One of the key questions facing the social housing sector since the 2017 Grenfell fire tragedy is how do we focus more on tenants? The disaster has shone an unprecedented light on social housing landlords and forced them to re-evaluate their relationship with tenants. In board rooms across the country, there has been a good deal of soul searching. Board members have been asking: do we really listen to our tenants? And are we responsive as a landlord?
It’s against this backdrop that the Regulator of Social Housing has begun the process of putting in place a new system for consumer regulation. On the back of the Social Housing White Paper of 2019, it has recently consulted on a proposed new set of 22 Tenant Satisfaction Measures (TSMs) which will be the basis of how landlords’ performance is measured and compared. The consultation on this set of measures ended on March 3rd.
So, are they the right set of measures? And will they have the desired outcome?
Firstly, I think the principle of more active consumer regulation is something the whole sector would welcome. In many respects this is something which has been missing for more than a decade. If we cast our mind back to 2010, the fledgling coalition government took an active decision to move away from the consumer elements of regulation and instead focused on viability and governance. It’s right that the pendulum is swinging back again, to hopefully rest somewhere in the middle.
But as the regulator faces increasing pressure to come up with the right response to Grenfell, we need to be sure that a new system is fit for purpose. And in my view the 22 proposed TSMs aren’t. There are too many of them, they don’t allow fair comparisons to be made between landlords, and they risk creating an entire industry devoted to distorted benchmarking.
Let’s take a couple of the TSMs as examples. Firstly, under the proposed system, landlords would have to provide data on tenants’ views around anti-social behaviour (ASB), specifically how good landlords are at dealing with reports of ASB. There’s an obvious flaw here: most tenants won’t have made an ASB complaint. And those who have will probably be more focused on whether they got their desired outcome, irrespective of whether the landlord did a good job or not.
Another TSM will measure tenant satisfaction with their local neighbourhood. But this is an unfair evaluative measurement of a landlord’s performance from a tenant satisfaction point of view. How people feel about where they live is determined by many factors – and many stakeholders have a part to play, not just registered providers of social housing. It would be unwise to conclude a landlord is performing badly if they scored poorly on this measure.
I do think there is value to having some kind of comparative set of measurements around consumer regulation. But they need to be much more focused and appropriate. The RSH’s Value for Money metrics are a good example of universal cross-sector indicators which largely work, and which are then supplemented by a provider’s own complementary VFM metrics. Why not a similar approach here?
And as always context is key. KPIs and benchmarks are what I like to call a “can-opener”. They can lift a lid on problems, but they don’t always tell you why things are the way they are. Raw data only takes you so far: it’s ultimately quite a blunt instrument.
It is well understood by anyone who takes even a passing interest in tenant satisfaction that surveys consistently report that social housing tenants living in London are less satisfied with their lot. Meanwhile, older people are more likely to say they are satisfied. Having more properties in London in your portfolio isn’t down to poor performance: it’s geographical potluck. Likewise having a skew towards older tenants isn’t a reflection of your performance good or bad. It’s just the way things are for you.
I’m sure the sector will be awaiting the results of the consultation with great interest. And I’m also sure there will have been lots of sensible and measured responses which will hopefully give the RSH reason to pause and reflect.
The question is whether political pressure will win the day. Will being seen to do something prove more important than doing the right thing? My hope is that the regulator will use feedback from the consultation to ensure it has the right set of TSMs, in the right format, with the right methodology. A lot is riding on it and the sector will be eagerly awaiting its response.
