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NRSCH Compliance

Provider Guide

As at October 2015

NRSCH Compliance User Guide for Community Housing Providers

TABLE OF CONTENTS

1 INTRODUCTION 1

2 STANDARD PERIODIC COMPLIANCE ASSESSMENT 2

2.1 Guiding Principles in Completing Compliance Return 4

2.2 Compliance Assessment 4

2.3 Financial Performance Report (FPR) Community Housing Asset Performance Report (CHAPR)

6

2.4 Tools and Guides to Assist in Completing the Compliance Return 6

3 COMPLIANCE PROCESS 7

3.1 Contacting the Provider 7

3.2 Release of Compliance Return 9

3.2.1 Logging In 9

3.2.2 Accounts tab 11

3.3 Completing the Compliance Return 18

3.3.1 Introduction Page 19

3.3.2 Core Documents Page 19

3.3.3 Performance Outcome 3

3.3.4 CHAPR Page 27

3.3.5 Consent, Authorisation and Declaration Page 27

3.4 Submitting the Compliance Return 29

3.5 Process Post Submission of Compliance Return 30

3.5.1 Change in scale, scope or Primary Registrar of Provider 31

3.5.2 Supplementary Evidence 32

3.6 Release of Draft Compliance Determination Outcome 33

3.7 Providing Feedback 33

3.8 Release of Final Compliance Determination Report 35

NRSCH Compliance User Guide for Community Housing Providers 1

1. INTRODUCTION This guide is prepared to assist Providers (users) complete a standard compliance return using the online regulatory system known as CHRIS (the Community Housing Regulatory Information System). Before setting out the process in more detail we begin by explaining the background and giving a brief overview of the compliance process. A provider’s primary jurisdiction is the one in which the provider delivers most of its community housing properties services, i.e. operates more community housing properties there than in any other participating jurisdiction. This includes assets owned or managed by community housing providers without assistance or with minimal assistance from the NSW Government. The Registrar of a provider’s primary jurisdiction is known as the Registrar. The provider reports to their Registrar. The Registrar is responsible for promoting both a culture of compliance and detecting and addressing non-compliance at the earliest opportunity in order to protect the integrity of the community housing sector. The Registrar proactively engages with providers on an ongoing basis to foster compliance. The engagement is risk-based and common risk profiling methods will be used to assess the risk of non-compliance in the future and for ongoing compliance assessment. In addition to proactive engagement with the sector to foster compliance, all registered community housing providers must periodically demonstrate that they are achieving relevant performance requirements under the National Regulatory Code (NRC), and otherwise complying with the National Law. Registered Providers must complete a standard compliance return on a regular periodic basis, and submit it to their Registrar. Tier 1 and Tier 2 providers must complete a standard compliance return every year. Tier 3 providers must complete a standard compliance return every two years. This forms part of a periodic assessment that seeks to ensure ongoing compliance with the NRC and constitutes the minimum level of oversight that will be applied. The Registrar may also seek input from other relevant parties, such as the housing agency for the relevant jurisdiction or other Registrars in the case of a multi-jurisdictional provider. The Registrar uses the information in the compliance return and in the supporting documents to prepare a compliance assessment report. This report sets out the outcome of the assessment on tier and compliance, findings on performance and the reasons for the determination. The compliance determination report will state whether the provider is compliant or non-compliant overall with the NRC. Where a determination is made that the provider is compliant there may be performance outcomes where compliance is determined to be ‘partial’. In these cases the report will include recommendations or actions to assist the provider improve performance and bring them to full compliance. The provider receives a draft determination report for comment before the final compliance determination report is issued.


Where the provider is determined to be non-compliant, enforcement action will be taken. This guide does not address enforcement and more information is available in the enforcement guidelines published on the website www.nrsch.gov.au Future refinement of the guide will encompass information from other sources such as the Registration Return Guide to limit cross referencing. This guide is a living document and will be enhanced over time. The Registrars are committed to ongoing engagement with providers to ensure guidance assists them in meeting their obligations under the National Regulatory Code and welcome feedback.

2. STANDARD PERIODIC COMPLIANCE ASSESSMENT Table 1 below sets out the steps involved in the compliance process and the standard deadlines. The whole process from the release of the standard compliance return will depend upon the type of regulatory engagement necessary for the Registrar to have sufficient information on which to make a compliance determination. Table 1: Steps and Timetable for Standard Compliance Return

Step Provider / Registrar

Lead time to complete

Description

Analyst contacts Provider

Registrar Week before return released to provider

To confirm provider contacts

Release of Compliance return with FPR excel template

Registrar Compliance start date

Provider will receive an email to prompt provider that the return is now available

Completion of compliance return

Provider 6 weeks Provider has six weeks to complete and provide/attach evidence

Compliance assessment

Registrar 8 weeks The analyst will check on completeness of return and if it looks reasonably accurate. If further information or clarification required they will contact provider and set new deadline. The time taken to carry out the assessment will depend upon whether in addition to the standard return further regulatory engagement is necessary. Composed of two elements: • Standard review and • Additional lines of enquiry

where necessary to reach a decision on compliance

Release of Draft determination

Registrar

Will vary as noted above

Provider feedback

Provider

Within 2 weeks from receipt of draft determination

Release of Final determination

Registrar Within 2 weeks from the receipt of provider’s feedback


The standard compliance return consists of the:

� Core financial and non-financial data sets (relevant to the tier of registration) � Standard business documentation that can be used to demonstrate the achievement of the

National Law outcomes. This is referred to as ‘core documents’. � Notification of significant changes to policy and procedures. The standard compliance return (return) will be completed and submitted through the CHRIS portal. Where registered providers have effective data systems and business documentation, the preparation and submission of the return should be a straightforward and streamlined process. There is no requirement to re-submit the same evidence required during registration if there are no changes to it. The focus of the return is on the minimum information needed to allow Registrars to make an informed judgement about compliance with outcomes at a point in time and to assess the risk of non-compliance in the future. A summary of the components of the return is presented in Table 2. Table 2: Components of the Standard Compliance Return

Standard compliance return

Tier 1 Tier 2 Tier 3

Core financial data

Tier 1 standard current financial return (incl. audit report) and 10 yr. forecasts



Core non-financial data

Tier 1 standard non-financial metrics return



Community housing assets data

Community housing asset performance report (part of ‘Return’ )

Community housing asset performance report (part of ‘Return’ )

Community housing asset performance report (part of ‘Return’)

Significant changes to policies & procedures

Updated policies & procedures



Action to address compliance findings

Report outlining actions to close-out any minor non-compliance or address compliance findings



Community housing (CH) development programme

List of CH development programmes and their status (or equivalent)

List of CH development programmes and their status (or equivalent)

Not required unless Provider has CH development and upon request by Registrar

Asset management Achievement of current strategic asset management & development plan (or equivalent)

Achievement of current strategic asset management & development plan (or equivalent)

Achievement of current asset maintenance plan (or equivalent)

Governance & management

Annual report (or equivalent)



Risk management Risk management plan and risk register (or equivalent)

Risk management plan and risk register (or equivalent)

Only upon request by Registrar


Continuation…. Tenant / resident satisfaction

Latest tenant/resident satisfaction report

Latest tenant/resident satisfaction report


Appeals and Complaints

Current appeals and complaints register (or equivalent document)



Performance against business goals

Latest report to Board detailing past and current performance against goals/targets in business plan & strategic asset management / development plan

Latest report to Board detailing past and current performance against goals/targets in business plan & strategic asset management / development plan


A failure to submit the return by the due date – six weeks from the start date, without the granting of an extension by the Registrar, may constitute a non-compliance with the National Law.

2.1 Guiding Principles in Completing the Compliance Return

In completing the return, providers should note the following principles.

� The return is structured around core data sets and standard business documentation rather than the outcomes in the NRC. This is because the same data item or document may contribute to demonstrating the achievement of multiple outcomes. The Evidence Guidelines document describes how different types of evidence may be used to inform judgements about the achievement of outcomes.

� Apart from the standard data sets, the components of the return describe examples of evidence—rather than prescribing required pieces of evidence.

� Evidence can be presented in the form that it exists. Providers are not expected to adjust existing key documents or plans to meet the specific description in the return. For example if a provider outlines its annual business activities and targets in a series of action plans rather than in one single business plan, these can be submitted as evidence.

� While the same ‘type’ of evidence may be required for different Tiers (e.g. current business plan), the expected depth and rigour of the evidence is different for each Tier: risk stratification by tier means evidence from a Tier 1 provider will be expected to be more comprehensive and sophisticated than evidence from a Tier 2 provider. Evidence from a Tier 3 provider will be expected to be briefer and simpler—commensurate with the scale and scope of their community housing activities.

� The responsibility is on providers to determine the adequacy of the business documentation they submit with the compliance return. A provider will not be non-compliant for submitting a ‘poor’ business plan. However they may be assessed as non-compliant if that business plan does not have the sufficient depth and rigour for their Tier of registration to demonstrate the achievement of the required outcome. Similarly they may be assessed at high-risk of non-compliance in the future and be subject to additional, targeted monitoring.

� The responsibility is on providers to validate their financial and performance data before submission. By approving the submission of the compliance return the governing body is providing assurance of data reliability.


2.2 Compliance Assessment

Whereas the registration assessment confirmed the capacity of providers to meet all conditions of Registration, the initial compliance assessment is the first time the Registrar assesses actual compliance in achieving the outcomes and requirements of the National Law. As such, the initial compliance assessment requires greater scrutiny of submitted evidence than subsequent standard compliance assessments. Once compliance is confirmed at the initial compliance assessment and a provider is assessed as low-risk, standard compliance assessments will simply focus on confirming that there has been no change to the risk profile. Initial compliance assessments will be carried out by the Registrar for the provider. While Registrars may organise and structure their offices differently, assessments will be carried out in a consistent way—using the same assessment methodology guide.

The initial compliance assessment involves:

A. Reviewing information and evidence submitted in the return

B. Reviewing the results of the registration assessment where the provider has already submitted evidence that was recorded as demonstrating that the provider is compliant

C. Collating evidence from other sources including:

� notification by the provider of changes that may have an adverse impact on compliance � the Registrar’s record of any enforcement action � the Registrar’s record of any additional, targeted monitoring triggered by a change of

circumstances, risks or performance � the Registrar’s record of complaints and notifications under the National Law � the relevant state housing authority or authorities (this might include information about

the provider’s funding terms or leases, or compliance with a housing policy or contract) � other government agencies (this might include information about the provider’s funding

terms or compliance with a policy or contract, or housing-related service delivery) � other regulatory authorities (this might include information about regulatory engagement

with the provider) � the public record (this might include information about the provider’s body corporate

status, court or tribunal decisions, or media). D. Identifying where the evidence (or the lack of evidence) indicates that the provider is not

achieving the outcomes and requirements in the National Law

E. Following up on the lines of enquiry (requesting supplementary evidence) which have been identified, with the provider. This may include:

� requests for additional information to provide more comprehensive or rigorous evidence of the achievement of the outcome

� requests to attend a meeting to discuss the interpretation of the evidence about the achievement of the outcome

� requests for an on-site visit to validate the evidence about the achievement of the outcome.

F. Seeking advice from the relevant state and territory housing authority or other government

agencies where appropriate

G. Applying the principles of good decision-making and preparing a draft compliance determination report for the provider. The draft compliance determination report will include:


� a brief statement confirming compliance or non-compliance with the National Law � any findings outlining areas where the provider could take action prior to the next

Standard Compliance Return to improve the comprehensiveness and rigour of evidence submitted to better demonstrate the achievement of the outcomes findings outlining areas where the provider needs to take action to address a minor non-compliance – termed partial compliance (and requirements for reporting back on the closure of the non-compliance).

Separate to the compliance assessment process, the Registrar may take Enforcement Action to bring the provider back to compliance where the non-compliance is serious or the provider has failed to remedy the non-compliance.

2.3 Financial Performance Report (FPR) and Community Housing Asset Performance Report (CHAPR)

During registration, providers are asked to complete both these forms and submit them with their return. The FPR template is provided at the beginning of the compliance process while the CHAPR is now part of the online return and is identical to that submitted for registration. The CHAPR is on page 10 of the return. Any changes on the Provider’s portfolio from the registration date should be reflected on the CHAPR. There have been few minor changes to the FPR template in response to Provider comments. The main change is not visible on the template but significant to allow us to upload the financial information to the CHRIS database. This change was about coding all cells of the ‘Segmented Business Analysis’, Consolidated Business Analysis’, and ‘Ratios’ worksheets. Other minor changes on the FPR template include;

• Moving bad debts from Income to Expenses • Consolidating items • Updating scope of each segment • Updating some item names and definitions • Adding one validation formula • Changing message in validation formulas from ‘check’ to ‘error’ and colors (except sign

off sheet) • Changing colors to light grey financial viability measures that fall out of the threshold • Extending the variance formula to balance sheet and Cash Flow Statement

2.4 Tools and Guides in Completing the Compliance Return

There are a number of documents available on the National Regulatory System for Community Housing website at www.nrsch.gov.au that will assist you in making your compliance return. They are:

A. The National Regulatory System for Community Housing Charter This provides the overarching vision, objectives, regulatory principles and philosophy of the National Regulatory System for Community Housing.

B. The National Law and National Regulatory Code

These provide the legal basis for the operation of the National Regulatory System for Community Housing and establish the regulatory framework under which community housing providers are to be registered. As individual jurisdictions can choose to mirror or apply the National Law in a different way, providers seeking further details about the law should refer to the appropriate jurisdiction’s governing act.


C. Evidence Guideline

This describes the performance indicators and evidence sources for assessing providers against the NRC, performance outcomes, and evidence requirements for different tiers of registration. The Evidence Guidelines are directly aligned with the requirements set out in the NRC and detail the range of evidence that may be supplied to demonstrate compliance with the National Law and the performance requirements of the NRC.

D. The Tiers Guidelines

Provides guidance on how Registrars determine the different levels of regulatory engagement applied to community housing providers based on the scale and scope of their community housing activities.

E. Enforcement Guidelines for Registrars

Provides guidance on the performance and legal requirements that providers must meet under the National Law and NRC and, if necessary, how Registrars will respond to non-compliance.

F. Registration Return Guide

This guide is targeted at registration application and contains relevant information about assessment in general and includes in detail the non-financial data requirements for both the registration and the compliance return.

G. Financial Viability Guide

Provides guidance on completing the Financial Performance Report and explains how the information is used by Registrars in their assessment.

3. COMPLIANCE PROCESS

3.1 Contacting the Provider

Around one week before their standard compliance assessment is due to start Providers (through their Nominated main contact) will be contacted by the Registrar’s officer (hereafter referred to as their analyst) to confirm that there have been no changes to their Nominated main contact. The nominated main contact person of the Provider, is authorised to receive all correspondence from the Registrar’s Office, facilitate the compliance process and will have access to the online regulatory system known as CHRIS (the Community Housing Regulatory Information System). If your nominated main contact remains unchanged from the last assessment, they will be able to log in and access the compliance return using their existing username and password. If the Provider’s contact cannot remember their password, it can be reset from the login page.


Regular log in: If password has been forgotten:

If your nominated main contact changes at any point in time during compliance, please advise your assigned analyst. Such a change must be confirmed by an officer of the Provider. Your analyst will facilitate the update of details on the account page in the portal and the provision of portal access. Once the new nominated main contact has been set up in the system, the new nominated main contact will receive an email confirming they have been granted access to CHRIS (see below).

Sample of system-generated email on Portal access


3.2 Release of Compliance Return

On the day the compliance process starts your Analyst will send you an email ‘Invitation to Begin the Compliance Process’. Attached on this email is the Financial Performance Report (FPR) template for the Tier in which the Provider is registered. Likewise, the online return is made available to the Provider to commence the compliance assessment.

3.2.1 Logging In

To login to CHRIS, go to www.nrsch.gov.au or click on the link in the ‘Portal access granted’ email. Then click on the ‘house’ icon - see below.

This will take you to the page illustrated below where, if necessary, you can reset your password. If you are a new user the login details will be in the email.

Do note that once you have changed your password the temporary password in the email will no longer work.

Upon log in, you will see the following page:


The home screen has three (3) tabs running across the top of the page, which provide quick access to your account, contacts and under ‘returns’ • your registration application • any previously completed compliance return • the current ‘open’ compliance return. For ease of use, the system features a pop up left side menu, which you are able to access by clicking on the small arrow icon on the left of the screen:

Clicking on the small arrow will show a menu with recent items, messages and alerts, and help links – see below. The recent items are helpful as they enable the user to visit links they have previously accessed via only one mouse click, instead of having to navigate through the system.


3.2.2 Accounts tab

The first tab on the home screen is . This tab shows the Provider’s entity name. If you don’t see the name of the provider’s account press, choose the “All accounts” and click on ‘Go!’ button.

The Provider’s Contact has ongoing access to CHRIS to enable them to keep up to date many details on their account page. These include entity details; main activities and main clients; and the provider’s address. Some details like jurisdiction detail, number of community housing assets registration detail, compliance detail and current enforcement action cannot be


changed by you and will be updated by the system based on information submitted by you such as the CHAPR. The latest performance metrics will show the most recent financial performance metrics and some non-financial performance metrics taken from your latest regulatory assessment. As part of the compliance process providers will be asked to confirm the details on the accounts page are correct.

A. Editing provider (account) details To view the account details, click on the “Entity name". Once clicked, it will take you to the window below. To edit account details click on the ‘edit’ button as shown below.

Once clicked, the section headings (such as account information and jurisdiction detail as seen below) will be highlighted in green to signify a user is in edit mode. Whilst in this screen, you will be able to fill out the required sections.


To save changes click the ‘save’ button on the edit page. It is recommended that users save whenever they are entering new data changes work may be lost if the tab or browser is closed.

Navigate through the system by using the ‘back to list’ link at the top left of the screen or by clicking on the account name, return number or contact name, rather than clicking the back button on the browser. Pressing back will return the user to the last completed action and can start an endless loop or result in work being lost.

Parts of the account can be edited individually. This can be done on the account page or a return by double clicking on the small pencil icon to the right of the editable fields on the account.

Double clicking on the pencil icon will enable a user to edit that field of the account without needing to enter edit mode as shown above. However – double clicking the pencil icon will only enable a user to edit that particular field. Click on the ‘Save’ button once editing is completed or before you moved to another page.


B. Contacts, affiliated entities and applications

On the account page there are four links: Contacts, Affiliated Entities, Returns and Partnerships. Clicking on these links, directs you to the specific field which is at the bottom of the page where an item can be selected. Moving the curser over these links pops up a box with further information and allows access to edit or view the same information.

You can click on these links directly to edit the particular field. These links are also viewable by scrolling down to the bottom of the page.

B.1 Contacts

The link provides information on contacts associated with the provider’s account. You will be indicated with a tick box against their name. Users are able to create a new contact by selecting the ‘new contact’ link or edit an existing one Provider can edit most of the fields except for the name. Contacts should include key persons in the organisation. You can add as many contacts as possible however only one person must be nominated as a contact person. All correspondence and enquires through the system (CHRIS) will be sent to the nominated contact person.

Contacts cannot be deleted from the list. You can edit some of its fields but not the

name. The Contact link is also available via the tab on top of the page on the Homescreen.

B.2 Affiliated Entities

The ‘Affiliated Entities’ link is where all affiliated entities are listed by the provider’s Contact.


You are able to create a new entry or edit details about an existing affiliated entity listing by selecting the ‘New Affiliated Entity’ button.

For more information on affiliated entity arrangements, you may refer to the Affiliated Entity Arrangements Guidance Note which is on the NRSCH website (http://www.nrsch.gov.au/publications/nrsch-operational-guidelines)

B.3 Partnerships link

Details on certain partnerships need to be submitted as part of the return and these are recorded on the account page. For example, if a provider outsources tenancy management, the provider will need to add a record for each outsourced tenancy partner by navigating to the ‘partnerships’ link in the main account page and clicking on the ‘New Partnership’ button.

On the partnerships section of the Return, it lists down all the partnerships that providers have an agreement to. This may be an outsourced service, formal support, development agreements or community engagement partnerships. Details on the types of outsourcing


arrangements which are required as part of the return are explained in more detail in the return itself. The screen shot below illustrates the options available.

Click on the “New Partnership” button to create a new line. When you click on the ‘New Partnership’ button, you will be directed to the following pages.

Once you have identified the record type name, click on “continue” button and this will get you to the page below;


Some Providers have a large number of support partners. You only need to record those support partners whose size and significance are such that you consider them to have a material influence on your performance outcomes.

B.4 Returns Link

The ‘Returns’ link is where all the provider’s returns (including their registration application) are listed, previous and current.

As can be seen above, hovering over the ‘Returns’ link will show the form reference, the return start and due date and the record type. The returns link is also accessible via the returns tab on the top menu. Clicking on the return number will open the return.


C. Deleting Contacts, Affiliated Entities and Partnerships

Providers cannot delete entries that have been created and saved. Where an affiliated entity or partnership is no longer in place then they cannot be deleted but the arrangement can be edited to show its end date Where an existing contact has left the provider you can edit the entry to show they are no longer associated with the organisation. If a contact, affiliated entity or partnership was created in error (e.g. a duplicate entry was made) you should contact your assigned analyst who will initiate for the entry to be deleted.

3.3 Completing the Compliance Return

Click on the tab then select the return to be edited or completed. The relevant return will have the form status ‘return in progress’ – see below.

Once opened the screen will show the timetable for submitting the return.

Unlike registration the return is submitted in one part.

To start the compliance return, click on the ‘Start Return’ button at the top of the return page. See below.


This will take the user to the first page which provides instructions about completing the Return including where to seek assistance; about saving the document; and the metrics. There will be 11 pages to complete the standard return.

3.3.1 Introduction Page

This page provides a brief summary on how to fill out and complete the Return. It is important that you read the Introduction page before moving to the next page. Once done reading the Introduction page, you may click on the ‘Next’ button or choose from the drop down menu on the top of the page. You may do any of the Performance outcome at any time.

3.3.2 Core Documents Page

As with the edit screen for the account details, the page headings in this screen will be highlighted in green. To move forward click in the return on the ‘next’ button. Page Two provides you a checklist of the core documents that should be attached.


As noted earlier the provider’s account page should be kept up to date between assessments but the Return provides a reminder to check and edit the details at this point. Check the boxes once the account details are confirmed as correct.

Adding / Editing Affiliated Entities and Contacts on the account page You may also enter new or edit existing information. You access these from the account page as these are not specific to a particular return. To navigate easily to the account page, click on the ‘View Account (displays in a new tab) link at the top page whilst editing the return.


There is no requirement to re-submit the same evidence required during registration if there are no changes to it.

The Core Documents page lists the core documents the provider must attach to the standard compliance return. These are described and specified by Tier where this is relevant.

More information about the core documents is contained in the introduction to this guidance. You may also find the definitions and descriptions e.g. of Business Plan contained in the Registration Return Guide useful.

Core Documents

The FPR referred to in the core documents was attached to the invitation to commence the compliance assessment email.


You can attach the evidence at this point or as you are completing the relevant performance outcome page of the return. However before submitting the return check • the boxes to indicate all the required documents have been attached and; • the core documents completed box at the foot of page 2.

On the other hand, CHAPR is now built in and included as one of the pages of the return.

Attaching Evidence Evidence needs to be uploaded to the return as part of the compliance process. Once you click on Start Return they will see the ‘Add Attachment’ link at the bottom of the page. To attach the necessary evidence required for the return, click on the ‘Add Attachment’ button at the bottom of the return. This will only be visible after the Introduction page and the return is editable.

Clicking on the ‘Add Attachment’ button will launch the evidence attachment page. See the evidence attachment section above for more details.

The system allows a maximum of three (3) evidences or supporting documents to be attached at a time.


Evidence successfully attached will be visible at the bottom of the return.

You should indicate which performance outcome and performance requirements the core documents meet. The evidence guidelines give more information about this.

The relevant Performance Outcome and Performance Requirement should be selected for each evidence attachment. Additional related performance requirements should also be selected if the evidence attachment is being submitted as evidence of compliance with multiple performance outcomes. Any number can be selected. You may put in a description of the evidence attachment on the ‘Comment’ field section. A clear description will assist the analyst when assessing the return, but will also assist you in ensuring all necessary evidence has been attached prior to the submission of the return. Once you have selected the Performance Outcome and Performance Requirement that the evidence attachment relates to, clicking the ‘browse’ button will allow the user to select the file they wish to attach from their computer. Clicking on the ‘attach’ button will then attach the document to the system. When completing the standard compliance return, you will need to attach what are described as ‘core’ documents as supporting evidence.

A provider can view the evidence they submitted as part of a previous assessment by opening the relevant return. There is no need to resubmit evidence that remains identical but if the provider does do this they should ensure their return clearly specifies where and what this evidence is on their new return.

The Evidence Guidelines and the Financial Viability Guidance Note are available from the NRS website www.nrsch.gov.au and provide examples of evidence to demonstrate compliance with each Performance Outcome.

3.3.3 Performance Outcome Pages

Each performance outcome has its own page (pages 3-9), which includes data fields that a user will need to complete. The performance metrics will be automatically calculated by the system based on the figures reported by the user. The metrics below of the page will become visible after you clicked the ‘Save’ button. The data is identical to that requested on the registration return.


.

To complete the registration return, a user should refer to the introduction to this document for basic information. The Evidence Guidelines contain useful information about data definitions which remain identical for compliance. The Financial Viability Guidance Note will assist providers complete Performance Outcome 7 and the FPR template. If a user needs assistance when filling out the return, there are question marks in yellow circles throughout the return which provide further information and definitions when a user hovers their cursor over them.


There are fields on the return that require you to ‘mark’ the box if the answer is ‘No’. For example, in Performance Outcome 2, section 2.4a, you need to mark or tick the box, if the answer to this question is ‘No’. Succeeding sections (2.4.1 up to 2.4.6) are no longer to be filled out and therefore may be left blank. If Section 2.4a remains blank, it means that you have or had been engaged in property development in which case you are required to fill out the sections 2.4.1 to 2.4.6. If a section does not apply to the provider, enter a zero value. Note that number fields cannot be left blank. If there have been no projects for section 2.4 in the example above, a zero would need to be entered into each field. Evidence you have successfully attached to the return will be visible at the bottom of each page. Additional performance requirements can be added to an existing piece of evidence by clicking on the number of the piece of evidence you wish to edit. The ‘Previous’ and ‘Next’ buttons will automatically save data on that page and will take you to the next or previous page. If at any point you wish to stop completing the form or return to the overview page, pressing ‘Save’ then ‘Cancel’ will return you to the overview page.

Previous Outcomes If the Registrar made recommendations to the Provider in their last regulatory assessment these will be visible on the relevant performance outcome page(s). In addition to providing relevant documentary evidence you have taken to address these recommendations, a comments box is available to explain in detail. If action has not been taken or only partially completed, you can also use this comments box to explain. If you consider that the recommendation is no longer relevant during compliance then an explanation of the circumstances is necessary. Such explanation needs to be supported by an appropriate documentation.

Example

Metrics included in the compliance return

Once data has been entered and the ‘Save’ button is pressed the system will calculate metrics at the bottom of certain performance outcomes. The data from the provider’s last assessment will be displayed and you are encouraged to compare and explain any significant differences. The help icons next to each metric indicate how these metrics are calculated, and traffic lights will appear if data is outside the thresholds. See the screen shots below.


A red or amber traffic light does not mean the provider has ‘failed’ a performance requirement or outcome – instead, it indicates that the data does not meet the threshold and the provider has the option to provide an explanation in the comments field for each outcome’s metrics.

There is opportunity for comment on any information or evidence provided in the performance outcome comments box listed at the foot of every performance outcome page. Providers are encouraged to make comments when: • The performance metric is showing as red or amber • There is a significant change in performance from the previous assessment – better or worse.


3.3.4 CHAPR Page

Information regarding the Provider’s portfolio is indicated on the Community Housing Asset Performance Report (CHAPR). This page is similar to the CHAPR template you have used during the registration assessment. Any update on your portfolio or development plans must be reported on this page. It is important that the data reported here are verifiable. Once this page has been completed, click on the ‘CHAPR Completed’ button.

3.3.5 Consent, Authorisation and Declaration

This is the final page to complete the return. On this page, you will be asked to answer a Yes or No on the Consent, Authorisation and Declaration fields.


Once this page has been completed, you may tick the ‘Ready to Submit form’ box. This means that the return is now complete and can be submitted to the Registrar for assessment. It essential that all performance outcomes are marked as completed, otherwise an error will prompt you that the Return is not yet ready to be submitted.

After ticking the ‘Ready to Submit form’, you may click on the ‘Finish’ Button.

Once clicked, it will take you to the Return home screen, as shown below. Clicking on the ‘finish’ button will save the return and the overview of the entire return will be available.


The Return may still be edited at this point in time. It means you may still change any data you have reported on in the Return. Once all necessary data has been provided and all required evidence has been attached an overview can be printed for your records and your Board by clicking on the ‘Printable View’ link on the top right hand side of the return overview.

3.4 Submitting the compliance return

Once all data fields are complete and all required evidence is attached for each of the performance outcomes, the box at the bottom of each performance outcome must be marked as completed otherwise the return cannot be submitted.

Click on the ‘Submit for Approval’ button to submit the return to the Registrar.

If there are difficulties submitting, ensure that the performance outcome completed boxes are ticked at the bottom of each page and that the ‘Ready to Submit’ tick box has been completed. When in the overview this is at the top right hand side of the form.

If you attempt to submit the return without completing all the required fields, an error message will prompt on your screen. This may be as a result of not making an entry where an entry is required, or entering a letter in a numeric field. If an error message is message is shown follow the instructions in red to remedy the issue before trying to submit the form again. When you have clicked the ‘Submit for Approval’ button, a window will pop up reminding you that once the form is submitted, you will be unable to edit information on the return:


Once you have clicked ‘OK’, the Registrar’s Office will be automatically notified that the return has been submitted. At this point, the return becomes locked as represented by the lock icon to the left of the edit button – see below. The return is unable to be edited.

If the application needs to be modified after submission please contact your analyst. You will receive an email to confirm the compliance return has been successfully submitted.

3.5 Process post submission of compliance return

Your assigned analyst is notified that the return has been submitted. The compliance assessment will then commence. The analyst will carry out an initial check to ensure the return has all the supporting evidence – essentially the core documents - attached and that the return appears to have been completed in full. If information is found to be missing your analyst will send an email listing the additional information required. Also, the analyst will unlock the return to allow you to resubmit with the missing evidence through the portal. The additional evidence should be attached in the portal following the same process when completing the return.


To access the return you will need to click on the ‘Start return’ button then the ‘Add attachment’ button. See ‘Evidence attachment’ above for procedure. To submit the return once you have attached the missing evidence or corrected the return follow the instructions given earlier.

3.5.1 Change in scale, scope or Primary Registrar of Provider

During their initial review of your return your analyst will check that your current tier of registration remains applicable. If the initial review suggests a significant change in scale and / or scope you will receive an email which will explain what, if any, additional evidence applicable to the new Tier is required.

The change in Tier will only be confirmed when the compliance determination is made.


If the evidence submitted shows that the provider’s main community housing business is now conducted in another state or territory a decision may be made to change the Primary Registrar. You will receive an email advising you of the change. In this case the compliance assessment will generally be carried out by the new Primary Registrar who will contact you to make arrangements for this.

3.5.2 Supplementary Evidence

Once your analyst has confirmed that the return is complete and the core documents have been received, they will use the evidence to assess your compliance against each performance requirement. In some cases they will be able to reach a decision solely on the return and its supporting documentation. In others they will require more information (supplementary evidence) to reach a determination. They may need this information because for example: • They need to understand more about your performance against a particular outcome

• Your business has changed significantly and they wish to follow up in more detail

• Written / documentary evidence is insufficient to determine whether compliance outcomes

are being met.

Supplementary evidence will only be requested for relevant performance outcomes. It can take the form of additional documentation, a telephone conversation, a meeting or a site visit. This will be outlined in the email sent to you.

If you are asked for additional documentary evidence you will be asked to submit it using the ‘Supplementary Evidence’ button at the top of the return.

This will take you to the page below where you can add evidence specifying the performance outcomes and requirements it covers. The process for upload is identical to that you carried out when completing the registration return.


However it is important to remember to check the supplementary box – see below.

3.6 Release of Draft Compliance Determination Outcome

Once the assessment is complete you will receive an email notifying you that the draft compliance determination has been completed and the draft compliance determination report is available, you will need to log into the system to access the draft compliance report.

3.7 Providing feedback

You will then have two weeks from the date the email was sent to comment on the determination through the portal. To provide feedback on the draft compliance determination you will need to click on the link in the email notifying the provider that the compliance report is available or, log in to CHRIS, navigate to the returns tab, click on the returns reference number and click the ‘provider reports’ link at the top of the screen.


Clicking on the provider report number show the Provider Report screen.

Clicking on the edit button will allow you to submit comment on the determination. Once comment has been made, tick the feedback completed checkbox and click the ‘Save’ button.


If the provider wishes to submit additional evidence during the feedback stage, they should attach it to their Return as supplementary evidence, and not attach it to the provider report section. This ensures that all evidence documents submitted are held in the one location (the Return) for future reference if needed.

Once comment is made and any necessary supporting evidence uploaded, you should click the ‘Submit for Approval’ button to send comment and evidence to the Registrar’s Office. The analyst will consider the feedback and may contact you to clarify matters before issuing the final determination. If the provider does not comment within the allocated two weeks, the draft compliance determination will be adopted as final.

3.8 Release of Final Compliance Determination Report

The release of the Final Determination Report signifies that the compliance process is now completed. You will receive an email from your assigned analyst advising that the Final determination report is now available on the Provider’s report page in the portal.