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Homes for Cathy seeks member feedback on the consultation for Consumer Standards and Code of Practice 

The landmark Social Housing Act has received Royal Assent to become law, transforming the role of the Regulator of Social Housing in regulating consumer standards.   

It is anticipated that many of the reforms introduced by the Act will take effect on 1 April 2024, when the new consumer standards are set in motion.  In the interim, the Regulator has published a consultation on the draft Consumer Standards and Code of Practice, seeking input from the sector.  Homes for Cathy has prepared a draft response to the consultation in collaboration with Crisis and is encouraging members to endorse the group’s proposals in their own submissions to the Regulator. 

Definition of consumers to include prospective tenants

Importantly, Homes for Cathy’s proposed amendments to the Standards and Code expand the definition of ‘consumers’ to expressly include prospective tenants who may be in statutory or non-statutory temporary accommodation or rough sleeping, not only in the scope of the Allocations and Letting section but also in the Transparency Influence and Accountability Standard sections. 

The proposed amendments also explicitly state the actions registered providers should take to implement the homelessness related provisions and require them to benchmark themselves on progress.   

David Bogle, chair of Homes for Cathy, said: 

“We welcome the provisions in the draft Standards and Code, including the retention of provisions in the Tenancy Standard which require housing associations to assist local authorities in their homelessness duties and to try to prevent evictions through tenancy sustainment support.   

“However, our proposals take this a step further, citing how this can be achieved and indicating how RPs’ progress should be benchmarked.  We hope that requiring providers to adopt the practices of the best will help to create a more level playing field for housing associations in tackling homelessness.   

“We also want to ensure that people experiencing homelessness – in other words prospective tenants – are recognised as consumers.  Ultimately, if we cannot provide effective services to the people that are most in housing need, what is our purpose?” 

To read Homes for Cathy’s draft consultation response, click here.  Homes for Cathy members are invited to contact Vicki McDonald at homesfor.cathy@hightownha.org.uk with any comments by Monday 18 September.  The Homes for Cathy Board will review any feedback and consider revisions to the draft before finalising a response. The final version will be shared with members by 12 October. 

It’s right that the sector focuses on tenant satisfaction but where does homelessness fit in? 

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Our Homes for Cathy panel discussion at last week’s Housing 2023 Fringe asked the question: Could an increased focus on tenant satisfaction undermine the sector’s work around homelessness? 

Homes for Cathy chair David Bogle steered the discussion between expert panellists Jo Richardson, Professor of Housing & Social Inclusion at De Montfort University, CIH past president and author of the Homeful report into housing-led approaches to ending homelessness; Callum Chomczuk, National Director, CIH Scotland; and Faye Greaves, Housing Programme Manager at Crisis. 

The discussion was a timely one, coinciding with news that the Social Housing Regulation Bill is set to become law after clearing both Houses.  This signifies the biggest changes to social housing regulation in a decade, including the introduction of a proactive consumer regulation regime underpinned by new consumer standards.   

The Regulator has already identified the themes the consumer standards are set to cover and will consult on the detail of each theme over the summer.  In advance of this planned consultation, the panellists gave their views on how the standards could best meet the needs of those experiencing or at risk of homelessness and the wider system changes that are needed to put an end to homelessness.   

A key area of focus for the panellists was the theme of ‘tenure’; under this theme, the Regulator has cited that landlords’ allocation process must be ‘fair, transparent and accessible to all’ and identified the importance of effective tenancy management so that ‘tenancies are sustained where appropriate’ including ‘supporting tenants, as well as working closely, and cooperating with local authorities in meeting their duties’.    

Here are our five key takeaways from the discussion: 

Three areas where housing associations can have an impact homelessness 

There are three key areas where housing associations can have an impact on homelessness: allocations and lettings to homeless households; tenancy sustainment and avoiding evictions into homelessness.  Despite constraints, the fact that some housing associations perform better than others in these areas shows that there is room for improvement. 

Current tenancy standards are not sufficient 

Under the existing tenancy standards, housing associations’ requirement to support local authorities in the execution of their homeless duties and to help sustain tenancies are not sufficient – we need to challenge housing associations on their nominations through homelessness channels.  If housing associations can’t provide housing and support for people who can’t afford the market, who can?  Unlocking access to social homes for people coming from homelessness is vital.  A code of practice around housing associations’ homelessness expectations based on the Homes for Cathy commitments could be beneficial.   

Processes can come before people 

In an environment where resources are scarce, processes can come before people and individual inconsistencies across organisations can ‘lock people out’.  Leaving the system to work itself out is not working – we need to look at ways providers can do better with regulatory accountability in the background.  One example cited was affordability assessments – as tenant support needs go up and housing-related support is squeezed, these need to be used as enablers and facilitators to give tenants access to the wider support system.   

Scottish RRTP example shows funding is a driver for partnership working 

In Scotland Rapid Rehousing Transition Plans (RRTPs), plans developed by each of the 32 local authorities to reduce the use of temporary accommodation, have created a driver for partnership working between local authorities and registered providers.  It’s proof that with political will and appropriate funding, homelessness can be alleviated (in 2019-20 the share of Scottish RP lettings to homeless households was 45%).  However, both the funding and the approach need to be long-term – we don’t always need to look for ‘shiny new things’ to make a difference. 

It’s a case of supply and demand 

Ultimately, we need more capital investment in housing to provide more social homes – it’s a case of supply and demand.  Currently we are using temporary accommodation as the default housing option.  Planning applications are already substantially down year-on- year.  We need housing associations to keep developing new social homes and not be creating any further development disincentives. 

Written by Vicki McDonald

Vicki is the Social Impact Manager at Hightown Housing Association and leads on communications and member engagement for the Homes for Cathy campaign.