Briefing Note to Regulated Housing Providers – Confidence and Conduct Standard for Social Housing – Qualification requirement

Dear Members

You will have seen the announcement of a new consultation regarding the requirement for leaders in the housing world to be qualified.

Competence and Conduct Standard for social housing: consultation – GOV.UK (www.gov.uk)

As you know we worked hard to influence policy and have, we hope, encouraged a sensible exemption for trustees as below.

“It is important that we take a proportionate approach in ensuring that the policy has its intended impact in terms of driving up standards in the sector but that it does not negatively impact on organisations’ ability to deliver good quality housing management services.

“We are aware that some small housing providers, for example, almshouses, smaller TMOs and housing co-operatives, are often governed or managed by volunteers. Some volunteers are ‘officers’ of the organisation in question, and we have assessed that where this is the case, they could fall within scope of the qualification requirements. Requiring unpaid volunteers to undertake a housing management qualification could lead to significant adverse impacts for small organisations, including in some cases closure, which would be to the detriment of tenants. Therefore, as detailed at paragraphs 15b and 46c of the policy statement, we propose that where an officer of a registered provider or a services provider is an unpaid volunteer, that person will not need to gain a relevant qualification.“

However, the provision of the Act may still require a clerk to hold a qualification: A Senior Housing Executive or Senior Housing Manager of a registered provider will be classified as a Relevant Person.

This consultation will point to who that person is in most cases. For our members that may not be so easy to identify, particularly as part of the inclusion is that a significant portion of the person’s time is spent on the housing activities. If a person is in a part time role the requirement for qualification is unclear but likely to include a Clerk working more than a few hours. This section from Appendix B1.

 “ A ‘significant portion’ should be taken to mean that these responsibilities are an important and substantial aspect of their role: in many (but not all) instances they will take up more than half of that individual’s working time.“

Do have a look at the consultation and let us know your thoughts. We will arrange a zoom meeting to discuss your thoughts about this and other consultations.

At present our view is that trustees must be exempt. We are also proposing that if a staff member of the membership body, The Almshouse Association, gains the appropriate qualification, member charities of The Almshouse Association with under 100 units should be exempt from the qualifications associated with the Competence and Conduct Standard for Social Housing. But you may not agree?

We look forward to our discussions with you.

posted 12 February 2024

The Zoom will take place on 22 February 2024 at 12.30. Please click here to access. Please contact angelawaters@almshouses.org for further details.