Written evidence submitted by believe housing [RSH 041]

 

  1. How widespread and serious are the concerns about the quality of social housing?

There are some concerns from some social housing tenants however these are not present in the wider public consciousness. The condition of some properties it would appear are unacceptable.

Some providers are not sufficiently aware of the condition of their own stock and the issues their customers face. However, this is not the case for all providers and it is important not to tarnish the sector as a whole.

 

  1. What is the impact on social housing providers’ resources, and therefore their ability to maintain and improve their housing stock, of the need to remediate building safety risks and retrofit their homes to make them more energy efficient?

There is a significant impact on social housing financing in maintaining their stock and retrofitting homes and this has been exacerbated by the impacts of Covid, Brexit and rising prices (materials, labour, staff time, trades skills shortages fuel etc).

 

  1. Is the current regime for regulating social housing fit for purpose?

The economic (governance and financial viability) standards are much more prescriptive and so they offer a more robust assurance. The Consumer regulation standards are not fit for purpose as they can be open to interpretation and are not regulated, however we would also have caution against overly prescriptive standards that do not allow landlords to focus on delivery which meets the needs of the communities they serve.

NROSH+ could be more streamlined and user friendly -inconsistencies between the returns, guidance documents overly complicated and difficult to understand.

 

  1. How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?

The Housing Ombudsman has become a lot more active in recent months in terms of learning, publishing reports and taking a more proactive role.  Currently, changes to the Regulator’s powers and role in relation to consumer standards have not yet taken place but it will be important when they do that the two organisations’ roles are very clearly defined, particularly from a customer point of view.

 

  1. Does the current regime allow tenants to effectively resolve issues?

Housing Ombudsman have become quicker at investigations and working with customers and landlords to try and resolve issues but this still takes longer than you would like.  This means that issues can be ongoing for a long period of time.

Repairs and complaints pocesses can be overly complex and customers are unable to navigate them easily

 

  1. Do the regulator and ombudsman have sufficient powers to take action against providers?

Yes, the regulator can downgrade an organisation however their emphasis is more strategic than operational. The ombudsman’s Complaints Failure Orders should improve the situation but Ombudsman still reporting landlords that fail to comply.

In terms of compliance there is a reliance on self-referring

 

  1. Will the reforms proposed in the social housing White Paper improve the regime and what progress has been made on implementing those reforms?

The proposed reforms will improve things however it will take time to embed these changes – Progress has been made on implementing them.

At government level this appears to have lost impetus due to the emphasis on the response to Covid

 

  1. What changes, if any, should the Government make to the Decent Homes Standard?

The standard is a minimum and is no longer fit for purpose. The sector should not need to be told to provide decent homes and the DH programme has become a tick box exercise. Guidance should be a whole house approach which references modern living standards.

 

  1. Should the Decent Homes Standard be amended to include energy efficiency and other means of mitigating climate change, and if so how?

Yes – to make it more comprehensive and to future proof it going forward.

How will compliance with the amended decent homes standard be funded – the sector needs assurances on grants to allow it to fund and deliver improvements under the new standard as they lack the capacity in their business plans.

  1. Should all providers of social housing, not just councils, be required to register with the regulator?

Yes – to aid consistency through the sector as a whole for the benefit of tenants

 

  1. What challenges does the diversification of social housing providers pose for the regulatory system?

The range of new products and services can fall outside of the existing regulatory regime.. Due diligence of diversification opportunities is essential.

 

December 2021