Memorandum from St Mungo's (SPP 51)
ABOUT ST
MUNGO'S
We are London's largest homelessness agency.
We provide over 100 accommodation and support services day
in and day out.
We run emergency services—including street
outreach and emergency shelter. We support homeless people in
their recovery—opening the door to safe housing, health
care and work. We help more homeless people into lasting new homes,
training and employment than any other charity.
We also prevent homelessness through our complex
needs housing and support teams for people at real risk.
By opening our doors, and our support services,
we enable 1,000s of homeless and vulnerable people to change their
lives for good every year.
INTRODUCTION
St Mungo's appreciates the opportunity to contribute
our experience and perspective to the inquiry into the Government's
"Supporting People" programme and we are very pleased
to make this written submission. Should it be helpful we would
be happy to discuss our points further.
We will comment both on our experiences to date
and the hopes and anxieties we have as the Supporting People (SP)
ring-fence is removed.
SUMMARY OF
KEY POINTS
1. There is a danger that too strong a focus
on local delivery and leadership can bypass the needs of vulnerable
groups, like rough sleepers. They are a minority group representing
an expression of intense deprivation, geographically dispersed
and by definition not tied to a locality. Their needs are best
met, and costs for this shouldered, at a regional level.
2. Government must reaffirm the importance
and role of "partnership" to set the tone for relations
between the statutory and voluntary sector.
3. There is a lack of a shared mission across
local authority boundaries which could be reaffirmed by a greater
emphasis on national standards.
4. Bureaucracy and inefficiency are still
major obstacles to realising the full potential of the Supporting
People programme. Excessive regulation, duplication of services
and associated bureaucracy and inconsistent local authority procurement
practices can stymie the delivery of services.
5. It is too early to know the full implications
of the removal of the ring-fence, but there is a fear that local
political priorities which drive area-based grants will tend towards
prioritising mainstream services over specialist interventions
focused on a minority "problem" population.
6. The removal of the ring-fence could provide
an opportunity to reconceptualise how SP can design and deliver
effective responses. Currently, there is an explicit service user
focus on housing related support, which implies helping those
groups who are in contact with services and are settled. Rough
sleepers by definition are service avoiders and unsettled and
we need to be more sophisticated about how to engage them.
7. "Housing-related support" has
been taken too narrowly to apply to housing management, rather
than more broadly also offering health and vocational support,
which are necessary to truly promote "independent living".
PCTs and DWP/DIUS should be required to address the needs of all
supported housing tenants.
ST MUNGO'S
RESPONSE
I. The extent to which the Government has,
so far, delivered on the commitments it made in Independence and
Opportunity: Our Strategy for Supporting People.
1. Keeping service users at the heart of the
programme and of the local delivery of the service.
1.1 The Supporting People (SP) Programme,
and the Quality Assessment Framework which underpins it, has been
to an extent successful in sharpening delivery and focusing it
on outcomes. It has resulted in some bad services being remodelled
or decommissioned, and it has helped focus more attention on the
promotion of independence.
Implications of localism
1.2 Localising delivery has had some unintended
consequences. In London, specialist services that had a cross-borough
remit before SP increasingly admit only people who have a local
connection rather than allowing access on a purely needs basis.
This has dismembered some such essential services or necessitated
wasteful duplication of the same services in different boroughs,
where one that could be accessed from different boroughs would
suffice.
1.3 Central Government has appeared unwilling
or unable to take a lead on creating regional mechanisms that
would ensure all needs in London are met in London, and broaden
access to specialist services for those who would benefit the
most. St Mungo's would advocate a clearer strategy for linking
provision, which some councils, in London at least, do rather
well at a local level—the key question is whether there
is a will to do this on a regional level.
1.4 The benefits of central commissioning
should not be overlooked—the Government commissioned the
Rough Sleeping Initiatives and the Homeless Mentally Ill Initiative,
which had a strong service user orientation and strategic framework
for local delivery. It is important to note that being service
user orientated is different to being orientated on needs on the
streets—arguably, rough sleepers are not users of services
to begin with. When considering local commissioning, councils
are reasonably good at taking account of service users' needs,
but poor at taking any responsibility for those who either refuse
or avoid services, or are barred by them.
The drive to lower costs
1.5 As the years have gone by under SP,
cost cutting has been the increasingly central focus. Service
providers are increasingly tending to win contracts by being the
cheapest bidder, and there should be a concern in the long run
that this drive towards commissioning by narrow efficiency may
increasingly undermine the quality of services and communities.
It results in endless churn, with broadly the same providers losing
or gaining some contracts to each other—a costly exercise
to providers, which has spawned a costly bureaucracy to supervise.
1.6 To minimise costs, increasingly floating
support is preferred to accommodation-based services, which has
implications for client choice. A significant minority of vulnerable
people choose to live with other people, as most of us do, and
for more than an arbitrary two-year period; for ideological and
financial reasons such choices are not respected under the SP
regime, and that is a great shame, which undermines a truly user-focussed
approach.
First principles of Supporting People and "housing
related support"
1.7 A key "promise" of SP was
that it would (a) map services; (b) project need; and (c) commission
accordingly. With some honourable exceptions eg Camden's Hostel
Pathway model, mapping has been rudimentary, and projecting virtually
non-existent. Despite the narrowness of their evidence base, many
local commissioners convey great certainty; to the extent that
provider knowledge or user group say are actually diminished.
1.8 Indeed, St Mungo's believes that there
has been confusion from the outset about the definition of the
Supporting People Programme providing "housing related support".
This is defined as "support which is provided for any person
for the purpose of developing that person's capacity to live independently
in accommodation or sustaining his capacity to do so" (Supporting
People, Directions and Grant Conditions, ODPM, 2004). Theoretically
therefore, housing related support was constructed to provide
support in areas like health and work as well as housing.
1.9 However, there isn't enough funding
to meet these broad aspirations, and thus SP spend has generally
been limited to the housing element. Many local authorities have
adopted a narrow reading of housing related support and confined
resource allocation and service commissioning to the management
of housing.
1.10 Housing supply, management and choice
cover only one aspect of support that can promote independence.
To be effective, support has to be multidimensional. The role
of health and vocational support should be recognised as contributing
to an individual's ability to participate fully in the social
and economic life of their communities. These types of support
are currently addressed through other funding streams that don't
explicitly promote independent living. This lack of agreed clarity
and consistency over the scope of the remit of SP is the source
of much frustration on the part of care providers, and baffling
to service users. To meet the needs of vulnerable people targeted
by the SP programme more effectively, PCTs and DWP/DIUS should
be required to address the needs of all supported housing tenants.
2. ENHANCING
PARTNERSHIP WITH
THE THIRD
SECTOR
Rationalisation of the provider base
2.1 SP has rationalised the number of providers.
This cleaning up of the provision maze has been in some respects
helpful for service users, who under pre-SP arrangements faced
navigating a bewildering array of services that were poorly coordinated,
and for commissioners.
2.2 There have been some positive adaptations
to this underlying dynamic. For example, St Mungo's has shared
its training resources with community based groups and otherwise
built their capacity, and we are committed to using them as delivery
partners when commissioning allows that. Many, mainly smaller,
organisations have, however, gone to the wall, some usefully so,
others that had a valuable contribution to make but couldn't handle
the bureaucracy of SP.
The need to reaffirm importance of partnership
2.3 The reality under narrow localism is
that administering authorities have increasingly sought to exercise
control over who "independent" third sector organisations
work with and how they work to an insidious level. St Mungo's
has seen an exponential increase in the number of referrals we
are expected to take directly from administering authorities and
their micro interventions in the detail of our work, to the extent
that we sometimes feel as if our expertise, built up over 40 years,
and charitable objects as a Third Sector provider are denigrated.
2.4 St Mungo's believes the value of true
partnership between the statutory and voluntary sector needs to
be more explicitly recognised and underpin interactions. Government
should reiterate the importance, and definition of partnership,
as referred to in the Compact, as based on trust and mutual respect.
Too often authorities see "partners" as supine subcontractors,
and impose their role aggressively and without imagination. This
is contrary to the vision and aims of the Compact, which we would
like to see more explicitly setting the tone for relations between
the statutory and voluntary sector.
3. DELIVERING
IN THE
NEW LOCAL
GOVERNMENT LANDSCAPE
Local priorities vs. national standards
3.1 In London, St Mungo's core client group
is transient and not geographically located by definition, and
this lack of overall shared mission across administering authority
boundaries has an implication for how quickly homeless people
can be moved through the support system from being on the streets
into independence. For some people under SP it's become too much
about borough lottery and not enough about meeting their needs.
3.2 The new local government landscape has
the appearance of being more accountable but little of the substance.
Government funk is legitimising local fiefdoms. Central Government
seems unwilling or unable to call administering authorities to
proper account. They are at best notionally accountable locally,
but not to any central authority.
3.3 There is a need to distinguish between
a "line of command" accountability and an accountability
which means that people can be questioned or decisions appealed
against. In essence, too much has been ceded to politicians—a
greater emphasis needs to be placed on national standards. This
would enable the needs of the minority vulnerable people to be
more reliably met within the community setting, the latter being
shaped primarily by local political priorities.
4. INCREASING
EFFICIENCY AND
REDUCING BUREAUCRACY
4.1 There have been some real gains—every
provider has had to "up their game" and some delivery
developments have been both innovative and efficient. It is unlikely
that they would have been achieved at the same pace without the
imperative of SP.
The need for more of a "light touch"
4.2 However, promised lighter touch arrangements
under mature SP have never materialised; the freedoms and flexibilities
that administering authorities get for being "excellent"
are not afforded to providers, even excellent ones, and this is
an area that we would strongly encourage your forward focus on.
There should be a system of provider reward eg if you get straight
A quality assessments as a number of our services have been doing,
that should be rewarded—by less interference at least.
4.3 Monitoring requirements are still too
complicated and this is a particular burden on smaller organizations.
Significant capacity is required on behalf of the provider to
meet these. There has been a serious balance in the extent to
which administering authorities and providers have been resourced
to handle the bureaucracy of SP; the provider experience has been
of increased cribbing about overhead costs despite an escalation
in monitoring and reporting expectations.
4.4 Central government has recognised the
extra costs associated with the extra admin involved in delivering
effective partnership and has subsidised accordingly with £138 million
of financial support to local government. Yet there has been no
correlating support for the third sector. £500k for capacity
building is paltry and does not reflect the extra costs taken
on by the third sector in dealing with the extra bureaucracy involved
in creating partnerships and competitive tendering.
The persistence of duplication
4.5 Due to borough boundary issues, services
that could be shared are duplicated. Duplication persists throughout
the system, and is a real obstacle to efficiency. It occurs not
just in the case of services that are commissioned in parallel
by different boroughs, but also the accompanying bureaucracy.
There is no reason why every local authority should have a commissioning
body—reducing the number of these would make for more efficient
use of resources and would concentrate expertise.
The inefficiency of procurement practices
4.6 The Third Sector Review Final Report
(Cabinet Office, 2008) produced scathing results about local authority
procurement practices, and revealed the depths of dissatisfaction
on behalf of the voluntary sector about the competency and consistency
of local authority procurement practices.
4.7 The crushing burden of tendering and
the extent to which it takes away providers' focus from delivery
should not be in any sense under-estimated. Seemingly under pressure
from Central Government to more regularly test the market, all
administering authorities, to a greater or lesser extent, transfer
that pressure directly to providers. Tendering takes up huge and
seemingly escalating amounts of time and services suffer in consequence,
as they can be prone to changing hands between providers every
three years.
4.8 Particularly as TUPE applies when services
are re-tendered, staffing gets disrupted and can often lead to
unplanned expenses which fall to the provider. This is an example
of a genuine case in which a provider was left with unplanned
staffing costs as a result of the disruption caused by losing
a contract three years after winning it.
4.9 Provider A wins a local authority contract
and staff who are in the LA pension scheme are TUPE'd over it.
These are the only staff from that LA that they have on their
payroll. Three years on the contract is tendered again and Provider
A loses it. Staff are all TUPE'd to the new Provider B: now Provider
A has no staff in the LA pension scheme on its payroll. Because
of this there is a cessation and any under-funding of the scheme
crystallises.
4.10 Provider A receives a bill for £200k
from the people who run the LA scheme. Although they still have
staff who TUPE'd across from other councils they don't count because
each Local Authoritie's membership is seen as a separate scheme
within the main scheme. Needless to say Provider A didn't build
this £200k into their tender for the original contract and
are left with a rather large deficit on their dealings with this
local authority.
The need for more consistency
4.11 There are systematic inefficiencies
within the system which allow multiple different approaches to
the same issue. From the point of view of the provider this can
often seem counter-productive: it is quite common for different
boroughs to give Cs and As for the same practice.
4.12 Therefore St Mungo's has concerns over
the lack of national consistency across the SP programme, which
is hard to achieve without an agreed standard of good practice
to guide priorities locally. By devolving so much to local authority
level, central government has actually made it more difficult
for local authorities to discharge their responsibilities. A more
effective system would have a regional remit and employ fewer
people, concentrating expertise and setting a high standard of
practice. There should be a London-wide system at least for monitoring
quality.
II. The implications of the removal of the
ring-fence, what needs to be done to ensure that the successes
of the programme so far are not lost, or services cut, following
the change; and what opportunities this change in the funding
mechanism will offer for innovation and improvement in the delivery
of housing-related support services.
5.1 We hold the hope that housing, health
and work priorities, which inextricably intermesh in practice,
will be picked up more efficiently and creatively through new
Area Based Grant arrangements, with agencies like Jobcentre Plus
and the Learning and Skills Council playing a more active and
integral role.
Early indications show need for further scrutiny
of developments
5.2 We don't yet know how all boroughs will
respond to the removal of the ring fence. Our initial experience
across a number has not been immediately adverse, but it is fair
to assume that different boroughs will respond in different ways.
Some are already stripping out Adult Social Care costs eg, in
respect of Sheltered Housing Schemes and transferring those cost
burdens to SP services. There needs to be clear scrutiny maintained
as the situation develops and a particular focus on whether "unpopular"
groups are systematically disadvantaged.
Fears over financial implications
5.3 It is too early to judge the financial
impact, but as area-based grants are driven by local political
priorities and therefore must surely prioritise mainstream services
and those accessed by broad sections of the community, for example
families. It is not clear where support for vulnerable single
adults, for example high support mental health projects, fit within
an agenda that is determined locally and potentially prone to
nimbyism.
5.4 Therefore there is a real concern that
with local authorities considering their actions in the climate
of local elections, their priority for funding will inevitably
be the majority mainstream services over interventions focused
on a minority problem population. It's our early view that some
authorities appear to be choosing National Indicators that they
feel they can meet or ones that have political added value rather
than genuinely innovative or needs-based ones.
5.5 There has already been leakage from
homelessness of all the grants that went into SP originally, and
we must prepare for a similar trend as a result of the removal
of the ring-fence. Preventative services are perhaps also more
vulnerable to cuts as it is easier to remove these services without
instant knock-on effects.
5.6 There are some potential positives.
For example in some authorities under SP there was a requirement
to find a 5% year on year reduction in spending. These strict
limits may be relaxed as budgets are pooled, and there is the
hope that a progressive authority could spend more on homelessness
services, for example, if it chose to.
The opportunity of the removal of the ring-fence:
re-conceptualising the support that is offered to vulnerable adults
5.7 St Mungo's would like to make the case
that the removal of the ring-fence provides an important opportunity
to re-conceptualise the support offered to vulnerable adults to
live independently, and clarify where the responsibility for funding
and provision of this should rest. This is a potential opportunity
to take the SP programme back to "first principles"
and address the broader reading of the definition of "housing
related support" alluded to in the first section, which seeks
measures beyond housing management to promote independent living.
5.8 SP funds support that exists up to the
boundary of care and sometimes over. The dividing line between
SP, Adult Social Care (ASC) and health boundaries and funding
streams is often blurred and porous. PCT and ASC funding often
goes into the pot, but is secondary to the SP contribution.
5.9 The prospect of reductions in SP allocations
should not lead to cuts in services for those who are dependent
on them and which are making genuine changes in peoples' lives.
The de-ringfencing could provide an opportunity for ASC and PCT
funding streams pulling more weight in terms of funding services
that support vulnerable adults to live independently. Therefore
the prospect of cuts should be deemed a separate issue to the
prospect of re-balancing how services are funded. For this to
be realised, clear cross-departmental objectives must be set nationally,
and achieved locally.
5.10 St Mungo's believes that the SP programme
is better conceived as resources to support what is best for society
rather than specific geographic communities and localities. Street
homelessness is an expression of dispersed pockets of deprivation
and intense need, which are significant within the context of
a city the size of London, but not in most localities. St Mungo's
client group often don't feature on the radar for resource allocation
and needs assessments by local authorities and PCTs, which are
carried out on a borough or ward level. Street homelessness is
therefore better conceived of as a regional issue, and responses
devised and funded at this level would be more appropriate.
5.11 Hostels provide the most effective
strategic opportunity to deliver the range of interventions and
support that homeless individuals need—across housing, health
and vocational policy areas. Yet the dispersed nature of London's
homeless population and the tendency to gravitate centrally means
that some local authorities, namely Camden and Westminster, carry
the burden for providing a response that doesn't relate to their
locality. For example, Westminster have stated that only 8% of
rough sleepers in their borough originate from there., but using
origination as the legitimising trigger for accessing services
is old-fashioned. If this is the thinking that is informing Local
Authority responses to what support they should prioritise, it
is clear we need to reconceptualise where support should come
from. Indeed, it is an accident of history and geography that
there is a concentration of homeless provision in these boroughs.
Whilst responsibility for supporting transient and unsettled homeless
men and women should be directed at a regional level, the response
should be conceived of as emergency provision, and the resources
shared city-wide.
5.12 In this context, SP can be considered
the right funding pot for people who are living in settled accommodation,
but for those who are unsettled a separate regional funding stream
would more efficiently allocate resources based on and directed
at an effective mapping of need. This regional strategy would
need to ensure that the views not just of service users, but also
service avoiders like rough sleepers, are taken into account.
Hostels to an extent distort the commissioning market—as
well as being an easy target for when savings are required, they
deflect commissioners' attention from how more mainstream services
should hang together. A regional strategy would be based explicitly
on the needs of vulnerable Londoners, and the services London
must provide to meet these—covering housing, health, vocational
support.
May 2009
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