Welsh Government Housing Policy Regulation

Transcription

1 Welsh Government Housing Policy Regulation Regulatory Assessment Report June 2015

2 Welsh Government Regulatory Assessment The Welsh Ministers have powers under the Housing Act 1996 to regulate Registered Social Landlords (RSLs) in Wales in relation to the provision of housing and matters relating to governance and financial management. Part 1 of the 1996 Act is amended by Part 2 of the Housing (Wales) Measure 2011 ( The Measure ) and provides the Welsh Ministers with enhanced regulatory and intervention powers concerning the provision of housing by RSLs and the enforcement action that may be taken against them. The Welsh Ministers are publishing this Regulatory Assessment report under section 33A of the Housing Act The work undertaken follows the risk-based approach to regulation and seeks to identify strengths and areas for improvement in meeting the delivery outcomes (standards of performance) set out in The Regulatory Framework for Housing Associations Registered in Wales ( The Regulatory Framework ). Basis of Regulatory Assessment The report is designed to provide the RSL, its tenants, service users and other stakeholders with an understanding of how well it is performing, at a specific moment in time, in relation to: Governance Financial management Services This report has been prepared for the RSL as a Regulatory Assessment. It is based on information provided by the RSL and the Regulator s knowledge and must not be relied upon by any other party for any other purpose. The RSL remains responsible for the completeness and accuracy of information provided to the Regulator. Housing Regulation Team Welsh Government Housing Division Merthyr Tydfil Office Rhydycar CF48 1UZ housingregulation@wales.gsi.gov.uk Digital ISBN Crown Copyright

3 Introduction Coastal Housing Group Limited (Coastal) The Group comprises Coastal Housing Group Limited (Coastal), the parent company, and its subsidiary, Pennant Housing Association Limited (trading as Pennant Homes). Both are RSLs, with Coastal providing general needs homes and Pennant Homes developing new homes for sale. Coastal was created following a merger of Swansea Housing Association and Dewi Sant Housing Association in Coastal is registered under the Co-operative and Community Benefit Societies Act 2014 and has charitable rules. Pennant Homes is a non charitable RSL. The Group owns and manages over 5,500 homes, including 845 sheltered homes, and provides services to 166 leaseholders. It operates in four Local Authority areas in Wales - Swansea, Neath Port Talbot, Carmarthenshire and Bridgend. Coastal applies a lean systems thinking approach to the delivery of its business and services. This approach gives prime importance to the issues and services that matter most to the service user, removing anything that does not add value to the service user and by learning from all service user contact to secure continuous improvement. Scope Details of the risks identified for the social housing sector in Wales can be found at: An assessment of these risks identified the following as significant for Coastal: Significant risks which are part of this Regulatory Assessment: Governance Managing a housing development programme Existing stock Differential inflation rates Services 2

4 Governance and Financial Management Governance Coastal s Self Assessment has sought to cross reference the requirements of Welsh Government self assessment guidance to the Group s lean systems thinking approach and wider corporate planning. More work is required for this to be fully achieved. The Self Assessment currently provides limited evidence to demonstrate its performance on delivery outcomes. Coastal continues to review its approach to self assessment, to include gathering more robust evidence to demonstrate outcomes. The Group needs to integrate its Self Assessment into its wider performance monitoring and corporate planning approach and develop its use as a live business tool. The Group s Board members and staff have clearly demonstrated understanding of, and adherence to, the principles of co-regulation. Coastal Housing has adopted Community Housing Cymru s Code of Governance ( The Code ). It intends to measure itself against The Code. The Group s Board governance is generally sound. Coastal acknowledges that further improvement is required. There has been significant progress in implementing a governance strategy and improvement plan. This has included a revised Board committee structure which has enabled a greater focus on continuous improvement in governance, Board member one to ones, which evaluate the contribution of individual Board members, and an annual Board self appraisal. The Group has acted to ensure that the Board has an appropriate range of skills and expertise, through development of a Board skills matrix and related training and development. This will inform a new Board succession plan and support recently introduced more targeted and structured Board recruitment. The Board has ownership of all key corporate plans and strategies and sets the strategic direction together with senior staff. Coastal is currently working to improve its performance information, to include additional indicators and measures to facilitate more focused Board decision making. This would be further improved by including more outcomes information in Board papers. The Board has a positive relationship with its senior management team, most of whom have been appointed over the last nine months. It could do more to encourage greater contributions, challenge and scrutiny from its Board membership. Coastal has a strong focus on outcomes for the people who use its services, applying, throughout its business, a lean systems thinking approach, driven by achieving positive outcomes for its tenants. The Group has made some progress in measuring and recording outcomes and is taking action to further develop this. 3

5 The Group is accountable for the quality of services delivered, open about its activities and publishes balanced performance information. Complaints are well managed, dealt with at the point of contact, with an emphasis on what people want to be resolved. The service focus is on getting it right first time and learning from when that doesn t happen. The Group plans to further develop its formal complaints log, to enable further learning from trend analysis. Coastal s staff and culture encourage early tenant involvement in shaping and reviewing services through a variety of methods. No formal strategic tenant groups exist, as the lean systems thinking approach takes feedback at the point of all service transactions and uses this on a continuous basis to influence strategic decision making and service improvement. The development of more collective opportunities to shape services is planned. Staff culture is positive, empowering staff at all levels to be involved in influencing improvements and encouraging staff to learn through their work and apply new practices. As a result, change is not instigated from the top down, but grows organically and is owned by all staff, irrespective of seniority. The Group has external objective assurance on the quality of its staff culture and morale. Communication to, and feedback from, staff regarding wider corporate messages has improved with evidence that staff have an understanding of the organisation s wider goals. Board members have an understanding of value for money. The Group has an appropriate strategy with defined outcomes which links to other relevant corporate strategies. This is embedded in the culture through the lean systems thinking approach and staff are empowered to apply it their day to day work. The Group s governance promotes equality of opportunity by monitoring the diversity of its Board, staff and tenants. The Board currently has 11 members out of a possible 12. Approximately two thirds of the current members (64%) are female. quality of self assessment formal assessment of governance against The Code quality of performance information, measuring and monitoring of outcomes greater contributions, challenge and scrutiny by Board members further development of the formal complaints log for further learning from trend analysis development of more collective opportunities for tenants to shape services Financial Viability Our judgement of the Group s financial viability remains unchanged from last year. As at 30 September 2014, the judgement is Pass - the Group has adequate resources to meet its current and forecasted future business and financial commitments. 4

6 Managing a Housing Development Programme Coastal has a well developed system in place to ensure potential development schemes are consistently appraised and that development risks are well managed. Development priorities are driven by future and existing tenants needs and aspirations. The Group s Development Strategy is high level, covering only financial and funding issues. Coastal needs to incorporate established geographical priorities and types of development within the strategy and has plans to address this. Coastal is currently working to apply its lean systems thinking approach to its development function, aiming to further improve efficiency and ensure that development is driven by tenants needs. the updated Development Strategy, to include geographical area and development types Existing Stock Coastal has met the Welsh Housing Quality Standard. The Group s approach is informed by up to date stock condition survey information. Coastal does not currently independently evaluate the quality of that information. It accepts that it needs to do so and is putting plans in place, giving priority to its older stock. Adequate funding is in place to maintain the Welsh Housing Quality Standard and deliver planned and reactive maintenance. The Group takes a planned and strategic approach to asset management informed by good understanding of its stock, based on staff knowledge and analysis of its older stock. Coastal plans to gather more comprehensive information across its whole stock and on which to base a more robust Asset Management Strategy. This will include a financial and neighbourhood evaluation of its stock as a basis for its formalised stock portfolio and options analysis. The Group manages relevant health and safety risks appropriately. further assurance of accuracy and sufficiency of stock condition information further development of a robust, strategic approach to asset management 5

7 Differential Inflation Rates Coastal s financial performance is robust. The Group undertakes some sensitivity testing on its Business Plan and should expand this to include more complex scenarios and an assessment of the impact of more than one risk occurring at the same time. expansion of sensitivity testing of the Business Plan, to include more complex scenarios and assessment of the impact of more than one risk occurring at the same time Services Coastal s tenants indicate good levels of satisfaction with its services overall. The Group s waiting list is currently partly closed for certain areas where demand is high but turnover is very low. Coastal keeps this approach under regular review in liaison with Local Authority partners. It seeks to ensure its dialogue with applicants achieves a full discussion of all their housing options to address their housing need within a reasonable length of time. Coastal recognises that its current time taken to let vacant properties could be improved. It is currently reviewing its lettings systems to achieve a balance of prompt lettings and the pre-tenancy work needed to achieve sustainable tenancies. Coastal has tenant profiling information for over 60% of tenants. It has used this information to date to target access to an appropriate range of services for individual tenants. The Group has plans to increase the information gathered and extend its use to inform wider service development and delivery. The Group involves tenants in shaping and reviewing services through a variety of methods and there are good satisfaction levels amongst tenants for the opportunity to make their views known. Its lean systems thinking approach captures learning from all service user contact which is used to drive continuous service improvement. Coastal has used tenant feedback to develop limited service standards for front line services. These are supplemented by a set of principles, currently being developed and refined, for staff to apply to service provision generally. The principles are based on a dialogue with individual tenants to find out what matters to them, thus enabling a tailored service. The Group has worked to understand the triggers that affect tenants financial circumstances and is using and sharing information from front line staff throughout the organisation to provide a proactive financial support service. Anti-social behaviour is dealt with by generic staff using a holistic tenancy approach through a variety of prevention, early intervention and enforcement methods. Lower tenant 6

8 satisfaction is evident for anti-social behaviour than for other service areas. Coastal has done an analysis to identify anti-social behaviour hot spots and is using this to inform its approach. It intends to undertake a detailed tenants survey to increase its understanding of its performance and to work with tenants in the areas concerned to improve its approach moving forward. Domestic violence awareness training is provided for all staff, along with support for victims, appropriate partnership working and target hardening. The Group supports its Local Authorities in their duty to rehouse homeless households, both operationally and strategically, making a valued contribution. Coastal does not currently have assurance that its services are being provided on the basis of equality. It is currently developing a methodology for carrying out Equality Impact Assessments which is compatible with its lean systems thinking approach. The Group does not undertake equalities monitoring for core services, apart from new lettings. Coastal recognises the need to improve its approach and intends to extend its equalities monitoring to cover all core services, including tenant satisfaction. review of approach to and improvement of time taken to let vacant properties, to include the balance of prompt lettings and pre-tenancy work needed gathering more tenant profile information and extending its use to inform wider service development and delivery additional tenant surveys and involvement to understand factors causing lower satisfaction with the anti-social behaviour service and adjustment of approach development of methodology for Equality Impact Assessments equalities monitoring of service and tenant satisfaction outcomes Shared Learning Coastal s recent Community Intervention Project was set up, using a lean systems thinking approach, to gain more knowledge from tenants in communities, challenge the organisation s assumptions and enable a change of approach to services. It is a wide ranging initiative, designed to influence the Group s delivery of services across the board, recognising that tenants are diverse so a one size fits all approach does not meet individual needs. It involved a cross functional team of staff going out to talk to tenants to find out what matters to them, what assets they have and what a good life looks like to them. The results have informed the development of a set of principles for staff to apply to service provision generally, which involve a dialogue with individual tenants to enable a tailored service. This means that services are designed flexibly and are responsive to individual demand, so are shaped in real time. Service performance is measured by asking tenants if they received the outcome that matters to them. 7