UK: RP Issues - A Briefing For Registered Providers Of Social Housing, December 2009

Last Updated: 10 November 2009
Article by Jonathan Pryor

Editor's comment

Getting to grips with new requirements

The key theme through this newsletter is one of planning ahead. We cover a range of different issues of critical importance to the future of registered providers of social housing (RPs), all of which will require investment of time by management to ensure that potential adverse consequences are minimised. We start with a commentary on component accounting, emphasising the importance of planning for this fundamental change in accounting. Our view is that housing associations will need at least 12 months to prepare for the changes and therefore an early start is important. Even if your association has already applied component accounting, or has started preparation, it will be important to check that your treatment is consistent with the latest proposals.

We also discuss the Social Housing Pension Scheme and the dramatic increase in the costs that associations and potentially employees will have to bear. We comment on the options available to RPs, emphasising the need for professional advice on this crucial decision. We have a wide ranging article on VAT covering some recent developments, but in particular commenting on the implications of the VAT rate change on 1 January and what RPs should be considering as a result. There is an opportunity to reduce the VAT burden to some extent if care is taken. We also highlight the forthcoming changes to service charge reporting, which for some associations will significantly increase their obligations in respect of reporting to service charge payers. If you think this only applies to leaseholders, then think again. All variable service charge payers (with a very limited number of exceptions) will be affected.

We then have an important article on reward strategy, which sets out a carefully thought through model to help deal with the reward outcomes of major organisational change, an increasingly common feature of today's environment. Finally, we conclude with a thoroughly scary article on the key issues arising from the Climate Change Act 2008. We are all going to have to get to grips with the new requirements in one form or another, and this article should help to start the process.

What should you be doing to prepare for the introduction of compulsory component accounting in the housing association sector?

As many RPs will be aware, the statement of recommended practice (SORP) working party consulted earlier in the year on component accounting. This accounting concept is not new; it is included in the key financial reporting standard (FRS) on fixed assets, FRS 15, and is also reflected in the SORP with wording unchanged from around 2000. The idea behind it is that if you have an asset, part of which wears out at a different rate from the others, then unless the effect is immaterial you ought to account for that part separately from the rest of the asset.

COMPONENT ACCOUNTING

With housing associations, the housing property typically comprises a number of parts, e.g. the roof, kitchen, bathroom and windows, which are replaced at varying intervals, while the core building remains for a very long time. The amounts of money involved in replacing these parts, or components, are sizeable. It is therefore not surprising that the consultation broadly confirmed the conclusion that component accounting ought to be applied within the housing association sector.

Perhaps what is surprising is that the consultation also concluded that there weren't any very difficult challenges to overcome in making the change. In responding in this way, the sector made it almost inevitable that component accounting would be brought in for all RPs, with only a minority in extremely rare circumstances being able to make a case against it. The likely date for implementation is the March 2011 year end, but with comparatives restated.

So what does it mean?

If your association didn't apply component accounting early, you may think that you have a few months before you need to start worrying about it. Unfortunately, this is not likely to be the case. Associations that applied component accounting early found there were many practical difficulties to overcome, and a period of at least 12 months was needed from start to finish. We strongly advise that you start planning as soon as possible and put together a clear project plan, which should include the decision making process to help structure the work plan. It is not going to be easy.

If you are one of the associations that has already applied component accounting, you need to consider whether your arrangements are consistent with best practice. Many RPs, including, in particular, the larger RPs, such as some of the G15, adopted it incorrectly with partial applications. They should be revising their policies, although it remains to be seen whether they will.

What will be the impact?

There are several effects of component accounting. Firstly, it will tend to smooth results. This is because fluctuations in major repair work from year to year will have much less of an impact on the income and expenditure under component accounting (where the costs will tend to be capitalised and then depreciated over the period of their lives), as opposed to being largely expensed under non-component accounting. Secondly, as a consequence of the first impact, it will be more difficult to influence results by deferring or accelerating major repair expenditure.

Finance directors will need to become more imaginative if they wish to affect their bottom line by late changes to expenditure. The third impact, and potentially the most significant, is that it will shed more light on associations which have been adopting aggressive accounting policies in respect of capitalisation rates. This hugely significant accounting policy, in some cases clearly abused by associations and misunderstood by supine auditors, will be much more transparent under component accounting.

THE SOCIAL HOUSING PENSION SCHEME

Have you missed the boat?

RPs who participate in Social Housing Pension Schemes (SHPS) have until 30 November this year to advise The Pensions Trust (TPT) of their new strategy for pensions. However, for those who cannot meet the deadline there are other options available.

Background

The SHPS had accrued a substantial past service funding deficit by the date of its last actuarial valuation, 30 September 2008. This has necessitated a dramatic hike in past service deficit recovery contributions from April 2010, increasing from 4.4% of pensionable payroll to 7.5% of a notional payroll (determined on the valuation date), which will increase by 4.7% per annum until the past service deficit is eliminated, which is expected to occur by 2023. Future service contributions have also increased.

Where n/60th final salary benefits are being provided, the new rates will result in contributions being increased by approximately 15% (n/70th final salary – 16%), relative to what is currently being paid. The monetary increase will be closer to 21% for those who have previously adopted the 'lower cost' career average revalued earnings (Care) alternative.

What's new?

A lower cost n/80ths defined benefit (DB) structure is to be introduced in April 2010, along with a 1/80th Care option. A defined contribution (DC) alternative will become available in October 2010, when TPT has appropriate administration systems in place. TPT will be withdrawing the n/70ths final salary option from employers who do not currently subscribe to it.

Timings

TPT has given RPs until 30 November 2009 to advise of their future pensions strategy, but a decision on the strategy cannot be made by a board of directors without first undertaking a formal consultation process with employees, which must last for a minimum of 60 days. This leaves little time to devise a strategy, consult staff and agree the final programme.

We anticipate the process could take up to five months to complete, including the 60-day requirement. Therefore, if you have not yet started this process, it is likely that you will miss the deadline and there will be no alternative but to pay 15% to 21% higher total pension contributions from next April.

So you think you're going to miss the deadline?

Good news; you have another chance. Historically, there has been little scope to adopt new benefit structures other than on dates specified by TPT, usually 1 October. This will change from April 2010, when it will be possible to adopt alternative structures from the first day of any month, on giving appropriate notice to TPT and having completed a formal consultation process. Notice periods will be three months (DB structures) and six months (DC structures).

On the basis that perhaps five months will be needed for formal analysis, consultation, management and board meetings, the process would need to commence now in order for you to be in a position to give notice to TPT on 1 April 2010. This would enable a revised DB structure to be implemented from 1 July, or the new DC option to be adopted from 1 October 2010.

Employees who move from DB to DC

Many employers will view the new DC option as more affordable than any of the DB structures. However, the DC option may not be quite as 'inexpensive' as it first appears. Consideration needs to be given to compensating existing members for the loss of certain benefits, as well as other direct costs, which are identified below.

Where employees leave one of the existing DB options to move into the DC environment, the following issues will need to be considered.

  • Full rate national insurance (NI) contributions will become payable (employers' NI contributions will increase by 3.7% of band earnings).
  • Deficit recovery contributions will continue to be payable (7.5%).
  • Whether compensation is needed for the loss of ill-health early-retirement provisions.
  • Whether compensation is needed for loss of survivors' pensions.

Benefits and contribution rates

We have outlined the total contribution rates associated with each benefit structure. TPT will remove its requirement for employers to contribute at least 50% of the cost, in order to facilitate the new DC option. Employee contribution rates may be revisited as a part of the review process and compliance with age discrimination legislation should also be considered.

Final salary n/70th will cease to be available for employers who do not currently offer it. Contributions on this basis will increase to 15.4% (future service) and 7.5% of notional salary (past service).

* Employee contributions will rise to 5% from April 2012 to comply with personal accounts legislation. If appropriate, deficit contributions of 7.5% of notional salaries would also be payable.

Conflicts of interest

For most RPs, their executive will be largely responsible for putting together proposals for their board, which will inevitably create challenges for them with respect to independence. TPT is not in a position to give independent advice or to make recommendations, so guidance must be sought elsewhere.

VAT ADVICE FOR HOUSING ASSOCIATIONS

New initiative from HMRC

HM Revenue & Customs (HMRC) is again trying to understand what housing associations are all about and how they operate. It is intended that a new notice will be issued before the year end, which it seems is as much intended to educate the average VAT officer as it is for the sector.

There are a number of HMRC roadshows taking place which will promote a special partial exemption 'framework' for housing associations.

What this means, in a nutshell, is that HMRC is trying to identify special methods for partial exemption calculations which are appropriate to the sector, and which it feels comfortable with, and consequently can more readily and easily agree without entering into protracted negotiations.

It will be interesting to see how this develops, and although the intention is good, perhaps, in practice, time might be better spent working with associations that are content to stay on the standard partial exemption method, but need help operating and understanding the basic approach.

Whether this will mean that we are likely to see an increased level of interest from HMRC, which will involve looking more closely at housing association activity, only time will tell, but with a tight restraint on resources, we suspect this is unlikely.

HMRC to return to old ways?

For much of the 1990s, and up until relatively recently, HMRC was focused on attacking the unacceptable face of VAT avoidance, and it must be said that the level of aggressive VAT planning has significantly declined. However, with considerable pressure on the Treasury to raise funds in the current difficult economic times, there appears now to be a mood shift back to assessing for compliance and administrative irregularities. This, together with a new penalty regime, means we could be heading back to the draconian approach from HMRC, last seen in the early 1990s, when we had the last major property recession.

Housing associations should ensure their VAT compliance and administration is up to scratch, as it is expected that HMRC may be looking for easy wins on the assessing front.

Change of VAT rate

With effect from 1 January 2010, the standard VAT rate will return to 17.5% from 15%, and it is widely expected that this rate may climb as high as 20% in the not too distant future. Housing associations that issue invoices with VAT to persons/bodies unable to make full VAT recovery should be thinking now about whether to advance the issue of those invoices to a date before 31 December, so that recipients may benefit from the lower VAT rate.

However, before rushing off to raise lots of invoices, there are a number of issues to consider. Commercially, you need to consider whether you will be paid promptly if this is outside the normal invoicing cycle, and from a VAT perspective, be careful not to be caught out by some complex rules introduced by HMRC to stop people taking an unfair advantage by advance invoicing. You should also consider whether efficiencies can be made to your own VAT position in preparation for the VAT rate change. Housing associations need to understand that contractors should, where possible, be asked to issue invoices before 1 January 2010 and apply the 15% VAT rate to their bills. But can invoices issued after 1 January 2010 charging the 17.5% rate be apportioned between the different VAT rates where the work undertaken crosses the rate change? VAT efficiencies could be secured where contractors' invoices are for significant sums and your housing association cannot reclaim all the VAT thereon.

Case involving Community Housing Association concluded

This case has finally been concluded in the High Court, and readers will no doubt be familiar with the details. Although Community Housing Association was ultimately successful, it was a long struggle to get there. The principles established are, however, important.

Clearly, before you embark upon any major project, some advance thought should be given to the VAT implications. For housing associations, VAT is effectively an outright cost on developments made available for rent. If there is a change of intention, and a recharge is to be made with VAT, any VAT on costs incurred in making that recharge should be recoverable. However, it is important that in making that recharge, something is actually supplied to the benefit of that other party.

In the Community case, it was the benefit of the works and professional costs incurred to date which became a cost component of the supply, and therefore VAT was correctly recoverable. However, this will not always be the case, and care should be taken when making recharges with a view to recovering VAT on costs incurred.

VAT recovery on shared ownership developments

Have you ensured that you have made full VAT recovery on any shared ownership developments? This may sound obvious, but it is a point which is often overlooked, and once purchase invoices have passed through the accounts system, picking up the reclaimable VAT at a later date will be unlikely. The amounts on professional fees alone can be significant. This should be a relatively easy claim to put together, so if you would like further advice or assistance, please get in touch.

'QUALIFIED PERSON' REPORTS TO BE INTRODUCED

Further requirement finally added to Clara

Most RPs are now very familiar with the various requirements within the Commonhold and Leasehold Reform Act 2002 (Clara). The rights of service charge payers to be consulted, to nominate contractors, etc. are all built into RPs procedures. Although there are some nasty effects on certain procurement policies, and there continues to be a steady flow of cases at the Leasehold Valuation Tribunal, for most RPs the broad principles are understood.

Those with a good memory may recall that back in 2002, and periodically thereafter, there has been discussion about one further part of Clara, namely the obligation to provide a report by a 'qualified person' alongside each statement of account, subject to certain exemptions to be decided upon later. This part of the legislation has lain dormant as many of the practical issues, including cost, were being given consideration. However, it is about to wake from its slumbers, and those of a nervous disposition might be advised to take a deep breath at this point.

We expect regulations to be issued imminently setting out the circumstances requiring qualified person reports. The draft version is remarkably specific in some areas. For example, it prescribes some disclosures, requires accruals accounting to be followed, and insists on the statement being at least ten point font size. However, the part that may cause many RPs particular problems is the requirement for all statements of account issued to variable service charge payers, tenants and leaseholders, to have a qualified person report attached, unless the specific exemptions apply.

Qualified persons

Let me start by commenting on who qualified persons can be. The list is quite short. They need to be a member of one of the main accountancy bodies and entitled to engage in public practice. However, connected parties are not permitted, e.g. the finance director of the RP.

Exemptions

There are three conditions that must be met before exemption from qualified person reporting is available. Firstly, the amount covered by the statement of account must be less than £5,000. Secondly, the statement of account must relate to four or fewer dwellings. Thirdly, if there is a sinking fund or equivalent, then it must not be held in a designated bank account jointly with other similar sinking funds. RPs with sinking funds need to be particularly careful.

When does this come into effect?

Accounting periods beginning on, or after, 6 April 2010 are the first to be affected, although RPs can apply the requirements earlier if they wish. In practice, this probably means that for most RPs the first period affected will be 31 March 2012.

So what should you do?

It clearly is going to be important to invest some time in understanding the requirements and what they will mean specifically for you.

REWARD STRATEGY IN TURBULENT TIMES

In the middle of redundancy programmes, HR teams can overlook the impact restructuring has on reward strategy. But, we all know that integrating and aligning key HR practices is vital to support business objectives.

To assist HR teams, we have developed a six stage model for dealing with the reward outcomes of major organisational change, detailed in figure 1.

Stage 1: Review changes to the size and structure of your job roles

As organisations shrink and structures and finances are reorganised, the boundaries of many job roles are likely to be extended. Both the depth and breadth of roles may change, and effective job design and evaluation techniques will be needed to review these changes.

Stage 2: Check the validity of your pay and grading structure

Consider whether or not the organisation's current pay structure is flexible enough to accommodate these different job roles. What will be the impact on any grades or levels? How will pay and career progression be affected?

Stage 3: Obtain accurate and current market data

Have internal job relativities been affected by changes to roles and pay structures? With a stagnant pay market it will be essential to benchmark pay levels so that you can keep your best people when the economy starts to recover.

Stage 4: Review the cost effectiveness of your benefit and incentive scheme provisions

Are you getting the best rates for benefits? From re-broking benefits to renegotiating bonus schemes, organisations can create greater cost effectiveness in their overall reward package.

Stage 5: Re-communicate the value of your total reward package

Work hard to communicate the total value of your reward package; get these messages out to your staff in clear and fresh ways.

Stage 6: Ensure your reward strategy is equal pay compliant

If you do make changes to roles and reward structures, check that these will be applied fairly. Equal pay analysis will help you test the effectiveness of any changes made and provide a benchmark for measuring future progress.

THE CARBON REDUCTION COMMITMENT – LARGER RPS TAKE NOTE

Key issues for the sector following the Climate Change Act 2008

The carbon reduction commitment (CRC) arises out of the Climate Change Act 2008. It is a carbon emissions reduction scheme for the UK that impacts businesses beyond the heavy industrial energy users already caught by European Union (EU) regulations. It introduces an annual 'cap and trade' system whereby organisations will be required to purchase carbon permits for their anticipated emissions and then later receive rebates plus or minus a bonus or a penalty dependant upon their actual performance against other participants. While the Government is likely to carry out some fine tuning, the main aspects are finalised.

The CRC scheme applies to all UK businesses with at least one half-hourly electricity meter (HHM) and electricity usage for the 2008 calendar year greater than 6,000 MWh, which may broadly equate to a spend of approximately £500,000 or more. It is not specifically aimed at RPs, but those with larger offices or other installations will find they have a HHM. In addition, even small organisations may potentially experience extra charges as larger landlords seek to pass on any costs they incur to tenants. There are a number of key issues to consider which we now explore.

Cost

Full participants must purchase permits from April 2011 at a fixed price of £12/tonne CO2 for their energy use in 2011/12. The anticipated minimum initial cost has been estimated at around £38,000 (with permit prices increasing in later years). Organisations that do not increase their energy efficiency will be penalised and will not receive all of their payment back over the scheme cycle.

Resource

Management time will be needed to complete returns and deal with ongoing compliance. Multi-site RPs could find data collection onerous and responsibilities in respect of leased offices may not always be obvious, although in principal, the registered meter owner is usually responsible.

Cashflow

Permits must be purchased in April each year, and while recycling payments will be made back to organisations, there will be a period where organisations have to fund the gap. Potentially, business plans may need to be revisited and extra financing considered.

Service charges

No historic lease envisaged the CRC. Complexities are likely to arise over dealing with recharges to tenants and leaseholders, although the intention appears to be to exempt purely domestic consumption. Therefore, the position in respect of communal areas and some types of care and support schemes will need some consideration.

Reporting

Many organisations that are not full participants of the scheme are likely to need to prove energy consumption and provide annual evidence packs.

Reputation

A national league table of energy efficient organisations will be published by the Government (with sector specific tables likely to be generated), which may impact upon future business development opportunities.

Upsides

There are, however, some upsides. Reducing energy use should reduce costs and those organisations that do well in the league table will be likely to receive economic and publicity benefits.

Finally, while it is rather bureaucratic, you never know but it might just help reduce climate change.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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