Unveiling Insights from Consumer Regulatory Trials
In June 2023, the Regulator for Social Housing (RSH) conducted consumer inspection copilot with housing associations and councils. The primary focus of these copilot was safety and data integrity, encompassing health and safety compliance, stock condition information, damp and mould, and safeguarding.
The copilot also highlighted the importance of customer insight and equality data in understanding tenant experiences. The RSH is currently testing different ways of hearing from tenants, with some copilot organisations suggesting that more of this should be incorporated into the settled methodology.
One challenge faced during the copilot was the interpretation of requests due to differences in terminology and structures compared to the housing association sector. Local authorities experienced more difficulty in this regard.
Differential experiences were noted in terms of the triangulation that copilot organisations saw play out, with expectations that the methodology will continue to develop. There were differences in the level of detail requested among copilot organisations, requiring some interpretation of the document request.
The RSH is developing an approach for assessing social landlords' compliance with new consumer standards. This approach will be published later in 2023. Copilot of engagement strategies is encouraged, as 'scrutiny' does not need to look the same in every organisation.
The focus is on the assurance received by Boards and Councillors, rather than on the services and homes themselves, aligning with the copilot approach taken by the Regulator. Involved tenants provide valuable insight, but it's important to consider who is not being heard.
Strong tenant engagement is seen as crucial, with tenants being the biggest advocates for organisations. Robust, evidenced self-assessment against new consumer standards should be part of 'business as usual' and involve heads of service.
The Tenant Satisfaction Measures (TSMs) are considered valuable for starting conversations and identifying patterns in dissatisfaction. Assembling a comprehensive assurance framework spanning all activities and having clear plans to address gaps in assurance may lead to a good inspection outcome.
'External assurance' (i.e., independent checks and advice) is important in demonstrating openness to challenge and a continually developing understanding of what 'good' looks like. The Regulator's focus is on the responsibility of senior leaders to obtain assurance that key things are happening as they should be, including through Board/Council papers and information.
In June 2023, a roundtable was convened by Campbell Tickell with senior leaders from housing associations and councils who participated in the consumer inspection copilot run by the RSH. The experiences of the copilot organisations have been overall positive, with the copilot aiming to cover the breadth of consumer standards appropriate to each subject's risk profile.
The inspection process will continue to evolve as the Regulator learns and develops its approach, but the lessons described above are expected to remain relevant. From April 2024, the RSH's approach to compliance with consumer standards will change under the Social Housing Regulation Bill.
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