Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
CHS Board 8 December 2015 Item 136, Regulatory Standards Self-Assessment (final draft)
1
Introduction
This documents aims to
 Evidence compliance with all HCA Standards, including revised (April 2015) Governance & Finance Viability Standard and Governance & Finance Viability Standard Code
of Practice, as part of CHS’s annual Regulatory process
 Prepare for forthcoming In-depth Assessment (IDA), as outlined in HCA document Regulating the Standards June 2015.
Priorities for strengthening CHS compliance:
G1.1
Requirement
Demonstrating adherence to all relevant law
P.3
G2.1
a
P.6
G2.5
a
P.11
G2.5
b
P.11
H1.1
a
P.32
H1.1
b
P.32
Key
Key
Self-assessment against the new NHF 2015 Code
of Governance
Maintaining a thorough, accurate and up to date
record of their assets and liabilities and
particularly those liabilities that may have
recourse to social housing assets
Carrying out detailed and robust stress testing
against identified risks and combinations of risk
across a range of scenarios etc
RPs shall ensure that tenants’ homes meet
standard set out in section 5 Decent Homes
Guidance and continue to maintain their homes
to at least this standard
RPs shall meet the standards of design and
quality that applied when the home was built,
and were required as a condition of publicly
funded financial assistance, if these standards
are higher than the Decent Homes Standard
On track
Risk of falling behind
Action
Independent advice sought from 5
sources on legal options and good
practice. RFOG mtg 25 Nov 2015
reviewed suggested approach.
Completion of NFH Checklist
By When/Who
25 Nov RFOG
mtg/JK
Progress as at 27 Nov
RFOG approval of approach outlined on P. 3
of this document, supported by Appendix A,
P. 4 - 5.
Dec 15/JK
Full compliance achieved.
Development of Group-wide Asset
Liability Register
Mar 16/HoC
Register in progress. CandCD notified of their
required contribution.
Mitigation policy in place. Detail on
strategies for implementation to be
further developed.
Better forward planning to ensure
Decent Homes works are not held up by
transitions between building contractors
Jan 16/SD
Latest valuation of commercial offices,
including Endurance House, requested – due
to be received end Nov 2015.
DHS now in contractors’ plans.
Providing assurance about extra design
requirements to be included in the
development of QL
Mar 16/GL
Behind programme
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
Mar 16/GL
RAG
Relevant properties and data components
now identified and awaiting implementation in
updated QL system.
Complete
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
1
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Key
The table lists the outcomes for each standard, then details the specific expectations for each section of the standard.
The order and numbering of the expectations is as in the published Regulatory Standards and Code of Practice from April/June 2015 except that:
 Some expectations have been split into separate points in this table where this makes sense from the evidence point of view – these are numbered a, b, c, etc. So
1.1a, 1.1b and 1.1c in this table are all expectation 1.1 in the Governance and Viability Standard itself
 Sometimes the expectations in the framework have a number of sub-points within them – these are shown as bullet points in this table. So 1.4a, 1.4b and 1.4c are
sub-points separated out in the framework
 The ‘Required Outcomes’ are not necessarily reflected in the ‘Specific Expectations’. Where they are different, they are both listed in this table.
Pink – new 2015 wording
3
Blue – relates to forthcoming In-Depth Assessment (IDA)
Yellow – relates to actions required in relation to Priorities for Strengthening on P.1
Detailed self-assessment December 2015
The numbering here corresponds to the numbering in the actual regulatory standards. Some of the sections in the standards have been split between more than one reference
here to make compliance reporting easier.
Ref
Standard
Comply
at 12/15
Compliance evidence
Action required
Lead
Time
scale
Comments /Plans to further
strengthen compliance
Governance and Financial Viability standard April 2015
1
Required outcomes
1.1
Governance
Registered providers shall ensure effective governance arrangements that deliver their aims, objectives and intended outcomes for tenants and potential tenants in an
effective, transparent and accountable manner. Governance arrangements shall ensure they:
1.1a adhere to all relevant law
1.1b comply with their governing documents and all regulatory requirements
1.1c are accountable to tenants, the regulator and relevant stakeholders
1.1d safeguard taxpayers’ interests and the reputation of the sector
1.1e have an effective risk management and internal controls assurance framework
1.1f protect social housing assets
1.2
Financial viability
Registered providers shall manage their resources effectively to ensure their viability is maintained while ensuring social housing assets are not put at undue risk (see G2.4
and G2.5)
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
2
Ref
2
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
Governance arrangements
shall ensure that registered
providers adhere to all
relevant law – Boards to take
reasonable measures to
assure themselves of
compliance with legislation,
common law and statutory
guidance
Yes
12/15
RFOG approval of this
approach agreed 25 Nov 2015.
Directors’ Annual Internal Control Statement,
next due in July 2016, will from now on
include clause on compliance with applicable
laws and regulations in each area under
their respective supervision.
G1.1bi
Governance arrangements
shall ensure that registered
providers comply with their
governing documents
Yes
G1.1bi
i
Governance arrangements
shall ensure that registered
providers comply with all
regulatory requirements
Governance arrangements
shall ensure that registered
providers are accountable to
tenants
Governance arrangements
shall ensure that registered
providers are accountable to
the regulator
Governance arrangements
shall ensure that registered
providers are accountable to
relevant stakeholders
Yes
Yes
G1.1ci
G1.1cii
CGPM
Adherence to all law is integral to everything
CHS does, as detailed throughout this
assessment.
See Appendix A overleaf, P. 4-5, for further
detail.
As detailed throughout this document CHS
has robust governance arrangements,
procedures and protocols in place to comply
with governing documents such as updated
Governance Policy (approved by the Board 8
Dec 2015)
Detailed throughout this self-assessment
Key
strengthen compliance
Governance – specific expectations
G1.1a
Code
6
G1.1
ciii
scale
No further action
required
CEx
No further action
required
CEx
See TIE 2.1, 2.2.2 and 2.2.4
No further action
required
CSD
Yes
See G2.7
No further action
required
CEx
Yes
See VfM 2.2
No further action
required
CEx
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
3
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Appendix A: Further supporting evidence for standard G1.1a
(previous page)
Generic process and mechanisms through which CHS keeps up with and implements legal requirements and changes:
 Regular cycle of policy and procedure review within each Directorate
 Senior manager tracking of legal, business and professional updates through training events, email briefings, regular updates from independent sources
such as professional bodies
 CEO emails to Heads of Service in response to CEO briefings and media scanning
 CEO updates to Board Members through Chief Executive’s Report, at least quarterly
 team info cascades, from SMG through to front line staff
 quarterly briefing and updates to Operational Managers Group
 Regular staff training programme
 Guidelines for written papers to Board, SMG and Management Team specify requirement to be in line with legal and regulatory changes
 Regular updating by Head of Capital to Audit & Finance Cttee on FRS102 developments
 Quarterly update to HR Cttee on relevant case law developments relating to HR
 Specialist legal advice proactively sought on specific issues - most recently on
o
o
o
o
Gas Servicing
Sleep-in and working time regulations, July 2015
TUPE transfer, August 2015
Companies Act, new FRS102 standard: external auditors, KPMG, reported to 11 Nov 2015 Audit & Finance Committee providing assurance on CHS’ readiness to
implement FRS102 fully.
Specific Recent Examples of CHS’s ”adherence to all relevant law”:
Health & Safety




Twice yearly mentoring and mini-audits, including checking of training records by independent advisor, Helen Ibbotson of SafetyWise Ltd, with bi-annual full audit (last
completed in May 2015)
Health & Safety included on Internal Audit by Mazars, next due in Jan 2016
CHS uses a range of external providers for regular Health & Safety training, for example Moving and Handling for Care, and internal train the trainer
Improved Adverse Incident process introduced 1 Oct 2015 – briefing to Operation Managers Group, 21 Oct, to Older People’s Services Oct 2015, formal 6 mth review
planned Jan 2016
Data Protection




Key
Independent review and recommendations on CHS’s ICT Services by Montal on data security, February 2015
Briefing on Data Security in Housing Associations to Operational Managers Group, 21 Oct 2015 and to Senior Managers Group 15 April 2015
7 Oct 2015 review by Housing Team of guidance note on QL housing management system for staff usage and training.
Project underway to review all Data Sharing Agreements with third parties by Jan 2016
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
4
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Appendix A continued
Gas Servicing





Robust procedure in place for access to carry out gas safety check and ensure compliance;
Procedure is up to and including court action to obtain an injunction to obtain access;
Procedure reviewed in April 15 – now allows access procedure to be brought forward where there are persistent difficulties in obtaining access;
Monthly compliance reported – above 99% for last 18 months;
Weekly tracking reports issued to Property Services Management – any non-compliance (ie Landlord Gas Safety Records out of date) are reported to Management
Team.
Safeguarding
from Safeguarding Policy, approved by Ops Cttee, 11 Nov 2015: section 5, Improvements achieved and identified for action 2015-16:
 Agreed Head of Community Support Services as Safeguarding Lead for CHS, with Head of Older People’s Services, and the two Community Support Managers in
support.
 Reviewed Safeguarding Policy and Procedures for Adults and Children, so in line with Care Act 2014.
 Widened the remit of CHS Annual Safeguarding Review to include all Heads of Service.
 CCTV Policy to explain use of CCTV if any untoward behaviour by staff is recorded – to be agreed by Human Resources Team.
 ½ day training on Safeguarding for CHS Cambourne nursery, 23 Oct 2015, by Gemma Hope, Camb County Council Early Years Safeguarding Lead
 Identified training course for CHS staff in property services, community investment and general housing, to ensure they identify and report any safeguarding concerns
– to be run in 2015-16. Asked HR to include annual ½ day refresher in corporate budget from 2016-17.
 By Oct 2016, programme to widen remit of staff involvement, beyond Community Support Service staff, in identifying any issues with implementing the Safeguarding
policy and procedures.
 Identified the need to ensure our Whistle-blowing Policy and implementation is in line with Safeguarding good practice, so that staff are encouraged to come forward
with safeguarding issues because their identity does not need to be divulged when whistleblowing safeguarding issues. This point is is subject to further work to be
clear about requirements.
 Joined County Council led Working Party on Hoarding, making a major contribution to County-wide protocol development. Hoarding is a sign of self-neglect and
neglect of others where children also present and so amounts to a safeguarding concern when involves adults at risk and children.
 We have recently set up a central Adverse Incidents Log, inlcuding safeguarding (to be maintained by QA Manager) which will enable us to track safeguarding incidents
across the whole organisation, analyse any trends and help direct learning across CHS with the coordination of the CHS Safeguarding Lead.
Impact of legislation relating to National Living Wage

Scenario modelling by HRD for business planning
Preparation for imminent Housing and Planning Bill

Key
Scenario modelling by HoH for impact on eg housing services and rental income
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
5
Ref
Standard
Comply
at 12/15
G1.1di
Governance arrangements
shall ensure that registered
providers safeguard
taxpayers’ interests
[see G2.4 and G2.5]
Yes
G1.1di
i
Governance arrangements
shall ensure that registered
providers safeguard the
reputation of the sector
Governance arrangements
shall ensure that registered
providers have an effective
risk management and
internal controls assurance
framework
Governance arrangements
shall ensure that registered
providers protect social
housing assets
Yes
Registered providers shall
adopt and comply with an
appropriate code of
governance. Areas of noncompliance with their chosen
Yes
G1.1e
G1.1f
G2.1a
Key
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
External assurance: regular external &
internal audit; annual HCA financial viability
review; external review of CandCD Business
plan for Cand CD, reported to CHS Board 16
May 2012. Compliance with NFH 2015 Code
of Governance completed 2015; new
committee structure and terms of reference
agreed by Board Mar 2014; Internal audit
recommendations progress tracked by MTeam and reported to Audit and Finance
Committee quarterly. Annual review of
Financial Regulations and Delegated
Authorities in Sept 2015; Whistle Blowing
policy in place.
See G1.1a and evidence of robust
governance detailed throughout this document.
No further action
required
FD
No further action
required
CEx
Yes
See G2.4 and G2.5
No further action
required
FD
Yes
Mitigations plans in place to protect the
social housing assets from the non-social
activities. For example, CandCD Business
Plan (CandCD being the main vehicle for
carrying out the non-social activities) details
how CHS’s social assets are protected and
what actions will be taken in case the risks
materialise (Contingency buffer of £2m,
limiting CHS on-lending to £4m max).
Independent review of compliance in June
2015 confirmed compliance with 2012 NHF
Code of Governance.
No further action
required
FD
Board Approval
requested for
completed NHF 2015
Code of Governance
Checklist
CGPM
RFOG 25 Nov 2015 reviewed and amended
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
scale
strengthen compliance
12/15
Board approved completed
NHF 2015 Code of
Governance, 8 Dec 2015
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
6
Ref
G2.1b
Standard
code of governance should
be explained.
Governance arrangements
should establish and
maintain clear roles,
responsibilities and
accountabilities for their
board, chair and chief
executive and ensure
appropriate probity
arrangements are in place.
Comply
at 12/15
Yes
G2.1c
Registered Providers should
assess the effectiveness of
their governance
arrangements at least once a
year.
Yes
G2.2
Registered providers shall
ensure that they manage
their affairs with an
appropriate degree of skill,
independence, diligence,
effectiveness, prudence and
foresight (CoP: appropriate
skills strategy, regularly
assess that Board and
Management have the right
competencies, ensure
appropriate, impartial
Yes
Key
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
first draft of NHF 2015 Code of Governance
Compliance Checklist.
Board member and Chair role profiles
reviewed by Board 25 April 2012.
Governance Policy approved by Board 8 Dec
2015.
Delegated authorities and Financial
Regulations reviewed by Board 18 Sept 2014
and 22 Sept 2015
Former Schedule 1 and Conflict of Interest
Policy in place; annual review of declarations
reviewed by Board 10 June 2014.
CEx job description reviewed Nov 2014
Governance arrangements reviewed at
Board away day each year; last
Development Day 25 March 2015.
Committee effectiveness under review
September 2015. New committee structure
and terms of reference agreed by Board 18
March 2014.
Independent review of governance reported
to Board 21 April and 9 June 2015
Internal audit on governance completed July
2015, giving substantial assurance with no
recommendations.
Board members recruited to a job role and
person specification. Board members
appraised by and have regular 121s with the
Chair. Chair has independent appraisal
every 2 years, most recently July 2015.
Board skills reviewed regularly, most
recently 14 July 2015. Board development
plan in place, most recently agreed by Board
21 April 2015.
Independent advice taken for major
decisions, most recently on review of
sheltered housing and residential care 18
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
No further action
required
strengthen compliance
HRD
No further action
required
No further action
required
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HRD
Competency framework
planned for Directors by
autumn 2016.
IDA Model Component 5, on
Overall Governance Control
requires assurance on Board
skills, effectiveness & interface
with the executive
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
7
Ref
G2.3
G2.4
Key
Standard
internal/external advice is
taken for material decisions
and plans to address skills
gap)
Providers shall communicate
in a timely manner with the
regulator on material issues
that relate to non compliance
or potential non-compliance
with the standards.
Registered providers shall
ensure that they have an
appropriate, robust and
prudent business planning
and control framework. (CoP:
must all consider operating
environment). (CoP: should
consider potential
aggregated impact of risks)
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
strengthen compliance
June 2015 and for legal aspects of nurseries
review Sept 2015.
Yes
Yes
Full compliance with the economic standards
– see this self-assessment. On-going
dialogue with our contacts at HCA in place in addition to the usual regulatory returns.
CHS declared a minor non-compliance with
the Rent Standard in January 2015,
discovered through our own auditing.
Long term (30 years) business planning
process in place using the Brixx model.
Annual cycle of business planning and
budget setting.
30 year plan agreed in Sept provides a basis
for the following year’s budget. The Plan is
tested under individual risks as well as
aggregated risks – multi-variant analysis/
stress testing.
Business planning linked to the Corporate
Plan objectives. Business stream business
plan performance reviewed by Board
annually, latest June 2015. Monthly budget
monitoring in place. Group Audit & Finance
Cttee and Board get quarterly financial &
treasury reports, including key financial
indicators, covenants compliance and
forecast cashflows for the following 12
months.
Risk management framework in place,
corporate risk assessment reported to the
A&F Cttee and the Board quarterly. Risks
linked to the corporate objectives. Business
wide risks updated and consolidated into a
Corporate risk register. Self-assessment
against Regulatory Standards considered by
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
Review of the
assurance on
compliance with the
Rent Standard is
underway following
discovery of a breach
on one property
No further action
required
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
CEx
FD
12/15
IDA Model Component 1
focuses on Strategy: “the
clarity of the provider’s
strategic direction, priorities
and its operating markets.”
IDA Model Component 2
focuses on Structure, including
“The interaction between the
provider and the various
organisations …connected to
it; the legal identity of and
activities carried out by all
these organisations; how risks
flow between them;
transactional (including
recourse) arrangements; board
& committee structures and
memberships; and levels of
accountability.”
IDA Model Component 5, on
Overall Governance Control
states “our assessment of the
overall quality of governance
arrangements…will be linked
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
8
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
Board every 2 years, latest 8 Dec 2015.
Independent advice (Altair) sought on good
practice in Group governance arrangements.
G2.4.1
The framework shall ensure:
-
G2.4.1
a
There is access to sufficient
liquidity at all times
Yes
G2.4.1
b
Financial forecasts are based
on appropriate and
reasonable assumption
Effective systems are in place
to monitor and accurately
report delivery of the
registered provider’s plans
Yes
The financial and other
Yes
G2.4.1
c
G2.4.1
Key
Yes
CEx
Nov
15
-
Liquidity position assessed quarterly as part
of treasury reporting. Internal minimum
requirements for 18 months secured
available facility. Generally work to have 3
years secured available facility
Prudent assumptions used based on external
treasury advise and lenders’ expectations
No further action
required
FD
No further action
required
FD
Annual review and update of the corporate
plan, the progress quarterly reported and
monitored by the Board.
Corporate KPIs linking to corporate
objectives monitored quarterly. More
detailed reporting through financial KPIs and
operational KPIs reported to the respective
committees quarterly. Quarterly corporate
risk assessment and reporting also aid in
measuring progress on the plans.
The business plan report is subject to
No further action
required
FD
Business Plan Report
FD
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
Dec
strengthen compliance
to how well providers are
delivering their corporate
strategy and managing the
associated risks.”
IDA Model Component 5, on
Overall Governance Control,
includes “analysing how far we
have assurance that the
provider is mitigating key risks
to acceptable levels. Includes
 Quality of business plans
 Quality of management
reporting & forecasting
 Timely arrangement of
financing
 Overall & specific controls
assurance.
Future business planning
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
9
Ref
Standard
d
implications of risks to the
delivery of plans are
considered
G2.4.1
e
Registered providers monitor,
report on and comply with
their funders’covenants
Yes
G2.4.2
The business planning, risk
and control framework shall
be approved by the
registered provider’s board
and its effectiveness in
achieving the required
outcomes shall be reviewed
at least once a year.
Yes
G2.5
In addition to the above,
registered providers shall
assess, manage and where
-
Key
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
rigorous multi-variant sensitivity testing and
scenario planning. This includes potential
risks, adverse economic assumptions,
operational assumptions (e.g. voids level).
Covenant compliance monitored and
reported quarterly as part of the treasury
reports, reported to the Group A&F Cttee
and reported to the Exec as part of the SMG
pack. Also, monitored at the monthly
Treasury meetings.
Monitoring includes financial as well as nonfinancial compliances
The long-term Business Plan and Annual
Budgets are approved by the Board along
with the Corporate Plan. The Business Plan
and the Budget have robust internal targets
which provide headroom over the lenders’
covenants.
Controls include: Monthly and quarterly
management accounts with cash-flows;
Treasury reporting with covenants
compliance reporting, asset security cover
and non-financial compliance; annual review
of Treasury Policy and Strategy to reflect the
BPlan requirement; Business Stream
Reviews; Annual programme of internal
audits that is linked to risks; Risk
Management framework that is annually
reviewed.
Evidence based Internal Control Statement
prepared and signed-off by the Exec and the
Board
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
with stress testing
against agreed criteria
was reviewed by Board
in Sept & Oct 2015, to
be completed by Jan
16.
No further action
required
scale
strengthen compliance
16
process will include rigorous
multi-variant stress testing.
FD
No further action
required
FD
CT advice re IDA: ensure
business plan assumptions
prudent, especially relating to
resi care
-
FD
IDA Model Component 3
addresses Financial Resilience
- “In-depth analysis of the
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
10
Ref
G2.5a
Standard
appropriate address risks to
ensure the long term viability
of the registered provider,
including ensuring that social
housing assets are protected.
Registered providers shall do
so by:
Maintaining a thorough,
accurate and up to date
record of their assets and
liabilities and particularly
those liabilities that may
have recourse to social
housing assets
Comply
at 12/15
Will
comply
by 3/16
scale
Detailed assets and liabilities register is
currently being developed with view to have
a comprehensive register by Mar 16. Assets
register with key information developed,
plans in place to gather information where
there are gaps. Liabilities in the form of Loans
strengthen compliance
provider’s long term viability:
financial strength & financial
management” with specific
focus on Financial
performance; Debt, liquidity &
future funding; and Cost
structure & efficiency.
Will include log of agreements
created by Housing & Prop
Services, in preparation for
RTB
Comprehensive assets
and liabilities register
being developed
HoC
Dec
15
Further clarification
required of CandCD
and CHS
responsibilities
regarding
development-related
contracts &
employment
arrangements – NFH
2015 Code of Gov will
also be relevant.
HoC
Dec
15
CT advice re IDA – need to be
clear how we know about and
control problems in CandCD
Jan
16
IDA Model Component 4 on
Risk profile & mitigation
requires a “Rounded
assessment of the provider’s
understanding of the
significant risks facing its
in place & will also include HCA defined Disposals
and contract contingent clauses and penalties;
Contract Register both as service provider and
service recipient in place, working on electronic
links to the contracts.
Code
para
34
Boards should ensure that
they have full understanding
of where liabilities exist
between all
entities….including
understanding of how a
failure in one part of the
group may affect other
members of the group
Yes
G2.5b
Carrying out detailed and
robust stress testing against
identified risks and
combinations of risks across
a range of scenarios and
putting appropriate
Will
comply
by 1/16
Key
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
See G2.5a.
CandCD will create own Assets & Liabilities
Register, overseen by CandCD Board and
GCHS A&F Cttee. Multi-variant stress testing
in Nov will address how failure in CandCd
would affect CHS.
25 June 2013 CHS Board Business Plan,
building on 2013 advice from Campbell
Tickell, specifies 1. Scenarios with triggers in
CandCD performance for increased CHS
scrutiny and involvement. 2. Monitoring and
Recording Arrangements whereby CandCD
monthly management accounts must be
checked each month by FD.
Stress testing Board workshop in April 15
with follow-up presentation to Board in June.
Further stress testing of revised business
plan reported to the Board in Sept and Oct
included testing the Plan under different
scenarios to the point of ‘breaking’ the Plan
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
Mitigation policy in
place. Detail on
strategies for
implementation to be
further developed.
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
and
CGPM
FD
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
11
Ref
Standard
Comply
at 12/15
mitigation strategies in place
as a result
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
as well as the aggregated impact – multivariant analysis
strengthen compliance
business and how effectively
through its governance it is
managing them...”, including
specific focus on
Reasonableness of
assumptions, Risk
identification, Stress testing
and Materiality & impact of
risks.
CT advice re IDA: ensure
stress testing includes
 loss of funding or contract,
especially for support &
extra care
 multi-variant scenarios,
including nursery &
CandCD
 management of exit
strategies.
G2.5c
Before taking on new
liabilities, ensuring that they
understand and manage the
likely impact on current and
future business and
regulatory compliance
Will
comply
by 1/16
G2.6
Registered providers shall
ensure that any
arrangements they enter into
do not inappropriately
advance the interest of third
parties, or are arrangements
which the regulator could
reasonably assume were for
such purposes.
Yes
Key
Detailed assets and liabilities register to
include guidance on approval process for
taking on new liabilities. Guidance tabled at
Nov Audit & Finance Cttee. CHS Assets &
Liabilities Register will be reviewed with
Implementation Plan by internal auditors Jan
2016
NHF Code of Conduct is incorporated into
CHS Group Governance Policy, which is
reviewed and signed off by Board annually –
most recently agreed 8 Dec 2015. CHS
Group Board Member Code of Conduct
agreed Sept 2015. Policy on conflict of
interest in place, last updated December
2011.
Guidance for staff on
approval process for
taking on new liabilities
HoC
No further action
required
HRD
Jan
16
Code of Conduct signed by staff on
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
12
Ref
Standard
Comply
at 12/15
G2.7
Registered providers shall
communicate with the
regulator in an accurate and
timely manner. This includes
returns to the regulator,
including an annual report on
any losses from fraudulent
activity, in a form determined
by the regulator.
Yes
G2.8
Registered providers shall
assess their compliance with
the Governance and Financial
Viability Standard at least
once a year. Registered
providers’ boards shall certify
in their annual accounts their
compliance with this
Governance and Financial
Viability Standard.
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
recruitment and then annually. Regular antiBribery staff briefings, most recently to Ops
Managers Group Oct 2015.
All returns completed and submitted in line
with the regulator’s timescales.
Attempted cheque fraud in July was reported
to the HCA Financial Analyst and the
subsequent report by Mazars was also sent
to the Analyst. CHS did not suffer any
financial loss in this incident and Mazars
report provided Substantial assurance on
CHS’s internal processes.
The HCA was unhappy about the detail in 3
lines of information in our March 15
NROSH+ QS return. We had
correspondence about how we had
interpreted the data requirements and the
HCA clarified how we should complete this
information in the future.
Self-assessment considered at Board Sept 15
No further action
required
FD
Any actions agreed by
the Board to
ensure/improve
compliance
CEx
strengthen compliance
tba
3 Governance – specific expectations applicable to specific categories of registered provider: registered group parents/registered providers with
unregistered parents/profit making registered providers. Not relevant to CHS therefore not included in self-assessment
Value for Money standard
1 Required outcomes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
13
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
strengthen compliance
1.1a Registered providers shall articulate and deliver a comprehensive and strategic approach to achieving value for money in meeting their organisation’s objectives
1.1b Their boards must maintain a robust assessment of the performance of all their assets and resources (including for example financial, social and environmental
returns)
1.1c This will take into account the interests of and commitments to stakeholders, and be available to them in a way that is transparent and accessible
1.1d This means managing their resources economically, efficiently and effectively to provide quality services and homes, and planning for and delivering on-going
improvements in value for money
2
Value for Money – specific expectations
VfM
1.1a
VfM
1.1bi
VfM
1.1bii
Key
Registered providers shall
articulate and deliver a
comprehensive and strategic
approach to achieving value
for money in meeting their
organisation’s objectives [see
3.1a]
Boards must maintain a
robust assessment of the
performance of all their
assets (see VfM 1.1bii and
VfM 2.1b) (including for
example financial, social and
environmental returns
Boards must maintain a
robust assessment of the
performance of all their
resources (assets are
covered in VfM 2.1b)
Yes
Evidence detailed in points below, 1.1b –
2.2c
No further action
required
FD
Yes
Social value reporting in place using HACT
methodology for community investment
activity. Financial and social returns
reported as part of the Business Stream
review reporting. It is also reported as part
of the VFM self-assessment.
HACT model social
value reporting to be
extended to
Community Support
Service business
stream.
FD
April
2016
Environmental return is addressed in the
Affordable Energy Strategy.
The Community Investment team provides
energy advice to tenants/residents
This is done through the performance
management framework which links the high
level KPIs to the corporate objectives.
Each committee has suites of KPIs and a
reporting system to assess performance.
Comprehensive financial/treasury reporting
in place.
Clearer measure of
environmental return is
to be developed
FD
Mar
2016
No further action
required
FD
Yes
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
The SAP rating reported. The
outcomes from the CI team in
this area include: energy
saving advice, no. of energy
‘switches’ made resulting from
the advice, no. of energy
vouchers (via the local food
bank) issued
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
14
Ref
VfM
1.1c
VfM
1.1d
VfM
2.1a
VfM
2.1b
Key
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
This assessment of the
performance of assets and
resources will take into
account the interests of and
commitments to
stakeholders, and be
available to them in a way
that is transparent and
accessible
Registered provides must
manage their resources
economically, efficiently and
effectively to provide quality
services and homes, and
planning for and delivering
on-going improvements in
value for money
Registered providers shall:
 have a robust approach
to making decisions on
the use of resources to
deliver the provider’s
objectives, including an
understanding of the
trade-offs and
opportunity costs of its
decisions
Yes
The development scheme appraisal process
is reviewed annually.
See VfM 2.2
Yes
Yes
Registered providers shall:
 understand the return
Yes
No further action
required
FD
See VfM 2.1c
No further action
required
FD
VfM is overseen by the management team to
provide strong focus
VfM Strategy with Action Plan agreed and
approved by the Board 29 Feb 2012, and will
be reviewed by Dec 2015.
Major investment decisions include
evaluation from the VfM prospective – e.g.
see QL PID.
The revised new development evaluation
includes a section on trade-offs and
opportunities
PID is used for major projects and it includes
a section on VFM
Decisions on property sales are carried out
after certain value for money considerations
and alternative use of the assets
The Business Stream Review first developed
in March 2013 and reviewed and further
No further action
required
FD
No further action
required
FD
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
strengthen compliance
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
15
Ref
VfM
2.1c
VfM
2.1d
Key
Standard
on its assets, and have
a strategy for optimising
the future returns on
assets – including
rigorous appraisal of all
potential options for
improving value for
money including the
potential benefits in
alternative delivery
models - measured
against the
organisation’s purpose
and objectives
Registered providers shall:
 have performance
management and
scrutiny functions which
are effective at driving
and delivering improved
value for money
performance
Registered providers shall:
 understand the costs
and outcomes of
delivering specific
services and which
underlying factors
influence these costs
and how they do so.
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
strengthen compliance
reported on in April 2015 includes a model
for measuring return on assets. The return
on assets is reported on each major business
area. Where the return is poor plans are
developed to address this. This includes
consideration of alternative use of property
assets, most recently in the Nurseries
strategic review reported to the Board Sept
15. Decisions to sell property assets are
made after appraisals have been carried out
which include value for money consideration
Yes
Yes
Value for Money indicators are reported to
SMG, Management Team and Audit and
Finance Committee
The performance management reporting
framework includes different levels of
reporting at different levels of the
organisation, starting with Corporate KPIs at
the Board level and the Business
scheme/unit KPIs at the Manager level.
Each committee receives a relevant suite of
KPIs.
A report on the current performance
management framework was presented to
the Audit and Finance Committee in May
2014.
Cost and profitability analysis has been
carried and a number of presentations to
SMG, OMG and the Board have been made.
The annual Business Stream reviews address
the cost and profitability at business unit
level.
Six-monthly meetings with the heads of
services on the progress against business
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
No further action
required
FD
No further action
required
FD
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
16
Ref
VfM
2.2
VfM
2.2a
VfM
2.2b
VfM
2.2c
Ref
Key
Standard
Registered providers’ boards
shall demonstrate to
stakeholders how they are
meeting this standard. As
part of that process, on an
annual basis, they will
publish a robust selfassessment which sets out in
a way that is transparent and
accessible to stakeholders
how they are achieving value
for money in delivering their
purpose and objectives. The
assessment shall:
 enable stakeholders to
understand the return
on assets measured
against the
organisation’s objectives
 set out the absolute and
comparative costs of
delivering specific
services
 evidence the value for
money gains that have
been and will be made
and how these have and
will be realised over
time
Standard
Comply
at 12/15
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
stream targets also address the cost
elements.
A full self-assessment carried out for 2015
and published in Sep 2015
No further action
required
FD
strengthen compliance
A summary of the self-assessment was
included in the Financial statements for 2015
and the CHS Annual Report
Yes
2015 self-assessment includes the return on
assets. The business stream reviews also
include the return on assets for each key
business unit
No further action
required
FD
Yes
2015 self-assessment includes CHS’s yearto-year performance as well as relative
performance using HouseMark
benchmarking results.
CHS has developed an efficiency log to
capture cashable and non-cashable savings.
The log is reported to the VfM Working
Group. The annual VfM self-assessment
reports progress and plans for gains.
VfC staff and customers incentive schemes
in place for the best ideas.
No further action
required
FD
No further action
required
FD
Yes
Comply
at 12/15
Compliance evidence
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
Action required
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
Lead
Time
scale
Comments /Plans to further
strengthen compliance
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
17
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
strengthen compliance
Rent standard (also refer to Rent Standard Guidance April 2015)
1 Required outcomes
1.1 Registered providers shall charge rents in accordance with the objectives and framework set out in the Government’s direction to the regulator of May 2014 and the
Rent Standard Guidance [see 4.1]
2
Rent – specific expectations
R1.1,
2.1
R2.2
R2.2a
1
Registered providers shall
ensure they meet the
following requirements,
which derive from the
Government’s direction to the
regulator of May 2014, and
the ‘key requirements’ set
out in the Rent Standard
Guidance that accompanies
this standard.
Subject to paragraphs R2.3,
2.5 and 2.6, registered
providers shall set rents for
low cost rental
accommodation with a view
to achieving the following:
 Rents conform with the
pattern produced by the
rents formula set out in
the Rent Guidance1
(‘formula rents’) with a
5% upward tolerance on
individual rents (10%
for supported and
sheltered housing) (‘the
limit of the rent
Yes
CHS Rent policy, IT system, process of
annual updates & Internal Audit checks
ensure full compliance, as detailed in R2.2.
Minor breach of the Rent Standard, reported
to the HCA in Jan 2015, detailed in G2.3.
No further action
required
HoH
Yes
Detailed in R2.2a to R2.2e
-
HoH
Yes
The Housing IT system holds the full history
of target rents since 2003. These are
updated on an annual basis to ensure
appropriate rent increases and compliance
with target rents. This is checked by Internal
Auditors. From April 2014 CHS decided to
apply 105% Target Rents for general needs,
sheltered and extra care homes and already
applies 110% Target Rents to supported
housing
No further action
required
HoH
Rents in sheltered /extra care
accommodation follow general
needs pattern and conform Care Home fees set
independently by Board
The Rent Guidance means the Guidance on Rents for Social Housing issued by the Government on 23 May 2014 and any other guidance issued by the Government in relation to that document.
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
18
Ref
R2.2b
Standard

R2.2c

R2.2d

R2.2e

R2.3
Key
flexibility level’) but
subject to the maximum
rent levels specified in
that guidance (‘rent
caps’).
Weekly rent for
accommodation
increases each year by
an amount which is no
more than CPI + 1%
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
strengthen compliance
The calculation and process is also included
in the CHS Rent Policy
Yes
Weekly rent for
accommodation which is
above the upper limit of
the rent flexibility level
increases each year by
an amount which is less
than CPI + 1%, until it
reaches the limit of the
rent flexibility level
Rent caps increase
annually by CPI + 1.5%
Yes
Formula rents increase
annually by CPI + 1%
Yes
The requirements of
paragraph 2.2 do not apply
to accommodation let on
Affordable Rent terms.
Subject to paragraph 2.6,
N/A
Yes
This is calculated and updated on an annual
basis by the Head of Housing using our
Housing IT system.
(In April 2015 rents increased by CPI+1%
(2.2%) or CPI only in a few cases where
current rent exceeded Target.. This is
documented in relevant Board Reports)
General needs - This is calculated on an
annual basis using a capping mechanism in
our Housing IT system. It was necessary in
April 2015 to increase just a small number of
rents by CPI only where the current rent
exceeded the Target.
For general needs and sheltered / extra care
housing this is checked annually by the
Head of Housing. No current rents are close
to the Rent caps.
For general needs and sheltered /extra care
housing, target rents are uplifted within our
Housing IT system and checked by the Head
of Housing. From April 2015 CHS increased
by CPI + 1% - this is documented in
relevant Board Reports)
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
No further action
required
HoH
No further action
required
HoH
No further action
required
HoH
No further action
required
HoH
No further action
required
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
CHS does not let on Affordable
Rent terms
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
19
Ref
R2.3a
R2.3b
R2.3c
R2.4
Key
Standard
where accommodation is let
on Affordable Rent terms,
registered providers shall set
rents with a view to
achieving the following:
 Rent for accommodation
(inclusive of service
charges) is set at a level
which is no more than
80% of the estimated
market rent for the
accommodation
(inclusive of service
charges), based on a
valuation in accordance
with a method
recognised by the RICS.

Rent for accommodation
increases each year by
an amount which is no
more than CPI + 1%
 Rent for accommodation
is re-set, based on a
new valuation, each
time the accommodation
is:
a) let to a new tenant, or
b) re-let to the same tenant
(but where a probationary
tenancy comes to an end and
the registered provider relets the accommodation to
the same tenant the provider
is not required to re-set the
rent).
Affordable Rent terms can
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
strengthen compliance
N/A
No further action
required
CHS does not let on Affordable
Rent terms
N/A
No further action
required
CHS does not let on Affordable
Rent terms
N/A
No further action
required
CHS does not let on Affordable
Rent terms
N/A
No further action
CHS does not let on Affordable
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
20
Ref
R2.5
R2.6
Key
Standard
only be used in relation to
accommodation provided
pursuant to a housing supply
delivery agreement entered
into between a registered
provider and the Homes and
Communities Agency (HCA)
or the Greater London
Authority (GLA).
The Rent Standard shall not
apply to rental
accommodation let by
registered providers to a
social housing tenant
household during a financial
year where the household
income was £60,000 or more
in the tax year which ended
in the final year preceding
the financial year in which
the Rent Standard will not
apply.
Where the application of the
Rent standard would cause
providers to be unable to
meet other standards,
particularly in respect of
financial viability including
the risk that a reduction in
overall rental income causes
them to risk failing to meet
existing commitments such
as banking or lending
covenants, the regulator may
agree to waive specific
requirements of the Rent
Standard for a period of
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Compliance evidence
Action required
Lead Time Comments /Plans to further
scale
required
Rent terms
N/A
No properties are let by CHS on this basis in
relation to income.
No further action
required
HoH
N/A
CHS meets Rent standard
No further action
required
HoH
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
strengthen compliance
Government is terminating
rent convergence before all
target rents have been
achieved
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
21
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Consumer Regulations
See Consumer Regulation Guidance April 2015
The Housing and Regeneration Act 2008 (the Act) places a restriction on the regulator’s ability to use its powers in relation to a provider
failing to meet a consumer standard. The regulator may use its regulatory and enforcement powers only if it thinks that a standard has
Ref
Standard
Comply
at 12/15
Compliance evidence
Action required
Lead
Yes
This is available in the tenancy agreement,
tenancy handbook, website and online
leaflet
No further action
required
HoH
Time
scale
Comments /Plans to further
strengthen compliance
time.
R2.7
Key
Registered providers shall
provide clear information to
tenants that explains how
their rent and any service
charge are set, and how they
are changed, including
reference to the CPI
benchmark to which annual
changes to rents should be
linked (except where rents
are controlled under different
legislation).
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
Also applies to Older Peoples’
and supported housing
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
22
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
been failed and there are reasonable grounds to suspect that:
• The failure has resulted in a serious detriment to the provider’s tenants (or potential tenants), or
• There is a significant risk that, if no action is taken by the regulator, the failure will result in a serious detriment to the provider’s
tenants (or potential tenants)
Tenant Involvement and Empowerment standard
1
1.1
Required outcomes
Customer service, choice and complaints
Registered providers shall:
1.1a) provide choices, information and communication [see TIE 1.1a] that is appropriate to the diverse needs of their tenants in the delivery of all standards [see TIE 2.3.1]
1.1b) have an approach to complaints that is clear, simple and accessible that ensures that complaints are resolved promptly, politely and fairly [see TIE 2.1.2a]
1.2
Involvement and empowerment
Registered providers shall ensure that tenants are given a wide range of opportunities to influence and be involved in:
1.2a) the formulation of their landlord’s housing related policies and strategic priorities (see TIE 2.2.4 – covers housing related strategic priorities)
1.2b) the making of decisions about how housing related services are delivered, including the setting of service standards (see TIE 2.2)
1.2c) the scrutiny of their landlord’s performance and the making of recommendations to their landlord about how performance might be improved (see TIE 2.2.1c and 2.2)
1.2d) the management of their homes, where applicable (see TIE 2.2.1a)
1.2e) the management of repair and maintenance services, such as commissioning and undertaking a range of repair tasks, as agreed with landlords, and the sharing in
savings made (see additional point TIE 1.2e)
1.2f) agreeing local offers for service delivery (see TIE 2.2)
1.3
Understanding and responding to the diverse needs of tenants
Registered providers shall:
1.3a) treat all tenants with fairness and respect (see additional point TIE 1.3a)
1.3b) demonstrate that they understand the different needs of their tenants, including in relation to the equality strands and tenants with additional support needs (see
TIE 1.1a)
2.1
Customer service, choice and complaints – specific expectations
Ref
Standard
Comply
at 12/15
Compliance evidence
Action required
Lead
TIE
1.1a
Registered providers shall provide
choices, information and
communication that is appropriate
Yes
(see TIE 2.3.1)
No further action required
CSD
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
Timescale
Comments / Plans to further
strengthen compliance
Information is available in the
tenancy handbook, on the
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
23
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
website, in leaflet form and in
the sign up packs. CHS has
published service standards
available on the website and
reviewed them in 2013/14 (see
Operations Committee reports).
Annual Report summarises
performance against standards;
quarterly reports are produced
for Customer Committee on
performance of repairs and
maintenance services.
to the diverse needs of their
tenants in the delivery of all
standards
TIE
1.2a
TIE
1.2b
TIE
1.2c
Ref
Registered providers shall ensure
that tenants are given a wide
range of opportunities to influence
and be involved in the formulation
of their landlord’s housing related
policies and strategic priorities
Registered providers shall ensure
that tenants are given a wide
range of opportunities to influence
and be involved in the making of
decisions about how housing
related services are delivered,
including the setting of service
standards
Registered providers shall ensure
that tenants are given a wide
range of opportunities to influence
and be involved in the scrutiny of
their landlord’s performance and
the making of recommendations
to their landlord about how
performance might be improved
Standard
Yes
(see TIE 2.2.4 – covers
housing related strategic
priorities)
No further action required
CSD
Yes
(see TIE 2.2.2)
No further action required
CSD
Yes
(see TIE 2.2.1c and 2.2.2)
No further action required
CSD
Comply
at 12/15
Compliance evidence
Action required
Lead
Yes
Tenants are part of tendering
and commissioning panels for
new contracts, and also have
places on the core group that
monitors the performance of
No further action required
HPS
TIE
1.2e
Registered providers shall ensure
that tenants are given a wide
range of opportunities to influence
and be involved in the
management of repair and
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
Timescale
Comments / Plans to further
strengthen compliance
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
We do not offer tenants the
opportunity of carrying out
repair works themselves as the
lessons of the pilot projects were
not encouraging. We have no
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
24
Ref
Standard
Comply
at 12/15
maintenance services, such as
commissioning and undertaking a
range of repair tasks, as agreed
with landlords, and the sharing in
savings made
TIE
1.3a
Registered providers shall treat all
tenants with fairness and respect
TIE
2.1
Registered providers shall provide
tenants with accessible, relevant
and timely information about:
 how tenants can access
services
TIE
2.1a
Yes
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
those contracts once in place.
Estate inspectors are
recruited from among
tenants, and meet regularly
with the contractors and CHS
staff to scrutinise the estates
management service.
Respect is a core CHS value,
and is covered in corporate
induction as well as in local
inductions. This behaviour is
reinforced by training in our
code of conduct. Our
complaints process deals with
any alleged breaches of this
standard of behaviour.
Fairness is delivered through
the application of our policies,
procedures, and service
standards. Our allocations
are managed through the
local authority’s choice based
letting scheme.
See TIE 2.1a to 2.1h
Information is available in the
tenancy handbook, on the
website, in leaflet form and in
the sign up packs
CHS service standards
(reviewed 2013 – 15) are
published on the website and
in the Tenancy Handbook.
Tenants are reminded of
revisions & updates in CHS’
service standards in quarterly
TIE
2.1b

Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
the standards of housing
services their tenants can
expect
Yes
immediate plans to consult over
tenants carrying out repairs and
are focussing on their top
priority of improving our repairs
service.
No further action required
CSD
No further action required
CSD
No further action required
CSD
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
25
Ref
Standard
Comply
at 12/15
TIE
2.1c

how they are performing
against those standards
Yes
TIE
2.1d

the service choices available
to tenants, including any
additional costs that are
relevant to specific choices
Yes
TIE
2.1e

progress of any repairs work
Yes
TIE
2.1f

how tenants can
communicate with them and
provide feedback
Yes
TIE
2.1g

the responsibilities of the
tenant and provider
Yes
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
Newsletter.
Annual report to tenants
summarises performance
against standards
No further action required
CSD
There are currently no
permanent additional choices
available within our housing and
property service, but we consult
over the service charges and
what is included in them, and
within the Service Standards.
No further action required
CSD
This is available directly from
our main contractor for most
responsive repairs, or from
our Customer Services Team
by phone or by email via
[email protected] We
plan to introduce a web
portal that will allow tenants
to follow repairs progress.
Handbook and Newsletters
include ways of
communicating with CHS.
We have a Tenant Scrutiny
panel – see TIE2.1h We have
a Customer Feedback
Standard and a ‘how to be
involved leaflet’
Information is available in the
tenancy handbook, on the
website, in leaflet form and in
the sign up packs; this
includes a clear Complaints
Policy, reviewed in April 2015.
A Scrutiny Panel has been
established and full training
provided. Scrutiny chair is
Redevelopment of CHS
website is included in our
Corporate Plan for 2014-16
and will include a customer
portal.
CSD
No further action required
CSD
No further action required
CSD
No further action required
CSD
TIE
2.1h
arrangements for tenant
involvement and scrutiny
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
There are no plans for exploring
offering additional choices.
By June
2016
By Jan
2016
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
26
Ref
TIE
2.1.2
a
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
mentored by external
business consultant. The
Scrutiny Panel presented its
first findings, on Voids, in
Spring 2014. The most
recent report, on tenant
feedback, was reported to the
Board in September 2015. A
report on the Scrutiny Panel
recommendations was
included in Dec 2014 CHS
Customer Newsletter.
CHS has a comprehensive
complaints procedure
covering these points,
reviewed during 2014 with
our Customer Complaints
Panel and launched in April
2015. Information is also
available in the tenants’
handbook, on the website, in
leaflets. Staff are also trained
on handling complaints.
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 accept complaints
made by advocates authorised to
act on a tenant’s/tenants’ behalf.
Providers shall inform tenants how
they use complaints to improve
their services.
Yes
TIE
2.1.2
c
Registered providers shall publish
information about complaints each
year, including their number and
nature, and the outcome of the
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
TIE
2.1.2
b
Yes
Feedback is given to the
tenant making the complaint,
and more generally as part of
the annual report to tenants,
and in reports to the
Customer Committee. We
have an annual review of
lessons learned by
Complaints Panel
Annual Report summarises
this. Customer Committee
also receives an annual report
and lessons CHS has learned
No further action required
CSD
No further action required
CSD
No further action required
CSD
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
We have a trained Customer
Complaints Panel, recognised by
CHS and registered with the
Ombudsman.
Nov 2015
The Complaints Panel will agree
how it wants to review the
outcomes of complaints.
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
27
Ref
Standard
Comply
at 12/15
complaints.
2.2
TIE
2.2.1
TIE
2.2.1
a
TIE
2.2.1
b
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Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
as a result.
Involvement and empowerment – specific expectations
Registered providers shall support
their tenants to develop and
implement opportunities for
involvement and empowerment,
including by:
 supporting their tenants to
exercise their Right to
Manage or otherwise exercise
housing management
functions, where appropriate

See TIE 2.2 1a to 2.2 1d
Yes
supporting the formation and
activities of tenant panels or
equivalent groups and
responding in a constructive
and timely manner to them
Yes
the provision of timely and
relevant performance
information to support
effective scrutiny by tenants
of their landlord’s
performance in a form which
registered providers seek to
agree with their tenants.
Such provision must include
the publication of an annual
report which should include
Yes
-
Housing Strategy, agreed by
Ops Cttee 11 Nov 2015,
includes provision of support
to leaseholders who wish to
exercise their Right to
Manage or any customers
who wish to exercise housing
management functions e.g.
estate services.
CHS has dedicated resources
to respond to tenants,
including staff resources, a
budget for tenant lead
initiatives (Neighbourhood
Grant) and financial resources
to support tenants
associations.
An annual report is published
for customers which includes
data on repair and
maintenance budgets and its
content is led by a customer
group. CHS provides data to
a Customer Committee, which
meets quarterly.
Performance information also
published periodically in the
Residents’ Newsletter, last
TIE
2.2.1
c

Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CSD
CSD
No further action required
CSD
No further action required
CSD
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
28
Ref
Standard
information on repair and
maintenance budgets, and
providing support to tenants
to build their capacity to be
more effectively involved
Comply
at 12/15

TIE
2.2.2
Registered providers shall consult
with tenants on the scope of local
offers for service delivery. This
shall include how performance will
be monitored, reported to and
scrutinised by tenants and
arrangements for reviewing these
on a periodic basis.
Yes
TIE
2.2.3
Registered providers shall consult
with tenants, setting out clearly
the costs and benefits of relevant
options, if they are proposing to
change their landlord or when
proposing a significant change in
their management arrangements.
Registered providers shall consult
tenants at least once every three
Yes
Key
strengthen compliance
December 2014.
TIE
2.2.1
d
TIE
2.2.4
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
Yes
Yes
CHS has a policy for
supporting tenants who meet
certain involvement criteria
with training and
development. Customer
Involvement Standard was
updated on this in May 2015.
At customer request, one
local offer applies over our
restricted geographical
operational area. Local offers
originally agreed by Customer
Committee in 2010.
Scrutiny panel has reviewed
Voids, recommendations
accepted by Board in 2014.
The Scrutiny Panel has
reviewed Customer Feedback,
recommendations agreed by
the Board Sept 2015.
Customers have been
involved in an external review
of our responsive repairs
service which led to new
contracts and processes in
place from April 2015
Consultation takes place over
all significant changes in
services or service
management.
No further action required
CSD
No further action required
CSD
No further action required
CSD
Formal tenant scrutiny
arrangements are in place
No further action required
CSD
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
Nov 2015
Formal 3-yearly consultation with
tenants on the best way of
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
29
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
years on the best way of involving
tenants in the governance and
scrutiny of the organisation’s
housing management service.
2.3
with a Scrutiny panel – see
6.2. Survey sent out in
March 2015. Results
published in July 2015
Newsletter and reviewed by
Customer Cttee and by Nov15
Ops Cttee.
Housing Strategy, agreed by
Nov 15 Ops Cttee, stipulates
customer consultation at least
every three years on the best
way of involving them in the
governance and scrutiny of
CHS’s housing management
service.
Understanding and responding to diverse needs – specific expectations
TIE
2.3.1
Registered providers shall
demonstrate how they respond to
tenants’ needs in the way they
provide services and communicate
with tenants.
Yes
CHS records information in its
tenant database on
communication preference
and records information on
disabilities/personal needs,
vulnerability and safeguarding
which may impact on service
delivery requirements.
Tenant communication
preferences are also sought
and communicated through
the Customer Committee,
door knocking data and
informal feedback through
Housing Officers’ day to day
contact. Our Housing
Management system records
client data for employees
and, in an edited and codified
format for contractors, on
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
No further action required
involving them in the
governance and scrutiny of our
housing management service is
now in progress, and the results
will be built into our new
Community Partnerships
Strategy
CSD
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
During 2015/16 we will develop
our database to further identify
levels of support required for
certain customers, and connect
this more clearly with processes
e.g. gas safety, tenancy
sustainment.
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
30
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
how they need to tailor
services for customers. Data
protection legislation is
embedded in all contracts and
in employee policies,
procedures and training on
sharing sensitive personal
information eg Policy &
Procedure for holding
sensitive personal data in QL
system, reviewed Oct 2015.
Home standard
1
1.1
Required outcomes
Quality of accommodation
Registered providers shall:
a) ensure that tenants’ homes meet the standard set out in section five of the Government’s Decent Homes Guidance 2 and continue to maintain their homes to at least this
standard [see H2.1.1]
b) meet the standards of design and quality that applied when the home was built, and were required as a condition of publicly funded financial assistance3, if these
standards are higher than the Decent Homes Standard [see additional point H1.1b]
c) in agreeing a local offer, ensure that it is set at a level not less than these standards and have regard to section six of the Government’s Decent Homes Guidance
[included in bullet points above]
1.2
Repairs and maintenance
Registered providers shall:
a) provide a cost-effective repairs and maintenance service to homes and communal areas [see 9.1] that responds to the needs of [see TIE 2.3.1], and offers choices to
[see 5.1d], tenants, and has the objective of completing repairs and improvements right first time [see additional point 9.3]
b) meet all applicable statutory requirements that provide for the health and safety of the occupants in their homes [see additional point 9.4]
‘Decent Homes Guidance’ means A Decent Home: Definition and Guidance for Implementation, published by the Department for Communities and Local Government in June 2006, and any
guidance issued by the department or its successors, in relation to that document.
3
‘Financial assistance’ is assistance given by the Homes and Communities Agency (HCA) under section 19(3) of the Housing and Regeneration Act, 2008; and (with effect from 1 April 2012) given
by the Greater London Authority (GLA). For the purpose of this standard, it includes financial assistance provided by predecessor bodies to the HCA.
2
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
31
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
2.1
Quality of accommodation – specific expectations
H1.1
a
Registered providers shall ensure
that tenants’ homes meet the
standard set out in section five of
the Government’s Decent Homes
Guidance4 and continue to
maintain their homes to at least
this standard [see H2.1.1]
Yes
H1.1
b
Registered providers shall meet
the standards of design and
quality that applied when the
home was built, and were
required as a condition of publicly
funded financial assistance, if
these standards are higher than
the Decent Homes Standard
Yes
H1.1
c
Registered providers shall in
agreeing a local offer, ensure that
it is set at a level not less than
these standards and have regard
to section six of the Government’s
Decent Homes Guidance [included
in bullet points above]
H1.2
ai
Registered providers shall provide
a cost-effective repairs and
All homes meet DHS
standards, apart from six, as
reported to the Ops
Committee in Sept: three of
these are due to the
customer refusing the works.
The remaining three are
planned as a priority and had
not been completed by the
end of March as a result of a
change in our maintenance
contractors at the start of
April.
As far as we are aware we
are compliant but are doing
additional work, especially on
properties with a historical
legacy.
The required works are
programmed for completion
prior to end of March 2016.
Additional measures are
being put in place to
identify possible failures in
advance and ensure works
are programmed to avoid
failures.
HPS
March
2016
Data on extra design &
quality requirements for
publicly funded schemes to
be built into QL system to
ensure properties continue
to meet these standards
HPS
Dec 2015
Yes
Standards agreed are above
Decent Homes Standard
No further action required
HPS
Yes
Contracts are tendered using
OJEU procedures for delivery
No further action required
HPS
Update following work on QL
See Page 1 and Page 2 above,
Action 8.2.
‘Decent Homes Guidance’ means A Decent Home: Definition and Guidance for Implementation, published by the Department for Communities and Local Government in June 2006, and any
guidance issued by the department or its successors, in relation to that document.
4
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
32
Ref
Standard
Comply
at 12/15
maintenance service to homes
and communal areas [see H2.2.1]
that responds to the needs of [see
TIE 1.1a], and offers choices to
[see TIE 2.1d], tenants
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
of repairs and maintenance.
Customers are involved in the
procurement process through
membership of the project
team. The award criteria are
set with customers, and are
based on 40% cost:60%
quality. The contractors are
required to take account of
customers’ needs and to offer
choices where appropriate.
Completing work ‘right first
time’ (in line with Housemark
definition) is an objective
included in all our contracts
with maintenance
contractors. It is now
included in new Responsive
Repairs contract, as a key
performance indicator, is
measured and performance
reported to Operations
Committee on a quarterly
basis.
There is a wide range of
provision, with regular
certification, testing and
awareness training,
supported by our QA system
and QL database, to ensure
health and safety in CHS
housing to meet the HHSRS,
Decent Homes, Fire Safety,
Water Safety, and Gas Saftey,
and other requirements. This
includes: regular property
inspections; gas servicing;
H1.2
aii
Registered providers shall provide
a cost-effective repairs and
maintenance service to homes
and communal areas [see H2.2.1]
that has the objective of
completing repairs and
improvements right first time
Yes
H1.2
b
Registered providers shall meet all
applicable statutory requirements
that provide for the health and
safety of the occupants in their
homes
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
No further action required
HPS
No further action required
HPS
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
Dec 2015
Recent changes implemented to
take account of changing
regulation/best practice;
 Asbestos Management Policy
update May 2014;
 Water Risk Management
Policy introduced August 2014
 Annual Gas Safety Access
Procedure updated April 2015
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
33
Ref
H2.1
.1
2.2
Standard
Registered providers may agree
with the regulator a period of noncompliance with the Decent
Homes Standard, where this is
reasonable. Providers shall ensure
their tenants are aware of the
reasons for any period of noncompliance, their plan to achieve
compliance and then report on
progress delivering this plan.
Comply
at 12/15
Yes
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Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
legionella testing; fire risk
assessments, fire equipment
testing; fire alarms testing;
PAT testing of electrical
goods; asbestos register;
daily, weekly, and monthly
health and safety checks.
CHS Strategy is to always
bring homes up to Decent
Homes Standard.
No further action required
HPS
No further action required
HPS
No further action required
HPS
Mar 16
Repairs and maintenance – specific expectations
H2.2
.1
Registered providers shall ensure
a prudent, planned approach to
repairs and maintenance of homes
and communal areas. This should
demonstrate an appropriate
balance of planned and responsive
repairs, and value for money. The
approach should include:
responsive and cyclical repairs,
planned and capital work, work on
empty properties, and
adaptations.
Yes
The approved asset
management strategy
delivers this, along with the
resulting programme of
planned and cyclical works.
In January 2012 we let a new
voids repairs contract on a
partnering basis. New
contracts for Responsive
Repairs, and Planned and
Cyclical Maintenance were
operational from April 15 with
value for money savings. The
Asset Management Strategy
will be reviewed by the Board
in October 15.
Assessments by Occupational
H2.2
Registered providers shall co-
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
34
Ref
Standard
.2
operate with relevant
organisations to provide an
adaptations service that meets
tenants’ needs.
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
Therapists and Adult Social
Care are made for all tenants
who may require adaptations,
either as they move in, or as
they develop the need for
such adaptations. Aids and
Adaptations Policy last
reviewed November 14
Tenancy standard
1 Required outcomes
1.1
1.1.1
Allocations and mutual exchange
Registered providers shall let their homes in a fair, transparent and efficient way (see T2.1.1, T2.1.4, T2.1.5, T2.1.7). They shall take into account the housing
needs (see T2.1.1) and aspirations (see additional point T1.1.1i) of tenants and potential tenants. They shall demonstrate how their lettings:
a) make the best use of available housing (see T2.1.2a)
b) are compatible with the purpose of the housing (see additional point T1.1.1ii)
c) contribute to local authorities’ strategic housing function and sustainable communities (see T2.1.1)
There should be clear application, decision-making (see T2.1.4) and appeals processes (see additional point T1.1.1iii).
1.1.2
Registered providers shall enable their tenants to gain access to opportunities to exchange their tenancy with that of another tenant, by way of
mutual exchange services.
1.2
1.2.1
internet-based
Tenure
Registered providers shall offer tenancies or terms of occupation which are compatible with the purpose of the accommodation, the needs of individual households,
the sustainability of the community, and the efficient use of their housing stock (see additional point T1.2.1).
1.2.2
They shall meet all applicable statutory and legal requirements in relation to the form and use of tenancy agreements or terms of occupation (see additional point
T1.2.2).
2.1
Key
Allocations and mutual exchange – specific expectations
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
35
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
Ref
Standard
Comply
at 12/15
T1.1.
1i
Registered providers shall let their
homes in a way which takes into
account the housing aspirations of
tenants and potential tenants
Yes
T1.1.
1ii
Registered providers shall
demonstrate how their lettings are
compatible with the purpose of
the housing
Yes
T1.1.
1iii
Registered providers shall
demonstrate how their lettings
have clear application, decisionmaking and appeals processes
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
strengthen compliance
We take applications via
home-link, so new applicants
are placed on the housing
waiting list via the criteria of
the relevant housing local
authority; transfers also go
through this process.
Residents then bid for their
chosen property, which
allows resident to choose the
location, type and style of
property which they feel best
suits their needs and
aspirations
We place our vacant
properties on home-link and
ensure that we describe the
property accurately. Where
we have experienced lower
demand for 2 bedroomed
flats since April 2013 we have
agreed a more flexible local
lettings plan with the relevant
LA which allows for some
(risk-assessed) underoccupation to avoid long
voids. We keep clear records
of any local connection
requirements which mainly
impact rural exception sites
and are included in any
Homelink adverts as
necessary.
This is included in our
Lettings Policy.
No further action required
HoH
No further action required.
HoH
No further action required.
HoH
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
36
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
Ref
Standard
Comply
at 12/15
T1.2.
1
Registered providers shall offer
tenancies or terms of occupation
which are compatible with the
purpose of the accommodation,
the needs of individual
households, the sustainability of
the community, and the efficient
use of their housing stock
Yes
T1.2.
2
Registered providers shall meet all
applicable statutory and legal
requirements in relation to the
form and use of tenancy
agreements or terms of
occupation
Yes
T1.1.
1c,
T2.1.
1
Registered providers shall cooperate with local authorities’
strategic housing function, and
their duties to meet identified
local housing needs. This includes
assistance with local authorities’
homelessness duties, and through
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
strengthen compliance
We currently offer starter
tenancies and assured
tenancies in general needs
housing. Starter tenancies
afford the tenant 12 months
to settle into their properties
and enables CHS to deal with
any issues that arise, before
granting a full Assured
tenancy. We reviewed our
approach to tenure in
February 2015 and agreed to
retain ‘Lifetime’ tenancies.
Instead we introduced a new
tenancy condition requiring
households to accept
alternative accommodation if
under-occupied by two or
more bedrooms, to aid
efficient use of housing stock.
CHS complies with all legal
requirements in terms of
tenancy terms and conditions.
We had our Starter tenancy
agreement reviewed by a
specialist lawyer to allow
tenancies to start on any
weekday and to introduce the
clause mentioned in 10.15
above.
CHS currently works with a
number of strategic partners,
through choice based lettings
and Service Level
Agreements. We also are
mindful of the implications of
local lettings plans, choice
No further action required.
HoH
No further action required.
HoH
No further action required
HoH
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
37
Ref
Standard
Comply
at 12/15
meeting obligations in
nominations agreements.
T2.1.
2a
Registered providers shall develop
and deliver services to address
under-occupation in their homes,
within the resources available to
them. These services should be
focused on the needs of their
tenants, and will offer choices to
them.
Yes
T2.1.
2b
Registered providers shall develop
and deliver services to address
overcrowding in their homes,
within the resources available to
them. These services should be
focused on the needs of their
tenants, and will offer choices to
them.
Registered providers’ published
policies shall include how they
have made use of common
housing registers, common
allocations policies and local
letting policies.
Registered providers shall clearly
set out, and be able to give
reasons for, the criteria they use
Yes
T2.1.
3a
T2.1.
3b
Key
Yes
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
based lettings protocols, and
the housing strategies of local
authorities when developing
our lettings and tenure policy.
CHS is also an elected
member of the regional
Homelink Board.
CHS has remained in contact
with those customers affected
by the under-occupation
penalty and continues to
review their choices and to
remind them of our financial
assistance to downsize (up to
£900). We have signed up to
the sub-regional underoccupation strategy and we
meet the partners regularly to
share good practice and
resources.
CHS actively works with
Homelink and Homeswapper
to support residents who are
overcrowded. We have used
Direct Lets to accelerate
necessary up-sizing and we
use doorknocking visits to
update household details
This information is held in our
Lettings policy and Tenancy
Handbook
This information is held in our
Lettings policy and Tenancy
Handbook
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
No further action required.
HoH
No further action required
HoH
No further action required
HoH
No further action required
HoH
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
38
Ref
T2.1.
4
T2.1.
5
T2.1.
6
Standard
for excluding actual and potential
tenants from consideration for
allocations, mobility or mutual
exchange schemes.
Registered providers shall develop
and deliver allocations processes
in a way which supports their
effective use by the full range of
actual and potential tenants,
including those with support
needs, those who do not speak
English as a first language and
others who have difficulties with
written English.
Registered providers shall
minimise the time that properties
are empty between each letting.
When doing this, they shall take
into account the circumstances of
the tenants who have been
offered the properties.
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
Yes
CHS offers translation
services to support residents
who need additional support.
We have an annual budget
for translation /. Interpreting
which is well used each year.
Additional support provided
by Housing Officers and
Advice Services.
No further action required
HoH
Yes
Our performance on relet
times for general needs was
13.5 days between April 2014
and March 2015; and 13.4
days between April and
September 2015. We
negotiated a shorter
turnaround target with our
voids contractor and start
tenancies on any weekday.
CHS uses digital core and its
use is periodically checked in
internal audits.
No further action required
HoH
No further action required
HoH
This information is available
in the Tenant Handbook,
website and customer
services, plus marketing
material for specialist housing
available
We have an annual
subscription to homeswapper
and promote it to customers.
No further action required
HoH
No further action required
HoH
Registered providers shall record
all lettings and sales as required
by the Continuous Recording of
Lettings (CORE) system.
Registered providers shall provide
tenants wishing to move with
access to clear and relevant
advice about their housing
options.
Yes
T1.1.
2,
T2.1.
Registered providers shall
subscribe to an internet based
mutual exchange service (or pay
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
T2.1.
7
Yes
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
April 2016
Scrutiny Panel Voids review
reduced property void time from
20 days to 13.5 days.
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
39
Ref
Standard
8
the subscriptions of individual
tenants who wish to exchange),
allowing:
 a tenant to register an interest
in arranging a mutual
exchange through the mutual
exchange service without
payment of a fee
 the tenant to enter their
current property details and
the tenant’s requirements for
the mutual exchange property
they hope to obtain
 the tenant to be provided with
the property details of those
properties where a match
occurs
Registered providers shall ensure
the provider of the internet based
mutual exchange service to which
they subscribe is a signatory to an
agreement, such as HomeSwap
Direct, under which tenants can
access matches across all (or the
greatest practicable number of)
internet based mutual exchange
services.
Registered providers shall take
reasonable steps to publicise the
availability of any mutual
exchange service(s) to which it
subscribes to its tenants.
T2.1.
9
T2.1.
10
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
Yes
This is achieved via our
annual subscription to
homeswapper
No further action required
HoH
Yes
Information is available via
our website, through a
website link, in the tenants
handbook, in the lettings
policy and advertised in
tenant newsletters
Computer access can be
provided via our head office.
In specialist housing, support
workers can give individual
No further action required
HoH
No further action required
HoH
T2.1.
11
Registered providers shall provide
reasonable support in using the
service to tenants who do not
have access to the internet.
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
40
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
support to vulnerable tenants.
In general housing officers
visit with internet-enabled
tablets to complete online
applications.
2.2
T2.2.
1
T2.2.
1i
Tenure – specific expectations
Registered providers shall publish
clear and accessible policies which
outline their approach to tenancy
management, including setting
out:
Interventions to sustain tenancies
and prevent unnecessary evictions
Yes
See T2.2.1i to T2.2.1j
-
HoH
Our approach is included in
our ASB and Arrears policies,
publicly available; we make
use of both internal expertise
on supporting vulnerable
customers and other
agencies.
We take prompt action when
cases are identified and
gather evidence e.g. electoral
roll checks. For new tenancies
we take copies of ID. Fraud
policy was reviewed in 2014.
Our policies state that we
give Starter tenancies in
general needs housing
leading to Assured tenancies,
and Assured tenancies in
Older Peoples Services. We
do not offer fixed term
tenancies.
No further action required
HoH
No further action required
HoH
No further action required
HoH
T2.2.
1ii
Tackling tenancy fraud
Yes
T2.2.
1a

The type of tenancies they will
grant.
Yes
T2.2.
1b

Where they grant tenancies
for a fixed term, the length of
those terms.
N/A
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
No further action required
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
CHS does not offer fixed term
tenancies
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
41
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
Ref
Standard
Comply
at 12/15
T2.2.
1c

The circumstances in which
they will grant tenancies of a
particular type.
Yes
T2.2.
1d

T2.2.
1e

T2.2.
1f

T2.2.
1g

Any exceptional circumstances
in which they will grant fixed
term tenancies for a term of
less than five years in general
needs housing following any
probationary period.
The circumstances in which
they may or may not grant
another tenancy on the expiry
of the fixed term, in the same
property or in a different
property.
The way in which a tenant or
prospective tenant may
appeal against or complain
about the length of fixed term
tenancy offered and the type
of tenancy offered, and
against a decision not to grant
another tenancy on the expiry
of the fixed term.
Their policy on taking into
account the needs of those
households who are
vulnerable by reason of age,
disability or illness, and
households with children,
including through the
provision of tenancies which
provide a reasonable degree
of stability.
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
strengthen compliance
No further action required
HoH
N/A
No further action required
HoH
CHS does not offer fixed term
tenancies
N/A
No further action required
HoH
CHS does not offer fixed term
tenancies
N/A
No further action required
HoH
CHS does not offer fixed term
tenancies
Yes
Set out in the Starter tenancy
and Lettings policy, last
updated 2013 and being
reviewed in November 2015.
As we do not offer fixed-term
tenancies, we have not yet
needed to consider more
stable tenancy terms for such
groups. Starter tenancies
offer stability as they lead to
as Assured tenancy once the
initial period is completed and
an appeal process takes
individual circumstances into
account should we seek to
end a starter tenancy.
HoH
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
March
2016
Quality Lives initiative:
Nov Ops Cttee agreement of
Housing Management Strategy,
including better ways to support
people with care and support
needs in General Needs Housing.
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
42
Ref
Standard
Comply
at 12/15
T2.2.
1h

Yes
T2.2.
1j

T2.2.
2
T2.2.
3
T2.2.
4
Key
The advice and assistance
they will give to tenants on
finding alternative
accommodation in the event
that they decide not to grant
another tenancy.
Their policy on granting
discretionary succession
rights, taking account of the
needs of vulnerable household
members.
Registered providers must grant
general needs tenants a periodic
secure or assured (excluding
periodic assured shorthold)
tenancy, or a tenancy for a
minimum fixed term of five years,
or exceptionally, a tenancy for a
minimum fixed term of no less
than two years, in addition to any
probationary tenancy period.
Before a fixed term tenancy ends,
registered providers shall provide
notice in writing to the tenant
stating either that they propose to
grant another tenancy on the
expiry of the existing fixed term or
that they propose to end the
tenancy.
Where registered providers use
probationary tenancies, these
shall be for a maximum of 12
Yes
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
If ending a starter tenancy,
we offer advice and support
through Housing Officers and
signpost to independent
advice. This will be more
explicit in the Starter Tenancy
Policy on its review in 2015;
the Appeals Procedure
includes giving advice to
approach independent advice
agencies.
Our Tenancy Changes Policy
was approved in April 2014
and updates our approach to
succession.
No further action required
HoH
No further action required
HoH
In general needs housing we
always grant starter
tenancies, but we do not use
starter tenancies in Older
people’s Services such as
sheltered housing. Other
than starter tenancies we
grant assured tenancies
which are not fixed term.
No further action required
HoH
No further action required
HoH
No further action required
HoH
N/A
Yes
CHS provides starter
tenancies that meet these
requirements. Our policy
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
CHS does not offer fixed term
tenancies
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
43
Ref
T2.2.
5
T2.2.
6
T2.2.
7
Standard
months, or a maximum of 18
months where reasons for
extending the probationary period
have been given and where the
tenant has the opportunity to
request a review.
Where registered providers
choose to let homes on fixed term
tenancies (including under
Affordable Rent terms), they shall
offer reasonable advice and
assistance to those tenants where
that tenancy ends.
Registered providers shall make
sure that the home continues to
be occupied by the tenant they let
the home to in accordance with
the requirements of the relevant
tenancy agreement, for the
duration of the tenancy, allowing
for regulatory requirements about
participation in mutual exchange
schemes.
Registered providers shall develop
and provide services that will
support tenants to maintain their
tenancy and prevent unnecessary
evictions.
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
includes an appeal process
for any decision to end a
tenancy, and a review
process by a Director where a
decision is made to extend
the Starter tenancy.
N/A
No further action required
HoH
Yes
A tenancy check is
undertaken at one and nine
month periods. If subletting
or abandonment is suspected
we take swift action to
resolve. Such visits and action
are evidenced in our housing
IT system.
No further action required
HoH
Yes
CHS has an in-house advice
service, and also works with a
range of partnership agencies
such as CAB, social services,
health authorities, police,
youth, child protection, drug
and alcohol, mental health
teams to provide support to
vulnerable residents or those
whose needs have changed.
New tenants are granted a 12
month starter tenancy, which
becomes assured if no
breaches with the 12 month
No further action required
HoH
No further action required
HoH
T2.2.
8
Registered providers shall grant
those who were social housing
tenants on the day on which
section 154 of the Localism Act
Yes
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
CHS does not offer fixed term
tenancies
April 2016
We agreed a new Mental Health
Strategy in 2015 and plan to
introduce a targeted tenancy
support service during 2016/17
to support vulnerable customers
generally and those with mental
health needs
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
44
Ref
Standard
Comply
at 12/15
2011 comes into force, and have
remained social housing tenants
since that date, a tenancy with no
less security where they choose to
move to another social rented
home, whether with the same or
another landlord. (This
requirement does not apply where
tenants choose to move to
accommodation let on Affordable
Rent terms).
T2.2.
9
Registered providers shall grant
tenants who have been moved
into alternative accommodation
during any redevelopment or
other works a tenancy with no
less security of tenure on their
return to settled accommodation.
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
period, or where applicable
the extension period. We
have updated our policy (with
legal advice from Buckles
June 2014) on mutual
exchanges to clarify the
position where tenants of
different landlords and with
different tenures wish to
exchange, and updated our
mutual exchange leaflets on
this issue.
Tenants are granted a licence
in the alternative
accommodation, if they wish
to move back to their
substantive home or tenancy.
If they wish to move on a
permanent basis they are
granted the same tenure as
their original tenancy
No further action required
HoH
Neighbourhood and Community standard
1 Required outcomes
1.1 Neighbourhood management
Registered providers shall keep the neighbourhood and communal areas associated with the homes that they own clean and safe [see NC2.1]. They shall work in
partnership with their tenants and other providers and public bodies where it is effective to do so [see additional point NC2.1.1].
1.2
Local area co-operation
Registered providers shall co-operate with relevant partners to help promote social, environmental and economic wellbeing in the areas where they own properties
[see additional point NC1.2].
1.3
Key
Anti-social behaviour
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
45
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
Registered providers shall work in partnership with other agencies to prevent and tackle anti-social behaviour in the neighbourhoods where they own homes [see
NC2.3.1].
2.1
Neighbourhood Management – specific expectations
NC2.
1.1
Registered providers shall keep
the neighbourhood and communal
areas associated with the homes
that they own clean and safe.
They shall work in partnership
with their tenants and other
providers and public bodies where
it is effective to do so
Yes
NC2.
1
Registered providers shall consult
with tenants in developing a
published policy for maintaining
and improving the
neighbourhoods associated with
their homes. This applies where
the registered provider has a
responsibility (either exclusively or
in part) for the condition of that
neighbourhood. The policy shall
include any communal areas
associated with the registered
provider’s homes.
Yes
2.2
We have an estates service
standard, and work with a
team of estate inspectors to
monitor the standards of our
estates. We monitor the
quality scores given by these
Inspectors. Housing officers
also complete quarterly
estate inspections and liaise
with other agencies.
Tenants are consulted on at
least an annual basis as part
of a review of the Gardening
and Estate Maintenance
Service Standard, published
on CHS website and included
in new tenant information.
No further action required.
HoH
No further action required
HoH
No further action required
CSD
We are developing a policy on
maintenance & improvement of
neighbourhoods, to build on the
Gardening and Estate
Maintenance Service Standard.
Local area co-operation – specific expectations
NC1.
2
Registered providers shall cooperate with relevant partners to
help promote social,
environmental and economic
wellbeing in the areas where they
Yes
We do this by participating in
local council-led forums with
other providers (such as the
Local Enterprise Partnership);
by working with other
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
46
Ref
Standard
Comply
at 12/15
own properties
NC2.
2
NC2.
2a
Registered providers, having
taken account of their presence
and impact within the areas where
they own properties, shall:
 identify and publish the roles
they are able to play within
the areas where they have
properties
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
providers in joint ventures to
provide money advice, job
skills such as in ICT, and job
search advice to people
experiencing homelessness.
We also offer work
experience and
apprenticeships to tenants
and other local people.
-
Yes
CHS Annual Report outlines
CHS’s various roles and
community benefit across
Cambridgeshire. The CHS
Newsletter regularly updates
our customers on the
different roles and services
we provide. We have
community engagement in
the following localities:
Cambourne, The Staithe,
Railway House, Care Homes,
River Lane, We also issue
Neighbourhood Grants to
groups of general housing
customers for local events
CHS is involved in a wide
range of partnerships,
including:
 Community Engagement
 Financial Capability
 Sub-regional Housing
Forum
Good relationships and
NC2.
2b

Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
co-operate with local
partnership arrangements and
strategic housing functions of
local authorities where they
are able to assist them in
achieving their objectives
Yes
No further action
CSD
No further action required
CSD
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
No change.
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
47
Ref
Standard
Comply
at 12/15
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
regular senior contact with
partner local authorities
2.3
Anti-social behaviour – specific expectations
NC1.
3,
NC2.
3.1
Registered providers shall publish
a policy on how they work with
relevant partners to prevent and
tackle anti-social behaviour (ASB)
in areas where they own
properties.
NC2.
3.2
In their work to prevent and
address ASB, registered providers
shall demonstrate:
 that tenants are made aware
of their responsibilities and
rights in relation to ASB
NC2.
3.2a
Yes
CHS has a comprehensive
ASB policy, last reviewed in
2014, and information is
available in the tenancy
handbook, on the website
and via our service standard.
Community Trigger protocols
have been introduced by
each of our local authorities
and publicised among our
customers.
HoH
Yes
During the tenancy sign up
residents are reminded of
their obligation under the
Starter tenancy, This
information is also contained
within the tenancy handbook,
on the website and via our
ASB leaflet
We have a clear procedure,
timescales and escalation
procedure. Cases are
reviewed at a set frequency
depending on severity, and
also reviewed in 121 sessions
with staff to agree actions.
We work closely with other
agencies, attending multi-
NC2.
3.2b

Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
strong leadership,
commitment and
accountability on preventing
and tackling ASB that reflects
a shared understanding of
responsibilities with other local
agencies
No further action required.
Yes
No further action required
HoH
No further action required
HoH
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
48
Ref
NC2.
3.2c
Standard

Comply
at 12/15
a strong focus exists on
preventative measures
tailored towards the needs of
tenants and their families
Yes
Groups\public\shared\SMG\Regulatory Code Self-Assessment\RSSA Working Version Item136 Board 8Dec2015
Lead Timescale
Compliance evidence
Action required
Comments / Plans to further
strengthen compliance
disciplinary meetings and task
groups. .
Our ASB policy includes a
number of preventative
measures taken at different
stages e.g. design, lettings,
No further action required
HoH
tenancy management; & takes
into account varied needs of
households e.g. for support.
NC2.
3.2d

prompt, appropriate and
decisive action is taken to deal
with ASB before it escalates,
which focuses on resolving the
problem having regard to the
full range of tools and legal
powers available
Yes
We deal effectively with ASB
cases, some of which are
very complicated. This
includes mediation, working
jointly with other agencies
and taking legal action. Our
housing IT system is used to
record all actions and next
steps. There is regular
training of the Housing
Officer team.
No further action required
HoH
NC2.
3.2e

all tenants and residents can
easily report ASB, are kept
informed about the status of
their case where responsibility
rests with the organisation
and are appropriately
signposted where it does not
Yes
No further action required
HoH
NC2.
3.2f

provision of support to victims
and witnesses
Yes
Tenants can report ASB on line,
via the phone, by email, letter
and in person. Complainants are
contacted at least monthly to
review their case, usually more
often. Cases are documented
and tracked on our new IT
system and monitored by
managers.
We work closely with the police,
the tenant and other relevant
third parties (e.g. Multi-Agency
Risk Assessment Conferences) to
support the victims of ASB. Work
is also undertaken to support the
perpetrator to stop causing a
nuisance e.g. through tenancy
support or advocating support
from external providers.
No further action required
HoH
Key
Code – ref to Governance & Financial Viability Standard Code of Practice 2015
CEx – Chief Executive
CoP – HCA Governance & Financial Viability Standard Code of Practice
CT – Campbell Tickell
CGPM – Corporate Governance & Planning Mgr
CSD – Community Services Director
FD – Finance Director
HPS – Head of Property Services
No change.
HoC - Head of Capital
HRD – HR Director
IDA – In-depth Assessment
49