Memorandum from Hact (Housing Associations'
Charitable Trust) (SPP 93)
SUMMARY
— Housing related support, delivered through
Supporting People, provides essential services to vulnerable groups
across the country. These services have significant benefit for
the delivery of a wide range of Government agendas and should
be protected.
— The Government should be congratulated
on the delivery of the Supporting People strategy and the role
that the CLG has taken in championing the value of Supporting
People across Government and to Local Authorities. This should
continue.
— Small locally rooted organisations are
at considerable risk, but deliver real value that some larger
regional or national organisations cannot. The reality of competitive
tendering, however, is that good organisations, which represent
the accumulation of social capital through many years of voluntary
effort, are going out of business or are significantly weakened.
Once this social capital disappears, it is not easily replaced.
SP needs smaller agencies that engage local people and reach those
that larger organisations cannot.
— It is not clear if the new SP market
and the ways in which some authorities are developing it locally,
delivers improvement in outcomes for vulnerable people. Commissioners
have a responsibility to look carefully at whether competitive
procurement is the best route to take. Decisions on whether to
tender should be based on an assessment of the business case for
tendering which adopts a "full value" approach, not
just focused on a narrow approach to anticipated savings.
— Collaborative approaches between larger
and smaller organsiations must be a key strategy to maintain diversity
and reach more marginalised communities. Commissioners have a
key role in supporting collaborative working, but commissioning
and procurement practice must improve to achieve this.
— Intelligent Commissioning, a phrase coined
by the Audit Commission, must lie at the heart of encouraging
greater collaboration. In 2007 the Audit Commission called for
advice from Government for commissioners on flexible procurement.
This is now overdue and should happen as a priority.
— Through our work, grounded in our experience,
we are very aware that there are needs that are not being met.
It is important that Government understands where gaps exist and
ensure resources are available to meet them. Government has a
key role to play in championing Supporting People as the ring
fence is removed, ensuring that unpopular groups are not deprioritised
and unmet needs addressed.
— The removal of the ring fence raises
both concerns and opportunities. The Government should continue
to award funding to local authorities as named un-ringfenced grant.
The impact of this and the identification of both good and bad
practice should be monitored.
1. ABOUT HACT
1.1 Hact is a national agency working across
the housing and community sectors to build multi-agency partnerships
that pioneer new housing solutions for those on the margins. Hact
has worked for many years with the CLG, and its predecessor departments,
in taking forward a range of initiatives to better address the
housing needs and aspirations of those on the margins.
1.2 Hact has worked with Government in both
the development and delivery of the SP programme. Over 8 years
we have been commissioned to deliver a range of capacity building
development and support to smaller providers. We have distributed
nearly £700,000 in small grants to around 250 small organisations,
delivered over 30 events, lead a specific consultation for small
providers to feed into the SP strategy, and more recently supported
the development of multi-agency partnerships to test new collaborative
models to service delivery. We have a strong engagement with smaller
SP providers from all parts of the country. Our submission to
the CLG Committee is based on the evidence that we have generated
through our work and focuses specifically on those issues where
we have developed specific expertise and learning of importance
to the future of the SP programme. Working in depth with a breadth
of organisations across the country we are ideally placed to comment
on the Supporting People programme, its strategy and future.
2. HOUSING RELATED
SUPPORT
2.1 Housing related support, delivered though
the Supporting People programme, provides essential services to
vulnerable groups across the country. It benefits individuals,
their families and their communities, ensuring that people sustain
the housing they need to live with dignity and independence. The
work that CLG have done in demonstrating the value of SP to other
parts of Government and to the public purse demonstrates the importance
of the programme in underpinning a wide range of other government
agendas and objectives.
2.2 Supporting People needs champions at
all levels both within and outside of Government to ensure that
the successes of the programme continue to be delivered and built
upon. Although delivery is predominantly at the local level, Government
should have a responsibility and commitment to championing Supporting
People and take a lead in monitoring how it is delivered by local
authorities and continue to commit resources to both providers
and commissioners that achieves continuous improvement.
2.3 Through our work, grounded in our experience,
we are very aware that there are needs that are not being met.
It is important that Government understands where gaps exist and
ensure resources are available to meet them. Specific attention
should be paid to those groups where official statistics do not
adequately reflect reality and where people face considerable
discrimination and disadvantage, such as refugees, new migrants,
BME communities and Gypsies and Travelers. Government has a key
role to play in championing Supporting People as the ring fence
is removed, ensuring that unpopular groups are not deprioritised
and unmet needs addressed. The CLG and the Homes and Communities
Agency, should continue to invest in developing needs mapping
exercises at the regional level.
3. DELIVERING
THE STRATEGY
AND REMOVAL
OF THE
RING FENCE
3.1 Since the publication of Independence
and Opportunity in 2007, the Government has delivered on some
of the key commitments made. This has included: the publication
of the National Strategy for an Ageing Society; locating the programme
in the new local government framework; acknowledgement of SP in
wider government agendas for the third sector and around the transformation
of social care; supporting capacity building of smaller providers;
contributing to the burgeoning agenda on commissioning; delivering
on creating a clear evidence base of the outcomes of SP services;
and promoting better quality. They should be congratulated on
this.
3.2 Although this work has the potential
to lay solid foundations for the future, there are considerable
risks for SP and the benefit it derives, with the removal of the
ring fence and the current and future pressures on public spending.
There is considerable concern, especially among those working
with socially excluded and unpopular groups, that there will be
a "raid" on SP budgets to meet other funding priorities
during harder economic times.
3.3 However, the removal of the ring fence
can bring added benefits as SP is integrated with other budgets
that could benefit vulnerable people. The evidence from the recent
pathfinders, whilst not necessarily conclusive, does give a hint
at what kinds of innovation is achievable, particularly when service
design if viewed from the user perspective. The lifting of the
ring fence has encouraged new approaches though this may have
been achievable with better joint commissioning approaches. A
more flexible approach, nonetheless, is welcome.
3.4 The approach by the Government in allocating
SP funds as a named un-ringfenced grant should continue and be
closely monitored to identify both good and bad practice.
3.5 An area of weakness in the delivery
of the strategy has been the real empowerment of service users
in the design, delivery and monitoring of the strategy, at national
and local levels. This has never been a strength of SP and greater
effort is needed by all parties to ensure that service users are
truly "at the heart" of the programme.
4. COLLABORATION
AND COMMISSIONING
4.1 Hact's recent work in building the capacity
of smaller organisations has focused predominantly on developing
collaborative approaches to contracting and service delivery.
For small organisations their future within the SP programme can
sometimes rely on developing collaborative approaches to service
delivery. This is clearly the case as local authorities have sought
to rationalise the numbers of contracts they hold with providers.
Rationalisation has benefits to commissioners in delivering greater
efficiencies, whether this benefits vulnerable people and communities
remains to be seen.
4.2 During our work it has become clear
that small, locally rooted organisation do have a real, identifiable
value which they contribute to their neighbourhoods. At their
best, they can be community assets in a way which services provided
by larger regional or national organisations simply cannot. Their
role in the SP programme must be valued and enhanced.
4.3 The reality of competitive tendering,
however, is that good organisations, which represent the accumulation
of social capital through many years of voluntary effort, are
going out of business or are being significantly weakened. Once
this social capital disappears, it is not easily replaced. Furthermore,
more marginal communities, such as refugees, rely on smaller community
based organisations to provide essential support and link them
into other services. SP needs smaller agencies that engage local
people and reach those that larger organisations cannot.
4.4 Local Authorities and Government should
monitor the extent to which small specialist providers and their
customers benefit from SP resources in local areas. If large service
providers dominate the market, smaller specialist providers, such
as those from more marginal communities may be under developed,
unsupported and excluded from SP funding. Given that SP is the
single biggest funding stream to the third sector from Government,
how it delivers on Equalities commitments and builds capacity
of smaller community based services to marginalised groups needs
to be considered.
4.5 Collaborative tendering can provide
a way for smaller providers to remain, and even thrive, within
the SP market, but it won't work for everyone. The environment
needs to be conducive to supporting partnerships to emerge and
deliver services. Government has a key role to play in supporting
and championing this.
4.6 Commissioners have a responsibility
to look carefully at whether competitive procurement is the best
route to take. Decisions on whether to tender should be based
on an assessment of the business case for tendering which adopts
a "full value" approach. Among other things this will
look at:
— how much the tendering exercise is going
to cost the local authority
— how much it is going to cost the voluntary
sector who are by far the majority of those delivering and bidding
for contracts
— what the impact will be on local networks,
particularly services funded by other commissioners
— what savings it might be possible to
achieve by negotiation
These should all be balanced against the anticipated
savings which might be achieved by going out to tender.
4.7 It is not clear if the new SP market
and the ways in which some authorities are developing it locally,
delivers improvement in outcomes for vulnerable people.
4.8 All too often decisions to go to full
competitive tendering appear to be driven by a narrow focus on
anticipated savings without taking into account the costs. In
one area where we worked with a consortium, we estimated that
around £100,000 was removed from the voluntary sector during
the bidding process for one contract. While it might be normal
commercial practice to expect organisations to absorb the costs
of tendering as a charge against their profits, for non-profit
organisations these costs represent a diversion of funds away
from the achievement of social and charitable objectives.
4.9 There are a number of authorities that
have taken a blanket decision that every contract must be put
out to tender. This runs counter to good practice advice from
a number of sources including Government and the Audit Commission.
4.10 There is a need for non-statutory guidance
to local commissioners and procurement teams about what is possible
within the EU rules. This could be taken forward by the Office
for Government Commerce, supported by Regional Improvement and
Efficiency Partnerships.
4.11 Where procurement is the appropriate
route, four things are needed for collaborative tendering that
involves smaller organisations to flourish:
— the small organisation must have the
capacity to pursue a collaborative approach and its Board and
senior staff need to have thought through what it entails
— suitable partners must be available
— the SP team must be committed to promoting
diversity of supply, and acting as an "intelligent commissioner"
— the SP team must be in control of the
procurement process, rather than it being driven by the corporate
procurement team
4.12 Of the above, only the first is under
the control of the individual small provider and the Collaborate
Toolkit published by hact can help with this. Local Authorities
and Government have an ongoing and critical role in ensuring that
the other three conditions are in place.
4.13 Creating a climate of expectation that
collaborative bids are valued and will be supported is essential.
Larger organisations should be encouraged to identify and develop
collaborative approaches with smaller organisations.
4.14 "Intelligent Commissioning",
a phrase coined by the Audit Commission in their 2007 report "Hearts
and Minds", must lie at the heart of any attempt to promote
collaboration as a means of sustaining diversity. The Audit Commission
called in 2007 for advice from Government for commissioners on
flexible procurement. This is now overdue and should happen as
a matter of priority.
4.15 Government's investment into Third
Sector capacity, through Capacitybuilders and Futurebuilders,
rightly identifies collaboration as a key way forward. This agenda
needs to be made more sensitive to the needs of SP providers and
matched by a greater awareness and capacity at the commissioning
and procurement level to support collaborative approaches.
4.16 There is an urgent need to improve
standards of procurement of support services—without this
other initiatives to sustain diversity area likely to be ineffective.
This will require action at government level and needs to include
both enforcement (audit/inspection) and support in raising standards.
Action taken together by the CLG, Office of the Third Sector,
Audit Commission and the Regional Improvement and Efficiency Partnerships
is needed to take this forward
4.17 Finally, Government should also monitor
the impact of recent tendering and contract rationalisation exercises
to ensure third sector providers who have won contracts, are not
lumbered with huge TUPE/wind down costs should SP services be
cut in future years. Any adverse impact of this may produce a
"knock on effect" on other services to vulnerable people
in local areas and thereby lose the benefits of "investing
to save".
May 2009
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