Library Archive
Implementing TSMs – Practical issues and challenges
At the recent CWAG AGM, Jonathan Cox from Housemark discussed the practical issues and challenges involved in achieving compliant data collection arrangements by April 2023 when TSMs are introduced.
The overall trend in perception surveys over the past 5 years has consistently shown a decline in satisfaction levels. Many landlords stopped carrying out the STAR survey once this was no longer mandatory, these landlords will find their baseline is now much lower than historical data.
The move to perception based TSMs will provide landlords with important resident feedback to constructively drive improvements that tenants recognise and value. However, in his presentation Jonathan identified five barriers to making the most of TSM survey feedback including being overly focussed on scores, a fragmented approach to surveying, questions overload and survey fatigue, as well as a lack of internal capacity to use the data effectively.
Housemark has also identified 11 major variables affecting perception survey scores including:
Contextual Issues
- Location / Urbanisation (tenants in cities report lower satisfaction)
- Tenant age (older people tend to be more satisfied)
- Tenure type (leaseholders, although not part of TSM surveying, tend be the most dissatisfied followed by shared owners with renters relatively more satisfied)
- Size of landlord (smaller landlords tend to get higher scores, possibly because there is likely to be a single point of contact for tenants)
Methodological Issues
- Collection method will impact on scores (on-line surveys will be 10 -15 points lower than face-to-face surveying, with telephone surveys somewhere in between) Transactional surveys give the highest scores but are not allowed for TSMs)
- Sample selection (general needs stock will differ from more specialist provision),
- Scale (smaller sample sizes can distort results)
- Time of year (scores of surveys carried out in Winter are approximately 2% lower than for surveys carried out in Summer)
Landlord performance drivers
- Landlord accessibility and responsiveness (how quickly and easily can the tenant contact the landlord and resolve issues)
- Respectful and helpful engagement (is the landlord perceived as helpful and respectful in the way it engages with tenants)
- Responsive repairs (tenant experience of the landlord on responsive repairs is a significant driver of overall perception of, and satisfaction with the landlord)
Consultation on Social Housing Rents – CWAG Response
The government social housing rents consultation closed on 12th October 2022. The consultation covered options for capping social housing rent increases in 2023/24 below the agreed CPI+ 1% formula.
The CWAG submission to the consultation argues that the decision should be based on local discretion and local circumstances rather than an imposed cap. In practice most local authorities are unlikely to raise their rents in 2023 by the maximum permitted under the formula.
An imposed 5% cap will leave HRAs constrained and under-resourced in business planning terms for years to come. Given that any reduction below inflation will represent a saving to the Exchequer as housing benefit and Universal Credit are reduced, these savings should be used to provide additional grant funding for essential building safety, maintenance and carbon reduction programmes that will inevitably be stalled by rent capping.
CWAG Newsletter – October 2022
This Update includes the following
CWAG Annual General Meeting
This year the CWAG Annual General Meeting discussed the introduction of Tenant Satisfaction Measures (TSMs) from April 2023.
Kate Dodsworth, RSH Director of Consumer Regulation introduced the session with an overview of TSM Consultation and key outcomes. The consultation itself generated significant interest among tenants, with 55% of the 1100 responses received being from tenants, a considerable achievement given that the RSH primary relationships are with landlords not tenants.
The Regulator is keen to stress that the 22 TSMs are only a small part of the new regulatory framework to be introduced over the next 18 months following the passage of the Social Housing Regulation Bill. The wider regulatory objective is to ensure that there are real opportunities for tenants to influence landlords and the way decisions are taken about their homes. This will require a fundamental cultural shift within the sector, but early indications are positive.
The Regulator is aware of possible concerns around gaming of the measures and will not hesitate to respond with changes if necessary. There was also an acknowledgement that we don’t yet know in detail how the new regulatory arrangements will work for councils with ALMOs. Whilst the overarching principle is that it will be the council landlord and not the ALMO that is ultimately responsible for delivering improvements and ensuring tenants voices are at the centre of decision making, further work will be required to determine how this will work in practice.
Our second speaker, Jonathan Cox from Housemark discussed the practical issues and challenges involved in achieving compliant data collection arrangements by April 2023. The presentation discussed current negative perception survey trends and the important variables influencing these.
The move to perception based TSMs will provide landlords with important resident feedback to constructively drive improvements that tenants recognise and value. However, the presentation identified five barriers to making the most of TSM survey feedback including being overly focussed on scores, a fragmented approach to surveying, questions overload and survey fatigue, as well as a lack of internal capacity to use the data effectively.
Finally, Jonathan summarised several key steps to prepare for the introduction of TSMs next year.
CWAG Consultation Response Social Housing Rents
The government social housing rents consultation closed on 12th October 2022. The consultation covered options for capping social housing rent increases in 2023/24 below the agreed CPI+ 1% formula. Read the CWAG response here.
Excellence in management and partnership – updated checklist
Last year CWAG and the NFA produced the report ‘Excellence in management and partnership’ to assist councils and ALMOs in preparing for changes to regulation.
An updated version of the council ALMO relationship checklist is now available here.
DLUHC New Ministerial Team
New government ministerial appointments and responsibilities at DLUHC have been confirmed as follows:
Simon Clark MP for Middlesbrough South and East Cleveland since 2017
Secretary of State for Levelling Up Housing and Communities
Responsible for the strategic oversight of all DLUHC departmental business.
Previous government posts:
- Chief Secretary to the Treasury 2021 – 22
- DLUHC Minister for Local Government and Growth 2020 – 21
- Exchequer Secretary to the Treasury 2019 - 20
Paul Scully MP for Sutton and Cheam since 2015
Minister of State for Local Government Faith and Communities and Minister for London
Responsibilities include:
- Local government policy and finance, including Office for Local Government
- Building Safety - remediation and regulation regimes
- Climate change, net zero and energy efficiency (building regulations)
- Grenfell recovery and rehousing
- Grenfell public inquiry
- Minister for London
Previous government post:
Minister for Small Business, Consumers and Labour Markets – BEIS 2020 - 22
Lee Rowley MP for NE Derbyshire since 2017
Parliamentary Under Secretary of State (Housing Portfolio)
Responsibilities include:
- Overarching responsibility for housing strategy, including supply and home ownership
- Investment Zones
- Housing funds, including Affordable Housing Programme (AHP) and other housing / land and infrastructure funds
- Homes England stewardship
- Planning - reform and casework
- Leasehold and freehold
- Corporate matters
Previous government posts
- Minister for Industry – BEIS 2021-22
- Government Whip 2021-22
Andrew Stephenson MP for Pendle since 2010
Parliamentary Under Secretary of State (Homelessness and Rough sleeping)
Responsibilities include:
- Homelessness and rough sleeping
- Refugee housing - Ukraine and Afghanistan
- Social housing
- Supporting Families and Changing Futures
- Private Rented Sector
- Electoral Integrity Programme
Previous government posts:
- Minister without Portfolio 2022- 22
- Minister of State – Department of Transport 2020-22
- Minister for Africa – Foreign and Commonwealth Office 2019 – 20
- Minister of State - Department for International Development 2019 – 20
- Minister for Business and Industry - BEIS 2019 – 19
- Government Whip 2017 - 19
Dehenna Davison MP for Bishop Auckland since 2019
Parliamentary Under Secretary of State
Responsibilities include:
- Local growth funding design and simplification
- Local growth funding delivery - UK Shared Prosperity Fund (UKSPF), Levelling Up Fund (LUF), Community Ownership Fund (COF), etc.
- Devolution deals and county deals
- Planning casework
Baroness Scott of Bybrook OBE
Parliamentary Under Secretary of State
Responsibilities include:
- Integration, communities and faith, including Hong Kong British National (Overseas)
- RED local resilience and emergencies, including winter preparedness
- COVID-19 inquiry
- Planning casework
- Lords work for the department
Bids invited for LGA Housing Advisers Programme
This programme is part of the LGA’s sector-led improvement offer and is designed to support councils seeking to innovate in meeting the housing needs of their communities. Awards up to £20,000 are available to successful applicants for the provision of bespoke expert support to councils – or groups of councils – wanting to transform the delivery of homes and places, improve the quality and security of existing homes and/or to prevent and reduce homelessness. This year the programme has a second strand, aimed at councils who are keen to lead on the delivery of new housing but do not have a recent track record in this area.
The deadline for applications is 24 November 2022.
For more information and how to apply for the 2022/23 programme – link
Diary Date - LGA Webinar - The Social Housing Regulation Bill – Information for councils – 21st November 2022
This webinar originally planned for September 2022, was cancelled due to the Queen’s death, will now take place on Monday 21st November 2022. This LGA event is a collaboration with ARCH and the NFA.
The programme will discuss the forthcoming Social Housing Regulation Bill and includes speakers from the Department for Levelling Up, Housing and Communities (DLUHC) and the Regulator of Social Housing (RSH).
The webinar is being held over Zoom and is free to LGA members. To find out more information and to book follow the link: Local Government Association
Recent Publications
Housing Ombudsman
The Housing Ombudsman has published its latest Insight Report covering April to June 2022 which shows that complaint volumes remain high. Case studies in the report are drawn from the South-East and South-West of England and focus on where landlords have implemented good practice around dispute resolution.
In addition, the Housing Ombudsman has used its powers to conduct further investigations, where complaints may be indicative of wider service failure, to look in more detail at 13 complaint cases relating to Clarion Housing Association. The resulting Special Report identifies multiple failings with poor record keeping and communication key issues undermining effective complaint handling. There are also important learning outcomes in relation to damp and mould and pest control cases. Interestingly the Ombudsman is keen to point out that offering sizable compensation should not become routine; the focus should rather be on identifying improvements that deliver earlier complaint resolution.
Regulator of Social Housing (RSH)
The RSH has published its Decision Statement setting out the outcome of the consultation on Tenant Satisfaction Measures. As a result of the feedback some changes have been made, mainly to ensure definitions are or to reflect wording improvements suggested by respondents.
CWAG News Update – September 2022
This Update includes the following
Consultation on Social Housing Rents
Diary Dates – Meetings and Events
New CWAG website – Update
Recent Publications
Consultation on Social Housing Rents
Current rent policy dates back to 2019 and permits social housing rents to increase by up to the CPI rate at the previous September plus 1% point. This policy was intended to run up to 2025 providing longer-term certainty and stability for business planning and investment.
However, faced with an unprecedented rise in inflation and the exceptional cost of living pressures on households, the government is now proposing to restrict the 2023 social housing rent increase and is consulting on alternative arrangements.
Under the consultation proposals social landlords would be permitted to increase rents by up to CPI+1% or by 5%, whichever is the lower, effectively placing a 5% ceiling on increases next year.
The consultation is also inviting views on alternative ceiling options (such as 3% and 7 %) and whether restrictions should be extended beyond next year to cover the 2024 increase as well. The government is also keen to understand what councils would opt to do in terms of rent increases if this ceiling was not to be imposed.
The intention is for the proposed rent increase ceiling to only apply to existing tenants, it will not apply on new properties and relets where the formula rent and full CPI plus 1% can be applied. The consultation also states that these arrangements will apply across the board, it is not proposed to make exceptions for certain less financially resilient categories of social housing – although feedback is sought on this. Where individual landlords face viability issues, it may under certain circumstances be possible to agree a waiver with the Regulator of Social Housing.
DLUHC has published an impact assessment alongside the consultation which estimates the loss of rental income for councils at £3.4billion in the 5-year period between 2023 and 2028.
In framing the CWAG response we are keen receive feedback from CWAG members on the consultation proposals and how these will impact locally on HRA business plans, the scale of financial loss and what this will mean on a practical level in terms of services for residents, repair programmes and investment plans including newbuild and meeting climate change targets.
The consultation runs for 6 weeks from 31st August 2022 to 12th October 2022