North Yorkshire Council
Executive
18 March 2025
Housing Revenue Account Policy Framework
Report of the Corporate Director Community Development
1.0 PURPOSE OF REPORT
1.1 To present to Executive the Policy Framework for Landlord Services and Housing Standards, a key component in our Housing Improvement Programme to meet the requirements of the Social Housing (Regulations) Act 2023 and deliver harmonised policies reflective of the Consumer Standards set by the Regulator for Social Housing.
1.2 The Framework sets out the Policies, Procedures and Standards which will be required to deliver a harmonised landlord service to our tenants.
1.3 The reports sets out the proposed consultation principles, adoption timetable and delegations to ensure that the Framework is compiled effectively and transparently.
2.0 SUMMARY
2.1 Prior to Local Government Reorganisation the stockholding authorities of Harrogate, Richmondshire and Selby each had a portfolio of tenancy and property management policies, standards, and procedures which define the relationship between landlord and tenant and the landlord’s approach to tenancy, property management and maintenance. As North Yorkshire Council move forward as a landlord there is a need to harmonise policy across the Housing Revenue Account functions, to align with the new consumer standards in terms of Safety and Quality, Tenure, Neighbourhood and Community and to promote Transparency, Influence and Accountability. Fundamentally, to document our relationship with our customers and to outline clearly to tenants what service they can expect from North Yorkshire Council.
2.2 The framework will support greater transparency when it comes to compliance and performance monitoring. It will also enable tenants and Elected Members to have new, focussed input into policy development and in-turn provide greater assurance around service delivery.
2.3 Pace and efficiency are required to ensure that harmonisation is achieved as soon as possible, whilst not detracting from the quality of the policy development. Therefore, approval routes are suggested, to expediate decision making and a set of policy development principles proposed to ensure that all policy development, consultation and decision reports are conducted to an agreed standard.
3.0 BACKGROUND
3.1 Across the three legacy stockholding authorities there are currently over 50 separate adopted policies and many other procedure documents directly relevant to the delivery of our HRA services. These policies vary in their stipulations, meaning North Yorkshire tenants in different localities currently expect different levels of service. There are also gaps in policy where no agreement has been or where policy documents are outdated. It is also clear where policy has been developed in isolation or as a reaction to a particular event, resulting in an overall HRA policy framework which is inconsistent and lacks alignment to core regulatory compliance standards.
3.2 In May 2024 North Yorkshire Council referred itself to the Regulator for Social Housing for non-compliance with some of the Consumer Standards. As a result of the referral and engagement with the RSH the Council was issued with a C3 Regulatory Judgement meaning that significant improvement is required.
3.3 The Regulator for Social Housing’s Consumer Standards require that all Registered Providers should provide service delivery policies to tenants in an open and accessible manner. Appendix A. Work has already commenced to harmonise some high priority policies (Allocations Policy, Repairs Standard and Domestic Abuse Policy) however, a clear, prioritised policy framework is required.
4.0 THE HRA POLICY FRAMEWORK
4.1 The proposed policy framework (Appendix B) has been collated, mapping out the core documents underpinning our service to tenants, the key drivers of our policy development and with a clear commitment that our policy approach will be based upon the needs of our customers and developed in consultation with our tenants.
4.2 The policy library (Appendix C) has been collated based upon good practice from peer organisations and an assessment of policies which are held by the legacy authorities and currently in place. The list is not exhaustive, and it should be recognised that additional policy may be required however to ease bureaucracy the first consideration will always be adding to an existing policy document rather than creating a new one, as long as this does not affect the clarity or accessibility of the policy for customers.
4.3 The policies and procedures within the framework, of which there are 65 have been prioritised on a high, medium, low basis based upon the requirements of the Consumer Standards, where there is currently no policy, or conflicting policy in place and the level of risk exposed by not having a harmonised policy in place.
4.4 The documents have been separated into 10 distinct work packages along similar themes so that as they progress through the decision-making process it makes sense for them to be considered together, allowing those scrutinising and adopting the policies to see linkages.
4.5 Transparency in decision making is central to the revised Consumer Standards. Therefore the policy framework includes detail on the approval route for all documents within it. As most of the policies currently sit outside of the Council’s Constitutional Policy Framework it is recommended that agreement will be sought[HH1] [VY2] from the Executive Member for Culture, Arts and Housing. Where documents are of a more strategic nature or impact on external organisations, for example the Tenancy Strategy and Asset Management Strategy, agreement will be sought from the Executive.
4.6
As mentioned at 3.3, some policy decisions have already been taken
by the Executive:
· Rent Collection and Arrears Recovery 24th January 2023
· Housing Complaints Policy, agreed 2 May 2023
· Housing Domestic Abuse Policy, agreed 16 April 2024,
· Housing Adaptations Policy, agreed 17th September 2024.
It is suggested that the future review of the above policies should be delegated to the Executive Member for Culture, Arts and Housing.
4.7 To ensure that all policy development is conducted in a standardised way a policy development checklist (Appendix D) has been created. The checklist supports officers to develop policy and also promotes transparency in the process, data based decision making and consultation principles.
4.8 As part of our drive to promote transparency, all policy documents, once adopted, will be published online alongside the associated Equality Impact Assessments and Decision Records.[HH3] [VY4] In order to ensure that information on landlord services is accessible to all the documents will be provided in EasyRead format as standard and alternative formats available upon request. The policy library will also be maintained, with clear policy review dates scheduled and all policy development documentation retained for the required period.
4.9 Data based decision making is a critical tool in the Council’s ability to demonstrate service improvement and delivery being driven by the specific needs and vulnerabilities of its tenants. The Housing Service is on a journey to improving the data it holds on both its customers and its housing assets and then how it uses that data to inform policy development. We will also use feedback from tenants, gained via the Tenant Satisfaction Survey, Complaints data and feedback from our responsive repairs service to prioritise any amendments to policy or procedures where we see trends in policy failure or gaps in policy resulting in dissatisfaction.
4.10 Established consultation principles are important to ensure that our residents are given the opportunity to shape and scrutinise policy development and service delivery. North Yorkshire Council has an Engagement Promise Our engagement promise | North Yorkshire Council which sets out the general engagement principles the council will adhere too. Further to this, the Housing Service will adopt a Tenant Involvement Strategy with an aim to: To listen and engage Tenants and use their insight to influence and improve services, including tenant satisfaction.
4.11 It is proposed that all key policy documents are subject to tenant scrutiny and consultation with the wider tenant population via online survey, focus groups and customer journey mapping activities. Officers may consult with tenants more freely on policy framework documents, without formal approval but in agreement with the Executive Member on a case-by-case basis, in order to achieve efficiency in policy development.
4.12 A tenant communication plan will be drawn up to ensure that consultation activity with tenants is coordinated, in line with the work packages and timelines identified, so as not to over burden tenant with engagement activity but to allow their voice to be heard in service improvement.
4.13 The Tenant Satisfaction Survey will be used to ensure that policy implementation is having a positive impact on levels of satisfaction and complaints data will be analysed to identify any trends or common areas for dissatisfaction.
5.0 CONTRIBUTION TO COUNCIL PRIORITIES
5.1 Adoption of an agreed HRA Policy framework aligns with the council priority : To ensure that our council housing stock remains decent and continues to improve, with an ambition to become an exemplar social landlord.
6.0 ALTERNATIVE OPTIONS CONSIDERED
6.1 Not to adopt a harmonised HRA Policy Framework and to retain the status quo is not recommended. The current position is disjointed, not aligned to any regulatory requirements, confusing for tenants and leaves the Council and its tenants open to risk.
6.2 As a registered provider of social housing, it is a legal requirement to comply with the Regulator of Social Housing’s consumer standards. Transparency, Influence and Accountability are central to the new requirements.
6.3 North Yorkshire Council has already self-referred to the Regulator indicating that it is non-compliant with a number of requirements across the consumer standards and as a result a C3 judgement has been issued against the Council. Failing to adopt a policy framework and promote transparency in decision making could create a risk of additional non-compliance and undermine the organisations’ credibility.
7.0 FINANCIAL IMPLICATIONS
7.1 There are no financial implications of adopting the proposed HRA Policy Framework. There may be financial implications of adoption of some of the policies within the framework and these will be identified to consultees, including the Executive Member on a case by case basis as part of the policy drafting, consultation and sign off elements of the policy development checklist.
8.0 LEGAL IMPLICATIONS
8.1 It is a requirement of the Regulator of Social Housing Transparency, Influence and Accountability standard for a Registered provider, ‘to provide tenants with accessible information about tenants’ rights in respect of registered providers’ legal obligations and relevant regulatory requirements that registered providers must meet in connection with the homes, facilities or landlord services they provide to tenants’ and ‘to take tenant’s views into account in their decision making about how landlord services are delivered and communicate how tenant’s views have been considered.’
8.2 Therefore, having an agreed, transparent HRA Policy Framework covering all aspects of our homes, facilities and landlord services with clear lines of decision-making authority, auditable development processes and timescales for review with policy development and consultation principles is best practice and allows us to meet the requirements of the Regulator and for the benefit of our tenants.
9.0 EQUALITIES IMPLICATIONS
9.1 An initial Equalities Impact Assessment screening form has been completed and reviewed internally (Appendix E).
9.2 No detrimental effects were identified by the Equalities Impact Assessment screening form. There may be equalities implications of adoption of some of the policies within the framework and these will be identified to consultees, including the Executive Member on a case-by-case basis as part of the policy drafting, consultation and sign off elements of the policy development checklist.
10.0 CLIMATE CHANGE IMPLICATIONS
10.1 A climate change impact assessment screening form has been completed acknowledging that there are no significant impacts. (Appendix F)
11.0 FEEDBACK FROM OVERVIEW AND SCRUTINY
11.1 The proposed HRA Policy Framework was presented to the Housing and Leisure Overview and Scrutiny Committee on 2nd September 2024. The committee welcomed the opportunity to be consulted on the framework. The Committee were invited to identify which of the documents they would be interested in looking at in more detail. It was felt that the best use of the Committee’s time would be in those reviews where a significant policy choice existed. The first Task and Finish Group, to review the Lettable Standard, has already convened.
12.0 CONCLUSIONS
12.1 The Executive is presented with the proposed HRA Policy Framework. This is a key component in our Housing Improvement Programme as we strive to meet the requirements of the Social Housing (Regulations) Act 2023 and demonstrate compliance with the Consumer Standards set by the Regulator for Social Housing.
12.2 The Framework sets out the Policies, Procedures and Standards which will be required in order to deliver a harmonised landlord service to our tenants. The report sets out the proposed consultation principles, adoption timetable and approval routes to ensure that the Framework is compiled as quickly, effectively and transparently as possible.
13.0 REASONS FOR RECOMMENDATIONS
13.1 In order to promote transparency, to expedite decision making and to ensure that a harmonised HRA Policy Framework is agreed, in place and communicated to tenants as soon as possible.
14.0 |
RECOMMENDATION(S)
|
14.1
14.2
14.3 |
That the proposed HRA Policy Framework is agreed.
That authority to approve the HRA policies within the framework is delegated to the Executive Member for Culture, Arts and Housing
That where policy decisions have already been taken by the Executive (para 4.7) future review of those policies will be delegated to the Executive Member for Culture, Arts and Housing. |
APPENDICES:
Appendix A – RSH Consumer Standards -
Appendix B – HRA Policy Framework
Appendix C – HRA Policy Library
Appendix D – Policy Development Checklist
Appendix E – Equalities Impact Assessment Screening Form
Appendix F – Climate Impact Assessment Screening Form
Nic Harne
Corporate Director – Community Development
County Hall
Northallerton
Report Author – Vicky Young, Service Improvement Manager
Presenter of Report – Andrew Rowe,
Assistant Director, Housing
Note: Members are invited to contact the author in advance of the meeting with any detailed queries or questions.
I think we need to be clear with legal whether the policies sit outside the Council's constitutional framework because they were missed off or whether they shouldn't form part of the framework. [HH1]
[VY2]There are a few 'strategic documents which should (ie. Tenancy Strategy, Asset Management Strategy) .. Can pick up with Dem Services.
If it is a procedure would it need a decision record? I think we need a sentence around the principle of that Policies affecting more than one community require Exec apporval? whilst procedures don't but for transparency we have included all in the framework? [HH3]
[VY4]Internal procedure documents would not require a decision record but for transparency could accompany policies upon decision.