9 February 2022
Tenant Satisfaction Measures: Any questions?
Rob Dryburgh
Assistant Director-Business Intelligence
Regulator of Social Housing
Image: Regulator of Social Housing consultation paper, Tenant Satisfaction Measures
It’s now a little over a year since the Government published the Social Housing White Paper. Since then, the team at the office of the Regulator of Social Housing has been working hard to develop our future approach to a new, proactive consumer regulation regime.
We’ve set three overall tests for any propositions that we develop on consumer regulation.
- We want anything that we do to make a meaningful difference to tenants;
- We want any new measures to be practical and ‘do-able’ so that landlords can be guided by them to deliver the best possible service; and
- We want transparent and easy to understand measures so that the Regulator can regulate well and residents can judge whether the rules are being followed.
So the question we have asked ourselves is – what principles and outcomes do we want new consumer regulation to deliver? We are a standards-based regulator, and we need to make it clear exactly what will be expected of social landlords, and what their tenants can expect of them, when the changes promised by the White Paper come into force.
We have tried hard to create measures that gather verifiable numbers but also glean some sense of tenants’ day-to-day experience of their landlords.
The new Tenant Satisfaction Measures (TSMs) will be an important part of the overall approach. We’ve come up with a draft set of 22 measures which you can read here, and up to 3 March 2022 anyone can suggest changes.
We’ve been talking to both tenants and landlords about these measures for many months now. Both have told us they’re concerned about making sure these new performance measures can’t be ‘gamed’ and really will tell an accurate story. So we have tried hard to put together measures that not only gather numbers that can be checked and verified, but also glean some sense of the underlying reality, particularly of tenants’ day-to-day experience of their landlords.
How will this be done? Our plan is to ask for both data from the landlord and assessments from tenants about how they see the real-world impact of their landlord’s work. It’s a difficult goal to achieve, and we’ve had to think through the likely problems carefully.
For instance, we’ve given quite a lot of care and thought to how we phrase TSM questions – and perhaps there’s still room for improvement. One asks tenants to rate whether their home is ‘safe to live in’. Some of the feedback that we had reveals how tricky it might be to pin down exactly what that means. Is it about the home itself, or is it about the safety of the neighbourhood more generally?
And if we ask only for the absolute number of complaints and the TSM results show that the number of complaints has risen, how do we know whether this is because something has gone wrong or because, in fact, the landlord has made its complaints process easier for tenants to use? On this measure, we plan to look for ways to ask tenants for more information, such as how easy it is to complain, and whether they know how to do that. What we’re looking for is ways to triangulate the stark numbers with input from tenants on the ground.
As far as possible, we’re trying make sure we stick to the same terminology and the same principles used by the Housing Ombudsman so that we don’t end up with two versions of the truth. We aim to make the Regulator’s work consistent with what the Ombudsman does; so TSMs that ask about landlords’ response to complaints will follow the timescales recommend by the Housing Ombudsman’s own complaints handling code.
The Regulator will look at TSMs alongside a range of other information such as news reports, whistle-blowers, tenants who contact us directly -we’ll be looking for an overall picture of landlord performance.
Finally, we’ve had to think about how we gather information from tenants. When we’ve spoken to tenants about how we can reliably find out whether they feel their landlord treats them with respect, many have pointed out how odd it would be to get this information through the landlord’s own complaints process. How could this work, they asked, given that the landlord has control over the categorization and the recording of complaints? We propose putting this into the TSMs as tenant perception question instead.
There are still many other difficulties to iron out such as how we judge a landlord’s performance in creating a high-quality neighbourhood or tackling anti-social behaviour if they are only one among many landlords and property owners in a particular area and have limited control. In the consultation, we’ve set out a range of different options for complex issues such as these and we are keen to see what people think of them.
Probably the most important thing to take away from all of this is that a set of TSM scores will not be the only measure of whether landlords are complying with the new consumer regulatory standards. The Regulator will look at TSMs alongside a range of other information we get from tenants, other data, whistle-blowers, referrals from the Housing Ombudsman and engagement with the landlord itself. We’ll be looking for an overall picture of landlord performance.
There’s still a way to go before the first TSM results are published, hopefully in 2024. After public consultation closes in March, we’ll start looking at all the responses and consider what we need to change in the draft to meet any concerns. Our aim is to publish a final version in late summer, giving landlords the rest of the financial year to get ready start gathering TSM information from April 2023. While it’s quite a long timetable, it’s one that makes the fullest possible consultation possible, particularly with tenants themselves.
So we warmly invite all social housing tenants s to take advantage of the remaining four weeks of consultation still to come, and tell us what they think. You can do this online, or by email, or even in a traditional letter sent through the post to our head office. We very much want to hear from you.
How to contribute to the consultation
The TSMs will apply to all social housing landlords, including local authorities, housing associations and other registered social housing providers. The Regulator wants opinions on whether the suggested measures (read them HERE) are relevant, accurate, responsive, do-able and will achieve these three goals:
- make a meaningful difference to tenants
- be possible for landlords to carry out
- set goals that the Regulator can check
The consultation closes at 6:30pm on 3 March 2022. Anyone with an interest in social housing can be involved in the discussion.
Add your thoughts online HERE;
or email consultation@rsh.gov.uk writing “Tenant Satisfaction Measures” in the subject line;
or write a letter to:
Tenant Satisfaction Measures
The Regulator of Social Housing
Referrals and Regulatory Enquiries team
Level 2
7–8 Wellington Place
Leeds LS1 4AP
