The new housing inspection (IRIS articles)

IRIS Consulting's comments on the Audit Commission's Best Value Housing Inspectorate's Consultation Paper "Framework for assessing excellence in housing management"

The consultation paper provides an informative preview of how the Housing Inspectorate envisages making assessments of what constitutes "excellence" in housing management. The wide range of issues to be addressed are clearly set out in ways which clearly indicate their inter-connectedness.

There is welcome recognition (in paragraph 32) of the importance of local factors. However the proposed sets of indicators and targets seem to be based more on national and averaged group statistics – which do not adequately reflect the need for local variation.

The quoted examples of local performance indicators do not convey the nature of local variation and some of them (such as those relating to adaptations for the disabled and racial harassment cases) are more appropriate for general application – as indeed recommended at paragraph 47 of the paper (see comments below on Diversity).

While there is clearly a need to be consistent with the national and local BVPIs when making assessments of "Excellence" in the housing management service we suggest there is a case for focusing on the areas of critical success when making such assessments. The assessment of excellence should be based on whether or not the LHA/ALMO is delivering an excellent service in the areas which really count to the customers (without being unduly swayed or distracted by services in peripheral areas).

There is a huge amount of research evidence which shows that the key determinant for tenants in assessing the housing management service is the quality and responsiveness of the repairs service. No matter how well the LHA performs in other aspects of its housing services, if it does not provide a good repairs service then the whole housing service is viewed poorly. Equally those LHAs which provide a good repairs service are viewed as the best performers by their tenants.

The repairs service is, therefore, the critical success factor. It is the most difficult service for LHAs to get right; it is the service which tenants regard most highly. So the Housing Inspectorate’s assessment of "excellence" should be similarly "repairs centred".

Unless the Inspectorate focuses on repairs as its central area of attention it risks setting up false standards and criteria which are not recognised and supported by the customers of the service.

We suggest that the provision of an excellent repairs service should be a necessary but not sufficient element in the assessment of excellence. An excellent repairs service would not by itself guarantee an excellent all-round housing management service; but it would be highly indicative that the LHA had got the right set of priorities in place.

The question of what constitutes excellence in repairs then turns on issues of 1) responsiveness, 2) quality and 3) cost.

1) Responsiveness: this aspect includes the time taken to deal with requested items of repair and the ease with which the tenants can access the organisation to register their repair requests. We suspect that often STATUS surveys will not have covered these issues sufficiently or be available for the relevant period.

2) Quality: this aspect includes not only the quality of the workmanship in carrying out the work involved in the repairs but also the capacity of the organisation to determine the appropriate work correctly first time, in keeping appointments and in the attitude of the staff who deal with the tenants in their homes and in taking the repairs request.

3) Cost: As well as gathering information on the above aspects in forming overall judgements about the repairs service the Housing Inspectors should also have regard to cost-effectiveness considerations. Available research findings indicate that there is no simple direct relationship between levels of costs incurred and the quality of the service and levels of tenant satisfaction. Here much depends on local factors – such as the history of previous investment, property types, local market/cost levels.

These factors underline the significance of local variations and complexities which make the suggested upper quartile targets (paragraphs 44-46 of the paper) appear too simplistic and crude. Moreover there is a spurious decimal place accuracy in the quoted targets which appear to determine acceptable levels of service according to which side of the decimal point the service scores.

There is welcome recognition of the need for landlords to address equal opportunity issues. However this seems to be couched very much in traditional terms of black and other racial/ethnic groups instead of reflecting the wider concept of diversity. Under a diversity approach the needs of people with disabilities, differing sexual orientations, life-styles, family commitments etc would be reflected and accommodated. This applies as much to LHAs in their roles as employers as it does in terms of the services they provide to a diverse range of clients. So the Inspectorate should have regard to the employment policies and practices of LHAs.

The description given at paragraph 48 of the paper seems to be in terms of the current HIP resource allocation system which is due to be replaced by a new single capital pot as from next year. Each LHA will be required to produce an HRA business plan which in turn will be supported by an asset management plan. The quality of these plans will be assessed by DETR/GOs as part of their process in determining the allocation of the Major Repairs Allowances to each LHA. These new arrangements will clearly require some time to "bed in" and we think that there is a need for further guidance from the centre on how the business planning process should apply to LHA Housing Revenue Account activities.

In general the consultation paper provides an informative description of current thinking on how the Housing Inspectorate envisages carrying out its difficult role in assessing what constitutes excellence in housing management. We suggest that the range of issues to be examined might be better focussed around the housing repairs service.

Instead of focussing effort on some of the peripheral aspects of the housing management service we suggest that the Inspectorate develops a number of methodologies for determining the excellence of the repairs service. In order to do this the Inspectorate will need to draw on all relevant information and available research.

A methodology for the Inspectors to follow would need to include all the "reality checks" outlined in the paper. But these would need to be supported by more rigorous information drawn from longer time series data. In some cases it may prove necessary to carry out special data collection exercises – especially as regards levels of costs and tenant satisfaction.