The Social Housing White Paper, and its predecessor green paper: a new deal for social housing, came about in part as a response to the tragedy at Grenfell on 14 June 2017. The fire which ripped through an apartment block in North Kensington, London, caused 72 deaths, in one of the deadliest structural fires in recent UK history; shining the light on building regulation, resident safety and social housing provision at large.

In the wake of the event, facing criticism over housing policy, the government began a review of social housing provision, publishing the social housing green paper in August 2018. This consultation with housing providers and housing organisations sought views on the government’s vision for “social housing providing safe, secure homes that help people get on with their lives”. Collecting feedback to enable the creation of an impactful social housing white paper with a likely new regulatory framework.

The Social Housing White Paper is due to be published in 2020, and when it arrives – IFF Research is your source for news and information on how it will impact your world.

Register to receive your Guide to the Social Housing White Paper today.

Why is the white paper important?

The Social Housing White Paper, and regulatory changes stemming from its recommendations will represent the widest sweeping changes in social housing since the Homes and Communities Agency was replaced by both Homes England and the Regulator for Social Housing in January 2018. This new (anticipated) regulation will be tied to development funding for housing providers.

What is the white paper likely to mean for the social housing sector and residents?

For the social housing sector, it will (likely) mean new regulatory requirements in terms of:

  • Building safety
  • Fire safety
  • Changes to how complaints are handled, both on a formal and informal basis
  • Greater transparency of performance data for residents and the public
  • Reporting of KPIs to the Social Housing Regulator, and linking that to funding for the Affordable Homes Programme
  • Increased choice for tenants in terms of governance, repairs contractor, or raised profile for forms of local governance, like community housing associations
  • Updating Decent Homes standards
  • Increasing housing supply
  • Exploring new models; and supporting existing models to increase homeownership

In addition to the new regulatory requirements, there may be a code of practice related to tackling stigma and empowering residents.

In addition to this new framework set out by MHCLG, the green paper consultation also touched on a range of concepts and proposals to aid governance, accountability, and oversight, including a National Tenant Voice and transparency of performance data. The latter suggests the introduction of league tables, bringing some trepidation within the sector.

Impact to residents

For residents, the impact of some of the themes will be significant, for example, replacing cladding in a high-rise will be disruptive.  For other themes, such as the update to the complaints process, it may not make a difference in their day-to-day lives. Overall, there will likely be some additional initiatives, as well as specific powers devolved to individual residents, for example:

A focus on safety – The Hackitt Review and the pending Social Housing White Paper will likely call for all cladding that does not meet fire safety standards to be replaced as a top priority.  In addition to replacement cladding, residents could see sprinkler systems, signage, and increased training and awareness on fire safety.

Increased voice – the Social Housing Green Paper echoes the Grenfell tragedy, with the call of residents for improved fire safety going unheard.  A top priority is to remedy that, so that disaster is never repeated.

“[People living in social homes] feel ignored and stigmatised, too often treated with a lack of respect by landlords who appear remote, unaccountable and uninterested in meeting their needs. It’s a situation the residents of Grenfell Tower have spoken about in powerful terms, not just in the wake of last year’s tragedy but also in the months and years before – only for their voices too often to go unheard.” – Social Housing Green Paper Foreword from Prime Minister Rt. Hon Theresa May

Improved visibility – to understand how a landlord is performing against their own key performance measures, and any set by the regulator.  Residents should also be able to see other landlord performance measures and be able to make comparisons easily.

A rebalanced relationship with their landlord – dealing with issues and opportunities with mutual respect, and a locally agreed offer; a set of rights and responsibilities to one another.

New governance structures and oversight – these may take the form of a Tenants Charter, a National Tenant Voice, or new local resident scrutiny boards. In any case, residents will be made aware of opportunities to have their opinions heard and to understand the impact these new governance and oversight bodies have; including getting involved themselves.

Faster, more streamlined complaints – with the proposal to remove the democratic filter, it’s likely that complaints will be resolved faster.

Greater emphasis on emotion and sentiment – the concept of stigma is complex, rooted in prejudice, perceptions and feelings.  Landlords could be expected to understand how their services are perceived by residents, with the aim to reduce feelings of being stigmatised and to increase feelings of empowerment.

When is the Social Housing White Paper likely to land?

Great question! There are external factors delaying the paper, such as Brexit, the General Election, and the Covid-19 pandemic. Honestly, we don’t know when to expect the white paper.  But what we do know is that landlords are expected to start taking steps to improve safety and engagement regardless of publication dates. Fiona MacGregor, Chief Executive of the Regulator of Social Housing has urged the sector to act immediately instead of waiting for government to develop policies and new regulations, saying “If you think there are things that you could be doing for your customers, for your tenants…just crack on and do it.”

There are expectations to take the themes already in the green paper and start applying them immediately.  This could be around listening to, and empowering residents, making performance data transparent and available, and streamlining the complaints process.  The message is clear – if you haven’t already started, start today.

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Social Housing White Paper Key Themes

Key themes of the Social Housing White Paper (and what it means for you)

The social housing green paper covered five key themes:

  1. Ensuring homes are safe and decent
  2. Effective resolution of complaints
  3. Empowering residents and strengthening the Regulator
  4. Tackling stigma and celebrating thriving communities
  5. Expanding supply and supporting home ownership

These areas are likely the focus of the upcoming white paper and are explored further below.

1. Ensuring homes are safe and decent

The theme of home safety is directly linked to the tragedy at Grenfell and preventing any recurrence of that incident in the future.  The Government has taken steps on fire prevention by:

  • Commissioning the Hackitt Review
  • Testing cladding at the Building Research Establishment (BRE)
  • Providing funding to replace cladding
  • Providing fire safety information, such as fire risk assessments, to residents proactively

The MCHLG also asked a range of consultation questions to the sector.  One of the questions on Home Safety asked how landlords could support residents in reporting safety issues.

To ensure decency of homes, the green paper recommends a review of the Decent Homes standard (last updated 2006).  Although there is a low proportion of properties (13%) that failed to meet the standard when the green paper was published in 2018, the Government is keen to review the standard, and ensure all properties are brought up to any new standards that are set.  Examples cited in the paper included mandatory smoke alarms, CO alarms, and upgrading Energy Performance in social housing properties.

Consultation questions on the topic of Decent Homes asked about the safety measures and bringing the published standards up to date.

Why does this theme matter?

The research and recommendations for safety and Decent Homes proposals and consultation questions are based on published reports and are supported by existing frameworks, so there is nothing radical here, just some common-sense policies that are likely to be in the Social Housing White Paper.  Fundamentals such as replacing cladding, adding sprinklers and alarms is covered in this section, in addition to updating the Decent Homes Standard Framework.

What does this theme mean for landlords?

Overall, social housing providers strongly support the recommendations in the Social Housing Green Paper for Safety and Decent Homes, and these measures are likely to be taken forward.  For capital works like replacing cladding and making large-scale improvements to all stock, landlords would require funding.  To what extent the release of that funding is dependent on measures of resident engagement with the safety measures remains to be seen.

What does this theme mean for residents?

Residents can expect greater communication, engagement and awareness campaigns for building safety.  Those residents living in tower blocks should expect disruption when cladding is replaced, and new safety measures are put in place.  If Decent Homes standards are updated, residents could expect visits from surveyors and EPC engineers as homes are evaluated to meet the new standards; then disruption as works are carried out to meet the standard, typically on a large scale, for example, an entire street within a housing estate.

2.  Effective resolution of complaints

This theme is about improving the resolution of complaints and the complaints process in terms of speed, however, this theme is closely linked to empowering and listening to residents (Theme 3) and is born of the first theme around safety; remember the residents at Grenfell felt their concerns about fire safety were going unheard.

The green paper helpfully provides a summary of the current process for complaints. First, the resident complains through the process the landlord sets out in their policies, then either takes the route of the democratic filter or the 8-week waiting period, before finally sending their complaint to the Housing Ombudsman.

The green paper poses consultation questions to understand the value of each step in the process from the landlord and resident point of view, and the real impact of timings to speed up the process to achieve complaints resolution faster.  The consultation questions also seek advice from the sector to strengthen mediation and support locally, possibly eliminate the democratic filter, set out a Code of Practice, and prioritise resident safety.

The Government has already taken some action to address concerns about complaints in the sector through their consultation ‘Strengthening Consumer Redress in the Housing Market’ which ran from February to April 2018.  In January 2019, a summary of consultation responses was published.

Why does this theme matter?

In real terms, complaints are unpleasant for residents as the stages and steps could be difficult to navigate without sufficient guidance, and the process takes a long time from start to finish.

For landlords, when considering staff time and compensation, complaints are costly in real terms. It would benefit the sector to have a standard Code of Practice and measurable performance guidelines so landlords can see if they are meeting the standard.

What does this theme mean for landlords?

Based on consultation responses reviewed, there is no support from landlords or from residents for the Democratic Filter, so that is likely to be omitted from white paper guidance.  In terms of escalating safety concerns, the Hackitt Review makes recommendations for an independent body with enforcement powers to take safety complaints escalated from residents – this could be the Housing Ombudsman but could also be another independent body.

What does this theme mean for residents?

It’s likely the Social Housing White Paper will offer a new streamlined approach to the complaints process with standardised stages and steps for clarity and reassurance to residents.  In terms of speed, removal of the democratic filter will take away unnecessary steps and time delays from the process so complaints can be resolved swiftly.

The Housing Ombudsman may have new processes or procedures that bring it in line with other Ombudsmen, and may also be responsible to act as an independent body to take priority escalation of important safety complaints from residents.

3. Empowering residents and strengthening the Regulator

Not only does this theme combine resident empowerment with regulatory changes, it also serves as an umbrella to several sub-themes underneath it.

Each of these topics has enough substance to warrant it’s own individual consultation and white paper so we’ll cover the highlights, and likely impact of each sub-theme.

  1. Sharing landlord performance information with residents
  2. Rewarding good landlord performance with financial incentives
  3. Ensuring all resident voices are heard
  4. Providing residents with greater choice in services they receive
  5. Value for money for leaseholders
  6. A strengthened Regulator for Social Housing and strengthening the consumer standards

Sharing landlord performance information with residents

This is all about providing transparent, accessible performance information to residents, so they are in turn “armed” with the information they need to provide scrutiny and challenge to their landlord.  One of the hot topics from this theme is the proposal for an NHS-style “Friends and Family Test”.

There is also a proposal to include new KPI’s for complaints handling, bringing a standardised approach across the sector, which is echoed in Theme 2.

The proposal for league tables or a single test to understand performance of a landlord isn’t viewed by the sector or housing bodies as a valuable measure of performance.  There are a range of factors that go into a landlords performance, including governance structure, location, stock size and tenure mix.

The impact:

Standardised measures for complaints handling is a step in the right direction in that there will be measures of success or failure, but there are many questions to ask in terms of complaints reporting, compensation, and the process overall, which the White Paper will clarify.

Rewarding good landlord performance with financial incentives 

This subject is about including key performance indicators in the evaluation of landlords – before providing funding from the Affordable Homes Programme.  The performance indicators might also be used to evaluate landlords for suitability in strategic partnerships.

The impact of these proposals

The KPI’s may be directly linked to the Regulatory judgements for Governance and Viability, which could have a serious impact on how housing organisations are rated and placed under further scrutiny by the regulator.

Ensuring all resident voices are heard

Ensuring all resident voices are heard is a central, strong thread running throughout the green paper, most likely because of the complaints from Grenfell residents that their complaints about safety went “unheard”.

Overall the proposals put forward in the green paper are vague and say that engaging with residents is important:

  • To improve value for money, citing a study by the University of Westminster.
  • By ensuring residents have visibility of performance and influence over decisions that impact their lives
  • To fulfil existing regulatory requirements to consult residents on governance arrangements at least every 3 years. They are suggesting a review of this requirement to see if it needs to be applied more consistently and transparently

Importantly, the green paper suggests monitoring whether landlords are engaging effectively with residents, which could mean work for Engagement and Insight managers.  The green paper also sets out some engagement successes from landlords in co-designing services with residents, but also highlights challenges faced when trying to engage with vulnerable and isolated residents.  A further proposal is the idea of a national, independent National Resident Voice.

The impact:

This theme is both wide-reaching and fundamental to the green paper, however, the proposals put forward are still at the stage of weighing up challenges and opportunities tentatively, without a clear vision.  The one watchout is a regulatory requirement for engagement monitoring, which would have an impact directly with Engagement Teams and Insight Managers.

Providing residents with greater choice in services they receive

Residents in the social housing sector don’t have the same choices as in other sectors, and there is little or no ability for individuals to “switch” providers of any social housing service.  This section of the green paper does outline opportunities for management of housing to be taken back under council control of the Local Authority, or to manage the housing function in a Tenant Management Organisation (TMO).  Mentioning the TMO structure, however, raises concerns as that is the governing body of the Grenfell building, and the TMO organisation structures are now being evaluated for effectiveness.

Of course, residents can ballot to have their local authority housing transferred to a housing association, under a range of models such as co-operatives or mutuals.

The preference in the green paper is to use transparent performance information (KPIs) and League Tables to allow residents choice – but it’s not defined how that leap between visibility and choice will be made.

The paper publishes a range of options for organisational structure and culture, as well as community leadership opportunities:

  • New stock transfer programme from LAs to community-based housing associations
  • New community leadership trailblazer to trial governance structures and arrangements
  • Scrutiny and evaluation of Tenant Management Organisations (TMOs)

For individuals:

  • Supporting residents’ skills to choose and control services, or smaller parts of services to suit their capacity
  • Landlords to prepare local agreements of local offers to set standards with residents
  • Landlords to offer training, DIY services, and voluntary opportunities
  • Offering choice to residents in terms of offering an approved list of contractors

The impact:

New governance arrangements would be highly disruptive to housing organisations, but a wide range of options for structuring housing services in cooperation with tenants is welcome.   For individuals, there will still be very limited choice, but possibly additional support so that control and choice would available over more services, and particularly repairs and maintenance.

Value for money for leaseholders

Leaseholders can sometimes represent the smallest population of customers for a landlord, and customer touchpoints around service fees can be contentious.  For these reasons, the Social Housing Green Paper has highlighted Value for Money for leaseholders to be an important part of resident engagement for all customers.

The consultation focuses on a lack of transparency around service charges, and there are complications for social housing residents that want to buy the freehold for the property, for example in a shared block.

To address these issues, the Government has announced a set of reforms to restrict ground rents, ease freehold purchase, and standardise how service charges are presented and communicated to leaseholders.

The impact:

The consultation question in this section was vague and open, only asking how landlords could help leaseholders.  Our guess is that the responses will be wide-ranging and unlikely to have further impact or regulatory change beyond the reforms that have already been announced.

Governance and regulation are likely to change when the Social Housing White Paper is published – and when it arrives, you want to be prepared.  Register to receive your Guide to the Social Housing White Paper today.

A strengthened Regulator for Social Housing and strengthening the consumer standards

Despite reporting satisfaction with repairs and maintenance at 66% amongst social housing residents in the green paper, the Government has recognised that not all residents are satisfied and wants to make changes to improve levels of satisfaction overall.

Their proposals are centred on:

  • Transparency and comparison of performance with other landlords, which links to the Government proposal of Social Housing League Tables
  • The ability for the Regulator to monitor Key Performance Indicators and take a risk-based approach to intervention.
  • Recognising that there are sector-led initiatives that are robust and effective, but that those initiatives need to be underpinned by regulation.
  • Recognising the inadequacy of the consumer standards, which do not have the same rigorous standards to meet as with the economic standards.
  • Strengthening consumer regulation by proposing a Code of Practice for the consumer standards, so they carry the same importance as the economic standards
  • Proposing the ability to enforce the consumer standards
  • Acknowledgement that serious actual harm to residents is the threshold for intervention in the consumer standard, which is higher than the threshold for intervention in the economic standard
  • A proposal and consultation questions around introducing a “serious detriment” test to the consumer standard, and when the test is failed, the regulator will publish a regulatory notice and take enforcement action.
  • Improve the ability for the Regulator to scrutinise performance and enforce standards within Local Authorities, who are currently exempt from 6 out of 13 enforcement powers
  • Making the oversight, governance and accountability of Local Authorities and their arrangements with TMO’s and ALMO’s more robust
  • Change accountability of the Regulator for Social Housing from the Homes and Communities Agency to report directly to Parliament, as a stand-alone Non-Departmental Public Body (this change was completed on 1 October 2018, see Regulator of Social Housing website)

The impact:

These proposals would give greater importance and weight to the Social Housing Consumer Regulatory Standards which include the Tenant Involvement and Empowerment Standard, Home Standard, Tenancy Standard, Neighbourhood and Community Standard.  For landlords, this would mean a significant change in terms of understanding, and responding to, the needs of residents.

The Home Standard – deals specifically with matters of how repairs and maintenance to properties is carried out, the quality of homes, and meeting the Decent Homes standard.

The Tenancy Standard – deals with allocations, mutual exchanges, and policies and procedures around tenure management and lettings management, such as probationary tenancies and decants.

The Neighbourhood and Community Standard – deals with neighbourhood management, anti-social behaviour and working within local area partnerships that provide supporting services, for example, Citizens Advice or local charities.

The Tenant Involvement and Empowerment Standard – the only consumer standard re-published immediately post-Grenfell, in July 2017, deals with customer service, complaints, empowering and involving tenants in management, governance and decision-making, and respecting diversity in their resident population.  There is prominent and specific guidance on complaints handling:

“Providers shall offer a range of ways for tenants to express a complaint and set out clear service standards for responding to complaints, including complaints about performance against the standards, and details of what to do if they are unhappy with the outcome of a complaint. Providers shall inform tenants how they use complaints to improve their services. Registered providers shall publish information about complaints each year, including their number and nature, and the outcome of the complaints. Providers shall accept complaints made by advocates authorised to act on a tenant’s/tenants’ behalf.” – HCA, Tenant Involvement and Empowerment Standard, 2017.

Giving the consumer regulation “greater teeth” through a Code of Practice, detriment tests, and enforcement measures would be a significant change in the social housing sector, and with it, greater empowerment to residents; bringing the resident-landlord relationship more into balance.

“I have absolutely no doubt that the regulation around resident engagement is coming in the white paper. But we need to be above the baseline standard. That is the platform to stand on to create brilliant futures for our residents.” — Lesley-Anne Alexander, current chair of Metropolitan Thames Valley Housing

Social Housing White Paper Strengthening the Regulator

4. Tackling stigma and celebrating thriving communities

This theme is in response to feedback “raised consistently” by residents during the Government green paper consultations. Simply put, residents felt like second-class citizens, looked down upon by their landlord. This could stem from perceptions in the media that residents are lacking in aspiration or otherwise disadvantaged.  The MHCLG cites published research in the green paper to back up their proposals:

Feelings and perceptions of stigma relate to a diverse set of factors – power (and empowerment), historical bias (and bias in the media), and in negative language used by all of us.  Accent Group tenant, Richard Wilkinson, speaking at the National Housing Federation Customer Excellence event in 2020 called out the negative language used by housing organisations as particularly unhelpful, for example housing “officers”, voids, and “front-line” services.

Social Housing is a high-barrier industry with little or no choice.  Residents are not able to “vote with their feet” and simply move on when the service they receive does not meet their needs.  Also, power in the resident-landlord relationship is with the landlord.  Residents can feel like their views are not being taken into account, and services provided are based on company policy rather that resident preference.

Rebalancing the power in the relationship through recommendations in the Social Housing White Paper, and importantly, legislation enacted to support those recommendations is needed to address this imbalance.

What is the impact for landlords?

Although landlords are closest to this issue, and likely to have the greatest impact in both addressing issues of stigma and celebrating success, much of the problem is in the media and in everyday bias of individuals. Viewing policies, content, communications and service levels through the lens of the customer experience adds to the empowerment of, and advocacy for, each resident.

There is a road ahead to end these negative perceptions and celebrate the best. But feelgood initiatives won’t help until the fundamentals of governance, involvement and the balance of power is addressed.

In addition to addressing the complex problem of stigma, the regulator asked for recommendations to celebrate the very best of thriving social housing neighbourhoods and wider communities.

There is a call to improve professionalism in housing management, a call echoed by the sectors well-known education charity, the Chartered Institute of Housing, and also to develop key indicators to measure how landlords are performing in customer service and neighbourhood management.

In addition to addressing stigma, sector professionalism and performance, the green paper talks about the importance of housing organisations in a wider context; how they add social value to their communities, addressing issues of financial inclusion and tackling anti-social behaviour.

In this section about tackling stigma and celebrating communities, is also a good deal of information on the quality and design of new homes, even in terms of promoting healthy lifestyles and being energy efficient.  So, if you are looking at Theme Five: Expanding Supply and Supporting Homeownership, it’s also worth a visit to this theme on stigma, to understand the relationship of home and neighbourhood design to the wellbeing of residents overall.

5. Expanding supply and supporting home ownership

The Government published Fixing Our Broken Housing Market in 2017, and is referenced heavily through this section to address and support concerns around supply, demand, funding, choice and aspirations.

They explore new models of co-operatives and community-based housing organisations, with a view to supporting and boosting these new types of organisations.

Importantly, this section of the Social Housing Green Paper addresses affordability and Universal Credit, but they don’t go far enough with new initiatives or consultation questions on the matter, in fact, this theme has the lowest number of consultation questions at four.  That tells us that these decisions will be taken from the top!

The consultation and next steps

The Social Housing Green Paper consultation with residents, stakeholders, landlords and sector bodies, ran from 14 August 2018 through 6 November 2018, via online survey, email or post.

A range of organisations have published their responses to the Social Housing Green Paper, a selection are linked here:

Sector Bodies

Housing Ombudsman

Tpas

CIH

The Social Housing White Paper is due to be published soon, and when it arrives – IFF Research is your source for news and information on how it will impact your world.  From blogs, insight pieces, webinars and events, we can help navigate the white paper recommendations and upcoming legislation in a practical and straightforward way.

Register for the Social Housing White Paper Guide

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