rents and that they understand and comply with expectations relating to service charges, including those set out in legislation. Where providers are renting out properties on the open market, they need to understand the implications should rent levels fall over time
  • Rental income and arrears – providers should be aware of the potential for rising unemployment leading to increased arrears and reduced income, as well as managing residual risks from previous welfare reforms such as the Benefit Cap
  • Costs and inflation – the outlook for inflation is more uncertain than normal at the moment including as a result of Brexit and changes to migration policy, and providers should ensure that different scenarios are modelled as part of stress testing
  • Data integrity and security – providers must comply with the Data Protection Act 2018 and any confirmed personal data breaches should be reported to the Information Commissioner’s Office. The failure to provide accurate and timely data to the RSH may be reflected in regulatory downgrades.
In April 2019 the RSH published an addendum to its SRP 2018 which focused on lease-based providers of specialised supported housing.  The main areas of concern for the RSH regarding such providers are an over-reliance on a single funding model of long-term leases, where the payments the RP makes over the period of the lease increase periodically (often annually) linked to the inflation rate at the time; low levels of working capital available to fall back on in difficult times; inadequate risk management and contingency planning arrangements; poor governance practices resulting in sub-optimal decisions being made; and doubts over whether rent levels are being set appropriately.

 

In March 2020 the RSH published an addendum to its SRP 2019 which focused on setting rents for social housing.  The publication highlighted specific issues which included the failure to take account of changing government policy and corresponding requirements in the provider’s rent setting policy and procedures, especially in relation to formula rent; incorrectly treating properties as exempt or excepted from elements of rent rules; incorrectly calculating or applying Affordable Rent; incorrectly calculating or applying service charges, e.g. in contravention of the Landlord and Tenant Act 1985; new, bespoke rental products with rents that do not comply with requirements; and poor quality data.

 

Operational risks – development

The key operational risks in relation to development which are covered in the SRP relate to:

  • Low cost home ownership and market sales – sustaining investment in both new homes and existing stock may put pressure on other funding sources if sale proceeds are lower than previously forecast. Providers should understand the financial implications of sales income being lower than forecast, including by stress testing for severe but feasible disruptions in the housing market
  • Construction process risks – providers need assurance that new homes comply with requirements relating to building regulations, health and safety and the Decent Homes Standard. Attention should also be paid to developing government expectations regarding decarbonisation, building safety and design.  The reliance on key development partners can be a source of significant counterparty risk which providers must manage.

Financial and treasury management risks

The RSH identifies five key financial and treasury management risks:

  • Existing debt – reductions in proceeds from the sale of properties and increased spend on existing stock may put pressure on interest cover ratios. Providers need to monitor compliance with interest cover covenants and take action ahead of any potential covenant breaches
  • New debt – providers need to consider which funding option is appropriate for them including taking appropriate external advice if innovative and/or complex funding structures are being considered
  • Alternative funding models – whilst alternative funding models, e.g. through lease arrangements or direct equity investments, can increase investment into the sector, providers should be aware that they introduce new risks and are potentially more expensive than traditional debt
  • Pensions – involvement in defined benefit schemes can lead to increased employer contribution levels as a result of triennial pension fund re-valuations. Providers should understand the risks involved, taking expert legal advice as appropriate
  • Fraud – providers should have robust internal control procedures in place and where they are the victims of fraud should take appropriate professional advice.

Boards of providers are advised to review the SRP 2020 and to ensure that they are taking account of the key sector-wide risks in their risk management arrangements.  If we can help you with that, please give us a call on 07867 974659.

 

Quarterly Survey – RSH to Sept 2020

Introduction

The Regulator of Social Housing (RSH) has published its latest Quarterly Survey (QS) report which covers the period from July to September 2020.  The report is based on QS returns completed by 214 registered providers (RPs) and groups of RPs, which own or manage more than 1,000 homes.

Operating context

The RSH sets the data which it collected in the context of the coronavirus pandemic, noting that although the nation’s Gross Domestic Product (GDP) rose by 1.1% during September 2020, it was still 8.2% below the February 2020 level and, with the second wave of the pandemic in progress, there remained considerable uncertainty in terms of both how the pandemic would evolve and also the consequent impact on economic conditions.

Funding

In the quarter, £4.5 billion of new debt was raised, meaning that total facilities in the sector stood at £111.3 billion at the end of September 2020, of which £28.0 billion (25.2%) was undrawn, the highest level ever reported and almost 30% more than undrawn facilities a year earlier.

Sept 2019

£ billion

Dec 2019

£ billion

March 2020

£ billion

June 2020

£ billion

Sept 2020

£ billion

Total facilities 99.8 101.9 103.0 107.1 111.3
Undrawn facilities 21.6 22.5 21.9 24.8 28.0
New facilities 2.8 3.7 2.4 4.5 4.5

 

Property sales

Affordable home ownership (AHO)

In the quarter, 3,652 AHO homes were developed whilst 3,823 were sold, with both figures being significantly higher than in the previous quarter.  At the end of September 2020, 7,676 AHO homes remained unsold, of which 3,973 (51.8%) had been unsold for over six months.  Whilst the number of unsold AHO homes overall reduced slightly, the number of homes unsold for more than six months increased by almost 15%, reflecting the record number of completions in the quarter to 31 March 2020.

  Sept 2019 Dec 2019 March 2020 June 2020 Sept 2020
Developed 3,576 4,150 4,870 1,663 3,652
Sold 3,773 3,826 3,959 1,963 3,823
Unsold 6,688 6,943 7,808 7,906 7,676
Unsold over six months 2,614 2,353 2,428 3,460 3,973

 

Market sale

In the quarter, 1,005 homes were developed for sale on the open market whilst 1,461 homes were sold, up by 189.6% and 187.6% respectively compared with the previous quarter.  At the end of September2020, 2,344 market sale homes remained unsold, of which 1,460 had been unsold for over six months.  At 62.3%, the proportion of unsold homes which had been on the market for over six months was the highest ever recorded, again reflecting the high level of completions in the quarter to 31 March 2020.

  Sept 2019 Dec 2019 March 2020 June 2020 Sept 2020
Developed 1,561 1,554 1,944 347 1,005
Sold 1,404 1,213 1,363 508 1,461
Unsold 2,229 2,537 3,073 2,816 2,344
Unsold over six months 883 1,028 1,190 1,520 1,460

Regulatory Judgements 16-17 Dec

The Regulator of Social Housing (RSH) has published another 39 Regulatory Judgements (RJs).  35 of the RJs followed annual stability checks, 29 of which confirmed existing grades.  In the other six cases the RSH also conducted reactive engagement resulting in grade changes:

  • Five providers – bpha, Catalyst, Irwell Valley, Raven and Your – were re-graded from V1 to V2 on Viability. Factors cited in the re-grades include increased investment in existing homes (including fire safety and other building safety work), development plans, exposure to the housing market and increasing debt levels
  • Reside’s Governance was upgraded from G2 to G1 having addressed concerns which the RSH expressed in the RJ which it published in October 2018, relating to oversight of health and safety compliance, lease management, stress testing, its internal control assurance framework and management reporting to the Board.

Three of the RJs – for Hastoe, Livin and North Devon – resulted from In Depth Assessments (IDAs), with existing G1 Governance grades being confirmed in each case.  Livin’s V1 grade for Viability was also confirmed.  Hastoe’s Viability judgement was re-graded from V2 to V1, having reduced its development programme and its exposure to the housing market.  Conversely North Devon’s Viability judgement was re-graded from V1 to V2 due to an increased exposure to the housing market.

Finally, My Space’s first published RJ contained non-compliant grades for both Governance (G3) and Viability (V3).  My Space operates a lease-based model and has grown rapidly in recent years.  Through reactive engagement the RSH identified concerns relating to business planning, risk management and internal controls, and concluded that My Space’s Board had failed to manage its affairs with an appropriate degree of skill, diligence, effectiveness, prudence and foresight.  The RSH also lacks assurance that My Space, which believes that its homes meet the specialised supported housing criteria, complies with the Rent Standard.

The full list of 39 RJs is set out below.

Registered provider Governance Viability
Aster Group Limited G1 V1
Black Country Housing Group Limited G1 V1
bpha Limited G1 V2
Bromford Housing Group Limited G1 V1
Catalyst Housing Limited G1 V2
Community Gateway Association Limited G1 V1
Eastlight Community Homes Limited G1 V1
Freebridge Community Housing Limited G1 V1
Gateway Housing Association Limited G1 V1
Golding Homes Limited G2 V1
Greatwell Homes Limited G1 V1
Habinteg Housing Association Limited G1 V1
Hastoe Housing Association Limited G1 V1
Home Group Limited G1 V1
Incommunities Group Limited G2 V1
Irwell Valley Housing Association Limited G1 V2
Jigsaw Homes Group Limited G1 V1
Livin Housing Limited G1 V1
Local Space G1 V1
Moat Homes Limited G1 V1
My Space Housing Solutions G3 V3
North Devon Homes G1 V2
Notting Hill Genesis G1 V2
Octavia Housing G1 V2
Onward Group Limited G1 V1
Raven Housing Trust Limited G1 V2
Red Kite Community Housing Limited G2 V1
Regenda Limited G1 V1
Reside Housing Association Limited G1 V2
Richmond Housing Partnership Limited G1 V1
Shepherds Bush Housing Association Limited G2 V2
Soha Housing Limited G1 V1
Solon South West Housing Association Limited G1 V1
St Mungo Community Housing Association G1 V2
Thames Valley Housing Association Limited G1 V2
Thrive Homes Limited G1 V1
United Communities Limited G1 V1
Worthing Homes Limited G1 V1
Your Housing Group Limited G2 V2

 

Spending Review 2020 – housing organisation highlights

The Chancellor of the Exchequer, Rishi Sunak, announced a raft of housing policies in the Spending Review on Wednesday 25 November.

Perhaps most eye-catching is the £7.1 billion National Home Building Fund, most of which will be directed to housebuilders in the form of loan finance. £4.8bn of this funding comes from capital grant funding which had been announced previously, but the remainder is a new commitment.

As well as the loan finance for housebuilders, £100 million from the Fund has been earmarked for non-mayoral Combined Authorities, in order to support their housebuilding efforts.

The Fund is separate to the Government’s Affordable Homes Programme, and more spending announcements on this are expected in the next Chancellor’s Spending Review.

A freeze was announced for the Local Housing Allowance (LHA), which is used to calculate housing benefit, meaning it will be kept at the same level – covering the lowest 30% of homes in any given area. Rates beyond the 2020/21 financial year have not been announced, but Inside Housing say it’s assumed that they will rise in line with the Consumer Price Index (CPI). This announcement means a freeze in cash terms, and analysis showed that in real terms, annual LHA funding could fall from £1 billion in 2021/22 to £300 million over the next five years.

Further details of the Government’s plans to decarbonise buildings were also announced, with £60 million to be spent on retrofitting social housing, on top of the £320 million earmarked for the same purpose in the Green Homes Grant Scheme. The combined £380m will be spent in 2021. The schemes have been extended past March, the money for which has been drawn from the Government’s £3bn commitment to decarbonisation of buildings, announced by Sunak in July.

An extra £151 million has been announced for 2021/22, earmarked for supporting the Government’s Rough Sleeping Initiative, as well as schemes run by local authorities. This is on top of the £103m which was announced earlier in 2020 in order to protect homeless people at risk as a result of the coronavirus pandemic, and brings the total committed spending for tackling homelessness in 2021/22 to £676bn, up 60% on 2020/21.

£87 million was also announced in capital grant funding, in order to support the building of long-term supported accommodation for homeless people.

The Help to Buy programme is to be extended for another two years, with an extra £5.3bn in funding announced – £2.2bn next year, and £3bn in 2022/23. Whilst the programme will continue to provide loans to first-time buyers, it will also implement regional price limits, set at 1.5x the average house price for a first-time buyer in any given area.

Lastly, the Government has spoken a lot of ‘levelling up’ areas worst-hit by the pandemic in recent months, and made moves to fulfil that in the Spending Review, announcing details of the £4bn Levelling-Up Fund. Under this Fund, local areas will be able to apply for up to £20 million of funding to support a range of initiatives, with priority given to those areas most in need. The projects must be deliverable within this parliamentary term (by spring 2024, unless an earlier election is called), and have support from their Member of Parliament and other local stakeholders.

Review of RSH recent regulatory judgements

In the two weeks from 2nd December 2020, the Regulator of Social Housing (RSH) has published 53 Regulatory Judgements (RJs), all of which confirmed existing grades.  The number of RJs published reflects that this is annual stability check season for the RSH, with all but one of the RJs resulting from a stability check, the exception being Optivo on which the RSH had conducted an In Depth Assessment (IDA).

51 of the registered providers (RPs) received the highest G1 grade for Governance with just two – Connexus and Progress – being graded at G2, meaning that whilst they are compliant with the RSH’s expectations on Governance, they need to make some improvements to maintain compliance.

38 of the RPs received V1 grades for Viability with 15 (including Connexus) being graded at V2, meaning that whilst they are compliant with the RSH’s expectations on Viability, they need to manage material risks to maintain compliance.

The full list of 53 RJs is set out below.

Registered provider Governance Viability
A2Dominion Housing Group Limited G1 V2
Acis Group Limited G1 V2
Arawak Walton Housing Association Limited G1 V1
Arches Housing Limited G1 V1
Bernicia Group G1 V1
Bolton at Home Limited G1 V2
Bournville Village Trust G1 V1
Byker Community Trust Limited G1 V2
Chelmer Housing Partnership Limited G1 V1
Christian Action (Enfield) Housing Association Limited G1 V2
Clarion Housing Group Limited G1 V1
Coastline Housing Limited G1 V1
Cobalt Housing Limited G1 V1
Connect Housing Association Limited G1 V1
Connexus Housing Limited G2 V2
Croydon Churches Housing Association Limited G1 V1
Curo Group (Albion) Limited G1 V1
Empowering People Inspiring Communities Limited G1 V1
Futures Housing Group Limited G1 V1
Golden Lane Housing Ltd G1 V1
Grand Union Housing Group Limited G1 V1
Havebury Housing Partnership G1 V1
Housing Solutions G1 V1
Karbon Homes Limited G1 V1
Leeds Federated Housing Association Limited G1 V1
Look Ahead Care and Support Limited G1 V1
Manningham Housing Association Limited G1 V1
Midland Heart Limited G1 V1
Network Homes Limited G1 V2
Newlon Housing Trust G1 V2
North Star Housing Group G1 V1
Nottingham Community Housing Association Limited G1 V1
Ocean Housing Group Limited G1 V2
One Manchester Limited G1 V1
One Vision Housing Limited G1 V2
Optivo G1 V1
Paradigm Housing Group Limited G1 V1
Paragon Asra Housing Limited G1 V1
Places for People Group Limited G1 V1
Progress Housing Group Limited G2 V1
Riverside Group Limited (The) G1 V1
Rochdale Boroughwide Housing Limited G1 V2
Saffron Housing Trust Limited G1 V1
Salix Homes Limited G1 V2
Selwood Housing Society Limited G1 V1
South Yorkshire Housing Association Limited G1 V2
Tower Hamlets Community Housing G1 V2
Trent & Dove Housing Limited G1 V1
Tuntum Housing Association Limited G1 V2
Two Rivers Housing G1 V1
Vale of Aylesbury Housing Trust Limited G1 V1
Wakefield And District Housing Limited G1 V1
Weaver Vale Housing Trust Limited G1 V1

 

 

Social Housing White Paper – and the Charter for Social Housing Residents

Here is the link to the Social Housing White Paper 

https://www.gov.uk/government/publications/the-charter-for-social-housing-residents-social-housing-white-paper

Watch our Events page on Monday – we are organising Tenant UNConference on 8th December

 

Here is summary of the white paper and the changes proposed:

Our summary – Social housing White Paper

 

Here is the response from the regulator:

https://www.gov.uk/government/news/statement-on-social-housing-white-paper

 

Here is a Residents toolkit – A summary of the changes within the Charter, and what they will mean for residents

Residents Toolkit – Charter for Social Housing

 

Here is a Communications toolkit – A brief summary of changes, as well as our communications products in a downloadable link, and further information for creating social media content to engage with the Charter, encouraging your network to do so also.

Communications Toolkit – Charter for Social Housing

RSH Coronavirus Operational Response Survey, September 2020

The results of the Regulator of Social Housing’s (RSH) coronavirus operational response survey for September have been revealed, and show service delivery has largely remained stable when compared to the previous survey, conducted in August.

However, some providers reported growing concerns around staff pressure, due to absences resulting from periods of self-isolation, and the difficulties of operating geographic areas which had different restrictions in place.

The survey was conducted before the announcement of the three-tiered COVID Alert Level system in England, and the response rate was 95%, down slightly from 97% in August.

This was the sixth such survey conducted by RSH, with the first conducted in April, and aims to give an insight into how providers are coping with the challenges posed by the coronavirus pandemic.

In comparison to August, the number of providers responding that all statutory gas and fire safety compliance checks were complete was up slightly, while a slightly greater number reported that in terms of ‘care and support staffing levels’ they were maintaining safe levels and essential delivery, but with some pressure.

This again chimes with respondents detailing concerns about absences as a result of self-isolation, and the challenges of working across different geographic areas.

Two more iterations of this survey are planned, for October and November, and as usual they will be launched through the RSH’s NROSH+ system on the final Friday of each month.

The October survey will cover the period up until Saturday 31 October, and the deadline for responses will be Friday 6 November.

Whilst the generally stable performance of the sector is to be welcomed, the situation regarding the pandemic is a dynamic one with varying impacts from location to location.  It is crucial therefore that providers regularly report internally on their position in relation to compliance checks, service delivery and staffing levels, and take action to address any issues.

NHF Together with Tenants – early adopter report

The NHF have produced their learning from the Together With Tenants Pilot

together-with-tenants—early-adopter-report_final

Call to Action:

  • Have you consulted residents and staff on the Tenant Charter yet?
  • Have you had your Charter signed off by the Board?

This is part of a plan from the NHF to help you provide evidence of compliance with good governance.

If you are a HA, you need to adopt a Code of Governance, to ensure you comply with the Regulator of Social Housing’s Governance and Financial Viability Standard.

If you don’t adopt the NHF code, you can sign up to the Corporate Governance code or the Charities Code – most HAs use the NHF Code.

 

As a reminder , the NHF has four-point plan for change following the Grenfell Tower

  1. A new requirement in the National Housing Federation Code of Governance for boards to be accountable to their residents

We are producing a new Code of Governance, which will be published later this year, in collaboration with partners and stakeholders, including residents. The new 2020 code builds on earlier versions to include provisions that the views and needs of residents and other customers must be at the heart of strategic decision-making.

  1. A new Together with Tenants charter

The charter is designed to ensure all residents know what they can expect from their housing association landlord, regardless of where they live, what type of home they live in, or who their landlord is. You can read the charter below.

  1. Resident oversight and reporting of progress against the charter

Resident oversight and public reporting against the commitments set out in the charter will give residents a stronger role in holding their landlord to account. This aims to prevent Together with Tenants from becoming a tick-box exercise that does not drive change. Boards will be expected to respond and take action where required.

  1. Giving residents a stronger collective voice with the regulator

Resident oversight and reporting against the charter may uncover issues of interest to the regulator, including potential non-compliance with consumer standards. Linking the Together with Tenants approach to regulation in this way will ensure that action is taken where necessary to protect the rights and interests of residents.

 

Scrutiny and Involvement Network, 14th Oct 2020

Here are the notes and the agenda for the last meeting online on 14th October 2020:

This was our agenda:

10am                        Introductions

10.10 -10.50            Building Safetywhat does it mean for resident engagement, followed by a 5 minute break

10.55 -11.30            RSH Consumer Regulation Reviewwhat does it mean for resident engagement, followed                                    by a 5 minute break

11.35 – 11.45            On the Couch: Chat facility

  • How do you engage residents in choosing your customer services standard offers, esp. prioritising this for residents?
  • What are your Resident Engagement KPIs
  • Can people share their method to recruit with any accompanying documents, such as an expression of interest?
    • Also, if scrutiny members are involved how does this happen on a practical basis.
    • How do you review this process to establish people’s drivers without making it too onerous or off putting – any ideas, what works well /not so well?
  • Supporting residents with the provision of IT etc to get involved – see D below

(Some ideas were shared but we decided the items were too meaty and would be returned to at the next meeting as more major agenda items)

11.45 – 12.25           NHF Code of Governance Reviewwhat does it mean for resident engagement

12.25 – 12.30           AOB (none) and agenda for the next meeting: Wed 25th November 2020 (10-12.30)

 

 

A: Building Regulations – changes, ideas and discussions:

This is the pre circulated article:

Building Safety Bill TA article

These were the headline slides which supported the discussion:

S.Net Building Safety 14.10.20

These are the notes from the discussions on the 4 questions in the presentation considered by our breakout rooms on Zoom:

1.The content of a Resident Engagement Strategy to show residents how they can get involved, and the benefits they gain from engaging in Building Safety Regulation

A separate strategy or do we change the involvement strategy

There is no guidance on whether this requires changes to the existing strategy for engagement, or whether a separate engagement strategy might be required by the BSR.

We debated the merits of having a separate engagement promise per improvement scheme, with overarching promises to engage, added to the existing resident involvement strategy/policy.

We felt a number of promises in different strategies would not be helpful, but if this was the case, then we would need to be clear with the affected residents of the combined promises.

Your Housing Group

Are developing a 2-year building safety engagement strategy with the first year focused on building over 18m.

  • Residents will shape the action plan for the strategy which will lead to the creation of resident forums for their high-rise stock.
  • The forums will link to the Customer Operations Committee that in turn report to the Board.
  • Quarterly newsletters
  • Residents will be able to be involved as “Safety Angels”.
  • A separate route for complaint and repairs relating to building safety.
  • A focus on putting residents first reflected in changes to some of the roles in their organisation for more resident focus.
  • Neighbourhood officers will deliver resident engagement and manage the high-rise forums and be the eyes and ears of the organisations
  • Newsletters detailing planned works and a resident portal that allows residents to see the progress of works are being considered.
  • The challenge of maintaining residents’ interest in being involved was discussed.

 

Learning from Grenfell

How do we capture the informal feedback from residents so we pick up safety concerns early?

  • Suggestion box?
  • Strengthening the role of the caretaker/site managers’ officer

 

Judith Hackitt enquiry stated that her remit was buildings 18 metres and above. However, Dame Hackitt had stated in her report that the recommendations equally apply to shorter buildings.

We debated the need for buildings 17 metres and below – which were flatted to have the same engagement strategy for planned major works.

We considered the merits of a strategy that covers all flats.

 

Sarah Carpenter MHCLG, High Rise Best Practice Group

This is made up of supported housing, high rise housing and involved tenants.

  • They are advising MHCLG on emerging regulations from the tenant perspective.
  • The HSE will determine the outcomes.
  • Resident involvement here has added value and comments have been well received.

 

2.Consulting residents on the information they need to help them understand the layers of protection and how landlords keep resident’s safe

There is a challenge in making the information relevant to residents.

Safety is not just about the risk of fire.

Accessing properties is an important element of keeping residents safe.

It was acknowledged that more could be done to involve residents in works to their building and some works will need to be carried out regardless of resident’s view but it is important to understand resident’s concerns.

 

3.How do we get residents to co-operate in keeping the building safe, to understand their rights and responsibilities?

The group debated:

  • whether the landlord was consulting, telling or asking – in an engagement strategy – the decision is made by boards and councillors – the risk of consultation outcomes being agreed?
  • the importance of gaining residents trust in the messages they receive was discussed.
  • Scrutiny Groups can be an effective way to engage residents by sharing risk assessments and having an annual health and safety review.
  • there are still difficulties – even where stay put advice has bene given at length, with residents acting on instinct and leaving the building when fire alarms go off
  • STAR Surveys and Home visits to explain policies on building safety to residents
  • many landlords are retrofitting sprinklers

The group felt that some simple headings in communication for consultation might be helpful like:

  • What are we doing?
  • What do residents want from us?
  • How do they want to engage?

 

4.Include residents within decision making on improvement schemes

The group discussed:

  • the Health and Safety review undertaken by the Scrutiny Group at Warrington HA.
  • Trafford HT sharing of full risk assessments on the website for transparency – but these are lengthy and complex documents
  • The benefits of estate officers and residents’ walkabouts to gather views during major works, with residents

It was felt that:

  • landlords needed to be clear on the roles and responsibilities of the various officers and parties engaged in the building contracts
  • landlords might make information available in full and summary form -plain English
  • fire safety advice should be reiterated in the resident engagement strategy for major works in blocks of flats.

 

 

B: Consumer Regulation review – changes, ideas and discussions:

This is the pre circulated article:

RSH con reg review report TA article

Here is the headline presentation to aid our discussion:

RSH LessonsTo Learn Oct2020

These are the notes from the discussions on the 4 questions in the presentation considered by our breakout rooms on Zoom:

1. Compliance with Consumer Standards to all tenants

This can be a bit of a “tick-box” exercise.

Evidence of real influence might be hard to prove.

This is similar to engagement on Policy when it comes at the end of an officer review and does not first ask residents who have received the service what they would like to see improved and what they liked about their service.

The scrutiny groups or high-level engagement panels or committees were felt to be the best place to get real challenge on compliance.

Residents need to be more involved, the annual review is co-produced with residents but generally this can be a rubber stamping of a Q&A session, where this happens.

It was felt that residents could lead on letting landlords know where they think they haven’t met the standards.

A rolling review rather than an annual review could be a better way of keeping residents involved.

Focus Groups that look at particular standards could be set up.

Some new Customer Boards have a specific remit for resident assurance to boards of compliance, for example: Salix and Yorkshire Housing

The issue of customer standards being in the same place, signposted, easy to find, easy to read and easy to understand style including websites or newsletters is a challenge.

 

2.Transparency in engaging residents to shape services

Some landlords have worked with resident to identify KPIs which are important to residents – e.g. Cobalt

There is a need to understand what residents would like to see and what area are important to them.  Focus groups could help with this.

There are a finite group of residents who want to engage for compliance.

Asking residents to shape services, based on data is a far reach.

Officers can identify poor performance, and engage residents in solutions for implementation, where no commentary is made on KPIs

 

3. Tenants  understand the requirements & responsibilities providers are subject to  and their own requirements

Managing residents’ expectations is important.

Videos that address roles and responsibilities are a good way to get the messages across.

Many landlords are reviewing service standards and intending a relaunch post CV19

Generally, focus groups and surveys are seen to be the best way to see if residents understand messages sent – with existing and new residents

 

4. Demonstrating that we treat tenants with fairness and respect- including taking account of their diverse needs – building trust

This challenging as it means different things to different residents, ideas included:

  • a survey to assess residents needs
  • being aware of communication preferences
  • looking at the complaints processes to ascertain if residents are being treated fairly.

It was agreed this is difficult to measure and evidence transparency/outcomes in this action

Most landlords have struggled to achieve a diverse group of residents commenting. Suggestions include the ability of residents to explain in detail what they think of each part of the NHF Charter and how they feel the landlord could measure this. this might require landlords to go to community groups, who might not otherwise see the benefit of engagement specifically for landlord compliance.

We need to be clear – what is in this for residents?

Together HG have shared their annual report to Board on involvement:

THG Customer Insight Report

 

C: NHF Draft Code of Conduct – changes, ideas and discussions:

This is the pre circulated article:

NHF code article_

Here is the headline presentation to aid our discussion:

NHF code article_

These are the notes from the discussions on the 4 questions in the presentation considered by our breakout rooms on Zoom:

1.Access to systematic information for scrutiny by all residents to hold us to account, including for diverse groups

The group acknowledged the need to strengthen this.

The challenges of making information available and comprehensible to all residents was discussed.

Obstacles include:

  • access to digital
  • language

Most see scrutiny panels as a way of feeding in “lived experience” to the Board.

Residents on a board are not representative of residents – they offer their own views and perspectives.

We need to ask residents what data they are interested in reviewing and seeing.

 

2.Views of a wide range of residents in influencing strategic decision making – their views reaching the Board

Customer voice groups that feed into the Board are the usual ways of achieving this, or high-level standing groups who influence strategy and have their skills and capacity built over time to engage.

Some landlords do a resident awayday on the Corporate Plan, prior to Board – Soha

Others update their standing groups on progress on the corporate plan.

ALMOs tend to put board papers on the website, including minutes and actions plans

 

3.Residents on the Board on Committees (direct lived in experience)

Plus Dane is considering opening up the Board on Facebook Live.

It already holds Board Member Q&A sessions with residents.

The need to strengthen the link between residents and governance was acknowledged.

Most landlords have moved to having customer experience from a resident(s) on the Committee or Boards of HAs, but they are ordinary members and not separately identified as tenant BMs.

Tenants can roundup the skills of the Board during decision making.

Resident contributions need to be supported in this, including confidence to speak and capacity building. Yvonne shared information on the course run by HDN which is for new BMs, existing BMs who wish to become Committee Chairs or Committee Chairs who wish to become Chairs of the Board.

It enables mixing, sharing and learning from others BMs:

https://www.housingdiversitynetwork.co.uk/mentoring/board-excellence

Some have paid to go on the course and have secured Board positions after the event. The HDN (Housing Diversity Network) course has been made a prerequisite of volunteering for some boards – Thrive Homes and Leeds and Yorkshire HA.

Some HAs have sponsored residents – Together and Progress HGs, who are diverse and under represented to join another HDN Course, to improve their diversity on boards and committees:

HDN Board Diversity Programme

The current link to board, as well as the Tenants BM and CMs and Council, is generally through reporting up from Scrutiny Groups – either quarterly or when reports are concluded and presented.

 

4.Reporting back to residents on how you have acted on their views and to keep them informed

Engagement HQ is a useful tool for organisations to consider. Leeds Homes, Catalyst HA and Community Gateway have just purchased this to try out a friendly digital platform

A variety of methods are used to make resident aware of organisational activity:

  • Infographics
  • You Said We Did
  • Social media
  • Customer magazines.

 

D: On the Couch – Supporting residents with the provision of IT etc to get involved

Here is the agreement provided from Weaver Vale, agreed with residents for the provision of a laptop.

Residents have been able to get initial training, with follow up training provided through the staff IT helpdesk:

Loan Equipment Agreement for Trust Volunteers 

ICT Security Policy Receipt

IT-SECURITY-POLICY-PROCEDURAL-GUIDANCE-NOTES

 

Date and time of next meeting:

On line on 25th November 2020 – 10- 12.30pm

Agenda to include:

  1. Latest on involvement and building safety
  2. Developing techniques on engagement – story telling and similar
  3. Engaging residents in customer service standards – resident priorities
  4. Resident Engagement KPIs
  5. Recruitment to Resident Panels
    • techniques
    • expressions of interest and documentation
    • people’s drivers