The government has published a consultation on its social housing rent policy from 2020.

The document reflects the government announcement in October 2017 of the intention to permit registered providers to increase their rents by up to CPI+1% each year, for a period of at least 5 years.

For the first time, the government intends to direct the Regulator to apply its rent standard to all registered providers – i.e. to both local authority registered providers and private registered providers.  Bringing local authority landlords within the scope of the RSH rent standard will respond to the roll out of Universal Credit.

The consultation also proposes changes to how “formula rent” is calculated and the rules around affordable rent – such as preventing social landlords from resetting annual rents by more than CPI+1% when re-letting a home to the existing tenant.

In its assessment of the impact of the new rent policy, the government states “Five policy options were considered ranging from permitting an annual increase of up to CPI+2% through to the continuation of the 1% rent reduction.  The preferred option is CPI+1%. This option is neutral in terms of delivery of affordable homes”.

The new policy will come into effect from 1 April 2020. It will not override landlords’ statutory obligation to complete the four year social rent reduction as required by the Welfare Reform and Work Act 2016. Where a landlord has not completed the social rent reduction by 31 March 2020 (because its rent year begins after 1 April), it must complete the reduction before the applying the new policy.

The consultation available here closes on 8 November.  If you are responding to the consultation, it would be helpful  if you could provide us with a copy of your consultation response to help with our deliberations.

Along with the rest of the sector the Northern Housing Consortium had been anticipating the publication of a Social Housing Green Paper for some time.  So, when the document was finally released on 14^th August, it was important for the NHC to bring members together and take full advantage of the opportunity to give detailed feedback to Government on what the Secretary of State described as a “landmark opportunity for major reform”.

Consultation Roundtables were arranged for each region of the North which drew around 50 attendees.  Karen Brown, Senior Policy Adviser at the Northern Housing Consortium provided an update on the Green Paper and highlighted that the door was now open for considerable debate on a range of issues – empowering residents and tackling stigma, resolving complaints and ensuring homes are safe and decent, through to expanding supply and development opportunities.

The evidence collected will be used as the basis of the NHC’s response to the Green Paper and members provided many points of discussion.  Organisations were keen to emphasise the work that is consistently completed to ensure homes are safe and to meet the Decent Homes Standard.  Overall the feeling was that health and safety regimes are robust; the issue at hand was more about ensuring consistency and clarity in the regulations which are currently complex and contradictory.    On mediation and resolving disputes, some members felt that, while there have been consistent improvements, that this is an opportunity to look at all good practice but that changes need to be proportionate and to manage expectations.   Considering the Government’s proposals on Key Performance Indicators (KPIs) to be published through League Tables, members felt that the implementation and use of a basket of measures would be most usefully linked to improvements measured through a structured plan so that outcomes were transparent for residents.  Some of the indicators proposed will be difficult to measure and a more nuanced and partnership approach may be required.  There was consensus that KPI’s would be affected by local circumstances and this would have to be sufficiently taken into account.

The meetings reflected the NHC’s earlier assertion that there is much in the detail that is welcome: the focus on decent homes, thriving communities and reversing the decline in council housing all of which reflect calls the NHC has been making for some time.  There are of course areas that may be of concern in the Green Paper and it will be interesting to see how the proposals on a new regulatory framework, the funding for supply of homes for social rent, and continued emphasis on home ownership are all evolved.

The Government has stated that it intends that the Green Paper will generate “a nationwide conversation on social housing”.   Through these roundtables and other engagement, the NHC is  working with politicians and civil servants to ensure a strong Northern voice is part of this conversation.  We would encourage our members to engage constructively in the debate that follows the Green Paper.

One area of interest contained in the recently published Social Housing Green Paper was the renewed focus on neighbourhood management and addressing anti-social behaviour as a core component of the ‘new deal’ between tenants and landlords.  This work has always been vital and respected as such by social housing providers, yet it was notable to see that alongside ensuring properties were in good repair and buildings were structurally safe was the announcement that the Government were considering introducing a key performance indicator (KPI) covering neighbourhood management “responsibilities” as well as a KPI that will “help tackle anti-social behaviour” (ASB).

The Social Housing Green Paper proposes separate KPI’s for ASB and neighbourhood management, both underpinned by obligations set out in the Neighbourhood and Community Standard.  Excluding ASB, the Standard requires registered providers to not just maintain but improve the neighbourhoods where their homes stand.   In keeping areas ‘clean and safe’, landlords should consult with tenants and work with partners in ‘promoting social, economic, and environmental wellbeing’. Landlords should work to appreciate their role in communities and outline the positive impact they can and will make.

A central tenet of the Neighbourhood and Community Standard is the landlord’s duty to prevent and tackle ASB.   There is again a strong emphasis on “local area cooperation” and working in partnership with various agencies.  Between stakeholders there is a clear need for a joint understanding on each other’s roles and responsibilities.  Within this eco-system though, it is the landlord that must demonstrate “strong leadership, commitment and accountability” in addressing ASB “promptly, appropriately, and decisively”.

It is in dealing with complaints where the Green Paper shows concern. “Some residents were concerned that their landlords were not taking appropriate action to tackle anti-social behaviour. Residents told us that they felt their concerns were not taken seriously or were resolved too slowly.”  Additionally, In the much-vaunted section addressing the stigma felt by social housing tenants, a good proportion of the Green Paper is dedicated to the stigma borne out of interactions with landlords themselves. “Too many residents felt they were treated with contempt by their landlord – that they were spoken down to, or treated as a nuisance.”

In thinking about how these KPI’s could be gathered and presented, the Green Paper puts forward the NHS ‘Friends and Family Test’ as a blueprint.  Operational since 2012, the test is based on the premise that patients (or tenants in this instance) have the right to participate in giving feedback as a standard part of their interaction with a service.  This feedback is gathered in as close to real time as possible and is a staple of every interaction; not a one-off survey or annual comms project.  Results are gathered by and published locally by NHS England for users to “inform their decision making” and for organisations to “highlight practices that lead to good experiences and where improvements could be made”.

In our ‘On the Day Briefing’ covering the Green Paper the Northern Housing Consortium queried whether KPI’s  and league tables could prove to be a too simplistic way of ranking services: “It is important that any measure doesn’t provide an incentive to make it difficult for tenants to register complaints if it means that those encouraging honest feedback find themselves languishing at the bottom of a league table.”  Indeed, and especially in relation to tackling ASB, landlords will be all too aware of the balance between resolving complaints swiftly, but also correctly and to the long-term benefit of their tenants and neighbourhoods.  The Government however does appear to appreciate these concerns, and as part of the consultative Green Paper outline they will need to “consider how [the KPI’s] could impact on areas, and whether it could lead to some people feeling more stigmatised.”

The NHC have invited members to a series of roundtables to help formulate a collective response to the Social Housing Green Paper, these meetings can be viewed and booked onto here.  The Neighbourhood Management and ASB specific questions, listed below, will be considered by the next meeting of the Safety in Neighbourhoods Network which will also be focussing on partnership working between housing associations, local authorities, and the emergency services.

• What key performance indicator should be used to measure whether landlords are providing good neighbourhood management?
• How are landlords working with local partners to tackle anti-social behaviour?
• What key performance indicator could be used to measure this work?

The next Safety in Neighbourhoods Network will meet Monday 1^st October 2018, 13.00 to 15.30, at Yorkshire Housing, Leeds.  The network is free to attend for NHC members,  follow this link to register your place.