The HQN guide to inspection

Over the past two years, HQN has been helping social housing providers navigate the new regulatory landscape, including the return of inspection for the first time since the days of the Audit Commission.

We take a deep dive into HQN’s approach, providing a step-by-step guide to inspection, top tips on what we think the regulator is looking for, and the different ways HQN can support organisations through the process. We also hear from some of the councils and housing associations about their experiences and the help HQN has provided.

To kick things off, Alistair McIntosh shares his thoughts on inspection and provides some top tips for success, drawing on his knowledge of how the regulator operates as well as HQN’s own consultancy work.

“When I looked at our performance reports properly, I realised they couldn’t possibly be right.”

Those are the exact words of a highly respected housing association chief. He phoned me up just after the old-style inspectors had visited. Yep, he got zero stars – a rock bottom score. As with any test you must go into it with total commitment and 100% concentration. That lesson is as true today as it always was and always will be. You might have got C3 or C4 due to historic lapses. It won’t wash the next time.

HQN takes a strong line on inspection. We pushed for it to come in under New Labour to reverse the damage done by Thatcher. And we predicted the chaos that would follow when Grant Shapps abolished the regime. Frankly, you didn’t need to be a genius to see what was coming down the track.

We’ve worked with associations, councils and almos that ran the gamut from C1 to C4. Here are the tips we would pass on.

Nuthin’ but a ‘G’ thang

The Regulator of Social Housing (RSH) looks at everything through the prism of governance. Yes, I know councils don’t get G ratings but bear with me. The RSH insists that the governing body – be it a board, cabinet or mayor – is on top of things. What does that mean? The inspectors will check that your leaders:

Understand precisely how you’re faring on the consumer standards
Own the improvement plan
Ask the right questions at the right time.

So, you need to explain how your governance works. Associations have been doing this for years so they should know what to do. But it’s a new world for councils.

Produce a clear diagram that nails down who does what and where the big risks sit. Show how your leaders get assurance. Many councils are setting up advisory boards with residents and experts. That can play well with the RSH. But do lay out the nuts and bolts of how the board supports the council to meet the standards. Don’t just rely on ‘Galacticos’ with stellar CVs. The RSH team will read your papers and attend meetings as the proof of the pudding.

“The more we look, the more we find”

The RSH insists that you must have up-to-date accurate stock condition survey data for all homes and common parts. That explains why landlords procured over £40m of stock surveys last year. If you don’t hold good data here you’re looking down the barrel of C3 or C4. Put simply, you don’t know if your homes are safe and you have no idea if there’s enough cash to maintain those homes. Problem is that the survey can throw up the need to spend more than you had planned to. Bitter experience tells us that ignorance isn’t bliss.

These surveys are an important way of proving that homes meet the Decent Homes Standard. C1 landlords will have very low rates of non-decency – two recent cases coming in at 0.09% and 2.4%.

“Produce a clear diagram that nails down who does what and where the big risks sit. Show how your leaders get assurance”

Safety fast

The RSH needs to be certain that you’re checking safety risks across the ‘big six’ of gas, fire, electrics, asbestos, legionella and lifts. But they won’t just take your word for it. The RSH expects to see:

Third party validation from technically qualified professionals
Intelligence-led sampling of risks. Tell the inspectors what you did with these reports. Have you fixed any defects?

Take off the ‘big six’ blinkers. What are you doing about other risks such as trees, electric bikes, car park gates etc etc?

Works like a Swiss watch

Some landlords tell us they were on the cusp of C1. But the reliability of the repairs service held them back. Do you complete the lion’s share of works on time? That’s what the tenants want, and so too does the RSH.

“Wes Streeting wants to tie hospital funding to patient ratings. Will we see this in housing? It would certainly bring much of shared ownership to a grinding halt given the ratings we see there”

“Landlords must listen, hear and act”

That’s what a tenant said to me at yet another meeting on consultation. Yes, it sounds obvious. And it is. But as we bounce from policy to policy and fad to fad, we can lose sight of the basics.

So far, the RSH teams have stuck to the task and seek evidence that:

You’re tailoring services around the actual requirements and vulnerabilities of your residents
Shows the tangible impact of resident consultation
Explains how you apply the lessons from reports from the ombudsman and experts (and member’s enquiries at councils)
You undertake root cause analysis (that phrase comes up a lot) of problems with plausible improvement plans.

Now we’ve a second year of satisfaction TSMs, the RSH may take an interest in:

Your trends in satisfaction
How satisfaction breaks down amongst different groups of residents
How you compare to peers
The actions you take to dig into the reasons for low satisfaction with the follow-up actions.

“You never get a second chance to make a first impression”

At the start of every inspection, you can present your case to the RSH team. Don’t waste this opportunity. You can talk for 15 minutes – somebody, somewhere at the RSH must be a fan of Andy Warhol.

Our advice is to try and write the inspection report for the RSH in this slot. That proves you are self-aware. Honesty makes life easier for everyone. Areas to cover include:

How the standards are governed – who does what
Context – explain demographics and counter myths (eg, facts to disprove any notion you work in an easy leafy area)
Accuracy of data – sources of assurance such as stock condition survey, professional pollsters and third party technical experts (beware: the RSH know all the tricks to boost satisfaction)
Areas of strong and weak performance – with a summary of how you’ll improve
Examples of impact of resident engagement
Before and after – photographs of estates/homes that have been improved. (The RSH will not visit estates – so you must paint pictures for them.)

This presentation will be a distillation of material from your self-assessment, mock inspections and improvement plans. Test it out by using it to brief the senior people the RSH will interview. Start early – remember the old adage: I wrote a long report because I didn’t have time to write a short one!

“At the start of every inspection, you can present your case to the RSH team. Don’t waste this opportunity. You can talk for 15 minutes – somebody, somewhere at the RSH must be a fan of Andy Warhol”

Words of warning

Make sure all improvement plans are SMART – Specific, Measurable, Achievable, Relevant and Time-bound. Check the facts behind RAG ratings. These are often weak
Some of the improvement plans landlords have volunteered to the RSH are, how can we put this, ambitious. It’s hard to see whether these will ever be delivered. New management teams can be guilty of promising the earth – keep it real or you’ll be in meetings with the RSH for eternity
If you’re not complying with the standards, talk to the RSH – in serious cases a timely self-referral can be the difference between scoring C4 or a more respectable C3
Plan for the future – what difference will Awaab’s Law and a revised Decent Homes Standard make?
Think carefully about how you’ll meet the standards if you’re working on a merger or setting up a new service via local government re-organisation
Watch for the curveballs.

Wes Streeting wants to tie hospital funding to patient ratings. Will we see this in housing? It would certainly bring much of shared ownership to a grinding halt given the ratings we see there.

Plans for mergers and the new unitary councils will assume big savings from AI. Will AI work better than previous tech? Watch this space!

Category: Features