Welsh Government
Housing Directorate – Regulation
Housing Association Regulatory Assessment
Cardiff Community Housing Association Limited
Registration number: L035
Date of publication: 16 August 2013
Welsh Government
Housing Association Regulatory Assessment
The Welsh Ministers have powers under the Housing Act 1996 to regulate Registered
Social Landlords (RSLs) in Wales in relation to the provision of housing and matters relating
to governance and financial management. Part 1 of the 1996 Act is amended by Part 2
of the Housing (Wales) Measure 2011 (“The Measure”) and provides the Welsh Ministers
with enhanced regulatory and intervention powers concerning the provision of housing by
registered social landlords and the enforcement action that may be taken against them.
The Welsh Ministers are publishing this regulatory assessment report under section 33A
of the Housing Act 1996.
The regulatory assessment work undertaken follows the risk-based approach to regulation
and seeks to identify strengths and areas for improvement in meeting the “Delivery Outcomes”
(standards of performance). These are set out in the Regulatory Framework for Housing
Associations Registered in Wales, which is also known as “the regulatory framework”.
This report sets out the Welsh Government’s assessment and is designed to provide the RSL,
its tenants, service users and other stakeholders with an understanding of how well it is
performing against the “Delivery Outcomes” relating to:
• Landlord services and
• Governance and Financial management
© Crown copyright 2013
WG18713
ISBN 978 1 4734 0107 5
Description of Cardiff Community Housing Association
Cardiff Community Housing Association Limited is a ‘traditional’ community
based housing association. It is a provident and industrial society with charitable
rules, formed in 1996, as a result of the merger of the ‘Adamsdown’ and ‘Moors’
Housing Associations.
The Association has more than 2,600 homes providing both general and supported
accommodation within Cardiff. Many of its properties are located in the most
deprived areas of the City, some of which are also significantly deprived when
compared to Wales as a whole.
Customer services are provided principally from a local office in Adamsdown, Cardiff,
with its head office a short distance away, close to Cardiff Bay.
CCHA hosts two local agencies:
• ‘Cardiff Accessible Homes’: works with Housing Associations throughout the City
to help match housing applicants with mobility needs to vacant adapted housing;
and
• ’Care and Repair Cardiff’: which helps older people in their own homes, or renting
privately to complete repairs, improvements and adaptations to their homes.
The Association has an established development programme, which aims to deliver
176 new homes over the next three years. It also undertakes community regeneration
work, including the provision and improvement of housing, health and community
facilities, in liaison with the Council and a range of other partners.
Overall Assessment
Summary: Landlord Services
CCHA builds and renovates homes to a good quality, to meet a range of local
housing needs. It has started to analyse the impact of its lettings process in liaison
with its partners, but needs to replicate this in understanding whether the range
of activities it takes to prevent and alleviate homelessness maximise the impact
it can achieve.
It works effectively with its partners to meet the needs of tenants who require
adaptations to their existing or newly allocated homes. The Association has taken
steps to improve the level and quality of long term empty homes in the community.
It has also improved the speed in which its empty homes are relet, but this shows
mixed results, needing it to make more strategic improvements to drive this
further forward.
CCHA aims to uphold the rights and duties of it and its tenants in a fair and
supportive way and can demonstrate success in providing support to tenants to
sustain their tenancies, in liaison with its partners. It is seeking to replicate this for
tenants at risk of financial difficulty, to balance their needs and protect its income,
as the UK Government’s welfare reforms take effect. Rents and service charges are
set in a clear and fair way.
1
The Association has also made a positive impact on tenants’ views about the
homes and neighbourhoods they live in, such as in reducing incidents of anti-social
behaviour and maintaining the cleanliness of its schemes. It plans to roll out
further improvements in all aspects of this work, as part of an increasing strategic
framework. This will be important in ensuring that it has a clearer understanding
of the needs and aspirations of the community and to increasingly target resources
to those areas where the need is highest and it can have the greatest impact.
CCHA recognises that it needs to embed improvements to the repairs and
maintenance services it offers, to maximise their efficiency and effectiveness. It needs
to do this with greater customer involvement. It has made some significant changes
to its responsive repair service, but it is too early to show this is delivering the
outcomes it is seeking, although there are some signs of progress. It is developing
an improved approach to asset management and investment, which provides a
platform for capturing the changes which are needed and delivering improvements
in a way which maximises their impact.
Summary: Governance and Financial management
CCHA can demonstrate that is aiming to place tenants and service users at the
heart of its work. This includes it valuing and responding to their views and
improvements it has made to boost their experience of the services which are
received. However, it can not yet show that this is always delivering positive
outcomes when tenants first contact the service or that its approach is consistently
effective in all that it does. It also needs to ensure that its developing approach to
understanding the outcomes it is achieving becomes more embedded and robust,
across the organisation.
The Association is open and honest with its customers and other stakeholders,
but could enhance this by providing more balanced information about its
performance. It understands the importance of meeting the diverse needs of
communities and is working to achieve this, although it recognises it has more
to do to make this effective across all of the work it undertakes.
CCHA undertakes a range of work to meet the economic, social and environmental
needs of communities, but needs to measure the impact it makes in a more robust
way, to help ensure it is targeting its resources, where it will make most difference.
CCHA has actively demonstrated strong leadership within the community and is now
seeking to replicate this within a new strategic framework for delivery of the entire
service. This is supported by its Board taking increasing ownership and control of
the direction it is taking. It is improving its planning and performance management
framework, along with its skills and capacity across the organisation to support
this, while retaining its ethos of making a positive difference to local communities.
It recognises that improvements are needed to make this more effective, with a
stronger outcome-focussed self assessment, which will help it make the best use
of resources and improve value for money.
2
CCHA embraces partnership working across all it does and can demonstrate
exemplary feedback from partners about how this works in practice. This is
particularly significant because this is consistent across all partners it works with,
from local community groups to statutory agencies.
The Association is a financially sound and viable business.
Future Regulatory Engagement
Cardiff Community Housing Association is assessed as requiring a medium
level of regulatory engagement in future. This engagement will focus on the
following areas:
• Improving impact measures to better understand the outcomes the Association
is achieving, including through self-assessment and the planning and performance
management framework;
• Increasing knowledge of tenants and service users and tailoring services
in a comprehensive way;
• Increasing the effectiveness of involving of tenants in shaping services,
reviewing performance and developing the Association’s future plans;
• Effectively implementing the Association’s welfare reform strategy and
responding to its impact on tenants and CCHA’s rental income;
• Ensuring the Association’s strategic understanding of diversity results in
measurable outcomes across all of its work;
• Implementing the Association’s new strategic framework to improve value
for money;
• Developing robust asset management plans in liaison with tenants and working
with them to embed further improvements in the repairs and maintenance services;
• Analysing performance and practice, to help optimise relet times for empty homes;
• Completing the Association’s analysis of the impact of its lettings arrangements
and responding to its findings, to help ensure a fair and effective allocations
scheme; and
• Undertaking and responding to comprehensive impact assessments of the
Association’s role in preventing and alleviating homelessness.
Regulatory engagement will encompass a range of activities including contact
with service users, including involved tenants and owners, senior management,
operational staff and the board, observation of events, visits to communities where
regeneration initiatives are planned and monitoring the Association’s progress
against its plans for improvement.
Landlord Services
1. We build and renovate homes to a good quality.
CCHA’s new build programme has provided a wide range of quality,
sustainable housing, to meet a range of community needs, in line with the assessed
local needs of the local authority.
3
The Association has a robust approach to assessing financial viability and risks
in new housing developments; and to seeking increased value for money in the
procurement of development activity.
2. We let homes in a fair, transparent and effective way.
CCHA plans to improve its strategic approach to ensuring the future viability of
its stock through its new approach to Asset Management. This builds on the progress
it has made in reducing the level of long term empty homes, to a small number
of properties. However, it has more to do to improve its understanding of the
reasons for the time it takes to let empty homes, as these are higher than some
other providers.
Housing applicants have open and well publicised access to social housing through
the Cardiff Common Housing Register, which is accessible and transparent. CCHA has
started to work with others to measure the impact of its lettings process and how
well this ensures a fair and equitable process, in line with the diversity profile of the
community, but this is not yet completed.
The Association cannot demonstrate that it always lets homes in line with resident
expectations. It needs to re-visit its lettings standard with its tenants, including those
who have recently moved into empty homes, to ensure this is up to date and reflects
their needs and preferences.
It has a proactive approach to working with the Cardiff Accessible Housing scheme,
to help ensure that adaptations for existing residents are installed in a prompt
manner and to ensuring that empty adapted homes are let effectively to those
who most need them. Tenants who have received adaptations have expressed
high satisfaction with the service provided.
CCHA supports the council and other organisations to help prevent and alleviate
homelessness. However, it needs to undertake a more comprehensive assessment
of the impact it is making, in liaison with the local authority, to be sure that it is
maximising the role it can play.
3. We manage our homes effectively.
CCHA makes clear the rights and duties of itself and its tenants from the start of a
tenancy and seeks to uphold these rights and duties in a fair and responsible manner.
It can demonstrate some positive outcomes in working with its partners to provide
support to tenants who need help in sustaining their tenancies. It is working to
improve the support it provides to its older residents, but it is too early at this
stage to determine how well this is meeting their needs. It needs to improve its
understanding of what needs exist as it collects more profile information, to help
ensure there are no needs which are not being met.
The Association sets rents and service charges in a clear, fair and accountable
manner, with tenants expressing a high level of satisfaction with the process. It has
plans to improve its engagement with its residents about the related services, as this
is currently not always as effective as it could be.
4
CCHA is actively improving the ways it provides support for tenants at risk of
financial difficulty, in liaison with its partners, while protecting the Association’s
income. This is particularly important in light of the UK Government’s welfare
reforms coming into effect. However, it recognises that it needs to develop this
further through the strategy it has in place and to measure the outcomes it achieves
robustly on an ongoing basis. This will help it to target resources where they are
most needed and to respond and adapt quickly to the impact of the changes on
both tenants and the business.
The Association has taken a number of steps to improve the communities it
works in and help ensure they are attractive, well-maintained, safe places to live.
These local initiatives have resulted in relatively strong tenant satisfaction with their
homes and neighbourhoods, especially when considered in the context of the areas
in which CCHA works.
The Association now plans to roll out a more strategic framework of estate
improvement plans, to provide a more coherent and prioritised framework for the
work it undertakes, in conjunction with wider asset management and investment
proposals. This will be important in it putting its resources into initiatives which will
have the greatest impact and in understanding and measuring the outcomes of its
work, against a clearer assessment of community needs and aspirations.
4. We repair and maintain homes in an efficient, timely and cost
effective way.
The Association is in the midst of developing a new asset management strategy,
which it recognises will be important to ensure it has deliverable and affordable
plans for long term investment in its housing stock and other assets. It recognises
that it needs to engage with tenants to ensure that these plans reflect their views
on customer needs, preferences and priorities.
CCHA is working to complete compliance with the Welsh Housing Quality Standard
over the next year. This is slightly behind what it might have achieved, but having
recognised this, the Association accelerated the work programme a few years ago
to minimise this delay in making improvements to all of its housing stock.
Tenants report high satisfaction with the quality of major work undertaken to their
homes, but CCHA needs to consider how it might understand tenants’ views about
earlier stages of the process in a better way than it does at present. It has plans to
improve the efficiency and effectiveness of planned works through a newly procured
contract, which it is at the early stages of forming.
The Association has re-designed its responsive repair service, following tenant
feedback, through a new procurement contract which aims to improve the service
and boost customer satisfaction. It is relatively early days in the new contract
delivery, which shows evidence of both improvement and some areas which are
not yet meeting expectations. The Association is however working closely with its
contractor to address this, so that it can maximise value for money outcomes over
the longer term. It also needs to re-invigorate tenant involvement in the process,
as this was effective as part of the initial procurement arrangements, but has since
dropped away.
5
5. We provide fair and efficient services for owners.
We did not assess this delivery outcome due to the relatively small number of owners
to which the Association provides services.
Governance and Financial Management
Governance
1. We place the people who want to use our services at the heart
of our work – putting the citizen first.
CCHA is working towards gaining a comprehensive understanding of its tenants and
service users, but recognises that it has more to do, to ensure this work is completed.
It can show some evidence of tailoring services and activities to individual needs,
particularly on a local project level, but plans to increase this across all its work,
as its data becomes more substantive.
The Association can demonstrate that it values the views of its tenants, whose
satisfaction with their views being listened to and acted upon has increased.
It also actively encourages tenant involvement in discussions about how services
are delivered and can demonstrate improvements which have been made as
a result. Tenant satisfaction levels also show improvement in how they value these
opportunities. However, the Association recognises that it has more to do to ensure
tenant involvement is comprehensive in enabling them to help shape its services,
review its performance and develop its future plans across all that it does.
CCHA is developing a clearer focus on outcomes through its corporate objectives
and strategic plans. On a project level it can also demonstrate that it works hard
to understand the needs and aspirations of local people and its partners in the
communities in which it works. However, it needs to build a greater relationship
between its high level corporate outcomes and the performance measures which
sit beneath these, to ensure a clearer understanding of the impact it is making
in the work it undertakes.
The Association has taken a number of steps to improve the ways in which tenants
can contact the service and its responsiveness to tenant enquiries. This resulted
from tenant feedback which suggested the service was not meeting their needs.
However, it is too early to determine whether these arrangements have been
successful, from service users’ point of view, which it will be important for the
Association to establish, as this underpins its ability to be effective in many aspects
of wider service delivery.
CCHA communicates information and advice in an appropriate, timely and effective
manner, which tenants’ rate highly as keeping them informed. It has developed
a range of service standards with its tenants, which clearly set out the level of service
which they can expect to receive. However, it needs to do more to promote these
and to measure and publish performance against them, in liaison with its tenants,
to provide them with confidence about their impact in improving service delivery.
6
In a number of ways, the Association demonstrates accountability to its tenants
and service users, including publication of its self-assessment. It could enhance this
further by providing clearer information about its performance and the outcomes
it is achieving.
CCHA has recently reviewed its approach to dealing with complaints. It makes it
easy for people to let it know when things go wrong and can show examples where
this feedback has been used to improve services. It now needs to embed its newly
implemented approach to ensure this happens in a consistent and effective way
across the service and to test tenant satisfaction with the arrangements to ensure
that they are effective in meeting their needs.
2. We live public sector values, by conducting our affairs with
honesty and integrity and demonstrate good governance
through our behaviour.
The Association is open and honest in working with tenants and partners, but could
enhance how balanced the information provided is, by being more challenging
about what its own expectations of performance are within its self assessment
and providing clearer data on trends and comparison with others, in information
which it publishes.
It is making progress towards ensuring its services reflect the diversity of the
communities where it operates. The Association understands and embraces the
importance of this in delivering positive outcomes in the diverse communities in
which it works and at a local level, this works effectively in practice. This includes
treating customers who prefer the medium of Welsh on an equal basis to English
speaking residents. However, it needs to ensure that its strategic understanding
is translated into effective actions and outcome measures across all it does.
CCHA undertakes a significant number of community initiatives which aim to
improve the economic, social and environmental wellbeing of the communities
in which it works. It can demonstrate strong anecdotal evidence, including the views
of local people and its partners of the difference made to individual residents and
communities. It now needs to improve the robustness of its impact measures, to give
a more clear understanding of the outcomes it has delivered, against the financial
and staff resources it has committed to them.
3. We make sure our purpose is clear and we achieve what we set out
to do – knowing who does what and why.
The Association is working to improve its strategic focus, so that the strong
leadership it has shown in working in challenging and deprived communities is
replicated in a more business-like focus across all of the work it undertakes. It has
developed an improved people management strategy, explicitly linked to strong
customer service. It now needs to roll this out effectively, to maximise its ability
to ensure clear, informed and transparent decision making, linked to its corporate
objectives, throughout all it does.
7
CCHA’s Board has enhanced its strategic leadership and control of activities. It plans
to develop this further to respond to the challenging housing environment as it
strives to balance its community and business objectives. It recognises that it needs
to develop the Association’s focus on outcomes.
The Association is developing a clearer strategic planning and performance
management framework. It aims to be open and frank within this, but it needs
to do more to ensure that this and its arrangements for the self-assessment which
inform it are more robust and challenging. This includes understanding the impact
the Association is making from the customer point of view and being more coherent
in terms of the outcomes it is aiming to achieve.
CCHA has a strong community focus which has helped embed a culture which
is about making a positive difference to the people and communities with which
it works. The Association is innovative and valued for its willingness to take on
challenging initiatives within deprived communities. It recognises that it could do
more to learn from others and to build on the positive work it does by embedding
an increased outcome focus within the work it undertakes.
It is taking a proactive approach to ensuring it has the right culture, to fit both with
its ethos of seeking to make a positive difference to the communities in which it
works and to support its shift to a more strategic organisation. It is making progress
in ensuring it has the right people, with the right skills and tools to achieve its
objectives. It recognises that it has more to do, which it plans to deliver through
its new people strategy, so it is too early to determine how well this is delivering
consistently positive outcomes at this stage.
CCHA recognises that it needs to do more to ensure a robust strategic approach
to improving value for money. It can show some improvements in costs achieved
through procurement exercises and work to increase the efficiency and effectiveness
of service delivery. However, it has developed a new framework to ensure outcomes
from this are more robustly measured and actions are taken in a more coherent and
coordinated fashion, to improve value for money and its use of resources across all
areas of its work.
4. We engage with others to enhance and maximise outcomes for our
service users and the community.
CCHA embraces partnership working across all it does and can demonstrate
exemplary feedback from partners about how this works in practice. This is
particularly significant, as this is consistent across all the partners it works with,
from local community groups to statutory agencies.
It ensures a strong link between its own and wider community priorities,
including working closely with the local authority, to help the Council deliver its
strategic housing role. The Association’s capacity to deliver improved outcomes has
been increased by the alliances it has developed, though it recognises that it needs
to enhance the measurement of the impact these achieve, as part of its improving
approach to understanding outcomes.
8
Financial Management
5. We are a financially sound and viable business.
Cardiff Community is a financially sound and viable business. It has a robust
financial management framework and adequate standards of risk management
and financial probity.
On 28 March 2013, the Welsh Government published a financial viability judgement
for CCHA. The judgement was: “Pass – The Association has adequate resources to
meet its current and forecasted future business and financial commitments”.
Sources of information and regulatory activity
The following information is generally received from RSLs:
• Audited annual accounts, including the internal controls assurance statement;
• External auditors’ management letter; and
• Financial forecasts.
In addition to the above, the following specific activities were carried out:
• Regulatory activity, via relationship management approach to regulation,
including contact with tenants and service users, board members, senior and
operational staff, key stakeholders; visits to a number of key sites and local
initiatives; and
• Review of self assessment, key customer information and associated “hard”
and “soft” evidence relating to the delivery outcomes.
Basis of regulatory assessment
This regulatory assessment is based on information submitted by the RSL,
our accumulated knowledge and experience of the RSL, its management and the RSL
sector as a whole.
In preparing this report, the Welsh Ministers have relied on the information supplied
by or on behalf of the RSL. The Directors of the RSL remain responsible for the
completeness and accuracy of such information.
This report has been prepared for the RSL as a regulatory assessment. It must not
be relied upon by any other party or for any other purpose. Any other parties are
responsible for making their own investigations or enquiries.
9
Key to High, Medium or Low regulatory engagement
High regulatory engagement
We will have a high level of engagement with the RSL where their profile indicates
we need the most tailored, intensive or continuous relationship. This may mean
engaging in a more sustained way with an organisation to develop a detailed
understanding of current and potential areas of risk and their approach to
managing them. Our engagement plan may involve a broader range of regulatory
activities e.g. monitoring progress; attendance of Board, Senior Management and
Tenant/resident meetings. We may also need a high regulatory engagement where
specific risks are likely to materialise, or have materialised, and we need to support
an organisation to improve its performance against the delivery outcomes.
Medium regulatory engagement
We will have a medium level of regulatory engagement with the RSL where their
profile indicates we need further assurance. For example, we may need more
information or a closer engagement with the organisation’s senior management
and/or governing body or to monitor progress against delivery outcomes and/or
improvement plans.
Low regulatory engagement
We will have low level of regulatory engagement with the RSLs where the impact
of problems occurring is low and the probability of the problems occurring is low.
In these cases we will plan to have limited contact with the organisation, unless other
events arise. In some cases we may highlight and monitor areas for improvement,
but in ways that are less intensive for medium or high engagement organisations.
10