When we first heard about the introduction of the upcoming Competence and Conduct Standard in social housing, we knew as an organisation that Clever Nelly and our continual assessment model were perfectly aligned to help support providers to meet the RSH’s expectations regarding the ‘Broad Standard’.
Continually supporting employees as individuals to improve their knowledge, optimise their competence and confidence in-role – and evidence this as a data point – is what we’ve done for a living over the past 10 years for some of the world’s leading brands, so it obviously felt like a perfect fit from the get-go.
At the start of our proposition journey scoping for housing, I naively looked at the new standard in isolation; as a singular piece of new regulation that we could help providers satisfy from a regulatory-based perspective. And whilst this is absolutely the case, it doesn’t tell the whole story about what we’ve learned about the sector over the last few months and how they are using our technology.
We’ve been on an extensive fact-finding mission – speaking formally with our brilliant customers in the sector – who have graciously given their time and feedback, and explained their use applications of Clever Nelly to help us understand how it aligns with the regulatory framework, expectations and operational challenges they face day-to-day.
Our fact-finding mission looked to get answers to a simple question: We wanted to know – in their words – why Clever Nelly for housing?
Why did they initially choose Clever Nelly? What challenges did they want our technology to solve? How would they use it for the Competence and Conduct Standard moving forward? And what did they see as the biggest challenges facing their business to comply with the upcoming standard?
If I’m completely honest, I was expecting our customers to validate my naive view of the new standard; that it’s another layer of regulatory complexity they needed to solve and tick off of their ever-growing list.
However, this was far from the case.
I was blown away by the level of maturity in the way our housing customers articulate and think about competence in their organisations. Not just in terms of demonstration and evidence, but in how Clever Nelly is being used to achieve and maintain employee competence, and how the subsequent data is informing and improving their day-to-day operations and interactions with residents.
Equally, I was also intrigued by how the standard is being viewed and approached by customers.
The conversations I’ve had have broadened my thinking about our own technology in some ways, because the use applications of Clever Nelly in housing often permeate the entire organisation – compliance, risk, operations and back office. Fundamentally, if there are people involved who need to learn and retain critical workplace training, Clever Nelly can help: that’s the simple underlying message from our customers.
From the outset of my first conversation, one of our North East customers said something that set the tone about how we should think internally about the Competence and Conduct Standard:
“It might have a formal title, but we recognise this for what it is: it’s about people and culture.”
We were told that we shouldn’t view the Competence and Conduct Standard as a separate entity, nor should we ‘pigeonhole’ the extent to which our technology can help providers, because the competence and conduct of the people delivering the services to residents underpins almost every regulatory standard objective and TSM.
Fundamentally, our customers recognise a simple and sometimes uncomfortable truth: that you can’t deliver great services to customers unless your people are continually supported, engaged and competent in-role to do so.
Subsequently, our housing customers think more holistically and strategically about how workforce competence improvement drives both internal and external performance improvement outcomes – i.e., those that help the business run more effectively, and those that make residents safer and happier.
We know how effective our technology is. It’s widely deployed in a range of regulated and non-regulated sectors to support both compliance and performance improvement projects, but the use applications we’ve heard of in housing are numerous and wide-ranging.
For example, we’ve heard firsthand from our customers how they articulate the benefits and outcomes:
- Our data and management information are helping to give better assurance to management and regulators that staff are competent in their roles.
- It’s supporting them to verify and demonstrate that frontline trades staff understand key regulatory topics, such as damp and mould under Awaab’s Law.
- It’s being used to justify strategic training decisions; reducing the need for time-consuming refresher training when it’s not required, giving much-needed time back to frontline services.
- It’s informing managers which employees need practical, on-the-job assessments and appraisals.
- It’s supporting assurance evaluations of property services and maintenance teams in relation to their individual understanding of critical health and safety procedures, such as working at height, lifting and carrying, and working with asbestos.
- It’s providing the business with assurance regarding how internal policies and procedures are being understood.
- It’s improving consistency and support during the induction process, giving managers the data required to create targeted training interventions where needed.
- It’s improving right-first-time processes, reducing service failures that often lead to complaints.
What these benefits and outcomes illustrate is that competence isn’t being seen as a ‘one-off’ achievement by our customers. They recognise that it’s the foundation of how resident satisfaction can be improved, how health and safety risks can be mitigated for their colleagues and residents, and how knowledge, consistency and confidence can be built and fostered within frontline teams.
It also illustrates why training outcomes and good data – that can be shared across the organisation – are vitally important.
The outcome of any training intervention shouldn’t be about the training taking place; it should be about whether the employee has understood, learnt and retained what you’ve trained them on. That’s often the fundamental difference between tick-box and non-tick-box approaches. Tick-box says something has been completed; non-tick-box thinks about competence as a qualifiable KPI that can inform risk narratives and operational improvements.
When I asked customers about the two workstreams of the Competence and Conduct Standard, the qualification aspect – although welcomed in the main – seemed to be viewed as the tick-box piece. And it was interesting that all customers I spoke with shared a similar sentiment about qualifications, notably that:
“It’s very easy to say you’ve met the requirements because you’ve got a qualification – but a qualification doesn’t necessarily mean competence, or that people understand what they need to do. I’ve seen some highly qualified people in my time, and they are terrible at what they do.”
I was keen to learn more about the emphasis our customers are placing on the ‘Broad Standard’ and how Clever Nelly will be used, because this element is arguably more challenging to implement and evidence on an ongoing basis without the right systems, processes, controls and performance monitoring in place.
It is also more ambiguous, which may explain why providers are searching for ways to gain better assurance that aligns with delivering against this element.
Providers have a relatively clear mandate with the qualification part, whereas the ‘Broad Standard’ asks them to ‘ensure their staff, and staff of relevant service providers, have the skills, knowledge, experience and behaviours needed to deliver a good quality service to tenants’.
The requirements are also policy-based; providers must ‘adopt or develop an appropriate code of conduct’ and have ‘written policies setting out their approach to learning and development, appraising staff, and managing poor performance’.
As a side note, one of our customers mentioned that they think the ‘approach to performance appraisal’ requirement is the one that many providers will overlook the importance of. In their view, this is the part that brings the ‘Broad Standard’ to life – what the intention of the Competence and Conduct Standard is actually about – and this is likely to be a key piece of evidence that the regulator will be keen on seeing.
What’s interesting in relation to the ‘Broad Standard’ is that our customers see huge value in Clever Nelly’s ability to bring regulatory policy to life within the organisation, helping to bridge the gap between policy and process:
“The policy bit is the easy part. It’s nice and easy for the regulator to check if we have a policy that says ‘this’ and ‘that’. But to make people care about what they do on a day-to-day basis is really hard. So, what I’m interested in is understanding if our colleagues understand our policies, know how to do their roles, how we can support them to be better, and being able to understand and identify where there are gaps in what we’re doing.”
I was also keen to understand how competence has been assessed historically and what the change now means:
“If we look at how the sector has taken an assurance-based approach to ‘competence assessment’ historically, training completion and certification of mandatory learning have been seen as equalling competence. But we now need to demonstrate to regulators that our people are competent to do their jobs.”
Having read through The Professionalisation Review (2022), a catalyst for the introduction of the new standard, I was also interested to validate their experiences of the training and cultural change challenges it highlighted.
Time, resources and the complexity of job roles were three of the main recurring themes.
One of our customers said:
“Every time training or interventions need to be conducted, we are taking people away from our frontline services – which is where the needs of the business are. So, we’re often asked to make learning as brief as possible, which is at odds with what the regulator is expecting, because they are asking for more. So that’s a real challenge we’re solving. The biggest challenges around the standard involve the scale and complexity of highly varied, niche job roles. You can’t begin to imagine how many there are, and we want to prove competence in a meaningful way and avoid pulling together a ‘broad opinion’ of competence.”
In conclusion, I’ve learnt about a sector that thrives on collaboration and sharing best practice. So much so that it is our intention to set up a Clever Nelly housing network for our customers to share their use application materials and narratives with their peers.
I learnt about a sector undergoing continual and significant regulatory change, and heard firsthand about the financial pressures of providers having to do more with less.
I’ve learnt that it’s a sector that’s continually maturing in relation to its systems, processes and assurance-based evidence approach.
Yet, above all – certainly from the insightful conversations I’ve had with our customers – I’ve learnt it’s a sector that is continually striving to improve the competence of their people to deliver the best possible outcomes and experiences it can for their residents.
I understand that providers benefit from sharing best practice, and we’d appreciate the opportunity to show you how our multi-award-winning continual assessment approach aligns with this. If you’d like to find out more, please do get in touch or visit our housing page to learn more about how we can help.
Huge thanks to our customers for their time and feedback.
Paul Davies
Communication and Campaign Manager