Memorandum from Home Group Limited (SPP
54)
1. INTRODUCTION
Supporting People has driven up professionalism,
quality and client involvement and has made costs more transparent.
We ask the committee to consider how the CLG
will ensure that once responsibility for Supporting People is
fully devolved, essential high quality services to vulnerable
people will continue to be provided, further developed and maintain
a strong focus on client choice and involvement. We hope that
the comments in this paper assist members in doing so.
If members of the committee wish to speak with
clients and to visit supported housing services then Home would
be pleased to facilitate this.
2. CLIENT INVOLVEMENT
Key issues in involvement are choice, accountability
and transparency. Much of the responsibility for involving clients
lies with providers. There are too few examples of local authority
commissioners really taking clients' views into account.
We would like to see CLG take a visible role
both in setting standards and in itself modelling excellence in
client involvement.
3. PERSONALISATION
AND JOINT
FUNDING
Most Supporting People services offer a personalised
client-centred service. Where different quality and monitoring
frameworks are brought together there should be a "levelling
up" of standards not "levelling down".
We believe that individual budgets have an important
place particularly for clients receiving long term support from
several funding sources, but that this is not the only way to
ensure that clients have real choice and control.
We would like to see recognition that commissioned
services offered in a personalised way are an appropriate choice
for many clients.
4. COSTS, EFFICIENCIES
AND CO-ORDINATION
Although transferring bureaucratic burden or
contractual risk to providers may offer savings in the short term,
it does not necessarily lead to the best long term results in
value or quality of service, or the best outcomes for clients.
Home works with over 100 local authorities
and sees the inefficiencies caused by the variation of practice
and duplication of work across the country, and the aggregate
cost of this to the public purse.
We would like to see government provide clear
advice on commissioning to local authorities with an expectation
of changed behaviour as a result.
We ask the committee to consider recommending
common frameworks for key tasks to share best practice and reduce
duplication to free local authorities from the need to develop
their own systems and deliver better, more responsive services
and local accountability, financial savings and greater efficiency.
We would like to see CLG, the Office of the
Third Sector and other government departments make the provision
of housing related support by providers in partnership with local
authorities and local strategic partnerships an exemplar programme
of partnership working.
HOME GROUP
LIMITED
1.1 This is a submission from Home Group
Limited, which includes Stonham (its care and support division)
and Home Prime (its older people's services). Home is the largest
and most geographically spread provider of Supporting People services
in England.
1.2 Home provides supported housing services
to over 15,000 clients every year. We work in cities, towns
and rural areas from Cornwall to Kent to Cumbria offering residential,
tenancy support, advice and gateway services. Home holds around
500 Supporting People contracts worth a total of £57 million
with over 100 local authorities. A further 60 partner
organisations work with us as managing agents providing a further
300 services.
1.3 We work with a wide range of client
groups and provide many generic services. We particularly focus
on:
— Families (including young parents and
domestic abuse).
— Offenders and Ex-Offenders.
— People with Mental Health Issues.
— People with Learning Difficulties.
1.4 Home has three elements to its purpose:
— We exist to provide affordable housing
to our customers—tenants, leaseholders and other residents.
— We exist to provide support to individuals—our
clients.
— We exist to secure sustainable neighbourhoods
for all our customers and clients.
Our customers and clients are at the centre
of all that we do.
1.5 Our support enables homeless and vulnerable
people to sustain what is often their first tenancy and to meet
their goals and aspirations so they can move forward in their
lives. For many of our clients the support we provide enables
them to increase and develop independence over time. As Stonham
we provide services that work effectively to that aim. We also
have clients who require longer term support to maintain a level
of independence. Both Stonham and Home Prime offer services that
successfully meet this need.
1.6 Committee members may also recognise
Home as a provider of general needs social and affordable housing
for rent, shared ownership and purchase. As LiveSmart@Home we
offer mid-market housing, as Nashayman Housing we provide specialist
BME housing services and wider consultancy services, and as Copeland
Homes we manage former local authority housing in West Cumbria.
In the south of England we were previously known as Warden.
1.7 Home Group Limited is a Registered Social
Landlord and a Charity registered under the Industrial & Provident
Societies Act.
2. GENERAL COMMENTS
2.1 Supporting People provided a new framework
which better enabled the strategic planning of services to meet
local needs, and improved the accountability and monitoring of
performance and quality. By making the costs, inputs, outputs
and outcomes of services more visible, it has enabled their value—both
financial and non-financial—to be better understood.
2.2 Home believes that two of the greatest
successes which providers, commissioners and CLG have achieved
in the last six years have been a significant improvement in the
overall quality of services, and a much greater focus on clients—on
their rights to make informed choices on their individual support
needs, and to be involved in shaping future development of services.
2.3 The last six years have also demonstrated
through research and through the personal experience of our clients
that supporting clients to gain and maintain independence reduces
the need for more costly emergency and acute services and provides
a secure foundation for other interventions. Supporting People
has been described as the "glue" which holds other services
in place. This is a message which the sector needs to ensure is
widely understood as the ring fence is removed to ensure that
the investment in supporting people services continues.
2.4 The committee indicated that the Inquiry
would focus on CLGs Strategy Independence and Opportunity:
Our Strategy for Supporting People. Our comments below are
therefore structured around the four key themes in that document.
3. KEEPING PEOPLE
THAT NEED
SERVICES AT
THE HEART
OF THE
PROGRAMME
3.1 In Independence and Opportunity,
CLG undertook that it would be "Keeping people that need
services at the heart of the programme".
Client Involvement
3.2 Home believes that the key issues for
our clients in involvement are choice, accountability and transparency.
We recognise that much of the responsibility for involving clients
lies with the providers that have the direct relationship with
clients and people looking for services. In Home we have worked
hard with our clients to meet this—we've introduced a new
support planning and recording framework—My Way Forward—we
offer our clients a menu of opportunities to become involved with
their own services and to influence the management and governance
of Stonham and Home up to Board level. We have three clients taking
an active role on the Board of Stonham.
3.3 We see a more varied picture in local
authorities. Some actively engage with clients. Others are not
so active—for example we have seen situations where providers
are left to explain to clients why a different organisation is
taking over their support service. We'd like to see CLG take a
visible proactive role both setting standards and itself modelling
excellence in client involvement in its own consultation and decision
making. We have offered our assistance in this to CLG—both
in sharing our experience, and in facilitating contact with our
clients.
3.4 Members of the committee may want to
take opportunities to speak with clients, and to visit supported
housing services. Home would be pleased to facilitate meetings
with individual clients or groups of clients. We have services
in or near to several members' constituencies and around London
to which we can arrange visits. The clients who are members of
our Board would be willing to offer the committee their unique
perspective.
Personalisation
3.5 The refreshed Quality Assessment Framework
(QAF) has set high standards in client involvement. There is more
to do, and one challenge is the need to ensure that greater freedoms
for local authorities and more use of joint funding enable further
progress. In particular where different quality and monitoring
frameworks are brought together there should be a "levelling
up" of standards, not "levelling down".
3.6 Individual budgets have an important
place for some clients, particularly those receiving long term
support from a variety of funding sources. We are working with
partners to pilot different models, including a key involvement
working with the Housing Association Charitable Trust.
3.7 However Home does not believe that individual
purchasing of support is always the most effective way to ensure
that clients have real choice and control. Commissioned services
are more appropriate to many clients who would chose them because
they don't (or don't yet) want to exercise a greater degree of
choice and responsibility. Individual budget systems which give
control of actual or virtual money to clients are not appropriate
to those with chaotic or addictive lifestyles.
3.8 The opportunity to open up choices will
be what many clients want. But CLG and the other government departments
involved should ensure that guidance to local authorities and
other commissioners stresses the need to involve clients in decisions
about and the design of future services. No assumptions or decisions
should be made without directly asking clients and potential clients.
Ensuring a real market
3.9 Choice can only exist where a number
of providers operate within a given area. Guidance to local authorities
and assessment of their performance should take account of the
need to ensure a healthy, diverse and vibrant market which affords
clients real choice, otherwise we offer clients only the illusion
of choice. Within the current climate there is a real risk that
choice and control may be used as mechanisms for rationing resources
and devolving risk to vulnerable individuals without ensuring
that adequate safeguards are in place.
Needs Analysis
3.10 Another important aspect of this topic
is consideration of what needs and expectations of current or
past clients are not being met and which people who need housing
related support services are not receiving them. The level and
quality of needs analysis and the transparency with which it is
undertaken is variable. As we state in considering the new Local
Government landscape below, CLG and the Audit Commission have
key roles in ensuring that the needs of vulnerable people are
addressed in every locality.
4. ENHANCING
PARTNERSHIP WITH
THE THIRD
SECTOR
4.1 CLG also set out in Independence
and Opportunity how it would be enhancing partnership with
the Third Sector. Supporting People (SP) has been one of the government's
most significant funding streams to the third sector. As we detail
elsewhere it has driven up professionalism, quality of service,
client involvement and made costs of services more transparent.
However it has not provided the stability promised prior to the
introduction of SP, and there has not been the step change we
had hoped for on reading Independence and Opportunity.
Compact
4.2 We often remind local authorities of
the commitments they have made in local Compacts to support the
voluntary and community sector. It is not unusual to find that
a local authority's SP team believes that Compact is optional
or is not relevant to SP. Short term constraints appear to prevent
authorities meeting the expectations CLG set out in Independence
and Opportunity.
Enabling Innovation
4.3 Members will be aware from their own
knowledge, from their own constituencies and from other submissions
to this inquiry of the wide range of work undertaken by third
sector organisations. The sector has great experience and expertise,
and our portfolio includes many unique and innovative services.
We would ask the committee to recognise the need to ensure that
third sector organisations maintain the independence and freedom
to develop new and innovative approaches to supporting vulnerable
people, without the constraints of over-specified and micro-managed
contracts.
4.4 Many of the points we make in the section
below on "Increasing Efficiency and Reducing Bureaucracy"
are relevant to this area. The bureaucratic burden on providers
is significant—whether considering the aggregate cost for
a large national provider such as Home or the smaller but sometimes
prohibitive costs for small providers.
Exemplar Programme and other suggested measures
4.5 Home would like to see CLG, the Office
of the Third Sector and other government departments work with
Third Sector organisations to make the delivery of housing related
support by providers in partnership with local authorities and
local strategic partnerships an exemplar programme of partnership
working—developing approaches that could be used in other
public service provision.
4.6 We would also suggest members consider
the following:
— Home believes that as a number of local
authorities have not heeded advice from CLG, there is a need for
some clear statutory guidance on full cost recovery, contract
length, disproportionate and duplicated monitoring and other issues
we detail in the later section "Increasing Efficiency and
Reducing Bureaucracy". There is the opportunity this year
to develop this alongside changes to the Compact.
— We understand that government's approach
is to reduce central direction and control of local authorities,
and to minimise their administrative burden. However this must
not lead to increased cost and burden on providers. We would suggest
that local authorities should not be permitted to claim a saving
in administration if that work is still paid for from the public
purse but is carried out by another party.
— Local authorities tell us that they receive
contradictory advice on balancing support for the Third Sector
with commissioning that is open and fair to competitors from all
sectors. We believe that government should make a clear cross-departmental
statement on this, addressed to local authorities legal and procurement
departments as well as supporting people managers, with an expectation
of changed behaviour as a result.
5. DELIVERING
IN THE
NEW LOCAL
GOVERNMENT LANDSCAPE
5.1 Since Independence and Opportunity
was published, the changes outlined have progressed, including
the "transition period" following the end of the ring
fence, the increasing role of LSPs and LAAs, the move to personalisation
of services, further integration with health, social care, employment
and training services. There has been a tight local government
settlement for the current CSR period, with an expectation in
the recent budget that from 2011 there will be a reduction
in public spending. There are additional pressures, costs and
needs brought by the current economic conditions.
Including provider and client perspectives
5.2 Improvement programmes within Supporting
People have until recently concentrated on the local authority's
perspective. Work from the Office of Government Commerce (OGC),
Regional Improvement and Efficiency Partnerships (RIEPs) and the
Improvement and Development Agency (IDeA) has focussed on the
commissioners' needs. The "Lifting the Burdens Task Force"
looked only at the central-local government relationship. Over
the forthcoming period improvement programmes need to take account
of the provider's perspective, and most importantly the client.
Transferring bureaucratic burden or contractual risk to the provider
may offer savings in the short term, but it does not necessarily
lead to the best long term results in value, or quality of service,
nor the best outcomes for clients. Models of individual budgets
which shift administration of support to clients or their carers
regardless of their choice or their capacity to manage may be
similarly difficult to sustain.
5.3 There has been movement toward more
inclusivity over the last two years—contrast some of the
earlier Value Improvement Projects with the recent development
of the refreshed Quality Assessment Framework (QAF). The latter
was led by provider organisations, had involvement from across
the sector and has been a more open process resulting in a much
better product and wider ownership of it across the sector.
Output measures and Public Service Agreement 16
5.4 There has been a welcome shift of emphasis
from measuring input and process to examining outcomes for individual
clients and for the wider community. The new local government
framework, for example in NI141/142 and PSA16 should
be driving this change further. It requires a strong partnership
approach. In some authorities this is becoming well established
but we are disappointed at slower progress in others.
5.5 Home is concerned that the choice of
some authorities not to select either NI 141 or 142 for
stretch targets, their low engagement with PSA16, and new freedoms
including the end of the ring fence puts housing-related support
services at risk.
Proposal for common frameworks for key tasks and
processes
5.6 Home suggests that the immediate future
requires both an inclusive cross-sector approach and more direction
from CLG. We would ask the committee to consider recommending
that CLG commissions the development of standard frameworks for
procurement and for needs assessment and a firming of the existing
arrangements for outcomes and other performance reporting.
5.7 As an organisation working across over
100 local authorities, Home is very conscious of the inefficiencies
caused by the variation of practice and duplication of work across
the country, and the aggregate cost of this to the public purse.
5.8 The use of common frameworks would free
local authorities from the need to develop their own systems and
enable them instead to concentrate their creativity on the needs
of their communities. It would thus strengthen local decision
making and accountability. Far from stifling innovation it would
improve capacity to develop local responses and then allow more
accurate benchmarking to assess comparative outcome.
5.9 For example, local identity should not
come from each authority developing a different system of needs
assessment but from what need is identified in its area, whether
it is met and by what means it is met. Nor does it come from a
different format of pre-qualification questionnaire, but from
identifying providers who can provide the services that local
people need.
5.10 Many elements of such frameworks already
exist, so this need not be an onerous task. It would involve bringing
together the best from existing guidance and good practice and
ensuring it was fit for the future. Key inputs would include for
example: Needs Analysis, Commissioning and Procurement for
Housing Related Support published by CLG last summer, the
work carried out on needs mapping in London and the North West,
and the present CLG/St Andrews client record and outcome systems.
The work could be achieved by a cross-sector working group similar
to that which produced the refreshed QAF. The change in emphasis
would be in the expectation that the frameworks would become the
standard or default used in the sector. CLG and the Audit Commission
would need to consider is how to ensure or incentivise their use
by local authorities and local strategic partnerships.
5.11 Some SP teams tell our staff that they
are prevented from following CLG guidance by the authority's own
legal or procurement advice. The framework suggested here would
ensure such advice was more carefully considered.
5.12 This would also offer an opportunity
to devise frameworks which link to the World Class Commissioning
programme in the NHS and fit with other areas (including housing,
social care, criminal justice, employment training) in order that
joint planning and joint commissioning are not frustrated by differences
in systems, and would offer the means for shared and co-ordinated
approaches to personalisation across sectors.
Risk of reactive budget reductions
5.13 Whatever approach is taken, the immediate
future is one in which housing related support needs to build
further on the work that has demonstrated its worth and value—in
lives transformed, in improving communities and by its preventative
nature in savings to the public purse. Where a medium term view
is taken, this should not be a difficult concept to justify in
spending decisions. Home's concern in the financial climate of
the future is that non-statutory services will be vulnerable to
short term reactive budget reductions. We will continue to make
our case. The CLG transitional package will provide some help
in this, and the national indicator set will track performance
and provide an incentive to continue services for vulnerable people.
Audit Commission Inspections and Comprehensive
Area Assessments
5.14 Among the drivers of improvement and
good practice over the last 6 years have been the Audit Commission's
SP inspections of local authorities. These have provided independent
assessments of performance, and have given a voice to the concerns
of clients and providers. At a time when light touch and desk
based assessments were the norm elsewhere, the Commission continued
detailed inspections and returned to fully re-inspect zero-starred
authorities—in some cases more than once.
5.15 These will not continue, but one of
the most important safeguards that will remain will be local authorities'
knowledge that the Audit Commission will focus on vulnerable people
in the Comprehensive Area Assessment. Home is pleased to see the
Audit Commission commit to issuing a Key Lines of Enquiry (KLOE)
document to set out its expectations and its view of excellence
in this area.
6. INCREASING
EFFICIENCY AND
REDUCING BUREAUCRACY
6.1 When Supporting People was first proposed
in 1998 one of the stated aims was to place housing support
on a secure legal and financial footing. Since 2003 the uncertainty
caused by cuts in SP funding to local authorities has been one
of the main themes. While some authorities will see small rises
during this CSR period, it is a fact that a significant real terms
cut has been made to SP funding over six years. Much of the financial
impact has been borne by providers who initially attempted to
absorb reductions but are no longer able to do so. The human impact
of service reductions and closures has been on vulnerable people
unable to obtain support, and on provider staff who have been
made redundant or transferred between employers several times
as short term contracts are won and lost. We know that the future
beyond 2010 is likely to see constraints on public expenditure.
Good Practice in Commissioning and Procurement
6.2 We consider that good commissioning
practice includes:
— involvement of clients from an early
stage;
— training and capacity building for providers;
— comprehensive needs assessment, ensuring
hard-to-reach and hard-to-measure groups are included;
— making use of providers' expertise and
knowledge in assessing need and designing solutions;
— considering and using alternatives to
competitive tender (particularly for small services);
— compliance with the local compact;
— an appreciation of the limits of capacity
of smaller providers;
— the space to innovate or add value;
— clarity about tender evaluation;
— sufficient TUPE information; and
— the encouragement of partnership working.
6.3 Service re-commissioning means disruption
and uncertainty to clients, and there are too few examples of
their involvement and their views really being taken into account
by commissioners when planning how to commission a service.
6.4 Where there is to be significant change—decommissioning
of services, provision in new service models—in some authorities
change management has been well planned and executed in partnership
with clients, providers and other stakeholders.
Poor Practice in Commissioning and Procurement
6.5 In others the process has not been so
positive. In one case a restructure of SP contracts for older
people's services resulted in the withdrawal of sheltered scheme
wardens, and instead an alarm-monitoring only service for most
clients. The changes were made without full regard to key issues
such as access, security, liability and health & safety for
the new providers; clients' tenancy agreements which in many cases
included terms related to the support provision; or that the existing
community alarm equipment provided other functions such as the
monitoring of fire alarms. Clients who had given up a previous
home to move into a sheltered environment felt they had no influence
on the change or how it was achieved. There was confusion and
distress for older people, their families and carers.
6.6 Many local authorities undertake a full
EU tender process for every contract whatever the circumstances.
This results from a misunderstanding of EU requirements and a
failure of communication between the SP team (or equivalent) and
legal and procurement departments. A further example of a particularly
inappropriate practice in a small number of authorities is the
requirement for the deposit of a bond at the start of a contract.
6.7 One key concern affects some of our
most vulnerable and excluded clients in our residential services
within purpose built accommodation such as hostels, foyers, refuges,
and older persons' sheltered accommodation. This is the practice
of some local authorities to commission support services separately
from housing management services and management of the premises
without full regard to the history or ownership of the premises.
In some cases this has resulted in models of working which are
unhelpful to the client and cost more to the overall public purse.
In the worst case it can result in accommodation built from public
funds standing empty at public expense.
6.8 A further issue for accommodation-based
services is that the short term nature of the support contract
is a constraint on investing in the property or developing new
residential services. The committee may wish to examine this area
with all the parties involved and consider how CLG and HCA can
encourage and incentivise new purpose built supported accommodation
and the refurbishment or reprovision of existing buildings. We
note that in other public sector areas longer service contracts
are often awarded to facilitate capital investment (for example
in school and hospital building or railway franchises), and would
suggest that longer term contracts could be considered in this
market too.
7. CONCLUDING
REMARKS
7.1 The evidence Home and others have provided
will demonstrate to the committee the contribution our services
make to the lives of vulnerable people, to the wider community
and to a wide range of government-wide priorities.
7.2 The main concern that Home would ask
the committee to consider is the risk of immediate reductions
in services to vulnerable people in some authorities, and in others
to a gradual reduction in number and quality of service as a result
of a combination of factors including the removal of the ring
fence, other freedoms and flexibilities given to local authorities,
the lack of visible priority given to services to vulnerable people
by many local authorities and Local Area Agreements, the reduction
of influence of CLG and the Audit Commission, growing financial
restrictions on local authorities with more in future, growing
demands for statutory and emergency services, and the additional
pressures of the current economic situation.
7.3 Our most important request to the committee
is that members consider how CLG and other stakeholders should
mitigate this risk—ensuring that essential services to vulnerable
and socially excluded people are provided and further developed,
maintaining a focus on client choice and involvement. We hope
that the comments in this paper assist members in doing so.
May 2009
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