Are you ready for the Regulator?

Jake Le Page

January 2017

48,000 homes

98,000 residents

50 years old in 2017 26,000 units

requiring gas

service

Stock Investment

New Forest, Dover,

Lincoln

Special Projects

The tap on the shoulder...

If the HCA called you today, would you be able to answer

the following questions:

• What is your current gas safety check compliance rate?

• If you have non-compliant systems, how many are one month (or more)

overdue?

• Are all of your overdue systems either in your referral or legal process?

• What evidence can you provide to show you’ve made all reasonable effort

to gain access?

• Can you prove that your data you hold on your gas safety compliance is

accurate and complete?

• Can you prove that your process for ensuring systems remain gas

compliant is fit-for-purpose?

The story of The Hyde Group...

• New Gas contracts procured went live on 28 October 2013.

• Based on a British Gas 3 star, all inclusive style contract

• 10 year partnering contracts

• Three contractors

• Hyde responsible for managing the programme, taking the calls,

arranging the appointments, scheduling the works...

The journey so far for Hyde...

The challenge, by January 2014;

• Contract mobilisation had proved difficult

• We had a higher than acceptable volume of overdue gas

safety checks

• Different systems were providing different compliance

figures

• Our gas consultant had miscalculated the number of

overdue gas checks

• Opportunities to carry out the checks were being missed

• Contractors finding it difficult to cope with peaks in the

service programme

• We were not confident in the data or process

Our gas recovery project

What we found...

• Data conflicts between our system and the contactor’s system

• Despite having a 10 month programme, systems were already

non-compliant by the time the contractor referred them back to

us

• Administrators spending much of their time conducting forensic

searches to recover missing LGSRs

• Resources stretched to the limit trying to arrange access for

overdue systems

• We were missing opportunities to gain access

• The cost of administering the scheme was significant

The cost of gas compliance for Hyde...

• Gas Manager and three Contract Managers

• Eight Compliance Admin Staff

• Customer services and Responsive Admin Staff

• Resident Services Staff

• Performance and Operations staff

• In-house Legal services staff

• Tracking systems (KSI) and administration (IT support)

• 10 month service programme (6 checks every 5 years)

• Warning Letter and phone Calls (min of three), SMS messages (min of one)

• Court Action, Solicitors Letters

• Legal costs

Total cost estimate: £1M per annum (average of £40

per property on top of the cost of the safety check!)

Balancing compliance and efficiency

Gas Safety Regs

VFM

The gas recovery plan

• Data integrity reconciliation

• Redesign the work-flow from end to end

• Smooth out and simplify the process

• Put those best able to deal with the risk in charge

• Set out the referral process

• Fit interval timers

• Rewrite no access letters (nudge; what about a little shaming?)

The gas compliance process redesign

The five principles

Principle 1: The client owns the data

• We own the truth (it is our version of the truth that matters)!

• We cannot outsource our responsibilities!

• Our compliance monitoring system is our one version of the truth

› We report from our system only

› If it’s not in our system it doesn’t count

› no other (contractor or consultant) system matters

The gas compliance process redesign – the

five principles

The gas compliance process redesign – the

five principles

Principle 2: The contractor owns the service

programme

• Contractors are best placed to schedule their own resources

• Contractors are best placed to manage the rolling service programme

› We give them all the property addresses

› It’s the contractor’s obligation to keep us compliant or refer back to us

well before the anniversary date

The gas compliance process redesign – the

five principles

Principle 3: No LGSR, no payment!

• Landlord Gas Safety Records are the ‘currency’ of the contract

› Incentivise the right behaviour

› Absolute clarity of purpose

• Suggestion: What about charging the contractor for non-

compliance? e.g. £40 for every referral back to the client, or £25

per week for every non-compliant system.

The gas compliance process redesign – the

five principles

Principle 4: Time passing triggers action!

• The referral process is triggered by a date (e.g. 30 days left to

due date) rather than a no-access event

› No waiting for the contractor to refer it back to the client after

two no-access events

› Automatically referred back to client at 30 days prior to

anniversary date

› The client manages the referral process

The gas compliance process redesign – the

five principles

Principle 5: The process must be fail-safe; either the system’s compliant or in the legal process!

• The process is front-ended rather than reacting to failure

› No ambiguity – either compliant or in the legal process by the

due date – No exceptions!

› Clear responsibilities

› Streamlined process

› Staff in control in new process checking and counting the

LGSRs in

› No longer a need for forensic searching for lost LGSRs

Lessons learnt

We recognise;

• Ultimately the landlord is responsible – you cannot outsource

this responsibility

• Poor data quality quickly erodes trust in the system – Good

gatekeeping is essential (not necessarily automated)

• There is a tension between being compliance and achieving

VFM

• Performance is improved by simplifying and smoothing out the

workflow - not by adding in more controls

• An adult-adult client-contractor relationship is more productive

(rather than a parent-child relationship)

• Play to the strengths of each partner and ensure each team

know what they are responsible for.

Thank you

Jake Le Page

Senior Project Manager (Stock Investment)

jake.lepage@hyde-housing.co.uk