Chartered Institute of Housing and councils back plans for Competence and Conduct Standard for social housing but question timing, resourcing

The Chartered Institute of Housing (CIH) and the Local Government Association (LGA) have welcomed the Government’s proposed standard for the competence and conduct of social housing staff, but called for changes to the timetable for its implementation.

The Department for Housing, Levelling Up and Communities (DHLUC) consultation on the proposed standard, which would require senior managers and executives to have, or be working towards, a relevant qualification, closed on 5 April 2024.

In their responses to the consultation the CIH and the LGA gave general support for a regulatory standard. However, both organisations expressed concerns about its implementation.

The CIH said it welcomed the introduction of a broad standard that relates to all who work in social housing.

However, it warned that the introduction of mandatory qualifications was “a significant change for the social housing sector coming at a challenging time”.

It suggested that “further consideration would be helpful to achieve the intended outcomes without negatively impacting the service delivery”.

The CIH has called for:

• An extension of the transition period to three years (the proposed length was two), with a focus on a minimum of 50% of qualification enrolments commencing within the first 18 months following introduction. The CIH reasoned that this would alleviate capacity pressures on landlords and study centres. Extension of the transition period would additionally help to address the risk of senior professionals exiting the sector or retiring early, or disincentivising skilled professionals from other sectors from moving into housing, it added. This would recognise existing recruitment and retention challenges within the social housing sector.
• The Government to ensure local authority Housing Revenue Accounts have sufficient capacity to introduce the changes through new burdens funding.
• A longer period for smaller providers to comply. Also, where a provider manages a high proportion of supported housing, there should be additional time for supported housing staff to qualify. “This reflects the tight margins and viability of some supported housing schemes and the ongoing recruitment and retention challenges that exist within supported housing.”
• Service providers who solely deliver repairs and maintenance services for social landlords to be exempt from the standard. “Whilst we understand the logic behind extending the qualification requirement to contractors the definition of ‘service providers’ is broad and there is a risk that those delivering repair services may choose to withdraw from the sector rather than commit to undertake the necessary training or seek to recruit qualified staff from within housing providers.”
• In instances where people have challenges in accessing learning, e.g. through experiencing learning difficulties or being neurodiverse, a pragmatic approach should be adopted that enables those learners an extended period to complete their studies.
• To avoid some people having to undertake multiple qualifications, e.g. with CIH and RICS, relevant providers of technical qualifications should be encouraged to ensure that their qualifications are compliant with the standard.

In its response, the Local Government Association said it supported “the overarching principle of a broad, outcomes-focused Competence and Conduct Standard which will ensure councils as registered providers of social housing have a policy in place which sets out their approach to managing and developing the skills, knowledge, experience and conduct of those of their staff who are relevant individuals”.

But it also raised concerns about the practical implementation of the new professionalisation agenda, particularly in relation to the qualification requirements.

It mirrored the CIH in having concerns about the lack of flexibility on transition periods and qualification eligibility thresholds.

Greater flexibility would help councils as registered providers of social housing “to plan and implement the changes more effectively, alongside all the other regulatory changes that are being introduced in parallel, allow more time for staff to prepare for qualifications and also help training/qualification providers to ensure they have sufficient capacity to deliver the relevant qualification programmes.”

The LGA warned that multiple changes were being introduced over the next few years that would impact on the delivery of housing management services, such as Awaab’s Law, the potential new Decent Homes Standard, and new Consumer Standards.

“The Government need to ensure that these changes are coordinated and introduced in a sensible manner so that landlords can review their housing management services and delivery models and respond to them in the round,” it suggested.

The Association also expressed concern that the cost impact assessment failed to adequately estimate the cost of implementing the proposals within the consultation.

“The impact assessment also does not take account the likely upwards pressure on salary costs that increased professionalisation is likely to bring, with increased expectation of an increased salary for roles that require specific qualifications. If these expectations are not met, it could lead to individuals leaving (or not joining) for better paid roles or not joining a local authority…. This will further exacerbate recruitment and retention challenges.”

The LGA meanwhile said implementation of the proposals would place an additional financial burden on local authorities in their role as registered providers of social housing. “The LGA has repeatedly made both the Regulator for Social Housing (RSH) and DLUHC aware of the significant financial income and expenditure pressures on individual Housing Revenue Accounts (HRAs) and the impact this is having on the ability to fund the vital investment needed to improve and regenerate existing stock and deliver effective social housing management services to tenants.”

It welcomed the commitment that new burdens funding would be paid to local authority registered providers without an HRA but said it was concerned that those with an HRA (“the vast majority”) would need to fund the additional costs out of the income from tenant rents.  

The LGA added that it continued to urge DLUHC to urgently undertake an in-depth review of the future sustainability of HRAs “given the cumulative impact of a wide range of competing income and expenditure pressures”.

Harry Rodd