The focus of this article considers the findings from recent RSH inspections specifically in relation to Consumer Standards and the significant implications they have for Awaabs Law and the consultations around Decent Homes Standard (DHS) and Housing Health and Safety Rating System (HHSRS) that are taking place this year.
Impact on Awaabs Law
The inspections reinforce the urgency of addressing damp and mould hazards, which are central to Awaabs Law following the tragic death of Awaab Ishak.
Landlords must now investigate hazards within 14 days and begin repairs within a further 7 days aligning with the Consumer Standards’ emphasis on proactive tenant safety.
The inspections highlight poor complaint handling which Awaabs Law seeks to rectify by ensuring tenants can hold landlords accountable for unsafe conditions.
Impact on DHS Consultation
The Consumer Standards inspections revealed gaps in stock condition data, reinforcing the need for a revised DHS that mandates better monitoring of housing quality.
The DHS consultation is considering expanding the definition of ‘decency’ to include energy efficiency and accessibility, which aligns with findings that many homes fail to meet modern living standards.
The inspections show that some landlords struggle with compliance, suggesting that the revised DHS standard may need stronger enforcement mechanisms.
Impact on HHSRS
The inspections exposed fire safety and structural risks, which are key hazards assessed under the HHSRS.
Awaabs Law is set to extend HHSRS protections, requiring landlords to fix hazards like excess cold and electrical risks within strict timeframes.
The findings suggest that landlords need better risks assessment frameworks, which could lead to updates in HHSRS guidance to improve hazard identification.
What actions and challenges should you be considering — and, more importantly, how can TIAA Ltd support you with the independent assurance solutions you need?
Action: Data Management systems need to have up to date information on housing conditions and tenant needs
Challenge: As Management and as a Board member your assurance requirements need to ensure data completeness and accuracy. How do you know the source of the data that is being presented? How do you know the data is accurate and complete?
TIAA Difference: Our core audit work routinely substantiates data back to source systems and validates the data being reported to Management and Board. Our specialist data team complete specific data analytics reviews to identify any exceptions and/or anomalies with the dataset presented.
Action: Implementing effective tenant scrutiny panels to ensure residents have a meaningful voice.
Challenge: As Management and as a Board member you need to be assured that the Tenant Scrutiny Panel is aligned to the strategic vision of the organisation.
TIAA Difference: Our governance specialist team attend and observe Tenant Scrutiny Panels to provide assurance that the panel is operating efficiently, has effective reporting and escalation routes and its focus is appropriate. In addition, we are linking in with Tenant Scrutiny Panels (where the core audit assignment is relevant) to ensure the resident voice is captured as part of the audit scope process.
Action: Refine your governance framework to improve oversight and accountability, ensuring they meet regulatory expectations.
Challenge: As Management and as a Board member, how can you be assured that any revisions to your governance framework are effective, are operating as intended and aligned to regulatory expectations?
TIAA Difference: Our governance specialist team review information flow / escalation routes across the governance structure, to ensure it remains effective and aligned to regulatory expectations. In addition, the team routinely complete board observations to provide that independent assurance that the expected oversight and accountability is operating in practice.
Action: Many landlords are implementing structured plans to address fire safety concerns and clear maintenance backlogs.
Challenge: As Management and as a Board member, how do you know that the structured plans being presented are adequate to address the technicality of the fire safety concerns raised or the maintenance backlogs?
TIAA Difference: Our specialist H&S team review the data and the planned actions to tackle concerns, backlogs and/or remediation works and provide assurance that the actions taken are appropriate to address technical exceptions and that they have been effectively and fully implemented.
At TIAA Ltd we are routinely helping our clients to be aligned with regulatory expectations. If you would like to discuss any aspects of this article or seek further information, please contact Angela Ward – Director Housing – angela.ward@tiaa.co.uk