Memorandum from North Somerset Supporting
People (SPP 13)
1. SUMMARY
1.1 North Somerset (NS) can demonstrate
a strong set of evidence towards "Independence and Opportunity:
Our Strategy for Supporting People (SP)". However, the proposal
to de-ring fence SP occurred before the current financial down
turn and in view of this it is even more important to protect
the most vulnerable and marginalised in society so they receive
equitable funding and access decisions.
1.2 NS's housing support is safer, more
efficient, and easier to access than prior to the strategy's launch
two years ago. Nevertheless, out of the strategy's four themes,
the "Keeping people that need services at the heart of the
Programme" continues to present the greatest challenge to
providers and commissioners. NS is responding to this challenge
during 2009-10 by increasing the number of practical options
for people who wish to personally plan the support they need to
remain independent.
1.3 NS has made the progress within all
the themes:
— Keeping people that need services at
the heart of the Programme;
— Enhancing partnership with the Third
Sector;
— Delivering in the new local government
landscape; and
— Increasing efficiency and reducing bureaucracy.
NS has used these elements of the strategy to
enhance joint commissioning and build financial sustainability
into future arrangements. The strategy has provided a valuable
framework for linking the housing and criminal justice agenda
to the health and social care agenda, which has led to better
quality less bureaucratic arrangements—for example joint
contracts in Extra Care housing, cross authority commissioning
for Dementia services, cross departmental service for Mental Health
and Learning Disabilities and cross voluntary and statutory sector
services for older people. At the same time, the strategy has
helped NS highlight the unique preventative role that housing
support on its own plays in reducing dependence upon less personalised,
higher cost interventions.
1.4 NS proposes the following steps are
taken to ensure that the successes of the programme are not lost,
or services cut, following the change and that this is backed
by a formal and full public risk assessment, otherwise the grant
conditions should remain:
— Authorities are required to involve local
communities in decisions about the future of housing & support.
— Authorities are required to maintain
an effective housing support resource, which is discretely identifiable
within their local joint strategic needs analysis and Local Area
Agreement.
— Authorities have clear local governance
for decision making through the Local Strategic Partnership for
housing and support strategies and outcomes for the local population.
— That the Audit Commission Comprehensive
Annual Assessments include standards and expectations for preventative
commissioning to be part of an authority's evidence of their quality
and excellence, evidenced by continued use of Key Lines of Enquiry
or similar diagnostic tool shared with the CLG.
1.5 The current position for SP in NS is:
— So far NS has retained the SP ring fence
and benefited from a small additional amount of service funding
through the Area Based Grant. However, this is against the backdrop
of significant and continuing social care cost increases due to
population and societal change. As SP is not provided on a statutory
basis it will inevitable that it could be seen as an option to
plug social care gaps. Additionally NS is part of the West of
England sub regional group, some client groups are dependant on
cross border services and facilities. Current grant arrangements
force cross border consideration and commissioning without protectionism.
Without this imperative, even neighboring authorities may take
self interest decisions which could have a domino affect in service
collapse in NS as providers are forced to leave the market on
a non cost recovery basis. Given SP funding is not needs based
and is unlikely to increase, gaps may open in provision which
will leave vulnerable people in a worse position.
— In NS the SP programme is seen as a key
area of activity guided through grant conditions and remains a
discrete team function within an Adult Social Services and Housing
department. This may change due to changes in commissioning, care
and personalization agenda.
— In NS the Local Strategic Partnership
has recently restructured and caused a review of themes and sub
groups. Housing and Support will feature as a sub-group to pick
up commissioning and decision making, however it does not fit
any single theme and will require significant cross group working
in order to achieve required outcomes.
— It would have been of help if there had
been a national SP needs system to re-allocate funding to needs
and could have led to a statutory system. As it is, in many areas
and client groups needs go unmet. This is complicated by care
funding budgets which are based on Fairer Access to Care (FACs)
criteria, where housing support costs may or may not be met. This
leaves many vulnerable people without either a care or support
service as they either do not meet the FACs criteria (eg those
with Autism or complex conditions), or SP services do not have
funding capacity and/or there is a lack of accommodation lettings
available.
2. INTRODUCTION
2.1 "NS SP" is a partnership comprised
of commissioners and providers that includes:
— Avon & Somerset Probation Area
— North Somerset Adult Social Services
and Housing
— North Somerset Children Services and
Youth Offending team
2.2 NS SP has assessed local evidence relevant
to the CLG Inquiry through consideration of the four themes within
"Independence and Opportunity: Our Strategy for Supporting
People".
2.3 This report analyses briefly the evidence
against each theme. This analysis finishes with a view about the
likely impact that removal of the ring fence will have for the
theme.
3. ANALYSIS OF
NORTH SOMERSET'S
EVIDENCE AGAINST
EACH THEME
Keeping people that need services at the heart
of the programme
3.1 As a medium sized unitary authority,
NS has been careful to avoid duplicating arrangements that are
already in place for service user care groups and public involvement.
Wherever possible, the housing support agenda has been integrated
into existing partnership agendas. This approach has ensured consultations
are a proper fit with the wider consultation agenda, and if necessary
investigated in more detail by sub groups working on behalf of
partnership boards. Although the SP team still supports the SP
Independent Provider Forum there has been a significant effort
to support sector/client groups and for the providers to work
with their clients either in groups or with individuals.
3.2 Service users have always had self interest
in supporting the SP programme as it stands. For many, in respect
of the removal of the ring fence and this theme, would find this
threatening as funding removal might put their home or well being
at risk. Service users are just beginning to take more of a participative
role in strategic commissioning which might lead to remodelling
and prioritising decisions. However, experience shows that when
asked to be involved in taking decisions which might disadvantage
fellow service users they withdraw from the process. It would
put back the progress made on service user participation if this
took place.
Enhancing partnership with the Third Sector;
3.3 NS SP has a strong track record of engaging
providers, and working in close partnership with them through
the introduction of housing support contracts, with common service
specifications and service delivery statements. The establishment
of sector groups has brought better performance and collaborative
working and has created opportunities for bringing together providers
of both care and community services, with commissioners, into
a more consistent business environment.
3.4 In this theme, NS can evidence good
progress with developing a culture of "partnering" between
commissioners and providers. This has resulted in jointly funded
posts working across Housing Options, SP, Children's Services,
Learning Disabilities and Probation.
3.5 This has improved access to services
and drawn together statutory and voluntary agencies to work better
for individuals both in social and private housing.
3.6 In respect of the removal of the ring
fence and this theme, providers have consistently flagged their
concerns that housing support resources are at risk if the ring
fence is removed. However, this conflicts with the Transforming
Social Care and Personalisation agenda for FACs cases. If the
SP market is destabilised this could impact severely on many vulnerable
people and may lead some landlords and providers to leave the
market putting pressure on social care budgets to deal with more
crisis cases.
Delivering in the new local government landscape
3.7 NS SP governance groups have responded
positively and energetically to the national and local challenges.
The primary care trust has increased its presence and influence
towards better health outcomes for the socially excluded and is
actively working on all Department of health (DoH) strategies
and requirements linking them to the LSP. NS has successfully
agreed a strategy for older persons and older persons housing
& support, and good joint working arrangements have facilitated
its implementation. NS's housing support governance groups have
been willing to adopt a strategic approach towards improving the
alignment of resource to the jointly mapped needs of its communities.
3.8 In this theme, NS can evidence significant
progress in the Personalisation agenda, particularly for older
people and those with learning disabilities. In addition progress
has been made on joint service commissioning teams and brokerage.
3.9 In respect of the removal of the ring
fence and this theme, the effect has yet to stimulate the market.
Many providers recognise that removal of the ring fence presents
opportunities for them to redesign services in ways that improve
the impact they have upon the statutory duties of partners. It
is possible that the increased interdependencies between commissioners
that removal of the ring fence involves, will lead to closer working,
and better scrutiny of plans in advance of commissioning services.
However, there is, as above, issues over commissioning for FACs
as opposed to vulnerable SP service users that can have open access.
Increasing efficiency and reducing bureaucracy
3.10 NS's SP Commissioning Body has supported
the development of joint contracts for people that have mental
health and learning disability care needs as well as housing support.
NS has made use of the CLG "Research into the financial benefits
of the Supporting People programme" to promote understanding
and confidence in the programme's investments. The availability
of CLG's revised tool for identifying local financial benefits
even more accurately is eagerly awaited, and no time will be lost
in applying it to joint commissioning ventures of the future.
3.11 In this theme, NS can evidence an ongoing
challenge with reducing the bureaucracy and cost to providers
of performance monitoring. The number of contracts and services
has been reduced and work is underway to simplify and streamline
processes used in performance monitoring.
3.12 In this theme, NS can evidence good
progress with taking forward the objectives set out in the Supporting
People Value Improvement Programme, and having used new technology
and business processes to improve efficiency. NS have been able
to introduce a weekly SP vacancy system with each provider and
referral agent advised. This has cut down wasted contact time
where agencies were being contacted without knowledge of vacancies
and improved customer access to those vacancies that exist. This
is currently being enhanced with a web based IT portal for public
interrogation and a needs and vacancy matching system. NS has
also been able to work with three other authorities to jointly
commission and tender a Dementia support service, thereby saving
staff and tender costs.
3.13 In respect of the removal of the ring
fence and this theme, it does appear that the ending of specific
grant conditions might support greater efficiency and reduced
bureaucracy with regards to reporting arrangements. However, removal
of standardised conditions also brings the potential for a growth
in different types of reporting arrangements which could ultimately
result in a greater level of bureaucracy than experienced under
the ring fence. NS's strong governance arrangements will be used
to ensure that partners continue to seek consistent reporting
criteria, and do not develop multiple requirements for a single
provider. Regional working arrangements will be used to try and
seek wider consistency where agreement can be found. Other efficiencies
resulting from removal of the ring fence are likely to be found
as the new flexibilities become used to personalise services through
use of direct payments and individual budgets. Development of
single assessments and single care/support plans is a much more
straightforward affair where the different elements of a person's
package do not have to be fitted to strict external criteria.
Packages, particularly for FACs cases can be better tailored to
the specific outcomes needed by the individual, and as such be
less costly for commissioners. However, this has to be put into
perspective, if SP contracting declines it will lessen tendering,
contract management and SP administration costs but would be replaced
with the administrative costs of managing the system underpinning
personalisation. It would also leave the authority with little
ability to impact on serious areas of concern by directing a provider
to meet need for the most vulnerable. The unintended impacts for
the most disadvantaged and homeless would be serious and cause
additional crisis costs.
4. CONCLUSION
4.1 NS accepts that removal of the ring
fence brings a number of potential advantages for service users,
providers and commissioners. However, some risks are also evident.
In order to mitigate these risks, NS proposes the following steps
are taken to ensure that the successes of the Programme are not
lost, or services cut, following the change. If these can not
be achieved it is thought that the ring fence should remain, at
least for a majority of services and client groups.
4.2 Authorities are required to involve
local communities in decisions about the future of housing &
support. This would require the CLG/DoH to instruct local authorities
to include and consult on housing and support needs (including
cross border issues) in the Local Joint Strategic Needs Analysis
(JSNA) and that these are reflected in the Sustainable Community
Strategy and a new Housing and Support Strategy annually updated.
Failure to meet targets tied to Public sector Agreements (PSA's)
should result in sanctions through the Comprehensive Area Assessment
(CAA) process.
4.3 Authorities are required to maintain
an effective housing support resource, which is discretely identifiable
within their JSNA, Strategies and Local Area Agreement. This should
involve annual self assessment by use of a national diagnostic
tool used in scoring by the CLG and Audit Commission. This
requires authorities to continue to collect local and national
indicator outputs and outcomes, supported by CLG commitment on
their data systems. Plus regular performance reporting through
corporate systems and sector strategy groups such as the Learning
Disabilities Partnership Board and Community Safety Drug and Treatment
commission group. Failure to meet targets tied to PSA's should
result in sanctions through the CAA process.
4.4 Authorities have clear local governance
for decision making through the Local Strategic Partnership for
housing and support strategies and outcomes for the local population.
This would require the CLG to instruct authorities to include
a Housing and Support Group as a sub group (or similar) within
the Local Strategic Partnership to replace the existing successful
SP Commissioning Bodies. Failure to meet this target should result
in sanctions through the CAA process.
4.5 That the Audit Commission Comprehensive
Annual Assessments include standards and expectations for preventative
commissioning to be part of an authority's evidence of their quality
and excellence, evidenced by continued use of Key Lines of Enquiry
or similar diagnostic tool shared with the CLG. Authorities
will need to be benchmarked and judged within relevant peer groups
and should be instructed by the CLG to use a national assessment
tool. This would indicate year on year performance and show if
and how SP commissioning/de-commissioning decisions impact on
meeting needs and performance and outcomes for service users.
Failure to meet targets tied to PSA's should result in sanctions
through the CAA process.
4.6 Many of the decisions about SP in the
past have been based on historical data and small scale pilots.
The CLG has had a level of control through grant conditions to
influence and meet wider Government targets, now in the PSA's
and national indicators. Appendix One shows the links. Removal
of the ring fence assumes that authorities will continue to do
this despite the uneven playing field of SP and local government
funding. De-ring fencing is a risk; in local terms, authorities
undertake a risk assessment when taking commissioning decisions.
This appears not to have been done, or if it has been done has
not been revealed for this proposed decision. It is essential
that if this decision is taken the consequences are fully understood
both at the centre and locally through formal risk-assessment.
May 2009
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