Housing Association Regulatory Assessment

Transcription

1 Welsh Government Housing Directorate - Regulation Housing Association Regulatory Assessment Linc-Cymru Housing Association Limited Registration number: L109 Date of publication: 21 December 2012

2 Welsh Government Housing Association 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 registered social landlords 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 regulatory assessment 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). These are set out in the Regulatory Framework for Housing Associations Registered in Wales, which is also known as the regulatory framework. This report sets out the Welsh Government s assessment and is designed to provide the RSL, its tenants, service users and other stakeholders with an understanding of how well it is performing against the Delivery Outcomes relating to: Landlord services Governance and Financial management Crown copyright 2012 WG14186 ISBN

3 Description of Linc-Cymru Housing Association Linc-Cymru Housing Association Limited (Linc) was established in The Association is registered under the Industrial and Provident Societies Act 1965 and has charitable rules. It works in the affordable housing, social care and health sectors in Wales, with around 4,000 properties in management. The Association has two primary strands - or business units - within its corporate structure: Linc Homes - operates across South Wales providing mainly social and affordable homes for rent, though it also manages around 125 homes which have been sold through the shared ownership initiative. It has no leaseholders. Linc Homes tenants are predominantly families, with most of its 3,500 homes having two or more bedrooms; and Linc Care - provides homes and related services to older and vulnerable people across Wales, including sheltered, supported housing and extra care schemes. Linc Care also manages a Nursing Care home, which is regulated by the Care and Social Services Inspectorate Wales. Linc Care has grown in size and complexity significantly over the past few years. The Association reviewed its governance and leadership team structures and capacity in 2012, to reflect the changes and challenges this has brought to its business. The Association set up a subsidiary company in 2009, called Tarbed Limited, to help maximise financial outcomes in relation to new developments. This company does not provide any direct services to residents. It has a committed development programme of 117 general needs homes and one nursing home, with 73 bedspaces. Its financial forecasts do not include any uncommitted development proposals. Overall Assessment Summary: Landlord Services Linc builds and renovates homes to a good quality. It manages its homes well to help ensure they remain in high demand. It is very successful in minimising the level of empty homes and quickly reletting them, which helps maximise the homes available to people in need and protect its income. However, while it is seeking to provide homes in an open, accessible and effective manner, it cannot demonstrate that it always lets its properties in a fair way or which always maximises the outcomes it could achieve. It adapts homes to meet tenants needs, but needs to do more to understand how well the process works from its tenants perspectives. It also needs to improve its understanding of new tenant views about their homes. 1

4 Linc can demonstrate positive outcomes in a number of areas related to the management of its homes. These include positive changes in the levels of anti social behaviour tenants have experienced where it has taken proactive steps to deal with cases reported and support for tenants which has helped them to sustain their tenancies and increase their life skills and chances. It is implementing a welfare reform action plan, linked to a new strategy which more robustly brings together a comprehensive approach to supporting tenants at risk of financial difficulty than it has had before. Some steps are also being taken to improve its understanding of tenant and community perceptions of their neighbourhoods, to inform future decisions, though there is more to do to make this comprehensive and outcome focussed. The Association has robust plans for future investment in the repair and maintenance of its homes. It has made significant improvements in the cost and efficiency of repair services tenants receive, including a number of areas which tenants have said were the most important to them. It now needs to build on this progress, to maximise customer facing outcomes and subsequently, the value for money the service offers. Linc sells houses fairly and efficiently through Right-to-Buy and Right to Acquire schemes. However, it has not yet engaged effectively with its shared ownership residents, so can not demonstrate that it provides fair, efficient and effective services to them at the current time. 2

5 Summary: Governance and Financial management Linc has made significant strides in laying firm foundations to demonstrate that people who use its services are at the heart of what it does. It can show customer focus in improvements it has made to overall service access and information arrangements. It needs to build on the progress it has made through understanding more about its customer make up, increasing its focus on outcomes and continuing to rollout the emerging role tenants are playing in influencing strategic direction, service design and performance monitoring. The Association is open, honest and increasingly accountable to its tenants and others. It takes an active approach to seeking to improve the economic, social and environmental outcomes of the communities in which it works. Linc can demonstrate a number of outcomes in meeting some diverse needs, particularly in relation to supporting older and vulnerable people. However, it has much more to do, to ensure that it demonstrates that it values diversity throughout its decision making processes. It also needs to provide customers with more balanced information about its comparative performance over time and in comparison with others. The Association has a clear purpose which is shared by its staff, tenants and partner agencies. Strong and visible leadership enhances its ability to deliver improvements, as it is self-aware and there is clarity about what it wants to do, by whom and why these are the options it has chosen. It supports this through effective capacity building and nurturing a positive, improvement focussed culture throughout the organisation. It now needs to re-focus some of what it sets out to do and the way it monitors outcomes within a more impact-focussed framework and with a greater emphasis on how it can ensure it makes the best use of resources. The Association takes a proactive approach to partnership working with other organisations, including local authority and community partners. This helps it to deliver improvements it could not achieve alone. It acknowledges that it could more regularly seek to understand its partners views of how well it works with them, to ensure it is maximising the partnership opportunities which exist. Linc is a financially sound business with a robust financial management framework. It identifies and manages risks in an effective way and has a robust approach to financial probity. 3

6 Future Regulatory Engagement Linc is assessed as requiring a medium level of regulatory engagement in future. This engagement will focus on the following areas: Embedding an outcome focussed approach across the association, to understand the impact it wants to achieve and the progress it is making, from its tenants, service users and partners perspectives; Increasing its understanding of its customer profile to help tailor and target services and resources, to meet tenants needs; Developing its new arrangements for resident involvement in shaping services, reviewing performance and developing plans for the future; Improving its approach to equality and diversity within the decision making process, including analysing service delivery against equality, diversity and other profile data to ensure fair service outcomes; Enhancing the Association s understanding of value for money, to help it ensure it is making the best use of its resources; Building on current customer information to address any gaps, enhance its accountability, through more clearly setting out comparative data and performance against its new service standards; Embedding its emerging new approaches to support tenants in financial difficulty and to understand and respond to the views of communities about their Neighbourhoods; Maximising customer facing outcomes within the Repairs and Maintenance service; and Engaging with shared owners to develop a service which meets their needs. Regulatory engagement will encompass a range of activities including contact with tenants and service users, senior management, operational staff and the Board, observation of events and monitoring the Association s progress against its plans for improvement. 4

7 Landlord Services 1. We build and renovate homes to a good quality The Association s new build programme has provided a wide range of quality, sustainable housing for people with differing needs, in line with local priorities, across the areas in which the Association works. Linc ensures that its proposals for new and renovated homes demonstrate financial viability and represent value for money. It considers all relevant risks and manages them to protect its core housing activity, utilising its subsidiary company to improve the financial outcomes it can achieve. 2. We let homes in a fair, transparent and effective way Linc is effective in managing its homes to ensure that they are in demand, maintained, modernised and adapted, as peoples needs change. It ensures that most of its adapted homes are available to those who most need them and is now investing additional resources to reduce the overall time that existing tenants wait for adaptation needs to be assessed. However, it needs to more robustly measure tenant satisfaction and the impact on tenants of the adaptation service and the outcomes of its local lettings scheme. The Association can demonstrate that its homes are let by giving reasonable preference to those in greatest need. Although it has worked with local authority partners to improve some aspects of its letting arrangements, it has not fully analysed and compared its various lettings schemes to help prioritise the issues it needs to advocate on, in discussion with other partners. It can therefore do more to demonstrate that routes to access housing are well publicised and customer focussed, fair and effective for the diverse communities in which it works and help to maximise outcomes in terms of individual choice and sustaining communities. Linc supports the local authority and other organisations to help prevent and alleviate homelessness. It has yet to fully assess whether it is maximising the outcomes it can achieve, in liaison with its partners, to help minimise actual or potential homelessness in the communities where it works. The Association is very successful in minimising the level of empty homes and quickly reletting its properties. This helps it to minimise the period when properties stand empty and protect its revenue. However, it does not provide applicants with a clear lettings standard and has too little feedback from which to clearly understand new tenant views. It is currently undertaking an independent survey of new residents to help it address this gap in its understanding of how well its service meets tenants expectations. 5

8 3. We manage our homes effectively The Association offers tenants security of tenure and seeks to ensure that tenants are clear on their respective rights and duties from the start of their tenancy. It aims to uphold these rights in a fair and responsible way. However, it needs to more robustly analyse the outcomes of its approach and to test whether tenants perceive the process to be effective. Linc has a good understanding of its tenants support needs and develops and adapts strategic approaches in response to identified local priorities, in liaison with partners. It has been successful in boosting peoples independence, life skills and their ability to sustain their tenancies, with many examples of this leading to more positive outcomes for service users, such as in employment and training opportunities. However, it needs to more clearly analyse the impact of the support provided by it and its partners, to determine how well this is meeting the needs it has identified. Decisions Linc makes about rent setting takes account of the Welsh Government s guidance, affordability for households on low incomes, the costs of managing and maintaining the Association s housing stock, and the need for it to be able to service its borrowings. However, it is not always proactively offering all of its tenants (who pay a service charge) a say on the nature and quality of services it provides and the charges which result. Linc can demonstrate that support it provides achieves some successes in helping people to maximise their incomes and reduce debts, including rent arrears. However, it recognises that it needs to do more to pull the different strands of the support it provides into a more co-ordinated approach, in line with its partners. It has recently developed a comprehensive strategy and has begun to take steps to deliver it, which incorporates the action it needs to take in response to Welfare Reform changes being implemented by the UK Government, to take this forward. Linc is seeking to ensure that the communities where it works feel their neighbourhoods are attractive, well-maintained and safe places to live, where they want to settle and stay. It can demonstrate successes from a proactive and preventative approach to anti-social behaviour, with some targeted approaches dramatically changing the pattern of behaviour in some neighbourhoods. This includes some examples of perpetrators re-engaging positively with their neighbours and high tenant satisfaction overall with the Association s response to problems they report. It has now started to build on this work, by developing a better understanding of residents wider perceptions of their neighbourhoods. It plans to use this information to extend its approach to investing in improvements which impact on the quality of life of tenants and their neighbours, by implementing a more comprehensive and targeted approach to its community work, across all of the areas in which it works. 6

9 4. We repair and maintain homes in an efficient, timely and cost effective way Linc has deliverable and affordable plans for the lifetime maintenance and improvement of its homes. It delivers maintenance programmes effectively, but needs to involve tenants more, to ensure that the service meets their needs in the ways in which they are planned and delivered. The Association has made significant strides in improving its repair service in response to customer feedback. It has improved aspects of both its efficiency and effectiveness, but needs to work with its tenants more closely, to ensure that they have an increasing say in decisions about its future design. 5. We provide fair and efficient services for owners Linc sells houses fairly and efficiently through Right-to-Buy and Right to Acquire schemes. However, it can not yet demonstrate that it provides fair and efficient services to shared ownership residents, as it has not engaged with them to understand and respond to their needs and expectations. 7

10 Governance and Financial Management Governance 1. We place the people who want to use our services at the heart of our work - putting the citizen first The Association is working proactively to gather information on its new and existing tenants and service users. It has good knowledge of its service users within its care arm and can demonstrate services are tailored using this data. However, this has not yet been replicated within its general needs and owned housing, though robust plans are in place for collecting and using this information over the next year. Linc can demonstrate emerging outcomes through a new shape and structure to its resident involvement arrangements. This includes improved approaches to involving customers in shaping its services, reviewing its performance and developing its future plans. However, this is in its early stages, so Linc has more to do to build on the strong foundations it has put in place, to date. This will be important to help it continue to build the capacity of its tenants to ensure effective engagement in the decision making process. The Association is developing a greater focus on outcomes for its service users. This is demonstrated in a more customer focussed approach to designing services and better involvement of residents to improve the quality of services provided. However, it needs to improve its understanding of the impact it wishes to achieve, based on a clearer assessment of the needs and aspirations of its residents, and to measure how well it is responding to their needs, from their perspective. Linc has made a number of improvements in the ways tenants can contact the service, which is starting to improve its timeliness and efficiency in responding to customer contact. However, it needs to measure its performance more effectively, to understand how well these changes are meeting tenant needs and to ensure that unnecessary contact is avoided. The Association has developed a new, comprehensive, set of service standards, together with a range of other clear information, in liaison with its tenants. This helps to ensure they have clear information about what they can expect from services and how to access them. However, it needs to measure its performance against these standards and tenant satisfaction with its communication arrangements, to ensure that its services are provided in a way which meets the standards it has set out and its tenants expectations. Linc values the views of people who use its services and can show that this has resulted in improvements to the service provided. It is making further improvements to these arrangements, by commissioning independent surveys on customer experiences of some business critical areas of the organisation. While this will help to address some key gaps in its current awareness of customer expectations, it needs to ensure more comprehensive arrangements in other areas where customer feedback is still limited. 8

11 Linc has made progress in demonstrating it is accountable, by becoming more open to challenge by its customers and partners. While this is encouraging, it needs to build on this by enabling tenants and service users to examine its activities in more depth and by providing them with clearer comparative performance information. The Association makes it easy for people to let it know when things have gone wrong. In most cases, it put things right quickly and can show that it learns from the complaints it receives to improve services. It does acknowledge however that it still needs to build on the improvements it has made, to ensure this happens in a consistent and effective way, across the service as a whole. 2. We live public sector values, by conducting our affairs with honesty and integrity and demonstrate good governance through our behaviour Linc provides information in accurate, timely and efficient way on request, only withholding this where there are clear, justifiable reasons for doing so. It has taken some positive steps to enhance its staff s ability to provide information to service users and others quickly and effectively. The Association is seeking to be open about what it does. However, it does not yet provide balanced information to its tenants and other service users to demonstrate comparative performance in a way it has agreed with them. Linc has more to do, to ensure that its activities and services are provided fairly and reflect the diversity of the communities in which it operates. It can however demonstrate positive outcomes in improving the provision and quality of housing and related services for older people in the areas in which it works. The Association has an up to date Welsh Language Scheme in place, which it can demonstrate is used in practice. However, as it has not yet collected information from all tenants on their communication preferences, it can not be sure that it is always providing information in the way tenants most prefer. Linc undertakes a range of initiatives to improve the economic, social and environmental circumstances of local communities. It works well with a wide range of partners to enhance its capacity in this respect. However, it needs to do more to understand the outcomes it wants to achieve as part of the decision making process and to more robustly measure its progress against what it has set out to achieve. 3. We make sure our purpose is clear and we achieve what we set out to do - knowing who does what and why The Association can demonstrate strong strategic leadership, which supports a clear and well informed decision making process. This has been enhanced recently, through a review of the governance structure and additional strategic capacity, to ensure this fits the changing shape of the organisation and its future business objectives. The development of managers throughout the organisation supports this further, providing visible leadership to both staff and tenants. However, Linc needs to ensure that it clearly sets out measurable indicators of the 9

12 impact it wants to achieve and to take a more active lead in demonstrating that diversity is valued within the decision making process. Its governing body exercises good control over decisions made and plays an active role in helping to ensure that decisions take into account the best interests of both the organisation and its tenants and service users. It does need to enhance some of the information used in making these decisions, including tenant views and influence, the diverse nature of communities and value for money. It also needs to ensure it sets out and measures impact more clearly, in considering how to make the best use of its resources. A positive culture permeates throughout the organisation, which helps align everyone to delivery of the Association s purpose. This encourages innovation, seeking new ideas and learning from both its own and others experiences, to enhance the services it delivers. Linc takes a proactive approach to ensuring that it has the capacity, skills and tools to deliver successfully, in liaison with its staff, tenants and partners. This is supported by Linc s planning, self assessment and performance management arrangements, though these could be enhanced by being clearer about outcomes and ensuring the robust staff, customer and partner challenge that has taken place to date, is replicated on an ongoing basis. The association has re-invested savings it has made through modern procurement arrangements into service delivery, which has resulted in a number of customer facing improvements. However, it does not always fully test whether the balance between its costs and the quality and performance it delivers, ensures value for money in service delivery and procurement arrangements across all it does. 4. We engage with others to enhance and maximise outcomes for our service users and the community The Association takes a proactive approach to partnership working as a tool to enhance the outcomes it can achieve for service users and the community. It engages well with a wide range of organisations, including local authority and community partners to provide extra capacity or expertise to deliver more than it could alone. It acknowledges, however, that it could enhance this further, by more regularly seeking to understand its partners views of how well it works with them and opportunities that may exist to improve further. 10

13 Financial Management 5. We are a financially sound and viable business Linc is a financially sound business with a robust financial management framework. It has a prudent approach to identifying, appraising and managing risks and continually reviews these to ensure they remain robust. Its activities demonstrate a high standard of financial probity. As at 30 March 2012, the Welsh Government s financial viability judgement was: Pass - The Association has adequate resources to meet its current and forecasted future business and financial commitments. 11

14 Sources of information and regulatory activity The following information is generally received from RSLs: Audited annual accounts, including the internal controls assurance statement; External auditors management letter; and Financial forecasts. In addition to the above, the following specific activities were carried out: Regulatory activity, via relationship management approach to regulation, including contact with tenants and service users, senior staff, operational staff, board members and key stakeholders; visits to some key sites; and Review of self assessment, key customer information and associated hard and soft evidence relating to the delivery outcomes. Basis of regulatory assessment This regulatory assessment is based on information submitted by the RSL, our accumulated knowledge and experience of the RSL, its management and the RSL sector as a whole. In preparing this report, the Welsh Ministers have relied on the information supplied by or on behalf of the RSL. The Directors of the RSL remain responsible for the completeness and accuracy of such information. This report has been prepared for the RSL as a regulatory assessment. It must not be relied upon by any other party or for any other purpose. Any other parties are responsible for making their own investigations or enquiries. 12

15 Key to High, Medium or Low regulatory engagement High regulatory engagement We will have a high level of engagement with the RSL where their profile indicates we need the most tailored, intensive or continuous relationship. This may mean engaging in a more sustained way with an organisation to develop a detailed understanding of current and potential areas of risk and their approach to managing them. Our engagement plan may involve a broader range of regulatory activities e.g. monitoring progress; attendance of Board, Senior Management and Tenant/resident meetings. We may also need a high regulatory engagement where specific risks are likely to materialise, or have materialised, and we need to support an organisation to improve its performance against the delivery outcomes. Medium regulatory engagement We will have a medium level of regulatory engagement with the RSL where their profile indicates we need further assurance. For example, we may need more information or a closer engagement with the organisation s senior management and/or governing body or to monitor progress against delivery outcomes and/or improvement plans. Low regulatory engagement We will have low level of regulatory engagement with the RSLs where the impact of problems occurring is low and the probability of the problems occurring is low. In these cases we will plan to have limited contact with the organisation, unless other events arise. In some cases we may highlight and monitor areas for improvement, but in ways that are less intensive for medium or high engagement organisations. 13