HCA Self-Assessment. Self-assessment against the regulatory standards 2014/15

Transcription

1 HCA Self-Assessment Self-assessment against the regulatory standards 2014/15

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3 Governance and Financial Viability Standard (Governance) Economic standard Governance Required Outcomes Registered providers shall ensure effective governance arrangements that deliver their aims, objectives and intended outcomes for tenants and potential tenants in an effective, transparent and accountable manner. Governance arrangements shall ensure registered providers: (a) adhere to all relevant law (b) comply with their governing documents and all regulatory requirements (c) are accountable to tenants, the regulator and relevant stakeholders (d) safeguard taxpayers interests and the reputation of the sector (e) have an effective risk management and internal controls assurance framework (f) protect social housing assets Key areas of compliance activity (2014/15) Building on the assurance that was provided to the Group s boards in the compliance statements for financial year 2013/14 the Group has continued to strengthen its governance activity and has prepared itself for the changes, which were implemented in the Homes and Communities Agency regulatory framework in April The Group s regulatory rating for Governance was upgraded to G1 status in October All of the future actions that were identified in the 2013/14 plan have either been completed or are substantially underway. Amongst the areas of compliance activity undertaken this year are: Changes to HCA Regulatory Framework 2015 In preparation for the changes that were introduced in April 2015, the board discussed and provided input into the HCA consultation on proposed regulatory changes in July 2014, with discussions and preparations for the likely changes also getting underway at that time. An overview of the work carried out to date and general compliance actions are set out below. A formal board and officer working party was established in September 2014 to review the performance and compliance reporting structure for the Group, along with the methodology to benchmarking reporting. The work of this group was completed in January 2015 with the board approval of a refined balanced scorecard, the introduction of a quarterly compliance report to board and a new benchmarking report. In particular the working party reviewed all areas of compliance reporting and established a new framework to monitor and report upon regulatory, financial, legal and policy compliance, which was introduced from 01 April The introduction of the revised compliance report strengthens the regulatory and legal requirement to comply with all relevant law. The working party will review the new structure in the autumn of 2015 and any appropriate operational changes to the framework will be recommended at that time. The Group commenced a review of the formalisation of its asset register in 2014 prior to the introduction of the new Governance and Financial Viability Standard and accompanying Code of Practice. Work is now well underway in reconciling the asset records for each Group company with Land Registry records and in producing asset records that are easily accessible throughout the Group. The collation of the Group s liability register has commenced and is scheduled to be fully implemented by the end of A report on the impact of the regulatory changes introduced in April 2015 was presented to the Group board in May This followed a series of ongoing discussion and dialogue both at board and officer level in preparation for the changes. A working party was established in September 2014 to review the Group s current governance arrangements and structure. There were numerous drivers for the timing and commencement of this review and these included: (a) the succession planning process in order to prepare for forthcoming retirements of non- executive directors; (b) ensuring that the skills and experience of the board are reflective and robust to implement the Group s 2020 vision; (c) learning and development from the last governance review within the Group in 2012 and also the changes implemented by the new HCA governance standard. 2

4 The working party has been facilitated by an independent consultant and recommendations for a revised board structure will be taken for board approval in September The implementation and consultation plan will then take place with formal changes anticipated to take effect from April As part of the implementation plan, the role of the Group s sub-committee structures and engagement mechanisms, both with customers and strategic partners, will be examined and appropriate changes will be implemented to streamline their process and efficiency and to maximise the use of skills and resources in the most effective ways. As part of the governance review process referred to above, the Group will work towards the adoption of the National Housing Federation model rules (2015) by March A full review of the Group s standing orders and scheme of delegation was carried out in 2014 and was approved by the board in November A further review and updating process will follow as part of the current governance review along with the Group s financial regulations. All necessary Group returns and reports to its regulator, the HCA, have been submitted accurately and in a timely manner. The Group has an established risk management framework. At the meeting of the Group Audit and Risk committee in April 2015, the committee approved the establishment of a working party with non-executive director input (together with external specialist input as shall be necessary) to review the existing framework and make such recommendations as may be appropriate to the framework. As part of the ongoing commitment to risk management within the Group, we are also holding a series of workshops and briefing sessions for staff who have responsibility for contract management, these will cover the contract and governance process, training on contractual terms and contract negotiation, contract administration and awareness of contractual risk. As part of the Group s periodic governance processes, a full report on compliance against the National Housing Federation Code of Governance was presented to the Group s Remuneration & Governance committee in May 2015 and was approved. Additionally, throughout the year the unregistered subsidiary within the Group, Key Unlocking Futures Limited has continued to review its governance arrangements. It has adopted the Voluntary and Community Sector Code of Governance and is currently working towards an action plan to ensure full compliance. During the year, the Group also reviewed its corporate Code of Conduct and streamlined its approach to the same by the introduction of one code for employees, non-executive directors and involved residents. Action plan financial year 2015/16 Complete the governance review and implement the changes and plan arising from that process by 31 March Review of the Group s strategic and business plans to take account of the recent budget announcements. Complete the corporate asset and liability project by 31 December The working party is to review the working and process of the new performance, compliance and benchmarking project by 31 December The risk management working party is to report its findings to the Group Board by April 2016 and make appropriate recommendations. Complete a review of the Group s data protection policy and procedures and implement any necessary changes by April

5 Governance and Financial Viability Standard (Viability) Economic standard Financial viability Required Outcomes Registered providers shall manage their resources effectively to ensure their viability is maintained while ensuring that social housing assets are not put at undue risk. Key areas of compliance activity (2014/15) The Group has maintained its V1 rating as last reported by the HCA in our annual viability review in March In February 2015, the Board reviewed and approved the new business plan for the Group. The Group is required to assess its compliance with the Governance and Financial Viability Standard at least once a year and the board is required to certify compliance in the annual accounts. This will be completed at the AGM in September 2015 for 2014/15 accounts. The Group is compliant with all loan covenants as at 31 March 2015, which is audited. Approval and publication of the Group s 2015 Value for Money self-assessment due to be approved by board in August Annual review and approval of the Groups Treasury Management Strategy in conjunction with external treasury advisors. To be approved at boards in August Sufficient funding is in place to support the Group s business plan in the medium term. This is reported to the board on a quarterly basis as part of the treasury management report. The Group has stress tested its long term financial plans and the board has undertaken a range of scenario planning in relation to significant risk factors or company crushers to assess the Group s resilience in this respect. This has been discussed and agreed in detail with board and work is ongoing in this area. The Group is updating its asset and liabilities registers and will conclude this work in December 2015 (see also the governance standard). Action plan financial year 2015/16 Production and approval of statutory accounts and loan covenant compliance as at 31 March 2016 including adoption of new accounting standard Final Reporting Standard 102. Production and approval of the Group s long term financial plans following budget 2016/17. Undertake stress testing of the business plan and long term financial plans and update our scenario plans to take account of the budget announcements in Resubmit the Group s Financial Forecast Return (FFR) by October Update and approval of the Group s annual treasury strategy. Maintenance of asset and liability registers. Completion of 2016 Value for Money self-assessment. 4

6 Value for Money Economic standard Required Outcomes Registered providers shall articulate and deliver a comprehensive and strategic approach to achieving Value for Money in meeting their organisation s objectives. Their boards must maintain a robust assessment of the performance of all their assets and resources (including for example financial, social and environmental returns). This will take into account the interests of and commitments to stakeholders and be available to them in a way that is transparent and accessible. This means managing their resources economically, efficiently and effectively to provide quality services and homes and planning for and delivering on-going improvements in Value for Money. Key areas of compliance activity (2014/15) Following the Group s downgrade from G1 to G2 due to none compliance with the Value for Money standard, the Group regained its G1 status in October 2014 based on the 2013/14 Value for Money selfassessment. All previous identified actions are either complete or on target. The Group has, over this period, undertaken further work to strengthen its approach to Value for Money and to remain compliant with the standard. Some of the key activities that it has delivered are: A Value for Money self-assessment and compliance statement, which was approved by board in July 2014 and published to the Group s website: An approved updated Value for Money strategy in May 2015 with focus on asset management, service costing, social value and efficiencies. Significant improvements arising from further development of the active asset management strategy with engagement from Savills; this has been discussed with board. The development of an internal service cost framework, which demonstrates the understanding of individual service cost areas and how these benchmark against a number of benchmarking groups. An independent Value for Money assessment completed on the repairs and maintenance service. The inclusion of efficiency targets as part of the long term financial plans. Action plan financial year 2015/16 To further support and enhance the Group s approach to Value for Money it will: Complete its work on its asset management strategy and actively implement the same. Develop a range of Value for Money indicators that can be reported on as part of the Group s performance reporting framework. Further develop service cost models for each of the Group s key services with service managers and benchmark these against peers and publish the results. Ensure all scrutiny reviews contain Value for Money position statements and recommendations. Continuation of the Value for Money Working Group to steer the strategy. 5

7 Rent Economic standard Required Outcomes Registered providers shall charge rents in accordance with the Government s direction to the regulator of May 2014 and the Rent Standard Guidance. Key areas of compliance activity (2014/15) The compliance statement reported to the board in 2013/14 confirmed the Group s compliance with the standard at that time. The recently updated standards and associated guidance has been addressed within the Group s approach to rent setting and long term financial planning. In complying with the standards, the Group has adopted the following approaches and actions: Each year, our Rent and Service Charge Forum meetings are held to which tenants are invited to provide an opportunity for feedback on the Group s proposals for rent and service charge increases for the following financial year. The board approved the rents to be applied for 2015/16 at its meeting on 03 February That paper set out the Group s approach to achieving compliance with the standards, whilst ensuring the financial viability of the Group. The board has approved the Long Term Financial plans ( LTFP ) for the Group that assume continued compliance with the standards as currently applied together with a steady Consumer Price Index figure. Stress testing has been carried out on rent levels, arrears and bad debts as part of the Group s stress tests and scenario planning. The Group s tenancy strategy sets out the approach to the setting of affordable rents for those tenancies that are on affordable rent terms. Statutory notices (where appropriate) and letters are sent to every tenant where rents are increased each financial year, together with guidance notes that explain how their rent and service charges have been set. Action plan financial year 2015/16 Assumptions within the Long Term Financial Plan stress testing and rent setting will be reviewed in light of the announcements by the Government in the summer 2015 budget. Review the tenancy strategy to ensure the strategy is still fit for purpose. Seek to put a Service Level Agreement in place, with the valuation agent responsible for carrying out valuations on conversion affordable rent tenancies. 6

8 Tenant Involvement and Empowerment Consumer standard Required Outcomes Customer service, choice and complaints Registered providers shall: (a) provide choices, information and communication that is appropriate to the diverse needs of their tenants in the delivery of all standards (b) have an approach to complaints that is clear, simple and accessible that ensures that complaints are resolved promptly, politely and fairly. Involvement and empowerment Registered providers shall ensure that tenants are given a wide range of opportunities to influence and be involved in: (a) the formulation of their landlord s housing related policies and strategic priorities (b) the making of decisions about how housing related services are delivered, including the setting of service standards (c) the scrutiny of their landlord s performance and the making of recommendations to their landlord about how performance might be improved (d) the management of their homes, where applicable (e) the management of repair and maintenance services, such as commissioning and undertaking a range of repair tasks, as agreed with landlords, and the sharing in savings made, and (f) agreeing local offers for service delivery. Understanding and responding to the diverse needs of tenants Registered providers shall: (a) treat all tenants with fairness and respect (b) demonstrate that they understand the different needs of their tenants, including in relation to the equality strands and tenants with additional support needs. Key areas of compliance activity (2014/15) A number of Group policies have been reviewed this year, including fire safety, pets policy, safeguarding, tenant match funding, customer choices, under occupancy, anti-social behaviour, income collection, tenancy strategy and allocations. All policies and strategies are reviewed in consultation with tenants. A review of service standards has been completed, reducing the numbers that the Group publishes and monitors from one hundred and ninety three (193) to twenty one (21). The published estate standards document provides customers with a range of information specific to local services in their community. Following consultation with tenants, a new approach to scrutiny has been adopted that creates a pool of tenants who will be drawn upon to undertake scrutiny reviews and other scrutiny activity. Complaints and feedback have resulted in additional customer care training for staff across the organisation as well as a change in the time taken to carry out repairs on white goods for supported living tenants. Two thousand one hundred and sixty eight (2168) tenants have been involved in tenant engagement and empowerment opportunities with forty two (42) active tenants carrying out tenant inspections. Over the last twelve (12) months, the Scrutiny Pool has conducted six (6) service area reviews, which looked at some key delivery areas that include: under occupancy support, repairs, anti-social behaviour, allocations, accessibility and estate management. Following these 7

9 reviews, thirty (30) recommendations were made of which twenty nine (29) have been actioned with the one (1) remaining recommendation to be completed with the introduction of the new website org.uk scheduled for September The Group has recently commissioned a piece of work by Human City Institute to assess allocation of properties to the Black Minority Ethic Group in our areas of operation. Performance reports presented to tenants were reviewed with the communications panel and Forum to improve the layout and presentation of information. Action plan financial year 2015/16 Mobile working will enhance customer service and choice for our customers by providing instant response to enquiries on a face to face basis. Enquiries will be dealt with through Progress Connect with the aim of providing an improved response, demonstrating first point of contact resolution. The Group is updating its website and this will provide a range of enhanced services to our customers such as: the ability to access tenancy specific information via separate sections for general needs, independent living and supported living tenants ability to search through our current void properties improved access to our policies and performance information. This is expected to be available at the end of August 2015 and has been done in full consultation with the tenant s communication panel. Customers to be consulted on the range of opportunities to become involved in governance and scrutiny by September Develop a strategic response to Human City Institute s recommendations by October Tenant s annual report will be published by October

10 Home Consumer standard Required Outcomes Quality of accommodation Registered providers shall: (a) ensure that tenants homes meet the standard set out in section five of the Government s Decent Homes Guidance and continue to maintain their homes to at least this standard (b) meet the standards of design and quality that applied when the home was built and were required as a condition of publicly funded financial assistance, if these standards are higher than the Decent Homes Standard (c) in agreeing a local offer, ensure that it is set at a level not less than these standards and have regard to section six (6) of the Government s Decent Homes Guidance. Repairs and maintenance Registered providers shall: (a) provide a cost-effective repairs and maintenance service to homes and communal areas that responds to the needs of, and offers choices to tenants, and has the objective of completing repairs and improvements right first time (b) meet all applicable statutory requirements that provide for the health and safety of the occupants in their homes. Key areas of compliance activity (2014/15) Building on the assurance that was provided in the compliance statements for the financial year 2013/14, the Group has continued to strengthen its position in complying with the HCA Homes Standard. The Group s investment in its existing stock ensures that all homes meet the Decent Homes Standards. New design briefs have been introduced for general needs and supported living properties that update our standards for new build properties. The Group s responsive repairs service continues to deliver an effective service. All targets for responsive repairs completions were exceeded during 2014/ % of all repairs requests were completed within the target timescales. The Right First Time Target is currently not being met. We believe this is a result of the complexity of the current system and inconsistency in its implementation. This will be addressed by new methods of working when the new IT system is introduced. A recent independent benchmarking review provides assurance on the Value for Money of our property expenditure with most falling into the lower quartiles compared to other housing associations (e.g. cost per repair). The review and development of the Group s Asset Management Strategy, supported by external consultancy has continued during 2014/15. Board have approved an interim guidance document titled Strategic Asset Management Principles. Following approval of this interim guidance document, Board has received an evaluation of the first phase of the evaluation of the financial and social performance of the stocks contribution to the Group s business plan. The board will receive a report on the current position in August The Group s management of its construction compliance activities continues to strengthen. Key changes include: A new compliance team has been established The asbestos policy has been reviewed and approved The asbestos inspection program is ahead of target A new database to support the improved management of fire safety risk assessments and implementation of recommendations Positive report on the management of Legionella responsibilities from an audit completed by an external specialist consultant Actions arising from the Legionella risk assessments on supported housing are being implemented The auditing of technical and procedural compliance of external gas works contractors has been strengthened 9

11 An internal audit of gas safety management identified one Landlords Gas Safety Record that was out of date. This was due to an IT system issue. A gas safety check was immediately carried out and immediate measures were implemented to ensure this was an isolated incident and provide assurance that gas safety management procedures are effective. Action plan financial year 2015/16 Action plan arising from the Asset Management Strategy to be produced and implementation to be commenced by August This will be reviewed in 12 months by August Undertake further benchmarking to assess the cost and quality of services. Complete the gas safe management project by ensuring all properties are recorded on the housing management database ( QLX ) by June 2015, (completed). Scrutiny review of the aids and adaptation service. 10

12 Tenancy Consumer standard Required Outcomes Allocations and mutual exchange Registered providers shall let their homes in a fair, transparent and efficient way. They shall take into account the housing needs and aspirations of tenants and potential tenants. They shall demonstrate how their lettings:: (a) make the best use of available housing (b) are compatible with the purpose of the housing (c) contribute to local authorities strategic housing function and sustainable communities There should be clear application, decision-making and appeals processes. Registered providers shall enable their tenants to gain access to opportunities to exchange their tenancy with that of another tenant, by way of internet-based mutual exchange services. Tenure Registered providers shall offer tenancies or terms of occupation which are compatible with the purpose of the accommodation, the needs of individual households, the sustainability of the community and the efficient use of their housing stock. They shall meet all applicable statutory and legal requirements in relation to the form and use of tenancy agreements or terms of occupation. Key areas of compliance activity (2014/15) The Group s allocations policy and under occupancy policy contribute to local authorities strategic housing function and sustainable communities by providing clear application and mutual exchange processes, which are consistently reviewed to take into account legislative changes. Mutual exchange services are publicised through the website, org.uk, tenants newsletters and in general advice given to customers. The Group reimburses costs for tenants wishing to join another scheme to move into an area not covered by the Choice Based Lettings scheme. The Group receives nominations to supported living vacancies from local authority service commissioners and support providers. Section 106 agreements are negotiated on applicable sites to support local authorities strategic housing function. The Group works in partnership with local authorities to provide interim accommodation for families, single homeless people and women fleeing domestic abuse to help with homeless duties. In the year, a total of one hundred and seventy eight (178) referrals were received from women escaping domestic abuse, of which thirty six (36) were accommodated at South Ribble Women s Refuge. Of the remaining referrals, 45% were not accepted due to the unavailability of accommodation at the time. Short term supported accommodation was provided for forty five (45) homeless people at Foundations/Inn2 in Preston and twenty three (23) young single homeless people were accommodated during the year at The Bridge in Chorley. The Group s allocations policy addresses underoccupation and overcrowding by enabling tenants to make appropriate choices. The Group employs an Under Occupation Officer who supports tenants who are under occupying by offering assistance to downsize through the Under-occupation policy. We have assisted one hundred and forty one (141) tenants to move as a result of under occupation, with fifty three (53) direct matches being made. The Group delivers a shared housing pilot in Central Lancashire and will consider roll out, dependent on success of the pilot. The Group s Choice Based Lettings policies provide common housing registers. Actual and potential tenants are supported in the allocations processes through the Choice Based Lettings policy, Customer Charter and Service Standards. Contact is made with non-active bidders to offer assistance. Additionally, an equality and diversity review of the allocations has been commissioned to demonstrate how the Group meet the needs of minority groups in allocation of properties. The Group has introduced voids plus to assist in the improvement of void turnaround times as well 11

13 as continuing with continuous improvement team meetings. This work is ongoing along with whole business target focus group in this area amongst others. Property services staff have increased resources to address the length of void time with repairs. The Group records all lettings and sales; all Continuous Recording of lettings and sales logs ( CORE ) are completed and co-ordinated through identified business leads. Progress Connect (the Group s customer services) supports tenants wishing to move by providing clear and relevant advice by way of leaflets and referrals to local authorities as appropriate. Tenants who do not have access to the internet are supported by way of Tenant Zones at both Warwick House and Sumner House. Our digital futures project is ongoing with our digital champions assisting over one hundred (100) tenants get on line. The Group also provides community based access to computers. The Group has reviewed the tenancy strategy to set out how properties are allocated and what tenancy agreements will be used. Discretionary succession rights are managed by the Succession Policy. The Group offers periodic secure or assured tenancies. The only occasion in which fixed term tenancies are used are for mortgage rescue properties, where a fixed term of 5 years is offered with a period of review etc. An annual audit is completed in relation to tenancy fraud to ensure that accommodation is occupied by the tenant in accordance with the relevant tenancy agreement. The Group has a financial inclusion team to support tenants through financial hardship. Progress Futures offers assistance to tenants to access education, employment and training. Progress Futures has assisted sixty nine [69] tenants into education, employment and training. Action plan financial year 2015/16 The Group s sheltered housing review is ongoing with consideration being given to potential change of use for some stock. Website improvements ( scheduled to be upgraded in September 2015) will assist with accessibility. The voids Whole Business Target project group continues to review and identify service improvement areas, which will include a lean systems review of voids. Mobile working due for implementation in September 2015, will assist with a more robust approach to verifying tenant identity. Financial inclusion policy to be reviewed by September

14 Neighbourhood and Community Consumer standard Required Outcomes Neighbourhood management Registered providers shall keep the neighbourhood and communal areas associated with the homes that they own clean and safe. They shall work in partnership with their tenants and other providers and public bodies where it is effective to do so. Local area co-operation Registered providers shall co-operate with relevant partners to help promote social, environmental and economic wellbeing in the areas where they own properties. Anti-social behaviour Registered providers shall work in partnership with other agencies to prevent and tackle anti-social behaviour in the neighbourhoods where they own homes. Key areas of compliance activity (2014/15) The Group s place management strategy determines our approach to neighbourhood management and takes account of the Group s impact in areas where we hold property. Provision of caretakers and regular estate walkabouts ensure compliance with the Neighbourhood management standard. The Group s portfolio of Supported Living have a separate place management strategy. Estate standard leaflets are in place and are under constant review with tenants (ongoing) in general needs and independent living. The Group promotes area co-operation through regular liaison meetings with local authorities through various forums, attendance at Police and Communities Together meetings ( PACT ) and parish council meetings. An audit of health and wellbeing activity has been completed to contribute to wider healthier Lancashire aims; work is ongoing in this area. There is a Health and Wellbeing strategy in place, which supports customers. Additionally a Health and Wellbeing toolkit is used at tenant meetings within supported living. The Group has environmental funds available to improve areas based on tenant demands and items identified through the sustainability review. This includes creating additional parking provision, security lighting and fencing. The Group s anti-social behaviour policy incorporates partnership working. In 2014/15 the Group, working in partnership with local statutory and voluntary agencies such as the Police, local authorities, Probation and Social Services, have dealt with five hundred and nine (509) reports of anti-social behaviour, in line with externally accredited policies and procedures. As a result, high satisfaction levels have been achieved from victims and witnesses for the way their reports of anti-social behaviour have been dealt with by the Group. Tenants are made aware of their responsibilities via: anti-social behaviour leaflets service standards tenant handbook tenant training the Group s website: their tenancy agreement. Representatives of the Group participate actively in community partnership meetings. Anti-social behaviour can be reported in a number of ways twenty four (24) hours per day and three hundred and sixty five (365) days per year. Anti social behaviour has been subject to a scrutiny review, following which recommendations were made and actioned. An example of one of the recommendations was the provision of in-house surveillance and audio recording equipment to obtain evidence. The Group has a tailor made witness support programme offering support twenty four (24) hours a day and three hundred and sixty five (365) days per year. This programme has achieved 100% satisfaction for the service. 13

15 All one hundred and twenty three (123) level one complainants were offered the support of the Witness Support Service. The community safety team referred thirty seven (37) customers for this service during 2014/15 and twenty nine (29) customers accepted this service. The Group also offer a twenty four (24) hour lifeline connection to our internal control centre. Twelve (12) witnesses accepted this offer, which is an increase of 100% on last year s figures. The Group achieved the HouseMark Accreditation for our anti-social behaviour service in August 2012, which lasts for a period of 3 years. Action plan financial year 2015/16 A scrutiny review of information provided to tenants in relation to service charges is due to complete in July The Place management strategy to be rolled out Groupwide by November Health and wellbeing champions for the business being considered for tenants and staff (level 2 awards for understanding health improvements). Website review ( scheduled to complete in September 2015) will make reporting of anti-social behaviour easier for customers. Mobile working will enable improvements to the way in which we deal with anti-social behaviour. 14

16 w: e: t: Sumner House, 21 King Street, Leyland, Lancashire PR25 2LW LinkedIn: Progress Housing Group Facebook.com/ProgressStreetTalk Facebook.com/ProgressPeople Progress Housing Group Limited is a Co-operative and Community Benefit Society registered with the Financial Conduct Authority No R and with the Homes and Communities Agency LH4189. VAT registration number Registered office for the Group and all subsidiaries: Sumner House, 21 King Street, Leyland, Lancashire, PR25 2LW