Memorandum from the Audit Commission
1. The Audit Commission welcomes the focus
of the Committee on user voice and citizen engagement with public
services and is pleased to submit evidence to this inquiry.
2. International comparisons and learning
from other sectors are and should be a vital part of public service
design and delivery. Much can be learned from the experience of
other countries and other sectors. Policy ideas and practices
can, however, be difficult to translate between different settings.
3. Where minimum standards for public services
are set, they would need to be universal and ensure equitable
access. However, the Commission would recommend that minimum standards
should be used sparingly. While standards should be nationally
consistent for issues such as education and health and safety,
for most local services it is important to take account of local
complexities and differences. We must accept that some areas will
take longer to meet the standards required due to local circumstances
or their historical starting points. There are cost implications
that should be recognised but may be difficult to assess.
4. Measures of customer satisfaction have
an important role in assessing the standards of public services.
However, surveys are only one source of information and cannot
provide the whole picture. Views of users, particularly those
who are vulnerable, should be monitored and acted upon at a local
level by public service agencies. Independent statutory agencies
such as the Commission have a role to examine whether local public
bodies take steps to know their communities and view services
from the perspective of those who use them.
5. Users and citizens should be directly
involved in service delivery. There is a fundamental distinction
to be drawn between individual and group involvement in service
delivery. There is evidence from across the public sector that
user involvement has led to improvement in public services while
empowering citizens. There is good practice across the public
sector in this area but progress is still patchy.
6. Local authorities can only be truly effective
if they know their communities, and are willing and equipped to
engage with them and respond to their needs in a meaningful way.
Effective consultation, as part of wider citizen engagement and
outreach activities, is therefore vital to help improve decision-making
and service quality for diverse communities.
7. There are examples where good, timely
consultation has led to improved services and outcomes. But there
are also examples where authorities have failed to consult with
sections of their communities, have failed to provide feedback
and have failed to translate consultation into action.
DETAILED RESPONSE
Introduction
8. The Commission's submission to this inquiry
is based on our knowledge and expertise in understanding user
voice and citizen engagement. One of the Commission's five strategic
objectives is focused on encouraging "continual improvement
in public services so they meet the changing needs of diverse
communities and provide fair access for all." Our current
comprehensive performance assessment (CPA) and corporate assessments
of local councils assess whether councils understand and meet
the needs of their diverse communities. We have also managed the
2006 Best Value Performance user[52]
satisfaction surveys of council residents and service users, which
is a statutory requirement for English local authorities. These
surveys, undertaken on a triennial basis, explore residents' views
of services in addition to priorities and quality of life issues.
Our housing inspectorate employs tenants as inspection advisers
to support the inspection process.
9. We have developed a range of tools for
local public bodies that focus on improving services for users.
This includes Knowing Your Communities toolkit[53]
that contains notable practice and was developed in conjunction
with a range of external stakeholders including the Commission
for Racial Equality (CRE). Our work on Area Profiles provides
a wide ranging picture of the quality of life and public services
in a local area.
10. On public consultations, our comments
are based on information from our and others' guidance and research
on good consultation practice and from our comprehensive performance
assessment (CPA) of all single tier, county and district councils
in England. Building on this, case studies, covering user focus
and diversity issues, are published as part of Learning from
CPA web tool[54].
We also carry out inspection of local authorities under best value
legislation, principally the Local Government Act 1999, which
requires local authorities to consult when conducting best value
reviews.
11. Similarly, in our audit work, our Code
of Audit Practice is focused on ensuring that `services meet
the needs of users and taxpayers'. Appointed auditors are required
by the Code to report their conclusions on an audited body's
arrangements for securing economy, efficiency and effectiveness
in its use of resources.
12. We have published a number of national
studies that contain evidence of authorities and others' understanding
of user focus. All these national studies are available at our
website www.audit-commission.gov.ukand include:
— Listen up! effective community
consultation—1999
— Connecting with Users and Citizens—January
2003
— Journey to Race Equality—January
2004
— Choice in public services—Sep
2004
— Housing: improving services through
resident involvement—June 2004
— Choosing well: Analysing the costs
and benefits of choice in local public services—May 2006
— Learning from CPA in 2005/06—August
2006
— Innovation in local government—Forthcoming,
early 2007
13 Evidence in this response draws on the research
in all these studies and from our audit and inspection work with
local authorities, NHS bodies, police authorities and housing
associations in England. The Committee's specific questions are
addressed in our response below.
QUESTIONS
1. Can public services learn from the way
that either non-public sector organisations or overseas governments
make use of user experience in service delivery and design?
14. Bodies delivering public services, like
those in other sectors, should establish themselves as learning
organisations, looking to international comparisons and other
sectors to improve their activities and outputs. This should include
learning from others' engagement with users to improve service
design and delivery.
15. The Commission has already done much
work to help public bodies benchmark their processes and services
against others. Our publication World Class Financial Management
provides private sector and international good practice in financial
management from which local public bodies could learn. In addition,
we use international comparisons in our national studies programme
on issues as diverse as waste management and recycling, policing
and performance management.
16. The public sector can learn from the
private sector on issues such as choice, which can empower users.
Choice can be an effective driver of quality and value for money
when consumers can choose from a number of competing suppliers
or from different options about service delivery. It is important
to understand the circumstances in which choice can operate as
a force for improvement in public services, while also guarding
against expanding choice into areas where it would undermine wider
objectives, such as community benefit, social justice or value
for money. A key difference exists between the private and the
public sector. In the private sector, the relationship between
paying and using a service is closely aligned. This is not necessarily
so in the public sector where increased consumption can lead to
financial deficit and higher taxes rather than to shareholder
profit.
17. Choice in public services can only truly
be available to individuals or groups where they have the ability
to make decisions. Without that decision-making power, individuals
and groups can only make their voice heard, in effect lobbying
other decision-makers.
18. Policy ideas and practices can, however,
be difficult to transfer between settings. Significant cultural
differences between nations, language barriers, different political
and institutional designs, and distinct regulatory environments
make international comparisons and policy transfer complex. Findings,
therefore, should be viewed in context. Our recent research on
innovation in local government, which we anticipate publishing
in March 2007, sets out how important it is for organisations
to learn from others and to adapt good practice to suit their
own circumstances.
2. Is it possible to set minimum standards
for public services? If so, how is this best done?
19. Where national minimum standards for
public services are set, they should in principle be universal
and ensure equitable access, taking full account of the needs
of citizens and service users. However, while it is possible to
set minimum standards, we would recommend that minimum standards
are used sparingly.
20. While there are some areas where standards
for public services should be nationally consistent, for example
in education, local complexities and differences mean that minimum
standards could and should be different for many services. In
most cases standards relating to local services and priorities,
such as access to green spaces, should be set locally and rely
on service providers agreeing what standards should be in practice,
in consultation with citizens and users.
21. Some areas will take longer and require
more resources to meet standards due to local circumstances or
their historical starting point. For example, public agencies
operating in deprived communities may require more time and resources
to achieve minimum national standards, compared with less deprived
areas. Where local factors, such as deprivation, impact on the
delivery of national priorities, these should be reflected in
any locally-agreed improvement targets set against the relevant
indicators. A balance needs to be achieved at a local level between
national minimum standards and local improvement targets.
22. Standards in public services can in
many cases be regulated and enforced voluntarily by the providers
themselves. The public also has a part to play. Effective complaints
and redress systems could lead to local self-regulation without
the need for heavy external intervention.
23 As an independent regulator, the Commission
has experience in measuring and assessing the delivery of national
outcomes at the local area level against agreed criteria. Our
role as a regulator provides an independent assurance framework
to ensure that standards are met. These include the following:
— measuring performance to provide
the baseline against which improvement can be assessed, and to
verify any improvement against the baseline;
— challenging services to improve,
through audit and inspection locally and through national reports
to draw attention to issues of wider concern;
— supporting choice by helping service
users and taxpayers to provide their own challenge and exercise
choice where it is available;
— sharing knowledge by working with
others to spread good practice, both within and across sectors;
and
— supporting public service managers
through seminars, workshops, and self-assessment tools.
3. What role do measures of customer satisfaction
have in assessing the standards of public services? How should
user views be monitored? How can the cost-effectiveness of user
surveys and feedback mechanisms be assessed?
24 Measures of customer satisfaction have an
important role in assessing the standards of public services,
although these should be complemented by a wider range of assessments
of the services, such as through audit and inspection.
25 Views of users, particularly those who are
vulnerable, should be monitored and acted upon at a local level
by public service agencies. This should be a continuous process
and not only part of an annual survey. The Commission's current
inspection framework, whilst not prescriptive about how public
bodies should monitor the views of users, seeks evidence of an
effective system. We have strengthened our corporate assessments
under CPA—the harder test by considering the quality
and robustness of councils' own customer surveys, citizens' panels
and other consultation methods. We examine whether local public
bodies take steps to know their communities and view services
from the perspective of those who use them. We also monitor the
impact of local public bodies' decisions and assess whether they
are responsive to citizen engagement and participation.
26 The Commission collects data from Best Value
Performance Indicators (BVPIs), including user survey of council
residents and service users, as part of our inspection process.
Data from the surveys provide knowledge about citizens' and service
users' experience, perceptions and expectations of a range of
council services and of the council as an organisation. The latest
BVPI user survey is currently underway and the Department of Communities
and Local Government (CLG) will be publishing the results early
in 2007.
27 Surveys of this kind are only one source
of information that can be used to capture people's experience
and perception of their local services. They can also help inform
citizens and users about the services being delivered and their
performance, and they can provide information to facilitate engagement
and information on levels of satisfaction with local services.
However, they should not be used on their own to provide the whole
picture of local services.
28 There are limitations to customer satisfaction
surveys that should be taken into account. Surveys do not necessarily
capture the whole spectrum of opinions. For example, surveys may
become unrepresentative if they fail to capture the views of hard-to-reach
groups and non-users of services. Some service users who are surveyed
may fundamentally disagree with policy decisions, for example,
they may not be entitled to free access, and would therefore not
be unbiased in their opinion about the quality of the service.
4. What constitutes best practice in responding
to complaints about public services?
29 Our knowledge in this area is based on local
inspection reports that specifically deal with how local public
bodies handle complaints. The Commission's key lines of enquiry[55]
(KLOEs) seek evidence of a `well-publicised, user-friendly and
supportive system for service users to submit compliments, complaints,
grievances, representations and suggestions; its response to these
is positive and timely and the results are used to help improve
services.' We describe what the ideal service should look like
and we seek evidence of this in our work but we are not prescriptive
about the complaints process. Effective complaints and redress
systems are key elements of a transparent and accountable service.
The process should at least have the following guiding principles:
— an embedded culture of learning from
complaints;
— clear aims and objectives that are
guided by a complaints strategy;
— integrated and effective systems
to monitor complaints;
— a monitoring system to identify whether
the complaints service meets the needs of diverse communities;
— a system to identify the wider costs
of handling complaints across the public body; and
— regular reporting to managers, users
of services and those who are part of the governance framework,
including councillors and the board of governors.
6. Should users be more directly involved
in service delivery? If so, how can this be achieved?
30. It is of vital importance that users
should be directly involved in service delivery. For example,
the best outcomes in increasing educational attainment can be
derived from a combination of support from parents and carers,
the local community as well as from teachers. The same principle
of co-production[56]
can apply to managing chronic conditions or improving community
safety. We should make a distinction between co-production of
services by individual users and engagement in decision-making
by local communities or groups such as through participatory budgeting.
31. Government and policy-makers have acknowledged
that direct involvement can lead to improvement in public services
whilst empowering citizens. There are examples of good practice
across the public sector. In housing, the joint Audit Commission
and Housing Corporation national report Improving Services
Through Resident Involvement examined the benefits of more
direct involvement. Housing associations found that involving
residents in refurbishing an estate helped to reduce empty properties,
tenancy turnover and improved local community involvement. The
last of these can have a wider-reaching impact in terms of stabilising
communities and helping to ensure their sustainability.
32. Elsewhere participatory budgeting has
given people a say in how their council's budget is spent in the
local area. A number of pilots have been undertaken across England
including in Salford, Bradford and Newcastle that are co-ordinated
by the Community Pride Initiative (CPI) with support from CLG
and the Neighbourhood Renewal Unit (NRU), as well as the more
ambitious Open Budget project in Harrow, which is coordinated
by the Power Enquiry.
33. There is evidence that direct involvement
in service delivery and design can also be cost-effective. The
Wanless Report estimates that investment in public health and
public engagement can save the NHS £30 billion per year by
2022, which is around half of the current budget of the NHS.
34. However, direct involvement is not widespread
and the evidence from our corporate assessments of local authorities
found that consultation is often better developed than participation
and involvement. The current position needs to be improved in
order to meet the aspirations of the Local Government White Paper,
which proposes an enhanced Best Value duty to `inform, consult,
involve and devolve' that will require local services to secure
the participation of citizens in the delivery of local services.
The White Paper also sets out a clear role for the Commission,
as part of its future annual risk assessment and in inspections,
to consider evidence such as citizen perspectives, including those
of the most vulnerable, as well as a local authority's compliance
with the new duty. The Commission's consideration of a local authority's
compliance with the new duty may examine whether opportunities
to participate are available and will enable bottom-up pressure
to improve services.
35. Regulators also have a role in ensuring
that there is probity and good governance in local services. Public
participation increases risks; for example, the transfer of assets
to communities may lead to inappropriate use or wasteful use of
public resources, and adequate safeguards should be built in.
8. Do official consultations typically manage
to capture the views of the right people? What kinds of consultation
are most effective in engaging with the appropriate people?
36. Consulting with the public and service
users is a statutory duty for many local public services. For
local authorities, these include broad duties in the Local Government
Act 2000. Housing associations, police authorities and Primary
Care Trusts have a statutory duty to consult with citizens and
service users. It is also an important aspect of community engagement.
37. The Commission has published reviews
of how well local authorities consult. A management paper in 1999,
Listen up! Effective community consultation, gave guidance
when Best Value was introduced, including the obligation to consult
when reviewing services. In 2003, we published Connecting with
Users and Citizens that provided an update on the issue and
outlined case studies of good practice on consultation.
38. The research underpinning Listen
up! found a mixed picture:
— local authorities did not use consultation
appropriately;
— consultation was of inconsistent
quality; and
— it was not always evaluated effectively.
39 Listen up! also found evidence of
good practice that demonstrated:
— strong links between consultation
and decision-making;
— a strategic approach to consultation;
— that high standards were applied;
— that all sections of the community
were involved; and
40. Our 2003 study provides case studies
to illustrate good practice in engaging and consulting with users.
There were issues identified including: lack of responsibility
and meaningful involvement; poor feedback on outcomes of the consultation;
and reluctance to hand over control and ownership of the consultation
process.
41. More recently, our corporate assessments
in 2005-06 found that good progress has been made by local authorities
in consulting with the public when setting its ambitions for their
local areas. Councils seek citizens' views through a wide range
of consultation processes, such as citizens' panels and targeted
consultation with specific groups. We found that better performing
local authorities have well co-ordinated approaches to consultation
and share information with partners. While all councils have ways
of consulting with representative groups, all face difficulties
engaging with specific minority groups. Many also fail to report
the results of consultations to young people.
42. The drivers and audiences for consultation
will vary, as well as the methods. Local authorities and other
public bodies will properly take a different approach when consulting
users about a directly-provided service compared with a service
delivered in partnership with or wholly by another organisation.
43. Evidence from our studies and corporate
assessments of local authorities found that some consultation
techniques may not be suitable for tackling issues where strong
feelings already exist in potential consultees' minds. Holding
a public meeting about the siting of a bail hostel or a travellers'
site may be essential to give local people a chance to let off
steam, and to convince them that those making the proposal are
willing to hear people's concerns. Local people have a right to
be informed, but there is also a responsibility for national and
local decision-makers to meet the needs of the population at large,
and for the needs of vulnerable and minority groups to be balanced
against others'. Some consultation mechanisms, such as neighbourhood
forums or public meetings, are much more likely to be dominated
by an unrepresentative minority than others. While these do have
a valuable role to play, their results need to be used with care
and effort made to ensure that these consultations are inclusive.
44. We have identified a number of principles
to ensure effective consultation, including:
— commitment and culture: prioritising
users must be part of organisational culture. There needs to be
commitment beyond the statutory duty of local public services
to consult with service users, and this should be made pivotal
to service design and delivery;
— support and structure: leadership
and collaboration between organisations is important, as is the
need for a strategic approach to long and short-term consultation;
— access to information: in order to
ensure meaningful responses, consultees must be provided with
relevant and accurate information;
— engaging with all users: it is important
to distinguish between service users and citizens who do not,
or cannot, use the service. Good practice would take both of these
into account. For example, new technology can reach wider and
more diverse audiences. Local public services need to be wary
of treating consultation with representatives and stakeholders
as being the same as consultation directly with users;
— handing over control: service users
should be involved in consultation design;
— learning from experience: previous
good practice and regular evaluation should be built in. We have
developed Knowing Your Communities toolkit to help local
public services assess their progress on consultation and citizen
engagement; and
— real results: consultation needs
to be timely in order to influence decision-making, and the results
need to be visible and communicated well to those taking part.
45. The Local Government White Paper sets
out measures for informing, consulting, involving and empowering
local communities, devolving responsibility, extending choice
and giving local people a say in running of services. While this
has yet to come into force, it is imperative that all public bodies
have an effective consultation process that takes into account
the needs of its diverse communities.
12. Are there situations where the views
and experiences of service users are relevant?
46. Views and the experience of service
users should always be taken into consideration in the design
and delivery of public services. However, this is not the same
as suggesting that these views should be the only relevant factor
when making decisions about public services. There are instances
where the views of service users should not be directly acted
upon. For example, consultations can produce results that do not
represent the views of local people as a whole or lead to suggestions
that are not financially sustainable or which conflict with statutory
obligations. In some cases, the scale of an issue and the potential
impact of the findings may require resources that are disproportionate
or do not provide value for money. Each case should therefore
be carefully considered.
47. There is always a risk that articulate,
well-educated people will be better able to use consultation mechanisms
than other sections of the community. Often the voices that particularly
need to be heard are those most likely to be unrepresented. For
example, depending on the objectives of the consultation, particular
efforts may be necessary to access the views of groups such as
rural populations, disabled people and Black and Minority Ethnic
(BME) communities.
48. Problems arise when local public bodies
use consultation mechanisms that allow a minority of people to
dominate the process, do not take steps to ensure that a wide
range of people participate, or use unrepresentative samples.
The questions asked or the methods employed to consult can also
have an impact on responses and findings. It is therefore essential
to ensure that consultation is objective and open to a wide range
of responses and opinions.
January 2007
52 This forms part of the Best Value Performance Indicators
are a national measure of performance, set by central government.
For further information on BVPIs, www.bvpi.gov.uk. Back
53
Further information is available from http://www.userfocus.audit-commission.gov.uk/KycHome.aspx. Back
54
Further information is available from http://www.audit-commission.gov.uk/cpa/stcc/Ifcpa/index.asp. Back
55
KLOEs are detailed questions that help to inform our inspection
judgemeents in all of our inspections, including our corporate
assessments of local authorities and in husing, and our crosss-cutting
inspections on regeneration and community safety. Back
56
The concept has been used, particularly in the USA but also in
the UK, to mean direct usere involvement in public services. The
extent and nature of this involvement varies between programmes
and countries.
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