Self Assessment

Governance Framework

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Governance self-assessment toolkit based on SHR's Regulatory Standards 2019

All RSLs must comply with the Scottish Housing Regulator's regulatory standards and guidance and, by doing so, demonstrate effective governance and sound financial management and deliver good outcomes for tenants, service users and stakeholders.

We developed our Meeting the Regulatory Standards toolkit to assist our members in carrying out governance self-assessment and to provide an easy to use facility to collate evidence in the course of preparing annual Assurance Statement. It was developed in collaboration with a Working Group consisting of both - board members and senior officers drawn from our membership.

The resource is split into workbooks designed to facilitate the self-assessment process both by individual board members and then collectively by a full Board with an option of benchmarking results against a peer group. The content of each self-assessment workbook is as follows:

  1. Scorecard
  2. Evidence
  3. Action Plan

Each evidence table contains SHR's guidance notes and each guidance note is supported by a list of possible measures for assessing the level of compliance. The suggested measures have been compiled on the basis of SHR's own publications such as regulatory advice notes, regulatory assessments, thematic studies, regulatory guidance and regulatory recommended practice.

Seven Steps

The planning tables are designed for you to define reasons for doing the assessment; what resources might be needed and the people who will be involved. It may be useful for your governing body to agree what these reasons are so that there is a common understanding about this issue. Is it about demonstrating compliance with the Regulatory Requirements and to produce an Assurance Statement? Or is it about achieving self-awareness and addressing areas for improvement? Or is it about both?

You must enter scores as follows:

  • where the criterium is fully met, 3
  • where the criterium is almost met ? depending on the opinion as to what degree, 2
  • where the criterium is partially met, 1
  • Zero, where the criterium is not met

The scorecards allow you to score your level of compliance as agreed by the governing body. When you enter your score in the last column a RAG colour rating is displayed giving you an instant visual of the perceived level of compliance. It is recommended that you review the initial scores after you have collected all available evidence by systematically completing the evidence tables.

It is recommended that the governing body should jointly arrive at a decision about the level of compliance with each and every regulatory standard based on information in the evidence tables.

Evidence tables provide you with an opportunity to test the level of compliance by considering the suggested lists of measures and by putting in documentary or practice-based evidence against each and every piece of guidance note.

To provide a robust audit trail which is ready for verification, it is recommended that members set up individual folders for each guidance note on their own office systems. Each of the folders should contain copies of the actual documents, ready for possible verification.

The completed evidence tables will form an audit trail for your Assurance Statement. While the SHR don't require you to send the evidence when submitting your Annual Assurance statement then can ask to see it when engaging with your organisation.

Once evidence tables are completed and analysed and key areas for improvement identified, you need to complete the action plan tables. The completed action plan can then be used as an improvement tool, with key actions for areas identified through the self-assessment as most challenging. Focusing on "when for?" element of this plan is crucial to ensure that resolving shortcomings are time bound.

Action Plan tables can also be used to define areas for improvement and to decide which areas if any are significant to a level, which may constitute non-compliance with the regulatory standards.

The governing body will need to decide if the identified areas of non-compliance are significant and material. It is a matter of judgement for governing bodies and indeed for SHR to decide whether non-compliance is significant. Such judgements will require to take account of a range of factors, including:

  • the potential impact of the issue
  • the scale of the issue, and
  • the context for the individual landlord
  • anything that seriously threatens the stability of an RSL's finances, operations, reputation or legality.

SHR will assess the significance of the area of non-compliance and how landlord is planning to address it. Your completed Action Plan table will be useful for this purpose.

If landlord's plans are in SHR's view effective, it would be up to the landlord to take forward improvement and keep SHR updated on progress. If the issue presents a significant risk to the interests of tenants, SHR will monitor it closely, or take action, to ensure it is resolved successfully.