SFHA Submits Response to SPSO re Proposed KPIs

To reflect feedback recevied from members, SFHA submitted a short response to the SPSO regarding its proposed KPIs relating to the Model Complaints Handling Procedure.   Many thanks to all members who provided feedback.  

In general, members were content with the majority of content in the document, but we noted the following points in our response to the SPSO:

• As more general point, we wondered if the SPSO could put in place a Memorandum of Understanding with the Scottish Housing Regulator to cut down on any duplication in reporting requirements.   RSLs have to submit data to the SHR regarding complaints handling on an annual basis as part of the Annual Return on the Charter.  However, given the reporting requirements detailed in the below – especially the annual complaints performance report -  also submitting data separately to the SHR represents duplication.  
• Some concern has been raised about the separating out of stage 2 complaints and escalated complaints (related to indicators 2, 3, 4 and 5).    For some associations this will be a manual exercise as systems are not set up to easily show the difference between a Stage 2 complaint that has gone direct to investigation or one that has previously been a frontline complaint that was escalated.
• Under Indicator 2 – the total number of complaints received – it was noted that at point 27 there is a suggestion that for benchmarking purposes that this could also be reported per 1000 units.   Consistency is very important for benchmarking, so it needs to be clear how this indicator should be reported on – whereas this suggestion at point 27 appears to be more of an optional example.   This could lead to different organisations reporting on this indicator in different ways.
• In terms of the recommended indicator 6 – Raising Awareness -  we received some feedback on how this might need a bit more clarity.     Customers tend to feel more defensive when raising complaints and seeking to gather information on protected characteristics at that stage may result in resistance or have an adverse effect of detracting interaction. 
• We received some feedback on the recommended customer satisfaction indicator, and it was suggested that a standard set of questions on the areas the SPSO would like to be included may help with benchmarking/consistency.   Whilst we would not wish the SPSO to be prescriptive, any further guidance to provide clarity on what could be included would be helpful.    Measuring satisfaction with complaints handling was noted as being problematic in general – as those who have had their complaint upheld are more likely to be satisfied and vice versa.
• It might be helpful to include examples of how reports might look – e.g. if SPSO could include an example of a fictional Annual Complaints Performance Report within guidance to show how reporting against the KPIs might look in practice.
• We also wondered if/when the “recommended” KPIs might also become mandatory?  
• Other than that the only query we had was when you intend to publish the final version?  

If you have any queries about the above please get in touch with Alan Stokes, Policy Lead astokes@sfha.co.uk