Competence and Conduct Standard

The Department for Levelling Up, Housing and Communities opened the consultation on February 6 and closed it on April 5 2024 . It forms part of a series of consultations on the implementation of the Social Housing Regulation Act.

The main aim of the CCS is to introduce a framework promoting high standards and professionalism in the sector.

To do this, the Government wants those who deliver social housing services to have or gain specific qualifications related to their work.

The CCS forms part of the Government’s drive to improve standards in the sector following the Grenfell tragedy in 2017 and the death of Awaab Ishak in 2020.

While we agreed with many of the proposals put to respondents, we urged the Government to consider our concerns on multiple sections.

Summary of Stonewater's main responses to the consultation:

Stonewater is committed to providing a customer-centred service based on the principles of respect, honesty and transparency.

Ensuring staff are working to the highest level of professionalism is an important step towards this goal.

But, while we welcome many of the proposals put to us during the consultation, we want to be sure the CCS recognises the importance of staff members’ prior experience in improving standards.

It is vital that new and existing staff are able to carry out their roles while working towards, or obtaining, a relevant qualification within a manageable time frame.

We also urged the government to give more clarity on certain responsibilities as providers, as well as further guidance on the legal position of organisations.

The main areas we asked the government to consider in our response are:

• To extend timescales set out for new and existing staff to have or work towards a qualification in line with other relevant qualifications. Staff who have a probation period should be given a 12 month period to have, or be working towards, a qualification. Likewise we estimate 3-5 years for existing staff within the sector to have or be working towards a qualification. This is even more relevant for smaller housing associations.
• A risk of senior housing managers and executives leaving the sector prematurely. We noted that those in such positions are likely to have been in the sector for a significant period of time, requiring them to keep abreast of sector changes and regulations. A requirement for them to re-sit any qualifications would be seen as inappropriate and unfair. We feel there is a missed opportunity for Recognition of Prior Learning and the importance of relevant gained experience. Consideration of other qualifications other than a housing qualification should be made for Assets related roles.
• To consider concerns surrounding the transition period. We believe the proposed time limits within which individuals will need to hold or be working towards a relevant qualification during the transition period are unworkable. We feel organisations should be able to develop an appropriate plan based on their own numbers and scale of impact. In terms of definitions, we are asking that continuity is ensured across the sector by using the National Housing Federation’s definition of smaller housing associations as those with fewer than 1,000 homes.

Sue Shirt, Stonewater’s Chief Customer Officer, said: “We support the Government’s proposals to address the significant concerns raised in the aftermath of the Grenfell tragedy.

“It is vital the sector strives to work to the highest possible standard so we can deliver a truly customer-focused service.

“While we welcome many of the proposal put to different providers and organisations during the consultation, we would urge the Government to consider our concerns.

“Most notably, it is critical colleagues have appropriate time to complete a qualification without impacting their ability to deliver services.

“We would like to see timescales for staff to be working towards a relevant qualification brought in line with other qualifications while working in their roles. This would make timescales more realistic and avoid high failure and repeat take figures.

“We also would urge the government to include relevant gained experience as a standard of professionalism, as well as qualifications.”