In a week of much material it was difficult to decide what was exercising me most. I was pretty certain it would be the much awaited Housing Strategy, and indeed that has much in it worthy of comment. But for now I’ll have to hope that the weeks to come will give me another opportunity. My immediate observation is that it seems to be more of an economic growth strategy than a housing strategy, a view reinforced by the presence of the CBI’s fingerprints all over it.
I could also have written about the shocking but, oh-how-telling-that-it's-not-surprising, report from the EHRC about the state of domiciliary care in this country. We must all hope that the lessons about allowing the cost-saving motive to create a business model where profit-driven provider interests outweigh those of the customer, have been well and truly noticed by those in Government responsible for the nascent Open Public Services agenda.
Instead, it’s the statutory consultation on the revised regulatory framework for social housing in England from April 2012 that’s got my goat. Dry and technical it is, but uninteresting it is not. Here we see the Localism Act’s impact, as consumer regulation becomes a “backstop provision - a matter of regulatory interest only when there is “serious detriment”. Co-regulation comes to the fore, with all that entails, and still without an answer to the question about why a tenant would want to volunteer to be a co-regulator.
We see also what I’m sure will become a diverting sideshow about the scope for tenants to share in benefits arising from closer involvement in commissioning or carrying out repairs. I think there may be the germ of a good idea in there, but whether the regulator can, as it sets out, pass on Government directions on such matters is a moot point. Without a clear legal basis for this direction, it suggests the return of policy passporting – the practice of Governments to use regulation to impose policy matters on the Boards of independent organisations. I’m sure the National Housing Federation will be concerned that this would compromise that independence and might leave the country’s associations another step closer to re-classification as public bodies.
But it’s the value for money standard that’s really got me bothered. Don’t get me wrong, economy, efficiency and effectiveness are vital, value for money is what we want and what our tenants want. We strive to deliver it and we know we can always do it better. The “money” bit is easy to calculate – by now most housing associations have a pretty good grasp of how much things cost and how to report them. But where are the metrics to measure value and in the absence of those, what will the regulator do?
Here’s my prediction: greatest emphasis will be placed on the things most readily measurable. Tenant satisfaction, repairs right-first-time, new homes built. These things are (pretty) tangible. We can count them and so do the arithmetic that the term “value for money” suggests is required. It won’t be on the value of a community allotment scheme, or of building confidence and self-esteem in young mothers; or even of getting people into jobs. Yes, the consultation document nods to the concept of social value, but without any agreed measure for it, what defence does a housing association have when the Regulator comes calling and says that the value side of the equation doesn’t add up?
It's much safer for the association to stick to the easily measurable, to cherry pick the easy wins and shy away from the things that instinctively we know build the strongest communities. We desperately need Government to say, loudly and clearly, that this is not its intention; that the Regulator will not act in this way and that determining the balance between growing wider social value and say creating new homes is the role of each Board, we'll be listening closely for the announcement.
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| Launch of the Housing Strategy (Source) |
I could also have written about the shocking but, oh-how-telling-that-it's-not-surprising, report from the EHRC about the state of domiciliary care in this country. We must all hope that the lessons about allowing the cost-saving motive to create a business model where profit-driven provider interests outweigh those of the customer, have been well and truly noticed by those in Government responsible for the nascent Open Public Services agenda.
Instead, it’s the statutory consultation on the revised regulatory framework for social housing in England from April 2012 that’s got my goat. Dry and technical it is, but uninteresting it is not. Here we see the Localism Act’s impact, as consumer regulation becomes a “backstop provision - a matter of regulatory interest only when there is “serious detriment”. Co-regulation comes to the fore, with all that entails, and still without an answer to the question about why a tenant would want to volunteer to be a co-regulator.
We see also what I’m sure will become a diverting sideshow about the scope for tenants to share in benefits arising from closer involvement in commissioning or carrying out repairs. I think there may be the germ of a good idea in there, but whether the regulator can, as it sets out, pass on Government directions on such matters is a moot point. Without a clear legal basis for this direction, it suggests the return of policy passporting – the practice of Governments to use regulation to impose policy matters on the Boards of independent organisations. I’m sure the National Housing Federation will be concerned that this would compromise that independence and might leave the country’s associations another step closer to re-classification as public bodies.
But it’s the value for money standard that’s really got me bothered. Don’t get me wrong, economy, efficiency and effectiveness are vital, value for money is what we want and what our tenants want. We strive to deliver it and we know we can always do it better. The “money” bit is easy to calculate – by now most housing associations have a pretty good grasp of how much things cost and how to report them. But where are the metrics to measure value and in the absence of those, what will the regulator do?
Here’s my prediction: greatest emphasis will be placed on the things most readily measurable. Tenant satisfaction, repairs right-first-time, new homes built. These things are (pretty) tangible. We can count them and so do the arithmetic that the term “value for money” suggests is required. It won’t be on the value of a community allotment scheme, or of building confidence and self-esteem in young mothers; or even of getting people into jobs. Yes, the consultation document nods to the concept of social value, but without any agreed measure for it, what defence does a housing association have when the Regulator comes calling and says that the value side of the equation doesn’t add up?
It's much safer for the association to stick to the easily measurable, to cherry pick the easy wins and shy away from the things that instinctively we know build the strongest communities. We desperately need Government to say, loudly and clearly, that this is not its intention; that the Regulator will not act in this way and that determining the balance between growing wider social value and say creating new homes is the role of each Board, we'll be listening closely for the announcement.
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