Whilst the paint may still be drying on the rebranded signs for the “Regulator of Social Housing” its regulatory framework, approach and powers continue as before and will do into the foreseeable future. This article picks up on the key lessons from the last few years of inspection and offers some suggestions for how you can use Clearview to challenge yourself before the “new” inspector comes calling.
Volume 4 of the With the benefit of hindsight (HCA, 2015) research and analysis neatly summarised the learning from the broad set of problems encountered by the regulator over the last several years into three broad areas:
- Weak governance
- Overstretched ambition
- Incompetence and lack of attention
As organisations operating in the sector we should ensure that one of our key metrics is that we do not become a case study in volume 5!
Remember, regulation and inspection is not merely a tick box exercise borne out of necessity but is a valuable opportunity: to challenge ourselves to demonstrate the value that we offer; to evidence what we achieve in an increasingly challenging environment; to gain assurance that we are purposefully enacting our mission; and to show that we are resilient enough to cope with the unexpected.
Reviewing the recent HCA regulatory notices, however, shows how our sector continues, perhaps lemming-like to follow the well-trodden, yet distinctly avoidable path, towards a downgrade. These are just a few of the common themes:
Uncontrolled costs; overly optimistic income projections; poor governance; limited oversight and control; lack of co-ordinated risk management; limited capacity to withstand the emergence of downside risks; poor data quality; poor performance; and lack of systems to effectively monitor and accurately report progress against plan delivery.
Be better prepared...
For many years, Clearview has been providing products and services to help social landlords to be better prepared for regulatory scrutiny in all of it’s forms. From the Board down to individual members of staff you can use Clearview as a “devil’s advocate” to challenge your assumptions and as a learning tool to ask the right questions.
Use Clearview Project as a guide to test your attention to detail, identify the gaps between what you promise you are going to do and the reality of how you are going to do it and juggle the limited resources you have available. All your change programmes and projects don’t have to be in year one of your plan and your plan doesn’t have to just be a glossy brochure in the bottom draw. Make it live.
Clearview Service Excellence provides a framework to structure the questioning around how well you are operating, to establish the evidence in support your claims and to identify focussed actions where assessment falls short.
Clearview Strategy can help to ensure that you, your colleagues and your Board, clearly understand your purpose and how you are going to achieve it whilst seizing the opportunities, mitigating the threats and keeping a wary eye on the bigger picture.
Use the Key Performance Indicators of Clearview Performance Scorecard to assess the progress along on your journey, to monitor your sector scorecard, compare performance against your peers and targets, and ensure that you relentlessly focus on what really matters.
Use Clearview Risk to support the work of your Audit & Risk Committees in helping to embed risk awareness and good practice across the organisation and enable you to quickly assess your current situation. Consider, as a starting point, capturing the Sector Risk Profile (2017) and judging how well you are controlling the risks identified. Develop a three lines of defence model to help provide assurance to the Board that what you say you are doing well is really what is being done well.
Use the dashboards and data visualisation tools of Clearview Business intelligence and reporting to focus on the right measures, with drill down to your actual data to improve performance and regulatory outcomes as they need to be tackled.
“Unsinkable, absolutely unsinkable” expounds Birling in JB Priestly’s An Inspector Calls when describing the soon to depart Titanic. Let’s do our best to ensure that our housing associations are not filled with such hubris and are willing to rigorously challenge themselves and avoid the avoidable.
To find out how Clearview can help you to challenge yourself and be better prepared for regulatory scrutiny please do pick up the phone and give us a call on 0845 519 7662.