North Wales Housing

The Welsh Ministers have powers under the Housing Act 1996 to regulate Registered Social Landlords (RSLs) in Wales in relation to the provision of housing and matters relating to governance and financial management. Part 1 of the 1996 Act is amended by Part 2 of the Housing (Wales) Measure 2011 (“The Measure”) and provides the Welsh Ministers with enhanced regulatory and intervention powers concerning the provision of housing by registered social landlords and the enforcement action that may be taken against them. The Welsh Ministers are publishing this regulatory assessment report under section 33A of the Housing Act 1996.

The regulatory assessment work undertaken follows the risk-based approach to regulation and seeks to identify strengths and areas for improvement in meeting the “Delivery Outcomes” (standards of performance). These are set out in the Regulatory Framework for Housing Associations Registered in Wales, which is also known as “the regulatory framework”.

This report sets out the Welsh Government’s assessment and is designed to provide the RSL, its tenants, service users and other stakeholders with an understanding of how well it is performing against the “Delivery Outcomes” (standards of performance) relating to:

• Landlord services
• Governance and Financial management

Description of North Wales Housing Association Limited

North Wales Housing Association Limited (known as North Wales Housing/NWH) was established in 1974 with rented properties spreading across the counties of Ynys Mon, Gwynedd, Denbighshire and Conwy. It has a stock of around 2,400 homes of which the majority is general needs housing. The Group is registered as an Industrial & Provident Society with charitable rules.

NWH established a Group structure in April 2011 by setting up a trading arm subsidiary called ‘Domus Cambria’ that will be developing homes for sale.

The Group have committed to a development programme of 320 new homes that includes 138 General Needs, 91 Supported Housing and 91 units built for outright sale between 2012 and 2015. Its future programme from 2015 is based on developing 20 new homes per annum.

After a successful trial, the repairs and maintenance service is provided by the Direct Labour Organisation (in-house workforce) which is part of the Group.

Overall Assessment

Summary: Landlord Services

NWH has demonstrated positive outcomes for a number of delivery outcomes, particularly in relation to building new homes, letting of vacant housing and helping prevent and alleviate homelessness. It is aware of the areas it needs to focus on and improve in the future.

Key areas of improvement relate to effective management of homes, the repairs and maintenance service including delivery of the Welsh Housing Quality Standard (WHQS), information about its current and potential service users and tailoring services to meet the needs of service users, services to support tenants in financial difficulty or suffering from anti-social behaviour.

Summary: Governance and Financial management

NWH is aspiring to achieve excellence in all it does and has a strong commitment to the communities in which it works. This is demonstrated in the value it places on using tenant feedback and in its positive approach to partnership initiatives to improve economic, social and environmental opportunities in the community. It is also aware of the areas it needs to improve and is making progress in building a culture of continuous improvement.

It has acknowledged that there are aspects of governance that require improvements. They have identified inconsistent and poor quality management in some areas, a lack of focus on issues of importance to tenants and a need for enhanced data collation/analysis/monitoring. Specialist external support has been sought and applied in this regard and a restructuring of the senior management structure is to take place over the next year.

It has a clear commitment to placing its service users at the heart of what it does, however, there are occasions when this does not happen in practice. A number of barriers to improvement have led to weaknesses in translating its overall vision into outcome based plans which reflect what is most important to tenants and service users. NWH needs to do more to demonstrate that its services are provided in a fair way and address equality and diversity issues.

NWH has demonstrated that they have a robust financial management framework and effectively identify, appraise and manage risks. The financial viability judgement issued in March 2011 was: “Pass - NWH has adequate resources to meet current and future business and financial commitments”.

Future Regulatory Engagement

NWH is assessed as requiring a medium level of regulatory engagement in future. This engagement will focus on the following areas:

• the way in which homes are managed – including delivering better outcomes related to financial inclusion, anti-social behaviour and services to home owners;
• day to day repairs and programmed investment including delivery of Welsh Housing Quality Standard and planned work;
• improving understanding of its tenant and service users to tailor services to meet their needs;
• planning and measuring future service outcomes from the perspective of tenants and service users;
• more effective involvement of tenants and service users in the design of services at a strategic level;
• addressing equality and diversity and ensuring services are delivered in a fair way;
• demonstrating value for money; and
• further developing a culture to promote the translation of vision into impact measured delivery.

The regulatory engagement will be carried out through a range of activities, via governance, senior management and user engagement arrangements and monitoring progress against NWH’s improvement plans.

Landlord Services

An assessment of the key strengths and areas for improvement against each delivery outcome is set out below.

1. We build and renovate homes to a good quality

NWH builds and renovates homes to a good quality, in line with established design standards. It has a robust, cautious approach to ensuring that development proposals demonstrate scheme viability and value for money.

It acknowledges that it could improve its approach by seeking and learning from feedback given by residents of its new homes.

2. We let homes in a fair, transparent and effective way

NWH lets empty homes quickly, maximising the rental income and the number available to new tenants. It works well with the local authorities and other partners to help prevent and alleviate homelessness through provision of supported housing and hostel accommodation. It is also committed to the development of common (shared) housing registers throughout its area of operations.

NWH needs to do more to demonstrate that access to its homes is fair and that the standard of properties which are offered to housing applicants meet their expectations.

3. We manage our homes effectively

NWH uses the most secure form of tenancy available for all new lettings and sets rents in line with Welsh Government’s expectations. When new tenants accept properties, it provides clear information to them about their rights and responsibilities.

However, it needs to do more to demonstrate that it is always managing its homes effectively. It lacks comprehensive information on current and prospective service users, which means that it does not know whether it is consistently responsive to individual housing and support needs, to help sustain tenancies.

It also needs to do more to better understand what tenants think about the services they receive. It is not able to demonstrate outcomes from its work to support tenants in financial difficulty, in dealing with anti-social behaviour (ASB) or the quality of environment in which its tenants live. Some tenants we contacted felt that the response to reports of ASB was not always effective.

4. We repair and maintain homes in an efficient, timely and cost effective way

NWH recognises the need to improve outcomes in this area and has taken steps to improve its approach to provision of information to, and liaison with tenants in relation to delivery of future maintenance programmes.

It has acknowledged the need to improve its approach to responsive repairs to provide an efficient and effective service which meets the requirements of its tenants.

NWH has not made full use of the stock condition survey information that has led to difficulties in developing accurate plans for improvement of its homes. and providing information on future programmes of work to tenants. Tenants we contacted highlighted these issues as key areas for improvement.

The deadline for achieving the Welsh Housing Quality Standard (WHQS) was 2012. However, NWH has submitted a request for an extension of time to achieve the Welsh Housing Quality Standard (WHQS) by 2014. The Minister for Housing Regeneration and Heritage will be asked to consider potential extensions once officials have considered the reasons for seeking the extension of time. This decision will be made by the end of December 2011.

5. We provide fair and efficient services for owners

NWH was not able to demonstrate that it is always providing fair and efficient services to owners as some shared owners we contacted were not satisfied with the quality of service provided. It is noted that NWH has only a small number of owners/leaseholders.

Governance and Financial Management

Governance

An assessment of the key strengths and areas for improvement against each delivery outcome is set out below.

1. We place the people who want to use our services at the heart of our work – putting the citizen first.

NWH aspires to put service users at the heart of its work and individual staff will, where they have the relevant information, put the citizen first. Where service user feedback is collected – including formal complaints – this is valued and used to improve service outcomes. It acknowledges the need to develop a more integrated approach to achieving strong outcomes from service users’ perspective and is developing plans to improve its performance in this area.

Tenant and service user involvement in shaping service delivery is mixed, being much stronger at frontline operational level than in strategic decisions about service design and comparative performance.

NWH lacks comprehensive information on its current and potential service users and their service priorities. It needs to do more to understand its own service delivery outcomes and service quality, from the perspective of tenants and service users as its self-assessment did not focus on these.

2. We live public sector values, by conducting our affairs with honesty and integrity and demonstrate good governance through our behaviour.

NWH has a clear commitment to ensure that its activities and services reflect the diversity of the communities where they operate, are free from discrimination and provide equality of opportunity. This is confirmed by contact with external partners. However, it is currently unable to demonstrate that this is the case although it is developing plans to address this. The association is not always able to provide a service in Welsh but has well developed plans to achieve this. Published information does not always have management/performance data to help tenants and service users to measure the quality of services compared with others.

It acknowledges the need to improve many of these areas and is developing plans to address them. It has contributed positively to the improvement of economic, social and environmental circumstances in the local community, often taking a lead role in doing so.

3. We make sure our purpose is clear and we achieve what we set out to do – knowing who does what and why.

NWH has recently formed a group structure which is comprehensive and well thought through. It has well developed plans to improve data quality and is proposing restructuring at senior management level. This, along with plans to improve its capacity, skills and tools is designed to build a stronger culture of continuous improvement. It takes a proactive approach to improving procurement arrangements, which has resulted in efficiency savings.

Whilst NWH has a clear vision for what it is aiming to achieve, it is not always effective in translating that into positive outcomes for tenants across the whole organisation. This is due to a number of issues such as poor data quality and management in some areas, variable quality of management and leadership and some restricted understanding of issues of greatest importance to tenants, including quality of customer service. It does not have a clear understanding of service costs, linked to service outcomes, to determine whether value for money is being achieved.

4. We engage with others to enhance and maximise outcomes for our service users and the community.

NWH has demonstrated effective partnership working that is supported by feedback received from partners. It is delivering positive outcomes for the community and demonstrating leadership in this area.

Financial Management

5. We are a financially sound and viable business.

NWH is a financially sound business with a robust financial management framework and it has a prudent approach to identifying and managing risks. Its activities demonstrate a high standard of financial probity.

In March 2011, a financial viability judgement was issued. The judgement was: “Pass – NWH has adequate resources to meet current and future business and financial commitments”.

Sources of information and regulatory activity

The following information is generally received from RSLs:

• audited annual accounts, including the internal controls assurance statement;
• external auditors’ management letter;
• financial forecasts;

In addition to the above, the following specific activities were carried out from February 2010 to September 2011:

• regulatory activity via relationship management approach to regulation;
• review of self assessment and associated “hard” and “soft” evidence relating to the delivery outcomes;
• meetings with executive team;
• attendance at board meetings;
• attendance at stakeholder meeting/Discussions e.g. tenant/resident forum; partnerships, etc.

Basis of regulatory assessment

This regulatory assessment is based on information submitted by the RSL, our accumulated knowledge and experience of the RSL, its management and the RSL sector as a whole.

In preparing this report, the Welsh Ministers have relied on the information supplied by or on behalf of the RSL. The Directors of the RSL remain responsible for the completeness and accuracy of such information.

This report has been prepared for the RSL as a regulatory assessment. It must not be relied upon by any other party or for any other purpose. Any other parties are responsible for making their own investigations or enquiries.

Key to High, Medium or Low regulatory engagement

High regulatory engagement

We will have a high level of engagement with the RSL where their profile indicates we need the most tailored, intensive or continuous relationship. This may mean engaging in a more sustained way with an organisation to develop a detailed understanding of current and potential areas of risk and their approach to managing them. Our engagement plan may involve a broader range of regulatory activities, e.g. monitoring progress; attendance of Board, Senior Management and Tenant/resident meetings. We may also need a high regulatory engagement where specific risks are likely to materialise, or have materialised, and we need to support an organisation to improve its performance against the delivery outcomes.

Medium regulatory engagement

We will have a medium level of regulatory engagement with the RSL where their profile indicates we need further assurance. For example, we may need more information or a closer engagement with the organisation’s senior management and/or governing body or to monitor progress against delivery outcomes and/or improvement plans.

Low regulatory engagement

We will have low level of regulatory engagement with the RSLs where the impact of problems occurring is low and the probability of the problems occurring is low. In these cases we will plan to have limited contact with the organisation, unless other events arise. In some cases we may highlight and monitor areas for improvement, but in ways that are less intensive for medium or high engagement organisations.