Correspondence

2023 CEO letter re data collection (large providers) - accessible version including annex

Published 16 March 2023

Applies to England

Dear Chief Executive

2023/24 RSH data requirements

I wanted to write to you to let you know about the arrangements for data collection in the coming year. Timely and accurate data submission is a cornerstone of the co-regulatory settlement, and we rely on the information you supply us to ensure proportionate and risk-based regulation. I would therefore be grateful if this letter can be passed onto the appropriate person within your organisation.

From April 2023, we will be commencing our round of data collection from private registered providers (‘providers’) via the NROSH+ website

NROSH+ closure and update

In order to prepare for the 2023/24 survey period, the NROSH+ system will be offline from 18:00 on Friday 17 March until launch on Monday 3 April. During this time, you should not access the site and should make alternative provision to access documents and templates should you require these during this period.

We will notify all users by email when NROSH+ launches for the 2023 collections.

Subject to final testing and quality assurance processes we intend to update the NROSH+ system during this downtime. This revised system should deliver a number of improvements requested by providers, whilst retaining a similarity to the current system. We have endeavoured to ensure that the layout and processes remain aligned to the existing application, however, there are some key changes which users will need to familiarise themselves with assuming the updated NROSH+ system launches. These include:

• Changes to the way in which survey data are imported to and exported from the system;

• Contact details being updated during the submission process and not within the surveys themselves; and

• Validations being viewable onscreen as well as the traditional exports.

Please note that we strongly recommend providers download PDF and/or Excel versions of their previous data returns as these will not be included in the revised system. Guidance on how to download previous data returns is available on the current NROSH+ application.

New guidance materials will be available on the website when it launches, and we will notify users of training sessions in early April. As with most IT systems, there will be a continuous development plan over the coming years, allowing the introduction of smaller changes, or to resolve smaller items of frustration. We welcome feedback on the revised system, and hope you will be patient as we resolve any issues we encounter.

We will keep users updated as to the system launch through their current user account details.

Details on how to reactivate user accounts on the system once it relaunches will be sent to all current NROSH+ users. It is imperative they reactivate their user accounts to ensure that your organisation continues to receive notifications from the system.

Data returns

During 2023/24, all providers that own 1,000 or more units of social stock will be required to submit the following returns:

Data returns	Deadline
Statistical Data Return	31 May 2023
Financial Forecast Return (with business plan and other supporting documentation)	30 June 2023 We encourage submission within 6 weeks of business plan sign off by the provider’s board where this is earlier than 30 June 2023
Electronic Annual Accounts	3 weeks after each quarter end (Q4 2022-23 is due 25 April 2023)
Regulatory Documents
Audited Accounts Audit Management Letter Fraud reports	6 months after financial year end
Quarterly disposal notification Priority disposal notifications	3 weeks after each quarter end As required (see disposal notification guidance available on NROSH+ )

The deadlines for all returns are in line with those operating in a standard collection year. We rely on the supply of timely and accurate data from all registered providers. Failure to supply quality data in line with the timescales we outline may be reflected in our published judgements of your compliance with the regulatory standards.

If any of these present a practical problem for your organisation, please contact your key contact or the referrals and regulatory enquiries team enquiries@rsh.gov.uk as soon as possible.

SDR submissions are due 31 May and are required from all registered providers even if a provider owns no stock. We will publish a list of all late or missing returns for 2023 when the SDR data is published in Autumn 2023.

Changes to returns for 2023

It is essential that guidance notes are reviewed before the completion of the surveys as there are new, moved and revised questions within each survey. For more information regarding changes, please refer to the note enclosed with this letter.

Additionally, we remind you that it is your responsibility to correctly categorise and record stock accurately according to the latest applicable legislation and to ensure you understand and apply the rent (and any other) rules correctly.

SDR questions relating to stock condition have changed this year and now include questions relating to physical stock inspection coverage, DHS failures by criterion, exclusions from reporting and information about energy performance certificate ratings. We ask that you give particular focus to your reporting of decent homes non-compliance to ensure that the submitted figures across all questions are an accurate reflection of your stock’s performance against the requirements of the Decent Homes Standard. Please refer to the note enclosed with this letter for more information.

We would also like to take this opportunity to remind providers that any properties covered by the Decent Homes Standard which contain one or more hazards assessed as serious (Category 1) under Housing Health and Safety Rating System which have not been rectified are non-compliant with the Decent Homes Standard by default. Therefore, homes reported as having Category 1 damp and mould hazards in our survey of December 2022, and which have not seen these hazards rectified, should be reported as non-compliant.

During 2023/24 we will be undertaking further regulatory engagement to seek assurance on the quality of providers’ understanding of their stock.

Submitting data

In 2023 the annual surveys will launch in a staggered pattern, with SDR and FFR surveys launching in April 2023 and the FVA launching in June 2023. The Quarterly Survey (Q4) will launch alongside the SDR and FFR in April. Guidance materials and templates will be released on NROSH+ as they become available.

Please submit returns as early as possible within each of the survey periods. We encourage the submission of the FFR within 6 weeks of business plan sign off by boards where this is earlier than 30 June 2023. This will allow sufficient time to raise any questions you have regarding your submissions.

Query resolution

We aim to respond to all queries within five working days. Please note that queries made to us within five working days of a survey deadline may not receive a response until after the deadline has passed. This may result in submissions which do not meet the survey deadline. Extensions to the deadline will not be granted due to late queries.

During the checking of submissions, we may contact some providers to discuss their data returns before signing them off for further analysis. Subsequently, we may contact a minority of providers where there are any regulatory issues arising from this analysis of the validated data.

Organisational and contact details

The NROSH+ website requires your organisation to enter and maintain a suite of organisational and contact details. It is the responsibility of each individual provider to ensure that this contact information is kept updated and accurate throughout the year. This is important because we use this information to contact your organisation on regulatory matters. Please note that contact information cannot be updated between 1 April and mid-July except via your SDR return (please contact the enquiries team if you need to amend submitted data).

It is very important that the organisational and contact details in NROSH+ are kept accurate and up to date by your officers.

If they are not:

(a) your organisation may not receive important information on statutory consultations and/ or regulatory requirements; and/ or

(b) correspondence (which may include information about the provider’s business or regulatory compliance) may be sent to the wrong individuals (who in some cases may no longer work for the provider).

We take our duties in relation to data protection seriously, but to do this we rely on providers updating their contact information in a timely fashion. Please see our privacy policy on the NROSH+ site for more details.

If you have any queries, please refer to the guidance and FAQs on the NROSH+ website. If further assistance is required you can contact the referrals and regulatory enquiries team NROSHenquiries@rsh.gov.uk who will assist you with your query.

Yours faithfully

Will Perry
Director of Strategy

Annex: Changes to regulatory data returns for 2023

Introduction

This note provides an overview of the changes to data returns for 2023. These changes have been made to ensure that they continue to most effectively support our operational approach and reflect provider structures and risks.

Key messages

The following points are applicable to all returns:

• Timely and accurate data submission is a cornerstone of the co-regulatory settlement and we rely on the information you supply us to ensure proportionate and risk-based regulation. Failure to provide accurate and timely data may be reflected in our published judgement of a provider’s compliance with the regulatory standards. Following the 2023 Statistical Data Return collection we will publish a list of all late or missing returns as we have done in earlier years.
• It is essential that providers read the guidance available on the NROSH+ website prior to starting any of the returns.
• Providers have a responsibility to correctly categorise and record their stock according to the latest applicable legislation. We ask that particular attention is paid to the classification of units to ensure they align with the 2020 rent standard.
• We also ask that particular focus is given to your reporting of decent homes non-compliance to ensure that the submitted figures are an accurate reflection of stock performance against the requirements of the Decent Homes Standard. You should also carefully review the changes made to questions in this area in the SDR return below.
• During the checking of submissions, we may contact some providers to discuss their data returns before signing them off for further analysis. Subsequently, we may contact a minority of providers where there are any regulatory issues arising from this analysis of the validated data.
• Please access NROSH+ via https://nroshplus.regulatorofsocialhousing.org.uk/. For help and advice please refer to the guidance available and contact the Referrals and Regulatory Enquiries Team NROSHenquiries@rsh.gov.uk or 0300 1245 225.

Financial data

The regulator will keep the same suite of standard financial data returns that we collected in 2022 - Financial Forecast Return; Electronic Annual Accounts and Quarterly Survey.

FFR

A small number of changes have been made to the FFR in 2023. The adjustments are primarily to ensure that the data requested is relevant to the current operating environment.

FVA

Minimal changes have been made to the FVA in 2023. Guidance notes will be updated, and providers should refer to these to ensure continued quality in data submission. Providers are reminded that the new Accounting Direction - published in January 2022 - is applicable to accounting periods commencing 1 January 2022 and later.

QS

The Quarterly Survey will continue to collect data on key financial indicators and emergent sector risks. Guidance notes will be updated on a quarterly basis and providers should always refer to these to see if there are any changes to our requirements.

Statistical data

The following changes have been made to update terminology and to ensure the SDR continues to provide us with data required to support our operational activity.

Part 1: Entity level information

• This part will no longer include contact information, this will be collected as part of the submission process. You must ensure that contact details for your organisation are entered correctly as these details will be used by us to contact your organisation.

Part 2: Low cost rental and rents

• Existing building height questions have been updated to reflect the high rise definitions in the Building Safety Act (2022).
• A new question on low cost rental units failing each Decent Homes Standard criterion and those failing one or more criterion has been added.
• A new question on the number of low cost rental units which do not meet the DHS but which are excluded from the failures reported due to reasons set out in the DHS has been added.
• A new question added on the % of low cost rental units which have been physically inspected for DHS compliance in the last 5 years has been added.
• A new question on the number of low cost rental units with an EPC rating at each rating level (A to G); those which have no EPC rating (but will need one on sale or letting) and those which do not require an EPC rating has been added.

Part 5: Stock usage

• We have split the RP level data on the duration of unavailability of units (e.g. split ‘unavailable for letting’ into ‘temporarily unavailable for letting’ and ‘permanently unavailable for letting’).
• We have split of LA level data on the duration of unavailability of units (as above) for the general needs vacancies currently collected at LA level.

Part 6: Stock balance sheet

• We have added additional LA level data collection on the number of low cost rental units being sold via RtB, vRtB, RtA and other sales.

Part 8: Small provider stock and rents data

• Existing building height questions have been updated to reflect the high rise definitions in the Building Safety Act (2022).

For more details on the SDR questions and changes please refer to the SDR Guidance materials available on the NROSH+ website including the SDR changes for 2023 document.

Disposal notifications

Providers are required to notify us about disposals made in line with our Direction on disposal notification. The Direction and supporting guidance, available on our website, sets out the detail of what must be notified and the type of information that must be provided. Providers should read the Direction and associated guidance on NROSH+ prior to completion of the Disposal Notification Form.

Organisational data

The NROSH+ website requires your organisation to enter and maintain a suite of organisational and contact details. It is the responsibility of each individual provider to ensure that this contact information is kept updated and accurate throughout the year. This is important because we use this information to contact your organisation on regulatory matters. We take our duties in relation to data protection seriously, but to do this we rely on providers updating their contact information in a timely fashion. Guidance on how to access and amend this data is available on the NROSH+ website.