Campaign Outcomes
An evolving Sector - positive practices, changing behaviours and improvements.
Campaign Outcomes
Repairs and Maintenance Satisfaction
In 2017, the Registrar identified in its Annual Statement of Performance Report a dip in performance in Tier 1 and Tier 2 CHPs repairs and maintenance reporting. As a result, the Registrar conducted the Repairs and Maintenance (R&M) Campaign in 2018. The scope of the Campaign was largely preventative and targeted improved understanding to inform any potential/emerging weaknesses. The Campaign included advising CHPs of the identified dip in performance; engaging the Sector to form guidance on the Registrar’s expectations; a deeper analysis of all Tier 1 and 2 provider performance; engaging CHPs in risk identification and treatment and reviewing individual provider treatment plans. A follow-up report was recently conducted, to review the findings and re-assess performance in this area post Campaign.
Overall, Tier 1 and Tier 2 CHPs who received recommendations and improvement suggestions during the 2017/18 compliance assessment sufficiently satisfied the Registrar’s requirements. The Campaign was a positive influence on the Sector, the Registrar’s previous recommendations were sufficiently addressed with some notable improvements on CHP’s behaviour. The Sector has shown improvement in performance and meeting thresholds when compared to the previous reporting year. A small group of CHPs saw decreasing performance. Some declines in performance above the threshold were also noted but still related to strong results. A few CHPs’ results stayed the same as previous years.
The Registrar is aware that performance in this area may be negatively impacted as a result of asset transfers to those CHPs selected under the Social Housing Management Transfer program. In response, the Registrar has initiated a Campaign to monitor performance specific to those CHPs, with a particular focus on the potential decline in areas such as responsiveness, satisfaction rates, and viability where properties do not meet anticipated standards, or costs associated with repairs on transfer exceed budgeted allowances. Initial indications from the Campaign are that a decline in repair and maintenance performance of several large CHPs due to imposed constraints on their systems is likely in the next reporting year and will continue through the following year. This decline is likely to be of a size that is visible in national reporting data.
The Registrar is also working with other Registrars to consider broader improvements on recording CHPs asset level data that could assist in reporting and separating assets/programs where the CHPs have no set repairs responsibilities. You can read more about this Campaign here.
Conflict of Interest
In the 2017/18 compliance round, the Registrar noted an increase in recommendations and improvement opportunities around the quality of COI policies and some disconnect between policy and operational practice. Given the recent Royal Commission into Misconduct in the Financial Services Industry and its commentary on the importance and impact of having a robust COI management system, the Registrar thought it necessary to evaluate current COI practice and management in the community housing Sector.
The Campaign found all participating CHPs have a COI policy and procedure, however, the quality of documentation and its integration into operations differ and can be categorised into two distinct groups.
Some CHPs have adequate COI management systems that are well imbedded into the organisation’s culture and relevant policies are comprehensive and the practice of policies can be clearly demonstrated at all levels of operations. Or alternatively some CHPs have difficulties in demonstrating a practice of their policies and the COI policy is general in its guidance, often lacking clear definitions of actual, potential and perceived COI and the recording document lacks management strategies.
The reason for such a division within the Sector can be attributed to the following,
- a CHPs’ maturity around COI management and consequent knowledge of risks around COI malpractice that is relevant to their business
- a historical regulatory approach that relies on a self-reporting system in conjunction and needs to heighten skills in assessing culture and COI management
The Registrar will continue to engage with CHPs to offer consistent and clear guidance around better identifying indicators of potential non-compliance within an increasingly complex Sector.
The report details key findings around the conduct and culture in the community housing Sector and the link between regulation and COI management. Further details about this Campaign can be found here.
Memberships of CHPs
The Registrar undertook investigations after previous compliance rounds indicated differing membership arrangements for some CHPs. It was identified that a possible shift in membership base could have impacts on the sustainability and viability of organisations. Appropriate governance arrangements and ensuring that CHPs are well governed to support the aims and intended outcomes of the business is a requirement under the NRSCH.
The NSW Registrar targeted this area of performance across all Tier 1 and 2 CHPs in NSW as part of their annual compliance assessment. The Registrar found no evidence of a drastic shift in membership base of Tier 1 and 2 CHPs, although has identified some areas of positive practice and other considerations that CHPs may take into account based on the scale and scope of their business operations. Further details about this Campaign can be found here.
Property Utilisation
A Campaign was conducted in the 2017/18 compliance round to address concerns identified by the Registrar over the quality of property utilisation metrics reported as part the NRSCH compliance assessment process. The Campaign led to interaction with individual CHPs on a range of measures to improve the quality of utilisation data. The Registrar used the Campaign to initially test the quality of property utilisation data in the 2017/18 compliance period.
In the 2018/19 compliance period, data was retested to assess if the quality of data had improved. Along with other findings, the Campaign supported the need for the Registrars’ to collect property utilisation data at the individual property level, that more research is required and that enhancements need to be made to the Registrar’s analytical systems.
Further detail about this Campaign can be found here.
The National Rental Affordability Scheme
The Registrars have been monitoring how CHPs are making appropriate provisions/plans to prepare for the winding down of the National Rental Affordability Scheme (NRAS) incentives as part of their ongoing Compliance Return process under the NRSCH.
This paper is designed to support analysts and the regulator to adjust regulatory activities and monitor any impacts the cessation of the NRAS program may have. The paper provides guidance around how the regulator may respond to CHP behaviours and sets the direction for any further monitoring work focused on NRAS. Further detail about this Campaign can be found here.