The ICSH is endeavouring to provide our member organisations with the most useful and up-to-date information that can assist them in carrying out their roles over the course of the Covid-19 crisis. The ICSH staff are all working remotely. But please feel free to contact us with any issues as they arise.
Can rents be increased at this time?
Is rent collection and rent assessment being affected?
How should rent arrears be dealt with?
Can evictions take place at this time?
What about tenancies where the NOT has already been served?
How does this affect Part 4 rights?
Should allocations still take place?
Can pre-tenancy training continue?
Should AHBs still carry out repairs?
How can we make tenants in our multi-unit development aware of the advice on Covid-19?
Who should be considered vulnerable / at risk tenants?
What guidance is available for vulnerable group settings in the Covid-19 crisis?
Should we be providing any additional services to our tenants?
If older tenants are not cocooning, is there any way we can enforce it?
What is best practice if one or more of our older tenants (in one complex) are diagnosed as positive for Covid-19?
Should we notify other tenants that there has been a Covid-19 case in the housing scheme?
Should we be carrying out additional cleaning services?
Are we responsible for the cleaning of a tenant’s apartment who had Covid-19?
Is there any way that we can replace our Day Centre Services which are now closed?
Should we impose visitor restrictions in our schemes?
What happens if our staff member(s) / Board Members need to self-isolate – how will we continue to support our tenants?
Where can we source Personal Protective Equipment (PPE)?
Some of our units are void pending refurbishment – do we still need to do weekly inspections?
Is separate insurance required for employees working from home?
Can the annual servicing of gas boilers be postponed if they are due during this emergency period?
Are there insurance implications if properties are allocated for health service staff or as self isolation units as requested by the authorities?
Should AHB employees work from home?
What should essential workers who cannot work from home do?
What roles and services are classed as essential?
What proof do I need that I am an essential worker?
How are volunteers considered?
How should AHBs deal with closed sites during the lockdown period?
Under the Emergency Measures in the Public Interest (Covid-19) Bill 2020, no increases of rent are permitted during the emergency period. If you have already issued letters prior to the crisis advising tenants of a rent increase (as per the annual rent review) which will fall due during the emergency period then you can advise them any increases will not take effect during the emergency period.
Door-to-door rent collection or receiving rent payments in person is relatively rare however AHBs should contact tenants that make rent payments in person and encourage them to make their rent payments through other means for the duration of the restrictions. This is a time of considerable financial uncertainty for many with the slowdown in economic activity having a knock-on effect on some employment. We would advise members to deal sensitively with any tenants facing such worries or uncertainty. The ICSH advises its members to:
- Encourage tenants to approach them at an early stage if they are worried about their finances
- Assure tenants on differential rents that any changed income will be factored into their rent calculations, while being realistic that these calculations may not be done immediately and may take some time to resolve
- Keep tenants informed of social welfare assistance available to them
Under the emergency legislation, the period of warning in a case of rent arrears is increased from 14 days to 28 days. Tenants should be assured that should they fall into arrears as a result of income decreases from the Covid-19 restrictions, they should engage with you as soon as possible and their situation will be handled sympathetically and with understanding.
No Notices of Termination can be served during the emergency period.
Where a notice of termination was served before the emergency for a breach of a Part 4 tenancy and where the termination date falls during or after the emergency, it provides that the termination date shall be the revised termination date. The revised termination date does not apply where there is a determination that is issued following an adjudication or a Tribunal. In the case of a notice served before the emergency period, the revised termination date is the aggregate of the remaining period of the notice period and the emergency period.
A tenant who has been served with notice of termination and who has remained in occupation until the date of the commencement of the emergency period shall be entitled to remain in occupation until the expiry of the emergency period. The only exception to this is where a determination of an adjudicator has been made under subsection (4) of section 97 of the Act of 2004, or where an appeal from that determination is brought, the tenant is required to vacate the dwelling in accordance with a determination of the Tribunal under section 108 of that Act.
A person’s Part 4 rights or ability to acquire Part 4 rights are not affected by them being in situ during the emergency period.
Allocations should continue if they involve moving people out of homeless or otherwise unstable or unsafe accommodation. For other allocations that you are unsure about continuing with, consult with the relevant local authority to ascertain if they are priority allocations that should proceed.
Housing associations should consider the risks before carrying out any interviews for allocating new or void units in person. Creative ways of carrying out interviews should be considered such as over Skype or other video messaging or over the phone. Consideration should also be given to the fact that new tenants may find it a difficult time to move due to likely reduced access to goods and services. This is something that should be looked at on a case by case basis, having regard to the safety and stability of an applicant’s current housing situation and whether or not they are in an at risk group. Where lettings take place, a full risk assessment should take place and social distancing and strict hygiene protocols should be followed at all times if carrying out interviews in person or during all aspects of the letting process.
Click here to download a guide on current practices being adopted by AHBs to ensure that they can continue allocating properties to priority households whilst maintaining safe social distancing practice (Dated 24th April 2020)
Any planned pre-tenancy training should be postponed until after the restrictions on gatherings are lifted. Social distancing guidelines would be difficult to follow in any organised indoor setting and any meetings such as this would be best avoided. Pre-tenancy information can be given to new tenants via email or by post. Elements of your pre-tenancy course can still be provided to your applicants via video call or similar, for example, in regards to the tenancy agreement.
All planned and cyclical maintenance should be suspended until current “lockdown” restrictions are lifted. Routine and urgent repairs should also be suspended and only emergency repairs should be carried out. For emergency repairs that are absolutely necessary, guidelines for social distancing and hygiene should be strictly followed by any occupants and tradespeople visiting the property. The tradesperson or company carrying out the repairs should do a risk assessment of the situation and act accordingly.
If emergency repairs are required in a property where there is a suspected or confirmed case of Covid-19 or where someone is self-isolating, then the HSE should be contacted regarding best practice and in relation to protective equipment for any tradespeople. The HSE Live number is Callsave 1850 24 1850 / 041 6850300 and is manned 8am – 8pm Monday to Friday and 10am – 5pm Saturday and Sunday. Call volumes are likely to be very high at the moment and there are further means of contacting HSE Live outlined on their website.
AHBs should consider putting up HSE posters in common areas with advice on social distancing and preventing the spread of COVID-19. These posters are available from the HSE website. Communication by notices posted to letterboxes, or posters erected in lobbies, halls, lift cars, and carparks may be most effective.
As most tenants will now be at home for the most of the day due to the Government restrictions, it might be worth reminding tenants of the House Rules, and that respect and consideration for neighbours will help communities to manage through the period ahead. Email or other written communication would be the most appropriate format for such a reminder.
Tenants who are in the “at risk” category are those who:
- are 60 years of age and over
- have a long-term medical condition – for example, heart disease, lung disease, diabetes, cancer or high blood pressure
- have a weak immune system (immunosuppressed)
Those who are over the age of 70 and / or medically at risk are currently being advised to “cocoon”. Members should monitor current guidance for any extensions to the timeframe for cocooning. Many people are anxious about Covid-19 and the restrictions that have been put in place. Those in the at risk category are probably even more anxious. Many tenants in sheltered housing complexes are likely to be at risk if they were to contract COVID-19 due to frailty and other conditions. Social distancing is therefore essential. There is a risk that tenants who are lonely or socially isolated may become even more so during this time of reduced social interaction. We would advise all AHBs to inform tenants of local services (see below) that are available for those who are socially isolated or vulnerable and who may be stepping up their efforts at this time.
The Health Protection Surveillance Centre (HPSC) has issued guidance on cocooning (dated 17th May 2020) and also a guidance document that gives general advice about preventing the spread of COVID-19 in settings for vulnerable groups such as people experiencing homelessness, Travellers, refugees and asylum seekers, as well as housing for women and children experiencing domestic abuse (dated 15 April 2020).
The Garda National Protective Services Bureau (GNPSB) is overseeing the implementation of ‘Operation Faoisimh’, a proactive initiative, commencing as part of An Garda Síochána community engagement response to COVID-19, designed to ensure victims of domestic abuse are supported and protected in this extraordinary time. The initiative will utilise the Garda Victim Services Offices nationwide to facilitate phone contact with previous victims of domestic abuse to ascertain any existing issues of concern and to ensure the protection of families. Any concerns will be immediately responded to by An Garda Síochána. An Garda Síochána is available to help and support anyone who is a victim of the crime of Domestic Abuse, they should contact their local Garda station or in an emergency call 999/112.
Safe Ireland is the national social change agency working with 38 domestic violence services across the country. Details of these services, inlcuding the freephone national helpline, are available here. https://www.safeireland.ie/get-help/where-to-find-help/
While the measures outlined in the document (above) are mainly focused on congregated settings or facilities managed by staff, there is useful information on the following areas which can be applied to sheltered housing schemes:
- Advice on general measures e.g. hygiene, cleaning etc
- How to manage a symptomatic resident / service user
- How to manage a resident / service user who has been diagnosed with Covid (who is well enough to be managed outside of Hospital)
- Environmental cleaning/disinfection of self-isolation facilities whilst the resident is in their room
- Environmental cleaning/disinfection of self-isolation facilities when person leaves facility
- Cleaning of communal areas and laundry
- Managing rubbish
- How to manage a close contact of a confirmed case of COVID-19
- How staff can protect themselves
Many AHBs are providing additional services, where possible, to ensure their vulnerable tenants remain well and safe, for example grocery or prescription delivery, delivering meals, regular telephone contact, provision of hand sanitizer in communal areas etc. This is dependent on the availability of staff and resources in the AHB and guidelines for social distancing and hygiene should be strictly followed. Where these additional services are not possible by the AHB, tenants should be given a list of community support contact details i.e. for ALONE and the Local Authority Community Forums (see below).
AHBs may also want to encourage their vulnerable tenants to consider completing an anticipatory care plan and sharing their wishes with their GP/Carers for the future including arrangements for care and support if not already in place.
Cocooning is a practice used to protect those over 70 or those extremely medically vulnerable people from coming into contact with coronavirus. People within this category are strongly advised to stay at home and avoid face to face contact for the period of time recommended by the Government. In some cases, tenants are not adhering to this advice and therefore may be putting themselves, other tenants and AHB staff at risk. If your own correspondence, engaging appropriately with family and information in relation to cocooning does not resolve the issue, you should contact the HSE for further advice.
It may also be worth considering contacting your local Garda station to invite a Community Garda to come to speak to your tenants informally.
If you are notified of a tenant being diagnosed as positive for Covid-19 and they require your assistance, HSE and HSPC guidance should be adhered to. The HSPC guidance for dealing with Covid-19 in settings for vulnerable people sets out the following:
If the person feels unwell with symptoms of COVID-19 (e.g. cough, shortness of breath, difficulty breathing, high temperature) then they should:
- Isolate themselves (i.e. stay indoors and completely avoiding contact with other people or at least 1- 2 metres distance away from them)
- Testing should be arranged for them by contacting their GP. If they do not have a GP the ambulance service should be contacted on 112 or 999 to arrange testing. (The HSE is currently working on a streamlined care pathway to prioritise testing of patients in vulnerable groups)
- They should remain in isolation until the test results are back.
- They should not be visited by outside persons while they are in self-isolation.
AHBs who have confirmed cases of Covid-19 are generally carrying out additional services where needed by the tenant (groceries, prescriptions) and increasing the check in contact with the tenant while they are in isolation to ensure their safety and well-being. You may also want to consider additional cleaning of communal areas where the affected tenant may have been.
In cases where positive Covid-19 cases have arisen in AHBs, the AHB has generally notified other tenants in the scheme of the occurrence of a case, with advice to be extra vigilant in accordance with HSE guidelines to avoid the spread of the virus. The diagnosed tenant’s name and details should not be disclosed in accordance with GDPR.
AHBs should consider prioritising the cleaning of high-contact common areas such as common areas, particularly sanitising door handles, push plates, keypads, lift buttons, Refuse areas and handrails. Consider if resources could be diverted from non-essential works, e.g. gardening or litter-picking, to facilitate these measures.
The current legislation does not specify if the landlord is responsible for this. ICSH is aware, however, of some AHBs who have arranged and paid for a deep clean of an affected tenant’s dwelling, as it is highly unlikely that a vulnerable tenant would be able to arrange/afford this. The approximate cost for this ranges from €200 to €300 per room. Deep cleaning of communal areas would be additional to this.
The HPSC guidance for settings for vulnerable groups (dated 15th April 2020) has further guidance on cleaning of self-isolation units and communal areas.
The closure of Day Centres will have a significant impact on individuals and carers who have relied on this form of support. Service providers may want to explore ways in which they can support clients in different ways. This may mean one-to-one visits, however staff should be aware that they must be vigilant about their own health and not visit clients if they feel unwell. They should prioritise only high risk individuals for support – those where they consider that there is significant carer strain, or risk of a caring situation unravelling. Guidelines for social distancing and hygiene should be strictly followed. Alternatives to this could be online support, telephone support or video calling.
Government restrictions with regard to gatherings and social distancing should be adhered to at all times. Further guidance on this is available here and tenants and visitors should be made aware of this. Please note that homecare help and other community services are considered essential services and can continue to be provided.
If an AHB loses staff members or volunteers due to Covid-19, it can leave some tenants in a very vulnerable position. Housing associations should provide tenants with several alternative staff or board member contact details so communications in areas such as repairs and support can be maintained. In addition to this, there are community supports available as below. You can also continue to check in on your tenants by phone or video call where possible.
ALONE, in collaboration with the Department of Health and the HSE, have launched a COVID-19 support line for older people. The National Public Health Emergency has established a Vulnerable People Sub-group and as a member organisation of the National Public Health Emergency COVID-19 Subgroup for Vulnerable People, ALONE is working in collaboration with the Department of Health and the HSE on a coordinated national response to support older people who have concerns, may be at risk or who have contracted COVID-19. Contact ALONE on 0818 222 024 (8am-8pm) if you have concerns about your own wellbeing, or the wellbeing of an older person you know. Further information can be found on www.alone.ie.
Local Authority Community Response Forums: each local authority area is coordinating work to help ensure all vulnerable members of our communities affected by the recent restrictions (e.g. cocooning) are appropriately supported to access food, medicines, and other needs, including transport for medical appointments. A full contact list of these fora is available here.
The HSE now have supplies now of masks, aprons and sanitiser (there is a shortage of goggles). This was established for Section 38/39s but the ICSH have been advised that AHBs who do not have direct links to the HSE can also access this as it is a matter of public health. Please follow the steps below to put your order in which will then be couriered to you when completed.
The HBS Procurement COVID-19 Customer Service can be contacted by:
- Email Address: email@example.com
- Contact Number: 021 465 9770
Once you contact HBS Procurement COVID-19 Customer Service, you will be required to complete a standard PPE Request Form available via the following link.
Further information is available on dedicated HBS Procurement COVID-19 webpage.
The following guidance has been provided by Allianz, underwriters to the ICSH Group Insurance Scheme. As such, this guidance only applies to units covered under this scheme. Should you have an alternative insurer you should check directly with your provider about your cover during this time and any policy amendments that may be required.
Under the group insurance scheme Allianz have agreed to provide full cover without the weekly checks being carried out. Where possible, the unoccupied premises should be secured.
Allianz have extended insurance policies to cover employees working from home.
Under the Rental Housing Regulations 2019 gas, oil and electricity installations should be maintained in good repair and safe working order. If your annual service was due to take place during the lockdown, under the group insurance scheme, it is acceptable to postpone them. However, any concerns or potential leaks should still be reported to the authorities and servicing should be prioritised as soon as possible after the lockdown ends. We will monitor this area should the lockdown continue for a longer than expected period.
If a property is being allocated as a self-isolation unit during Covid 19 at the request of the HSE, then the HSE should be providing the insurances for these units and providing an indemnity to the AHB.
All employees should work remotely from home if at all possible.
AHBs should refer to the guidance to decide whether your organisation is providing an essential service; it is not necessary to seek official authorisation.
If you are providing an essential service, you should identify those employees (including sub-contractors and so on) who are essential to the provision of that service and notify them. This can be done by category of employee or by individual; it could include all employees of the organisation.
Please find attached a template letter which you can adapt for any employees that you deem essential workers and must travel to attend work.
The list of essential workers who are permitted to travel for work purposes for the period of restricted movement. This list is available here.
For AHBs the kinds of services that are classed as essential can include:
- providing essential accommodation (including homeless, direct provision and related services)
- emergency repairs: delivery of emergency services to homes on an emergency call-out basis in areas such as electrical, plumbing, glazing and roofing
- community and voluntary workers, working in a publicly commissioned service, not otherwise included on the list, deployed to assist in the delivery of essential services
- residential care activities (including nursing care, mental health and substance abuse, elderly and persons with disabilities, children’s residential services)
- homecare home help and other community services
- social work and social care activities (including disability services, mental health, child protection and welfare, domestic, sexual and gender-based violence, homeless services including outreach)
When travelling to and from work, you should at all times bring with you either a work identification or a letter from your employer indicating that you are an essential employee, as well as one other form of identification.
If you are a volunteer who is working as part of the national community response, you are permitted to travel for that purpose, for example, if you are delivering food, supplies or medicine to a person who is cocooned or vulnerable. The Local Government emergency response teams will co-ordinate that response at local level.
All construction sites were closed as a result of the lockdown. AHBs need to examine their contracts carefully to ensure appropriate action is taken in line with their contractual obligations. Your contractor should advise you of the site security measures undertaken for the closure and that insurance covers all requirements for closed sites. Local Authorities are currently liaising on the reopening a number of priority sites and if this should happen and involve an AHB site you will be advised accordingly.
The RTB have provided a list of FAQs and a guidance document which is available on their website here: https://onestopshop.rtb.ie/guidance-document-on-covid-19-supports-for-landlords-and-tenants