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Glasgow and West of Scotland Forum of Housing Associations

21st June 2012

Implementing the RSL Model CHPPaul McFaddenComplaints Standards Authority (CSA)

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Why changing complaints?

Problems across public services Inconsistent Poor complaints

handling Complex and

confusing Focused on

organisational need not on customer

Value for money

Benefits Cheaper and quicker Customer good will Fewer repeat

complaints Less stressful for staff Greater customer

satisfaction Improving services

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2010-11 SPSO ‘Premature’ rates

0%

10%

20%

30%

40%

50%

60%

70%

80%

Health HousingAssociations

Local Authority ScottishGovernment &

DevolvedAdministration

Further & HigherEducation

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Public Services Reform (Scotland) Act (2010)

Complaints Standards Authority A standardised, simplified

Model Complaints Handling Procedure for each sector Make complaining easier,

simpler and more consistent for all customers

Consistent process and timescales across whole public sector

Complaints Standards Authority centre of best practice Working with each sector to

develop and share best practice in complaints handling

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Model Complaints Handling Procedures (CHP)

Model CHP– adapt and adopt Customer facing information Employee guide

FEFERSLs

RSLs

LAs

LAs

HEHE SGSG

PrisonsPrisons

NDPBs & Agencies

NDPBs & Agencies

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Requirements of RSL Model CHP

What is / is not a complaint 2 stages, set timescales Standards for recording, reporting,

learning and publicising Dealing with unacceptable actions Clear roles and responsibilities Empowering frontline staff to resolve

complaints Share outcomes and lessons learnt

throughout organisation tenants Share outcomes and action taken with

tenants

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The major changes – streamlining

Written complaint to

Housing Officer

Written complaint to

Housing Manager/SD

Appeal to Committee/Director

or CEO

Review by SPSO

Informal local resolution

Frontline

Investigation

• Full investigation by designated complaints handler• Sign-off by senior manager• Written response within 20 working days

Review by SPSO

• Quick response from service staff – at point of service delivery• Resolve or remedy - within 5 working days• Where issues identified apology/explanation and/or redress• Complaint details recorded

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Roles and Responsibilities Empowering frontline staff

Senior management ownership Monitoring Reviewing cases / learning Signing off investigations – the final decision Leading culture change

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Defining the Management Committee role in Complaints

SHR Regulatory Framework - Governance and Financial Management

5.6 and Regulatory Standard 1 highlight the importance of the Committee concentrating on the strategy and leadership of the RSL rather than getting involved (as a Committee) in operational matters

Section 5.6:“When we refer to governance we mean the arrangements for the leadership, strategic

direction and control of an RSL.”

• Standard 1.1“The governing body sets the RSL’s strategic direction. It agrees and oversees the

organisation’s strategic and financial plans …..”

• Standard 1.5 “The governing body provides the necessary challenge and holds the senior officer

to account or his/her performance.”

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Defining the Management Committee role in Complaints

No ‘appeal’ to management committees

Strategic not operational role

However, some scope for individual tenant committee members being involved in Stage 2 – flexibility of approach on individual decisions

Monitoring and review information from complaints

Monitor and review complaints handling performance

Address service improvement issues

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Recording, reporting and publicising

Recording: Recording of all complaints Specifies minimum data requirements

Reporting: Quarterly reporting to senior management / executive team What information do Management Committee want/need?

Publicising: Quarterly – Publicly reporting to tenants on complaints

outcomes, trends and actions taken Show the impact not just stats – stories (you said we did).

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Complaints being used to improve services

Recording, reporting, learning and publicising

Systems in place to record, analyse and report on the learning from all complaints - subject, outcome and action taken. ‘You can’t manage what you don’t measure’

Service improvements identified through complaints analysis - changes made to services, guidance or policy to prevent the problem recurring

Senior managers receive and act on regular reports - service improvements are agreed, actioned and reviewed quarterly

Processes in place to identify and respond immediately to critical or systemic service failures

Informing complainants about the lessons learnt

Publicly reporting on the number of complaints received and the outcome

Evidence of sector wide sharing of learning

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Challenges in implementing Culture Change

Value Complaints – not all about reducing numbers Empower and support frontline staff – mindset of quick resolution Admit failings - apology Normalise complaints, engrain them throughout your organisation

Training and staff awareness

Recording systems Definition of complaint / service request

Processes in place to analyse, report and learn from all complaints

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Social landlords manage their businesses so that:

• tenants and other customers find it easy to communicate with their landlord and get the information they need about their landlord, how and why it makes decisions and the services that the landlord provides.

This outcome covers all aspects of landlords‘ communication with tenants and other customers. It is not just about how clearly and effectively a landlord gives information to those who want it. It also covers making it easy for tenants and other customers to make complaints and provide feedback on services, using that information to improve services and performance, and letting people know what they have done in response to complaints and feedback. It does not require landlords to provide legally protected, personal or commercial information.’

(Emphasis added by SPSO)

How will compliance with the CHP be monitored?

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How will compliance with the CHPs be monitored?

SSHC / SHR

Year 1: 2012/13– Pro-forma to SPSO by October– If not fully compliant, provide plans for implementation– APSR in early 2013

Year 2: 2013/14– Annual Return on Charter (ARC) includes performance information– Performance report to tenants– Self-assessment

Year 3: 2014/15 (and ongoing)– SHR - possible thematic report – ARC and self-assessment

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2013/14 - Performance 2013/14 High-level performance indicators consistent between

sectors Through ARC and self-assessment indicators include:

number and percentage of complaints received and closed at each stage

number of complaints upheld / not upheld at each stage as a % of all complaints closed

the average time in working days to resolve complaints at each stage measure on customer satisfaction with service (as opposed to

outcome). measures around: Publicising, Reporting, Learning

Benchmarking against peers (e.g. SHBVN, Housemark, CIH etc)

Monitor changes over time (eg % Stage 1, % Uphelds)

However, further discussion and consultation is required

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Significant Performance Failure

Now remit for the Scottish Housing Regulator

A significant performance failure is something that your landlord does or fails to do that puts the interests of its tenants at risk, and your landlord has not resolved the failure. This is something that is a systemic problem that does, or could, affect all of your landlord’s tenants.

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SHR - Significant Performance Failure

A significant performance failure happens when: your landlord is not delivering the outcomes and

standards in the Scottish Social Housing Charter over a period of time; or

your landlord is not achieving the regulatory standards on governance or financial management.

A complaint between an individual tenant and a landlord is not a significant performance failure. Significant performance failures are not, therefore, dealt with through the complaints handling procedure.

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CSA support moving forward

Training • E-learning modules

Module 1: Understanding the Model Complaints Procedure

Module 2: What Is A Complaint?

Module 3: What Customers Want When They Complain

Module 4: Getting It Right From the Start

Module 5: Active Listening

Module 6: Finding the Right Solution

Module 7: Learning From Complaints

Module 8: Managing Difficult Behaviour

• Investigation and Frontline classroom-based courses

Valuing complaints website www.valuingcomplaints.org.uk

Complaints handling developments and good practice resources Ask each other – cross-sector discussion forum / community Ask CSA – implementation guidance

Networks of complaints handlers Sharing best practice Developing standardised categories Benchmarking performance

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Discussion What is the biggest challenge you will face? How prepared are you and your staff? What training or awareness programme do you need? Do you record, analyse and report on all complaints? If not

how could this be achieved? What might be challenges / barriers to achieving this?

Do you regularly review the lessons learned to identify patterns in service failures? How could you improve this?

Do you publish information on complaints - volumes / types of complaints/performance?

Do your senior management receive and act on regular reports? Do you have processes in place to allow quick response to

critical or systemic service failures? What information do Management Committee want/need? How role does your management committee play in complaints? Howe might this be affected by CHP?

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Any Questions

?

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Contact Detailswww.valuingcomplaints.org.uk

Paul McFaddenHead of Complaints Standards

0131 240 2964 CSA@spso.org.uk

Francesca RichardsComplaints Standards Authority Officer

0131 240 8857 CSA@spso.org.uk