Arches Housing – Compliance Health Check

Arches Housing – a Yorkshire based registered provider who own and manage around 1130 properties primarily across the Sheffield and Rotherham areas – had their governance rating downgraded from G1 to a G2 following a self-referral to the Regulator in July of 2017. In Arches’ case, the then HCA deemed in the Regulatory Judgement that they needed “to strengthen its operational control arrangements to ensure adherence to all relevant health and safety legislation and regulatory requirements.” Prior to their voluntary disclosure Arches approached Pennington Choices for a professional assessment of their compliance management arrangements. They were keen to understand their compliance position across the “big five” areas of gas safety, fire safety, water hygiene, electrical safety, and asbestos management. Our Compliance Health Check was the perfect tool to allow them to establish and understand their compliance position and importantly how they could strengthen performance and assurance.

The Challenge

As a result of the Compliance Health Check we identified a number of weaknesses within Arches approach to compliance which, under co-regulation, they felt needed to be brought to the attention of the regulator. Arches were very open to this and engaged with the regulator in an honest and open manner. Our next challenge was therefore to support Arches through their voluntary disclosure and facilitate effective communication with the regulator; the ultimate aim being to ensure they understood what route needed to be taken to restore their governance rating and how it would be navigated. To help them to achieve this we used our findings from the Compliance Health Check to produce a Compliance Roadmap which detailed exactly what Arches needed to do to overcome its weaknesses and strengthen its approach. The Regulator judged that Arches needed to improve aspects of its governance arrangements to support continued property compliance, as it was unable to provide sufficiently robust assurance that it was compliant with statutory tenant health and safety requirements. In particular, Arches was unable to evidence they had carried out water hygiene risk assessments and asbestos management surveys to their non-domestic stock as well as electrical testing in respect of their domestic stock in the form of Electrical Installation Condition Reports (EICRs).

What We Did

The work we undertook for Arches can be broadly summarised in to 3 stages: Compliance Health Check – Our team carried out a professional assessment of each of the Compliance areas, and reviewed the processes and procedures Arches had in place for the management of each area and how effectively these were being implemented. These were reviewed against all relevant legislation, approved codes of practice, industry best practice, and the informed opinions of our experienced compliance consultants. We then reviewed the internal data management arrangements and made recommendations for improvement. We also assessed the level of compliance reporting at management and governance levels, a pivotal component of achieving compliance, to ensure senior leaders were aware of their true compliance position, the challenges they faced, and what was being done to overcome them. Facilitating and supporting the voluntary disclosure – ensuring that Arches had the right tools to engage with the regulator effectively and understand exactly what they would need to do to improve their compliance position and importantly demonstrate assurance. Roadmap to compliance and ongoing reports to Board – outlining clearly what the journey back to compliance looked like for Arches. The roadmap outlines the step by step process to be followed in order to fill the outstanding compliance gaps, and just as importantly, what actions should be taken in order to prevent them from reoccurring. Arches were also able to implement a process of ongoing reporting of the compliance position which allowed Board to ensure the organisation continued to progress in the right direction.

Our Achievements

A combination of the support we provided, and the huge amount of effort put in by the staff, senior leaders, and Board at Arches meant that the organisation was able to achieve a Governance regrade to G1 which was announced in July 2018. Additionally, we are now confident that Arches have a good understanding of what their statutory compliance obligations are and more importantly, how they should be managed, recorded, and reported.