Memorandum from SITRA (SPP107)
This evidence is based on consultation with
our member organisations. We ask the Committee to note that the
short timescale given to gather evidence has prevented us from
consulting as widely as we would have liked with users of housing
related support. Whilst we are aware that individual members have
submitted some evidence from service users, we believe that there
is much more that could be usefully gained from direct consultation
with service users about the core themes of the Inquiry. We would
encourage the Committee to consider either providing an extension
for service user feedback and allowing it to be provided in a
more flexible format, or to explore other ways to ensure the vital
input from service users can be achieved.
A. EXECUTIVE
SUMMARY
A.1 Sitra's response is based on an extensive
consultation with our members. Through meetings and questionnaires
we asked for input on the achievements of the SP programme, with
particular reference to the priorities of "Independence and
Opportunity", the implications of the removal of the ring
fence, and the actions required to build on the achievements and
continue to drive improvements in housing related support services.
A.2 Our main conclusions are summarised
below.
A.3 The SP programme has been highly successful
in delivering targeted support service to vulnerable people and
the socially excluded. Specific strengths include:
— Highly personalised services that are
responsive to needs and which encourage people to move towards
fully independent lives.
— Robust data to demonstrate how outcomes
meet needs. All authorities have conducted needs assessments,
on which SP Strategies have been based. These have informed commissioning
and spending decisions. Monitoring of service quality and value
for money has been delivered through the QAF and other mechanisms.
A range of robust outcome measurement tools has been developed
both nationally and to respond to specific local needs.
— Early intervention and preventative work
have both improved service outcomes, for example thought the prevention
of homelessness or hospital admissions and delivered significant
savings to the public purse.
— A body of expertise has been developed
in local authority SP teams and structures are in place for them
to work in partnership at local and regional levels with providers
and other stakeholders.
— Service user engagement has been highly
developed in service planning and delivery and in some areas in
service design and policy development.
— There is a diverse and highly skilled
provider sector.
A.4 The lifting of the ring fence and the
removal of specific grant eligibility criteria has the objective
of better integrating these services in the new local government
landscape. Our "headline" view of the implication of
this is that:
— The new flexibility and opportunity to
deliver more joined up services is cautiously welcomed.
— There is considerable concern that, particularly
with the current pressure on public spending, funds will be diverted
from support to statutory or other council priorities.
— There is a very real risk of loss of
expertise and understanding if specialist SP teams, commissioning
bodies and partnership structures are lost.
— SP has not been widely understood, partly
because of the ring fence and partly because of the marginalised
nature of many of its clients and it is an urgent priority to
communicate its value and importance to key decision makers.
A.5 Despite these concerns the sector is
divided on whether replacement of the ring fence would be positive.
We believe this would be incompatible with the wider agenda of
localism shared by the major parties and is therefore unlikely
to happen, and has the potential to further marginalise housing
related support services. However, we do feel this consultation
has raised alternative models which could be explored. We think
a core priority is to develop a strategic and monitoring framework
that will ensure that government at a national and local level
must continue to demonstrate that it is continuing to meet the
support needs of vulnerable and socially excluded people and to
deliver the savings to the public purse delivered by effective
preventative services.
A.6 We believe the following recommendations
provide this framework.
B. RECOMMENDATIONS
B.1 CLG to have clear responsibility for
leading and ensuring delivery nationally of a strategy for responsive
client orientated housing related support services.
B.2 That local authorities or LSPs are required
to consult on and publish and regularly update a needs-based strategy
detailing how they will meet the housing related support needs
of vulnerable and socially excluded people their borough. This
to include how their internal resources and commissioning arrangements
will ensure that the right expertise and knowledge of HRS is in
place and how they will engage with providers, clients and other
stakeholders to deliver appropriate, high quality, person-centred
services.
B.3 That in each local authority there is
a mandatory named officer with responsibility for ensuring delivery
of the strategy and maintaining the necessary levels of expertise.
B.4 That consideration is given to introducing
a mandatory requirement that commissioners use the QAF and require
completion of the St Andrew's outcomes data to ensure consistency
and comparability in assessing service quality and outcomes delivery
nationally.
B.5 The Audit Commission to be required
to include as a key component of their Comprehensive Area Assessments
an appraisal based on a clear methodology of how well the LSP
is serving the most vulnerable members of the community and the
socially excluded.
B.6 That all the above strategies and evaluation
processes place the interests of and engagement with service users
at their centre.
B.7 That the CLG consult on a clear definition
for housing related support to enable meaningful national monitoring
of it to continue.
B.8 That consideration is given to developing
a Code of Guidance, to which LAs and LSPs must demonstrate that
they have had regard, identifying best practice in the delivery
of housing related support.
B.9 That consideration is given to extending
statutory duties to protect the most vulnerable, either through
a general duty on local authorities to do so, or by extension
of existing statutory rights to particular vulnerable or excluded
groups.
B.10 That the scope of PSA 16 is reviewed
to ensure that it prioritises positive outcomes for all vulnerable
and socially excluded groups.
B.11 That alternatives to un ring-fencing
raised within this consultation, including the call for a targeted
national, ring-fenced budget for the most vulnerable and socially
excluded client groups are evaluated and consulted on.
B.12 That clear guidelines are produced
requiring local authorities or LSPs to report on their spend on
housing related support and the outcomes arising from that spend.
Also to monitor cuts and information about types of service and
client groups invested in.
B.13 That the CLG, with the HCA, run a consultation
exercise on how best to ensure the continuing link between housing
and support, including the continuing provision of accommodation
based services where appropriate, and ensure that capital investment
in new supported housing is not threatened by the risk of ongoing
revenue funding being unavailable.
B.14 That the current National Indicator
set is reviewed to ensure that NIs relating to HRS encourage LAs
and LSPs to make it a priority and that the NIs accurately demonstrate
the quality of services delivered and outcomes. Specifically that
consideration is given to making NIs 141/2, or any successor NI
relating to HRS a mandatory indicator.
B.15 That the value of early intervention
and preventative services is recognised and that the cost benefits
realisation model for supported housing is regularly updated at
a national and local level and that local results from the model
are collated centrally to inform the national picture.
B.16 That government actively promotes and
supports local and regional structures, such as the Regional Improvement
Groups,. Core Strategy Groups and Provider Forums, that guarantee
joint working and engagement with service providers and users
B.17 That the DH, in developing its proposals
for Care and Support in the Green Paper consult fully with the
HRS sector in order to deliver personalisation in a way which
maximises the benefits to service users, building on existing
strengths of the HRS sector, while having reasonable regard for
the viability of providers.
B.18 That the local connection requirements
associated with SP funding be updated with a view to ensuring
that no-one is prevented from receiving a service they need on
residence or other local connection grounds.
B.19 That short term support services continue
to be available without charge to the user through a variety of
formats appropriate to user need including floating support and
accommodation based services.
B.20 That CLG works closely with the Office
of the Third Sector and representative organisations such as Sitra
to develop a programme of capacity building for third sector HRS
providers. The detailed programme to be worked up in partnership
with the sector but key elements would be: (a) developing the
capacity and the structures to enable access to local strategic
decision takers such as LSPs; (b) help with the skills and capacity
needed for the third sector to compete in a tendering environment,
including developing partnerships and consortia; and (c)work to
build the capacity of organisations to support their clients in
engaging with strategic policy and decision taking processes.
B.21 That the CLG commission an independent
study of the use of competitive tendering for HRS with a view
to developing good practice guidelines for market testing that
is legal, proportionate and appropriate to the sector and will
deliver the best and most diverse range of services and providers
B.22 That, in recognition of the significant,
but in many respects still uncertain, implications of the removal
of the ring fence, and the range of measures put forward by the
sector to respond to them, the CLG should extend the transition
package and maintain SP funding as a named but not ring fenced
grant for a second year. This will offer a measure of support
and protection to the sector while the full implications of the
changes emerge and are evaluated. It will also enable greater
monitoring of the experience of un ring-fencing in Scotland.
DETAILED SUBMISSION
1. AN INTRODUCTION
TO SITRA
1.1 Sitra is the umbrella organisation committed
to raising standards in the housing, care and support sector.
We are a membership organisation and a registered charity with
over 25 years experience of offering practitioners a range
of affordable policy, training, consultancy, information, conference
and capacity building services.
1.2 Our membership comprises almost 800 practitioner
organisations in the field of housing with care and support. The
membership elects the committee. Members are drawn from both providers
and commissioners, and from the statutory, voluntary and private
sectors. We operate throughout England, and have offices in London,
Bristol, Newcastle and Birmingham. Our work covers all aspects
of supported housing, together with associated activities such
as human resources and staffing issues, financial management,
and community care.
1.3 We are recognised, funded and consulted
by government departments and other bodies as representatives
of providers of supported housing. We work with them on issues
of national strategic significance for the sector. For example
we have been working with CLG on developing the transition programme
which supports organisations through the changes resulting from
the removal of the ring fence, and with the Department of Health
on taking forward the personalisation of housing related support
services.
1.4 The monthly Sitra Bulletin is
widely recognised as a key source of technical information and
policy development news throughout the supported housing sector.
With a circulation of around 3,000, it is the most widely distributed
specialist publication within the supported housing sector. We
supplement the Bulletin with regular briefings on matters
relating to supported housing and its related fields.
1.5 Sitra is also known as a leading training
provider. Each year we train over 4,000 individuals across
the country, either on our general programme or on tailored made
in-house courses for members and clients. We also provide a range
of seminars and conferences on supported housing related themes.
We estimate that over 2000 people attend such a Sitra event
each year.
1.6 We are therefore in a unique position
of combining a detailed knowledge of the housing related support
(HRS) sector on the ground with an understanding of and engagement
with the developing national strategic agenda.
2. THE BASIS
OF OUR
EVIDENCE TO
THE INQUIRY
2.1 Our submission is based in part on our
general knowledge of the sector derived from our day to day work
but also from a number of specific consultation and engagement
exercises. These are:
— A series of "round table" events
organised in partnership with the CLG. The CLG had supported these
as part of their commitment to exploring the issues emerging from
the decision to lift ring fence. As a result, during January and
February of this year two events were held in each of the English
regions—a total of 18 events attended by a total of
635 people, including local commissioners, providers and
other stakeholders. This constituted the most significant national
debate among stakeholders on the issue of the removal of the ring
fence, the a core agenda under review in the Inquiry.
— A questionnaire to members, specifically
focused on the Inquiry's terms of reference, resulted in 91 detailed
responses. The questionnaire was sent to members in two formats.
It was sent as a list of questions to members; this generated
seven responses. In order to make it easier for members to respond,
an online survey was created (using Survey Monkey) and sent to
members; this resulted in 84 responses.
— A specific set of questions to commissioners
about commissioning structures, which elicited 39 responses.
— Regional consultation events in the London,
South West, West Midlands and North East regions, attended by
75 people.
2.2 The views presented in this submission
are therefore based on a solid body of evidence drawn from a total
of more than 800 personal and written contributions from
practitioners in the housing with care and support sector.
2.3 We have organised this submission around
the responses to our consultations. As these responses are not
specifically organised round the aims of "Independence and
Opportunity" we have drawn out a few of the themes most relevant
to these in an Appendix 2, attached to the main submission.
2.4 We have also included a section based
on our discussions with partner organisations in Wales and Scotland,
whose experience can make a significant contribution to the debate.
3. THE REGIONAL
ROUNDTABLES
3.1 These events were organised by Sitra,
with the support of the CLG, as part of the transition package
to assist in managing the changes arising from the abolition of
the Supporting People (SP) ring fence in April 2009.
3.2 Each event heard an introduction from
the CLG on the changes and the reasons for them. There was also
a presentation from a local Pathfinder authority[29]
on their experience of life outside the ring fence. These presentations
were followed by discussions in small groups ("round tables")
and then a Q&A with a panel consisting of the presentation
speakers and local provider representative. These discussions
were structured to ensure a constructive debate and a consistent
structure to the outcomes. Groups were asked to identify two key
opportunities or challenges arising from the changes locally,
two key initiatives to be taken forward regionally or locally
and two key issues to be taken forward nationally by Sitra or
the CLG. Each group was asked to prioritise one issue for discussion
with the Panel. The conclusions of these discussions were collated
by Sitra and form the basis of a detailed report which is Appendix
1 to this submission.
3.3 The key themes emerging from the discussions
were:
— There is a will to seize the opportunities
for more flexible service design and delivery.
— SP has achieved a great deal in delivering
services to vulnerable people and those otherwise in need of support,
based on rigorous needs analysis, strategic planning, joined up
commissioning, client involvement, and close monitoring of service
standards, value and outcomes. It is critical that these achievements
are preserved and built on.
— There is widespread concern that the
disappearance of a specific funding stream with eligibility criteria
will lead to a loss of focus and expertise, particularly if SP
teams are disbanded.
— There is universal concern that incorporation
into ABG (Area Based Grant) will lead to funding being diverted
away from funding for Housing Related Support (particularly for
the most socially excluded and least electorally influential groups)
to other local priorities.
— If the opportunities are to be seized
and the fears not realised the entire SP sector will need to demonstrate
its importance for both individual clients and the community much
more effectively to a wider audience.
3.4 The meetings discussed the impact of
these issues at local, regional and national level.
3.5 At local level the key issues were identified
as being:
— Ensuring engagement of service providers
and users with the LSP and ensuring that key decision makers understand
what HRS is;
— Demonstrating the strategic relevance
of HRS to wider objectives in the LAA and PSA 16 targets;
— Demonstrating the value, in both human
and financial terms, of preventative work;
— Ensuring continuing good, and appropriately
skilled and informed, governance for commissioning and investment
decisions.
3.6 At regional level the key issues were:
— Maintaining structures such as the RIGs
and regional provider forums to facilitate regional planning,
communication and support, operational liaison, and the sharing
of good practice.
— The continuing need for regional needs
assessments and planning;
— Linking the programme to other service
areas operating regionally, eg housing capital investment, the
Government Offices;
— Effective cross-border service working,
consistency and resolution of local connection issues and disputes.
3.7 National issues discussed included:
— Central government's role in demonstrating
and championing the need for HRS services;
— Ensuring services for non-statutory groups
do not erode over time;
— Consistency—avoiding a "post
code lottery";
— Refreshing and promoting the cost benefits
realisation model (see section 4.1 below);
— Arguing for resources for HRS at a national
level.
3.8 Other discussion particularly focused
on:
— Maintaining robust data and monitoring;
— Continuing to build the client focus
and personalised nature of HRS services;
— Effective communication on all these
issues.
3.9 A fuller account of these discussions
is in our report of the events, appended to this submission (please
see Appendix 1).
4. RESPONSES
TO OUR
CONSULTATION QUESTIONS
4.1 We sent a letter to our members setting
out 10 questions related to the terms of reference for this
Inquiry. This was then made available to members in the form of
a Survey Monkey questionnaire which facilitated their response
and enabled us to produce summary information. In all 93 members
replied, 84 of them using Survey Monkey. It is those 84 which
are broken down in the statistical information represented in
tables in this section.
4.2 We summarise the responses to the questions
below. We also structured four regional discussion meetings, attended
by 75 members, around these same question and we have included
commentary and examples from them in the commentary below. Detailed
records of the responses and notes from the meetings are available
if required.
4.3 The Benefits of the SP Programme
4.3.1 Respondents were overwhelmingly positive
about the ability of the SP programme to demonstrate its strengths
and successes. This reflected a theme emerging from the Round
Tables which is that the programme has developed excellent practice
resulting in and evidenced by robust data, including:
— Needs assessment in each borough;
— Clear SP Strategies and investment plans
based on the identified needs;
— Joint Commissioning based on the needs
and the strategy;
— Rigorous monitoring of value for money
and standards, through the QAF,[30]
benchmarking and other tools;
— Detailed information about outcomes for
clients though SPLS data, client record forms, data collected
by St Andrews University for the CLG and tools more focused on
specific client groups such as Outcomes Star and Spirit Level.
— The cost benefits realisation model developed
by CapGemini for the CLG[31]
that demonstrated the net value to the public purse, and which
is currently being updated for use at local as well as national
level.
4.3.2 In addition respondents pointed to
a wealth of evidence about positive outcomes for users. Individual
providers can provide individual case studies which are outside
the scope of this overview. As well as the tools referred to above
many providers have tracked client satisfaction. One of the key
National Indicators (NI 141) tracks successful transition to more
independent living (often referred to as move-on) and the sector
can generally demonstrate increasing success in supporting clients
through this process, despite the ever increasing shortage of
affordable social housing. Providers have also been able to provide
evidence of other elements of successful independent living including
debt management and access to education, training and employment.
It is a reflection of the positive relationship many providers
have with clients that they often maintain contact with clients
after the formal support or residence period has ended and are
able to track their success in sustaining positive, independent
lives.
4.3.3 Many respondents pointed to the importance
of early intervention and crisis prevention which is a feature
of housing related support. Examples include working with people
with mental health problems to prevent or manage occasional crises;
early intervention with people threatened with homelessness to
sustain their present accommodation or support them in finding
alternatives; the use of Home Improvement Agencies to support
older people in their own homes and work with survivors of domestic
violence to help them achieve physical safety and start to put
their lives back together.
4.3.4 A number of examples were given of
flexible and integrated services, both accommodation based and
floating support, which addressed the needs of individuals, rather
than being based on bureaucratic service categories. Examples
included working with landlords around anti-social behaviour,
drugs and alcohol treatment and support services working together
and the South West Gateway projects where SP providers worked
closely with Probation in the resettlement of offenders. It was
felt that the joint commissioning practised by most SP Commissioning
Boards (which include Social Services, Housing , Health and Probation
as well as provider reps) contributed to this flexible approach.
4.3.5 The programme has delivered efficiency
and value for money. It was noted that at least 70% of funding
is spent on direct user contact, as a result of the sector being
less bureaucratic than health or social services. Many areas had
increased capacity and throughput even though there have been
budget reductions.
4.3.6 These benefits could be demonstrated
because of the robust monitoring and recording referred to above
and described in more detail in section 4.4. In particular a number
of respondents reported a steady improvement in QAF scores over
repeated assessments across the sector since the commencement
of the programme. The same monitoring has also led to the decommissioning
of services which delivered poor standards, outcomes or value
for money.
4.4 Will the Removal of the Ring Fence lead
to Significant Changes in Resources?
4.4.1 While the largest number of respondents
answered "Don't know"—it was clear from supplementary
comments that this was simply because it is too soon to say for
certain. A tiny minority thought there would be no change.
4.4.2 Many commented that at present the
money is tied up in existing contracts and the "crunch"
will come, gradually in many cases, when contracts expire and
money becomes available for re-allocation. Many felt that the
existence of a named grant this year put some useful pressure
on authorities not to "raid" it for other purposes and
some suggested that this arrangement should be extended to future
years. A number stated that their authority had decided to maintain
a local ring fence for a period and welcomed this. It is clear
that the recent budget has greatly increased concerns about the
long term funding of public services generally and increased concerns
that support services will be squeezed.
4.4.3 While respondents were aware that
ring fence removal (and the attendant relaxation of eligibility
criteria) offered real opportunities for more flexible service
design and commissioning, the increasing pressure on public spending
means that worries about the future risks greatly outweighed optimism
about the new opportunities.
4.4.4 The single biggest concern is that
the pressure on statutory services will result in a diversion
of funds away from groups that do not have statutory protection
and the most socially excluded. There is also concern that many
groups who receive HRS services will be vulnerable as they are
not electorally popular, a factor which will become more significant
in locally determined budget decisions than in a national programme.
Such groups include gypsies and travellers, ex-offenders, those
with substance abuse problems, rough sleepers and possibly those
living with HIV/AIDS. Resources may go to statutory care groups
but also to other local priorities such as roads and street lighting.
Thirdly there is a recognition that, even in those authorities
which are committed to maintaining the proportion of spend on
HRS, the budget will be subject to the top slicing necessary to
achieve corporate savings from which it was protected by the ring
fence.
4.4.5 The risk may act as disincentive to
innovation. To commission new services means freeing money up
from existing or expiring contracts. There may be a reluctance
to do this if any money released from contractual obligations
is seen as an opportunity to make corporate savings or divert
to other uses, rather than re-investing in new models of support.
4.4.6 Concerns were also expressed about
the impact of local decision taking. There were clearly very different
relationships between local authorities and their providers sectors
ranging from comments which seemed to reflect a highly positive
shared approach though to ones which were clearly born of mistrust
and conflict. Views of how positive more local decision taking
would be varied accordingly. However the concern that the least
popular groups would lose out was closely related to this point.
There was a frequently expressed concern that issues of local
connection (NIMBY-ism) might emerge. The SP programme had very
clear instructions about not excluding service users on local
connection grounds and many feared the loss of this. This was
particularly an issue for specialist services located in one area
but with a wider reach (specialist hostels or refuges for example)
or those services which needed positive reciprocal referral arrangements
for people whose safety required a move out of the area.
4.4.7 It was recognised that PSA 16[32]
gave some level of priority to services to vulnerable people but
there was widespread concern that it was too narrow in its impact,
referring as it does to only four client groups.
4.4.8 Experiences of the role of Local Strategic
Partnerships, and particularly their inclusiveness and accessibility
to service providers and users, varied. However many were concerned
that they did not know how to influence the key decision takers,
that these people, whether senior local authority officers or
LSP partners, were difficult to reach and did not understand HRS
services. Third sector providers felt they were not adequately
represented on LSPs. In particular they generally did not have
relationships with and were not understood by the CVS, which was
often the third sector voice on the LSP. A dual track approach
of both educating the decision takers in the value of HRS (and
its contribution to their wider community strategies) and also
capacity building with providers and their clients to enable them
to access LSPs more effectively is therefore required.
4.4.8 Many expressed concerns about the
impact of the ring fence removal on commissioning structures.
The expertise of SP teams is widely recognised, as is their approach
to holistic commissioning. They were generally involved in the
needs analysis and the development of SP Strategies. In many areas
they have been working to enhance the capacity and diversity of
the provider sector. As well as commissioning services they have
been responsible for service review and monitoring through use
of the QAF and SPLS data. There is considerable concern that this
expertise and knowledge will be dissipated if SP teams dissolve
into more generic commissioning teams and there is particular
concern that the understanding the teams have from this overview
should not be lost by splitting their work across generic policy
and strategy, procurement and contract management teams. A move
towards generic commissioning may in some areas spread the benefits
of SP good practice more widely, but with the risk of dilution
and eventual loss of focus. In particular respondents feared that
support would be mixed with social care and that the essential
link with housing would be misunderstood and lost.
4.4.9 Generic tendering, combined with pressure
on public spending, is also seen as leading to more use of competitive
tendering which gives undue priority to cost over quality. Formal
competitive tendering is seen as often putting at a disadvantage
small specialist providers who may provide excellent services
but have neither the skills nor the capacity to be successful
in the tendering environment. Standard corporate models of tendering
may not be appropriate to commissioning specialist support services.
4.4.10 As mentioned earlier some respondents,
both providers and commissioners, did welcome the increased flexibility
offered by the removal of the ring fence. Resources could be allocated
to the greatest need without being forced to match eligibility
criteria. Certain activities would not be excluded because they
did not fit the criteria. The point was also made that joint commissioning
can reduce duplication and inefficiency as well as offering the
opportunity of more joined up services. Some respondents made
the link with the move towards personalised services, which will
also require more flexible service design and delivery.
4.5 Changes in Commissioning Structures.
4.5.1 This question was asked of all respondents.
We also wrote separately to commissioners and their responses
are summarised in section 5 of this submission.
4.5.2 Only a minority of respondents could
say for certain no changes were planned. The biggest number did
not know whether structural changes would happen and several expressed
concern about resulting uncertainty. In some cases lack of clarity
about future arrangements has led to short term contract extensions
which causes uncertainty for service users as well as providers
4.5.3 Change can of course be both positive
and negative.
4.5.4 In some areas there was a welcome
for the fact that the SP team seemed to be taking on a wider brief
and applying their skills to it. It was felt that adult care had
a great deal to learn from the SP model and that SP had often
led in developing new approaches. Integration with other service
areas might lead to better integrated services.
4.5.6 Elsewhere there were concerns that
SP teams were being taken over or broken up, with the feared consequences
described above.
4.5.7 Structures often followed budgets—a
retained local ring fence was likely to be linked to an unchanged
SP team and an unchanged SP Commissioning Board.
4.5.8 There is clearly a lot of change in
other structures associated with SP commissioning. Many areas
see the need for continuing Providers Forums and Core Strategy
Groups and these are generally seen as valuable by providers and
SP commissioners. However in some areas there is concern that
the opportunity is being taken to dismantle these partnership
and consultation structures, without putting adequate alternatives
in place. In one or two areas providers feel they have been squeezed
out and a number of respondents referred to changes made without
adequate consultation or lack of clarity about how new structures
would work.
4.6 Monitoring Outcomes
4.6.1 As we have seen monitoring of service
quality and outcomes is seen as one of the key strengths of the
SP programme. Many respondents referred to the role of the Quality
Assessment Framework (QAF). The QAF is a standard tool which enables
the assessment of services in a structured way, scoring their
performance in the areas of:
— Assessment and support planning;
— Security, health and safety;
— Safeguarding and protection from abuse;
— Fair access, diversity sand inclusion,
and;
— Client involvement and empowerment.
4.6.2 Use of the QAF is no longer mandatory
(although its use is written into service contracts by many commissioners)
so its continued use in the overwhelming majority of boroughs
is positive, reflecting a continuing commitment to demonstrating
and driving up quality.
4.6.3 The QAF has recently been reviewed
both to reflect the raised standards of provision within the sector
and to ensure that it is a more flexible tool, offering providers
the opportunity to provide evidence of excellence, rather than
simply being a tick box exercise.
4.6.4 There was some concern that use of
the QAF might decline if SP teams are dissolved, as more generic
commissioners may not understand it or its value. Other respondents
felt that one of the benefits of ring fence removal might be the
extension into other areas of social care commissioning of the
QAF.
4.6.5 A number of respondents made the point
that the QAF is only part of a systematic approach to service
quality and outcomes monitoring. The sector has been particularly
creative in developing measures for soft outcomes (ie those related
to how clients feel about and experience things) as well as traditional
hard indicators (eg level of rent arrears, numbers finding jobs).
4.6.7 It was also observed that that personalisation
and individual budgets will be a challenge to existing outcomes
measurement tools as they will need to match the flexibility ands
individuality of the services.
4.7 Client Involvement
4.7.1 Service user and client involvement
is seen by many as one of the strengths of HRS services.
4.7.2 The services themselves are inherently
client centred. Support planning is focussed on the needs of the
individual client and in the best services the support plan is
developed with their active participation and fully takes into
account their own views of their needs. The aim of the services
is to promote independent living—autonomy—not a continuing
dependence on professionals. Moves towards Individual Budgets
and Self Directed Support will build on this and generally the
HRS sector is confident about delivering personalisation.
4.7.3 Many organisations also involve clients
in service planning and review. Methods include house meetings,
focus groups, resident or service user elected representatives,
annual satisfaction surveys and feedback from former users. Examples
were given of clients developing and running services/activities,
such as a caf
, drama club or a fund raising group.
4.7.4 Clients were also involved in discussions
about how services should be delivered and about policies and
procedures that impact on their lives. Some organisations have
made payments to service users who have become actively involved.
4.7.5 Many examples were given of organisations
involving service users in their formal governance, for example
through reserved places on the Board, a service users committee,
and formal consultation or involvement procedures. Examples were
given of operational involvement such as involvement in recruitment
or procurement, or, in a residential scheme, the right to veto
evictions.
4.7.6 A number of respondents pointed to
the fact that client involvement and empowerment is one of the
five key objectives of the QAF. A service cannot achieve a good
or excellent rating without a good score in this area so this
has helped to maintain the high priority of the issue.
4.7.7 A number of areas have involved clients
in commissioning structures. One example was given of a county
which has a group of 66 service users through whom all commissioning
body decisions are referred.
4.7.8 There is some concern that new decision
making structures may be further removed from service users who
may, for example, find it impossible to access LSPs.
4.8 Innovation and Flexibility
4.8.1 Clearly the jury is out on how effective
the removal of the ring fences will be in removing barriers to
innovation and flexibility. It is encouraging that only 14% have
firmly made their minds up that this will not happen.
4.8.2 Many felt it was too early to say,
partly because they linked it to whether flexibility would be
genuine or a cover for cuts in services (by diverting money to
statutory groups, disguising "cost shunts" as efficiency
savings, delivering innovation at the cost of existing services
or by looking at cost rather than value and outcomes). There was
frequently expressed concern that floating support (which is acknowledged
to work very well in a wide range of services) would be promoted
as inherently more flexible and superior to accommodation based
services (which also have a long record of successful delivery)
simply because they can be cheaper, at least in the short term.
4.8.3 There is certainly an appetite for
flexibility in the sector. Some respondents suggested that the
removal of the eligibility criteria would enable more holistic
service provision, a more honest distinction between care and
support (rather than one made to chase available funding criteria),
and services that are designed to meet needs, rather than funding
rules. Joint commissioning can lead to more streamlined and focused
services. One respondent suggested that more flexible funding
would enable the design of services based round communities rather
than individuals. There was also the point that it would be easier
to design services for whole families or, for example, to provide
services for children in a women's refuge. A further example of
a positive service that did not conform to the old criteria was
a project offering sport to socially excluded groups.
4.8.4 Local authorities will need to be
geared up in order to provide a clear strategic direction. They
will need to update needs assessments to support joint commissioning.
They will need to ensure that they have the right expertise at
the right level. To promote and support personalised services
they will need to lose some controlling instincts, while ensuring
that basic safeguarding, risk management and financial accountability
mechanisms remain in place.
4.8.5 Concerns were expressed that more
flexible service design, with less rigidly defined eligibility
and funding criteria would make it increasingly difficult to monitor
and compare outcomes consistently As the inputs will be less well
defined, defining a common base for benchmarking or other comparisons
will become increasingly challenging. There was a concern that
we don't lose what we've gained. One respondent saw the risk of
fragmentation of the sector, although others might see this as
a positive development.
4.9 Will there be losers?
4.9.1 This is probably another question
where it is too soon to be sure of the answer. The removal of
the ring fence will mean change and change involves winners and
losers. There is as we have seen substantial concern across the
sector that the losers will be the electoral unpopular, the socially
excluded, those for whom there is no statutory protection and
those vulnerable groups who tend not to make their voices heard.
4.9.2 The likely reductions in public spending
will lead to higher thresholds of need being required before services
can be accessed. It is felt this may be exacerbated by traditional
care assessment and commissioning procedures being applied as
HRS becomes more integrated, in some areas, with adult social
services. Many who currently need and get HRS services would not
meet FACS[33]
criteria. This is seen as a risk if SP expertise in local authorities
is lost so that the needs of its clients are not represented among
those making resource allocation decisions.
4.9.3 There is a perceived risk from changing
commissioning practices. We have noted the increased dependence
on competitive tendering. There are also trends towards larger,
more generic floating support services. These can offer greater
flexibility and choice to the client, but they can also lack the
specific skills and understanding of more specialist providers.
To provide mental health services to asylum seekers may involve
a very specific understanding and skill-set that a general mental
health service provider may not have. There is also concern that
larger contracts, providing generic services make it increasingly
difficult for small and local providers to compete. In turn those
clients with very specific needs may find themselves marginalised.
4.9.4 We have previously referred to concerns
around local connection. Those respondents expressing concern
about this are particularly those providing services to women
fleeing domestic violence, services where people need to move
for their own welfare (eg young people seeking an exit from gang
culture, sex workers trying to get away from their pimp/dealer)
or more mobile social groups (gypsies and travellers, rough sleepers).
It will be apparent that these are some of the most socially excluded
and many fall into groups which some local councillors would be
only too pleased to exclude from their area.
4.10 Impact on Regional and National Structures
4.10.1 The above graph shows how many people
answered that the structures were effective in delivering outcomes.
Respondents were able to tick more than one box. Relatively few
respondents engaged at a national level. The responses indicate
that local and regional groups are most effective at promoting
HRS and promoting inter-agency working.
4.10.2 At a local level people commented
on both commissioning and provider structures.
4.10.3 Many of the issues raised in respect
of commissioning have been touched on already. The commitment
and skills of the SP team were clearly seen as central to their
success. It was important that local consulting structures were
open and involved listening as well as telling. There were examples
of good relations, shared learning and genuine consultation. There
were others where the local authority was seen as high handed
and unresponsive. Several respondents referred to the structures
being inaccessible to clients. One example of a county winding
up a Core Strategy Group without consultation and against the
wishes of partners and providers was cited by two or three respondents.
4.10.4 As previously indicated many respondents
felt that LSPs were even more inaccessible to providers and clients
and that they had a limited understanding of HRS. There were also
concerns that the local commissioning and consultation structures
had been set up in response to SP and would disappear with it.
4.10.5 Provider forums were widely valued.
They need an active commitment from the commissioner, but should
not be solely a vehicle for them. They are a valuable conduit
for communication from the commissioners (eg changing council
policies), and enable the providers to feed back information and
ideas to the commissioners. They provide a place for the sharing
of skills, information and good practice amongst providers. They
can link with client forums. Generally providers want to work
together. They have a strong sense of common purpose. One example
was given of several small hostels running a shared allotment
scheme for residents, which none of them could have sustained
individually. However competitive tendering tended to drive them
into commercial competition and inhibits working together.
4.10.6 Regional structures were seen as
valuable by those who engaged with them. They were seen as places
to develop a common vision, to coordinate specialist services
and to resolve some local connection and referral issues. Examples
of good practice included a new Regional Socially Excluded Strategy
in Yorkshire and Humberside and Supported Housing months and events,
showcasing the value of the sector in the SW and NW regions. It
was noted that London structures were poor and ineffective.
4.11 The Most Important Things to Preserve
from SP
4.11.1 Not surprisingly the majority of
respondents believed there were things it was essential to preserve
from the SP programme.
4.11.2 The thing most valued (or possibly
felt to be most at risk) by the biggest number of respondents
was the QAF/outcomes monitoring/standards. The sector clearly
wants to continue to deliver excellence and be capable of demonstrating
that it does. This was reiterated through all the methods of consultation.
4.11.3 Respondents also cited the importance
of linking the policy with housing and independent living, and
the importance of preserving accommodation based services.
4.11.4 The next priority was the continuation
of services to vulnerable and marginalised groups and those with
chaotic lives or complex needs.
4.11.4 Other elements people were keen to
preserve included:
— The importance of a preventative focus
and the emphasis on moving towards independence;
— Service user involvement;
— The skills and expertise of the SP teams;
— The skills of providers' workforces and
the professionalism of many care and support workers.
— Diversity—both the diversity of
the provider sector, and its ability to respond to the diversity
of the clients (including specialist, targeted resources for minority
groups)
— Services open to those who need them,
free at the point of need, without local connection criteria.
— Links to wider outcomes—employment,
training, health, etc.
— Protection of vulnerable adults and safeguarding.
— Clarity—a national direction and
strategy, guidelines, advice, consistency.
4.12 What national safeguards should be in
place?
4.12.1 This question also allowed respondents
to tick more than one option.
4.12.2 The HRS sector's focus on positive
outcomes was reflected in the answers to this question with the
largest number of respondents (62%).
4.12.3 A significant number (54%) of respondents
ticked the box for re-imposition of the ring fence. However the
more detailed comments scarcely addressed this issue, perhaps
reflecting recognition that this was unlikely to command the support
of either main political party and was not therefore likely to
happen in practice. This was certainly the view we took from both
the round table events and our own consultation events for this
Inquiry. Respondents and workshop participants also made comments
about the value of local partnerships and knowledge which perhaps
indicate an underlying endorsement of a wider localisation agenda.
One respondent forcibly argued there should be no new national
measures and that the challenge was to make LAAs and ABG work.
4.12.4 However the possibility of a more
limited ring fenced budget for services to the most vulnerable,
marginalised and socially excluded groups did attract support
from both survey respondents (46%) and in meetings. This approach
has been taken in Wales (see section ** below). Some respondents
made the point that service provision to some groups, particularly
survivors of domestic violence and gypsies and travellers, was
essentially a national network and that this should be recognised
in the funding arrangements. This is an option that merits further
consideration.
4.12.5 45% of respondents felt there was
scope for better defining or adding to existing National Indicators
relating to Housing Support. There was little appetite (8%) for
a more prescriptive inspection regime although a role could be
seen for the Audit Commission through Comprehensive Area Assessments
and a couple of respondents saw the need for a more proactive
and effective Ombudsman service.
4.12.6 Many respondents felt that there
should be mandatory reporting on indicators which relate to client
outcomes—such as customer satisfaction. One suggestion was
that reporting against standards should be mandatory for all local
partners, to ensure a continuing joined up approach and shared
priorities. Others felt that outcomes for particular client groups
should be monitored. Although the emphasis was on outcomes rather
than inputs and process there was some support for the idea that
spend on HRS services must be monitored.
4.12.7 A number of respondents stressed
the continuing importance of SP teams—that they should be
preserved and have a degree of autonomy. Most welcomed the relaxation
of eligibility criteria but felt that SP teams should be guaranteed
proper resources to commission good HRS services, but in a more
flexible way. Two respondents argued that SP teams should report
direct to Council Chief Executives who would have mandatory personal
responsibility for the standard of support services to vulnerable
people in their area.
4.12.8 A number of respondents wanted to
see some financial security. Ideas included the use of a defined
local ring fence, longer term (three year minimum) financial settlements
and the mandatory reporting of spend on HRS services. It was also
seen as important to reiterate continually the value of HRS services
and that money spent on support and preventative services for
the most vulnerable is money well spent. The regular use and updating
of the cost benefits realisation model and local regional and
national level would support this.
4.12.9 Some argued for new statutory measures,
either a general duty on local authorities to provide support
services to vulnerable groups, or the extension of statutory individual
rights to a wider range of needs. Some services, particularly
DV refuges, were seen as having a national dimension and needing
a national strategic plan.
4.12.10 A clear national strategy was called
for. The fact that there is no longer a national spending programme
does not mean that there should not be a national policy for HRS.
The CLG were seen as having a clear responsibility to lead and
to make clear that authorities should continue to provide support
services to vulnerable people. They should also continue to promote
good practice and the recording and use of outcomes information.
There is a need for a clear, updated definition of housing related
support to enable local ,regional and national monitoring of spend
and outcomes.
4.12.11 A role for the Audit Commission
in assessing in a clear and methodical way how well Local Strategic
Partnerships served the most vulnerable in their community was
seen as positive.
4.12.11 The scope of PSA 16 could be
expanded to encompass all vulnerable and socially excluded groups.
4.12.11 There could be local spending plans
and reports with HRS as a mandatory identified item.
4.12.11 The emphasis of HRS service on individual
support planning and promoting independent living was cited as
something to promote and build on at the centre of the agenda
for the transformation of social care though personalisation.
5. RESPONSES
FROM COMMISSIONERS
5.1 Sitra contacted Supporting People lead
officers directly with a request for specific information to inform
our response to the CLG Select Committee Inquiry for Supporting
People. It was important to capture information about the impact
of the removal of the SP ring fence on SP commissioning structures.
In total 39 commissioning authorities responded. This represents
26% of all commissioning authorities in England.
5.2 Commissioners were presented with five
key questions:
1. Has the removal of the ring fence led to changes
in the way that SP is delivered in your area?
2. Will an SP team remain in your area following
the removal of the ring fence?
3. If the SP team is being moved or restructured,
where will it sit?
4. Will there be any significant changes in commissioning
structures for housing related support?
5. Are there any elements of the SP programme
and commissioning arrangements that you feel needs protection?
This section of the response will provide a
summarised response to these questions, and include any overarching
recommendations inherent within the responses.
5.3 Has the removal of the ring fence led
to changes in the way that SP is delivered in your area?
5.3.1 This created a mixed response from
commissioners. For many it was difficult to gauge the impact of
the removal of the ring fence as the implementation of it was
so recent. However, even those who felt that it had not changed
things on a local level, broached their response in terms of "not
yet", rather than "no change anticipated". Where
no change had happened yet, it was acknowledged that this question
might usefully be discussed again in six months time. Others did
not anticipate any change, as they had already been operating
as an excellent authority with "freedom and flexibilities".
One authority felt that there had not been any change, and did
not anticipate any because they felt that the commissioning body
recognised the strengths of SP and would be committed to its ongoing
provision.
5.3.2 Whilst a number of authorities did
not feel that any change was happening at present, this was because
of acknowledged interim measures, put in place locally to ease
the transition, or to provide some short term stability. Interim
measures included:-
— Imposition of a local ring fence—enabling
some guarantees around the programme for anything between one
and three years. This measure was accompanied by some relaxed
eligibility, enabling funding of different services.
— Issuing of three year contracts from
April 2009. Providing stability for all services for the first
three years of the removal of the ring fence.
— Providing a guarantee of funds for 2009/10—with
no commitment beyond that—but allowing for a full transition
year.
5.3.4 The lifting of the ring fence has
enabled the removal of eligibility criteria, and it is hoped that
this will bring significant gains to the programme in relation
to flexibility of service provision. A number of authorities did
value this, and were already recognising that greater flexibility
was meaning the provision of new services which would offer support
to a greater number of people than might have been achieved with
a more rigid accommodation based or floating support service.
In addition one council felt that they were able to recognise
the recession pressures and gave an example of commissioning new
services within SP funding which would provide debt advice for
those at risk of losing their homes, and also to provide support
to credit unions to expand their remit.
5.3.5 Future planning within authorities
was an area of key concern. For one authority the reduction in
the administrative grant for Supporting People created an immediate
impact on their ability to fund needs analysis in order to determine
future provision. Another authority found that they had carried
out a needs analysis developing a business case for services needed
in 2010-11, but were anxious that they no longer had control over
the budget to ensure the development of this service. It was also
felt that the ABG did not encourage saving and forward planning,
as there was a general commitment to not carry forward any underspend,
therefore programmes could become very reactive.
5.3.6 The final message around general changes
happening as a result of the lifting of the ring fence is part
of a theme which runs throughout this consultation. This relates
to real concerns about what will happen without a ring fence in
a tighter economic climate. The fear is that authorities will
struggle to continue to fund non statutory services—and
a key casualty of this could be Floating Support. Floating Support
will be addressed in other areas of the report and has been seen
as one of the key successes of the programme, therefore the anticipation
that this may be a vulnerable arm in the future needs to be strongly
acknowledged.
5.4 Will an SP team remain in your area following
the removal of the ring fence?
5.4.1 Over two thirds of respondents felt
that there would be a dedicated team remaining within the authority.
However, a good proportion of those who responded positively to
this also noted that this had either only been confirmed until
the end of 2009-10, or was not something that they could confirm
would run into the future. It was noted that the administration
grant was critical to the survival and purpose of SP teams, as
this provided some of the flexibility to plan, carry out needs
analysis, commission research and providing training and support
for the provider sector. There was also a concern about how significant
they would be in the future if all strategic commissioning responsibilities
were taken out of the team, and lead officers were left with a
primary payment and monitoring function.
5.4.2 Where SP teams no longer existed,
their departure was not directly linked to the lifting of the
ring fence. A number of teams had been deleted in the last two
to three years, and responsibilities for SP had been moved into
more mainstream commissioning teams with a broader adult social
care, community care or housing remit. One authority commented
that this had been positive because of the potential to share
good practice across the authority.
5.4.3 Whilst it is positive that teams remain
in situ, there are concerns about how long, and in what capacity
they will continue to exist past 2009-10. There are strong messages
from other arms of the consultation about the importance of sustaining
a specialist resource within authorities, and whilst there may
be efficiencies to be made from mainstreaming, there are also
related concerns about loss of expertise and the ability to champion
the worth and the preventative support offered through the provision
of housing related support.
5.5 If the SP team is being moved or restructured,
where will it move to?
5.5.1 In response to this question it transpired
that many SP teams had already experienced a move in recent years.
Whilst it is not particularly helpful to note the names of all
the departments within which SP had been moved, it is of note
that out of the 39 authorities who responded to this question,
only two acknowledged that they were either now located, or were
to be located within housing. Many of those who had moved, or
who were planning to move had come out of housing and moved into
either adult social care or some form of social care commissioning
team. None of the authorities who responded particularly attributed
the move to the lifting of the ring fence, and rather that they
formed part of a wider internal restructuring programme. Concerns
were again raised about the future mainstreaming of the programme
within these wider departments and the potential to lose expertise.
5.5.2 However, the break between housing
and supporting people is of some significance when thinking about
the future. This links into the concerns raised within the regional
roundtable debates hosted by Sitra about the relationship between
capital and revenue funding, and the anxieties raised by members
about future commissioning of accommodation based housing related
support. Whilst SP established a break between housing and support,
allowing for the positive development of Floating Support, it
is important to ensure that this does not preclude the future
development or the remodelling of specialist supported accommodation.
5.6 Will there be any significant changes
in commissioning structures for housing related support?
5.6.1 A few authorities did not feel there
were likely to be any changes in commissioning structures, and
this stemmed largely from an acknowledgement that the existing
system was working well and had a lot to recommend it. Key strengths
were cited as positive partnership approach and strong multi-agency
approach as models of good practice.
5.6.2 Within authorities where change was
anticipated or in progress, there were a number of directions
of travel identified. One authority was exploring the best structure
to support the implementation of outcomes based commissioning.
A number of others were looking for new arrangements to improve
opportunities for joint commissioning and, where appropriate,
contract management—both within the authority and across
neighbouring boroughs. Where new structures were in place which
incorporated a commissioning body with a wider overview, it was
felt that this would enable SP services to complement those delivered
by other departments within the authority—and avoid duplication.
New developments also included the evolution of the SP Commissioning
Body to becoming the Social Exclusion Group—which takes
a lead on the strategic co-ordination for PSA 16 plus SP.
In addition a number of authorities had moved the commissioning
of services under the specific client group heads.
5.6.3 Final comments relating to commissioning
structures focussed on the future. The immediate concerns about
the squeeze on public sector finance came through in the form
of fears that there would be no money to commission with. In addition
questions about how the move to increased personalised services
and the increase in self directed support would be incorporated
within the commissioning bodies of the future.
5.6.4 Changes to commissioning structure
seem to reflect the longer term trend identified in the earlier
responses. They are not linked directly to the lifting of the
ring fence, and largely seem to be changes which are broadening
the scope of the commissioning body and where possible enabling
the sharing of expertise and knowledge. The commissioning body
arrangements for SP have often been recognised as a strong and
positive element of the programme, with commissioning being based
around clear and robust needs.
5.7 Are there any elements of the SP programme
and commissioning arrangements that you feel need protection?
5.7.1 Positive endorsements of commissioning
arrangements within SP have already been noted. However, for those
who commented again on commissioning, important factors to preserve
include the focus on partnership, the use of procurement practice
to develop wider market knowledge and reconfigure services and
the joined up thinking exhibited by commissioning bodies. One
authority expressed anxiety that transfer into more generic social
care commissioning would lose the developed understanding of needs.
5.7.2 One of the core strengths of the programme
has been the development of a long term strategic vision for housing
related support. The intensive understanding of needs has driven
the proliferation of quality services under the SP programme and
has shaped the sector. This growth has been built on positive
relationships with providers, enabling commissioners to build
on and negotiate enhanced flexibilities. The removal of the ring
fence has lifted the requirement for mandatory strategy, and the
loss of the admin grant is already limiting some authorities'
ability to support essential provider forums and thereby limiting
regular contact with those delivering services. The loss of knowledge
from links with providers will only compound the loss of expertise
predicted if SP teams dissipate. Concrete knowledge of the sector
and all that it achieves are seen as fundamental pieces of the
jigsaw to influence key stakeholders within LSPs and other potential
funders of the strength of the preventative nature of SP services.
5.7.3 The commissioners of SP services placed
a very high value on the Quality Assessment Framework, and the
need to continue to prioritise monitoring and validation visits
as an essential tool in the safeguarding of vulnerable adults.
Whilst the QAF has not been mandatory since 2006, there is a strong
feeling that the reduction or dispersal of teams, and the subsequent
loss of expertise may mean that authorities are less able to utilise
this excellent quality tool. There was a strong endorsement of
the need to integrate housing related support within other local
monitoring arrangements, particularly highlighting the future
importance of the Joint Strategic Needs Assessment.
5.7.4 Almost everyone responding made some
reference or acknowledgement to the increasing economic crisis
and the likely impact on future funding of public services. Whilst
it was acknowledged that all public services were likely to be
under attack, commissioners reinforced some of the concerns expressed
elsewhere, that the socially excluded groups were those most likely
to be at risk. It was also noted that changing demographics will
strengthen the call on statutory care based services. In addition,
a number noted the vulnerability of Floating Support services.
The difficulties associated with demonstrating the benefits—particularly
of low level Floating Support—and the "lag" effect
of reducing service provision—are likely to contribute to
it being an early victim of any squeeze. One authority noted that
Floating Support was an "easy target", yet at the same
time seeing the services provided in this way as "amongst
our real successes".
5.7.5 Additional points were made about
problems in moving the programme forward. The reduction in grants
has led to a reduction in supported housing units being developed
or re-commissioned within the borough. This is a significant cause
for concern for the future and it is felt that existing and future
procurement practices are reducing the incentive for RSL's to
invest in the future. It was noted:
"The introduction of Self Directed support
and IB's and the removal of the ring fence will mean we can be
more innovative with services, but people do need somewhere to
live in and an environment conducive to making a change."
5.7.6 All commissioners wanted to positively
endorse the success of the programme in relation to the impact
on service users lives. The local impact of reducing homelessness,
increased independence and greater access to move on were all
some of the strengths identified that should be built on as we
move forward. A small number of authorities did feel more positive
about the future, with one feeling that the lifting of the ring
fence represents pure opportunity, enabling the funding of new
and innovative ways to achieve outcomes. However the tone of the
majority of respondents was more aptly represented by the following
quotation:
"In future years the Council is being required
to find efficiency savings and the SP programme will not be exempt
from this. There is an underlying risk to the programme in that
the council may decide to prioritise the funding of statutory
services over non-statutory services."
6. EXPERIENCE
FROM SCOTLAND
AND WALES
6.0 It is helpful to look at the experience
drawn from the application of the Supporting People programme
through the devolved parliaments of Scotland and Wales. Both countries
have important parallels to the English experience which can usefully
be used to inform the Inquiry.
6.1 Scotland
6.1.1 Scotland adopted the SP programme
in a largely similar way to England in 2003. However, they made
the decision to lift the ring fence on SP funding in April 2008.
In May 2008 the Housing Support Enabling Unit[34]
in Scotland carried out a survey of providers and commissioners
within Scotland to create a baseline and to enable some measurement
of changes.[35]
They are just in the process of refreshing this data in a survey
started in April 2009 which will provide an update on how
things have changed in the intervening year. At the time of submitting
this evidence the full report is not available.
6.1.2 Commissioners noted some immediate
changes with the removal of the ring fence, and by July 2008 five
of the 32 authorities had already disbanded their SP teams
and no longer had anyone identified with core responsibility for
housing related support. Early evidence from the 2009 survey
show that this number is increasing.
6.1.3 Information from the new survey[36]
also reinforces English concerns about the removal of the ring
fence increasing the difficulties of tracking spending on housing
related support. Within one year of the removal of the ring fence
commissioners from Argyll and Bute noted: "It is difficult
to be totally specific about expenditure on housing support because
of the mix of funding from different budgets within the council
and the differing terminology used by the SP team, Social Work
and others".
6.1.4 Other evidence from East Ayrshire
highlights the issues of funding services within an increasingly
tight economic climate. They noted "expected reduction of
up to 30% in non social work expenditure from 2008-09 to
2009-10."
6.1.5 A number of other commissioners who
did respond stated that they were expecting a slight decrease
in funding and therefore in the volume of housing support commissioned.
Others reflected that there would be no change.
6.1.6 Whilst there is not an overwhelming
trend to observe, it is hoped that there is sufficient evidence
for the members of the select committee to want to look more closely
at what has and is happening in Scotland, and to read across to
the English experience. It is of note that Scotland has carried
out its own cost benefit analysis, which like the English model,
demonstrated the clear savings to be made from focussing on a
preventative housing related support agenda. However, despite
this, the argument at a local level is being hard fought, and
the non statutory clients are at real risk of losing out.
6.2 Wales
6.2.1 Wales approached the introduction
of SP in a different fashion. At the outset of the programme a
distinction was made between the money which was passed directly
to local authorities and that which was held centrally within
the Assembly. The Supporting People Grant was passed directly
to Local Authorities, and was un-ring fenced from the outset.
This pot was for older people's services and community care type
projects for whom LAs had a statutory duty. The LAs have total
control how to finance, commissioning and administer such projects.
An additional grant was established which was called the Supporting
People Revenue Grant (SPRG). The funding resulting from SPRG has
been categorised by Cymorth Cymru—an umbrella group for
housing support providers— as being for projects for which
LAs do not have a statutory duty and who are seen as "politically
sensitive". SPRG could be applied for by Local Authorities,
and also some projects with national or regional interest were
commissioned directly by the Welsh Assembly.
6.2.2 In 2006 the Welsh Assembly explored
whether LAs were ready to take on the administration of SPRG and
applied a series of conditions to determine whether SPRG should
be transferred. The conditions were as follows:
1. Local authority administration should ensure
that schemes are offered a reasonable guarantee of a term of funding
and that termination decisions will be taken openly and within
the context of local strategic plans.
2. Local authorities provide a clear commitment
to a level of local service delivery.
3. Local authorities should be able to demonstrate
a clear and logical structure for the administration of the grant
scheme including service standards, commissioning and payment
arrangements.
4. Local authorities should be able to demonstrate
the capacity to administer the grant locally.
5. Local authorities should have demonstrated
their capacity for strategic planning in this context.
6.2.3 Cymorth Cymru conducted a snapshot
survey with providers,[37]
on behalf of the Welsh Assembly and came up with two broad brush
conclusions:
— Concerns over the status of housing related
support within the local authority and lack of understanding and
support at both the corporate and political level;
— Insufficient capacity of LA SP teams
to effectively undertake all the roles required of them.
6.2.4 Whilst the conditions in England are
different, the two concerns identified in Wales do seem to resonate
with those highlighted within our research. The fears over limited
understanding of the importance of housing related support, the
centrality of a preventative agenda and the need to fund more
than statutory minimum are all mirrored in England. The transition
period is aiming to highlight and promote the value of housing
related support, but this is a long term project and one which
could be destabilised by lack of local, regional and national
understanding. The second concern about capacity of SP teams is
becoming a central concern of English providers. As teams are
merged or disappear completely, then the ability of SP teams to
conduct effective needs analysis, commissioning, develop expertise
on the sector, monitor and quality control services to the most
vulnerable comes into question.
6.2.5 The situation facing England can not
be directly compared to either the Welsh or Scottish experience.
However there are a number of lessons that could be explored by
the committee. Firstly the application of a set of conditions
for readiness for the change and the engagement of providers in
determining readiness seem to be principles that could usefully
be adopted in England. Whilst it is recognised that pathfinder
authorities did go some way towards trialling the experience of
un ring fencing, our knowledge of the pilots has shown that the
experience of different authorities within the pilot was extremely
varied and not tested against an established list of criteria
or tests. Secondly there are concerns over loss of expertise within
authorities. This message comes from both Scotland and Wales and
is a dominant message throughout our research. The establishment
of the SP programme in England was part of an active decision
to demonstrate that housing related support was a distinct sector
within social care. Having made that decision and built a strong
and productive sector, there is a danger that decisions made to
promote local democracy and notional mainstreaming may destabilise
a sector only just finding its collective feet.
RECOMMENDATIONS
1. CLG to have clear responsibility for
leading and ensuring delivery nationally of a strategy for responsive
client orientated housing related support services.
2. That local authorities or LSPs are required
to consult on and publish and regularly update a needs-based strategy
detailing how they will meet the housing related support needs
of vulnerable and socially excluded people their borough. This
to include how their internal resources and commissioning arrangements
will ensure that the right expertise and knowledge of HRS is in
place and how they will engage with providers, clients and other
stakeholders to deliver appropriate, high quality, person-centred
services.
3. That in each local authority there is
a mandatory named officer with responsibility for ensuring delivery
of the strategy and maintaining the necessary levels of expertise.
4. That consideration is given to introducing
a mandatory requirement that commissioners use the QAF and require
completion of the St Andrew's outcomes data to ensure consistency
and comparability in assessing service quality and outcomes delivery
nationally.
5. The Audit Commission to be required to
include as a key component of their Comprehensive Area Assessments
an appraisal based on a clear methodology of how well the LSP
is serving the most vulnerable members of the community and the
socially excluded.
6. That all the above strategies and evaluation
processes place the interests of and engagement with service users
at their centre.
7. That the CLG consult on a clear definition
for housing related support to enable meaningful national monitoring
of it to continue.
8. That consideration is given to developing
a Code of Guidance, to which LAs and LSPs must demonstrate that
they have had regard, identifying best practice in the delivery
of housing related support.
9. That consideration is given to extending
statutory duties to protect the most vulnerable, either through
a general duty on local authorities to do so, or by extension
of existing statutory rights to particular vulnerable or excluded
groups.
10. That the scope of PSA 16 is reviewed
to ensure that it prioritises positive outcomes for all vulnerable
and socially excluded groups.
11. That alternatives to un ring-fencing
raised within this consultation, including the call for a targeted
national, ring-fenced budget for the most vulnerable and socially
excluded client groups are evaluated and consulted on.
12. That clear guidelines are produced requiring
local authorities or LSPs to report on their spend on housing
related support and the outcomes arising from that spend. Also
to monitor cuts and information about types of service and client
groups invested in.
13. That the CLG, with the HCA, run a consultation
exercise on how best to ensure the continuing link between housing
and support, including the continuing provision of accommodation
based services where appropriate, and ensure that capital investment
in new supported housing is not threatened by the risk of ongoing
revenue funding being unavailable.
14. That the current National Indicator
set is reviewed to ensure that NIs relating to HRS encourage LAs
and LSPs to make it a priority and that the NIs accurately demonstrate
the quality of services delivered and outcomes. Specifically that
consideration is given to making NIs 141/2, or any successor NI
relating to HRS a mandatory indicator.
15. That the value of early intervention
and preventative services is recognised and that the cost benefits
realisation model for supported housing is regularly updated at
a national and local level and that local results from the model
are collated centrally to inform the national picture.
16. That government actively promotes and
supports local and regional structures, such as the Regional Improvement
Groups,. Core Strategy Groups and Provider Forums, that guarantee
joint working and engagement with service providers and users.
17. That the DH, in developing its proposals
for Care and Support in the Green Paper consult fully with the
HRS sector in order to deliver personalisation in a way which
maximises the benefits to service users, building on existing
strengths of the HRS sector, while having reasonable regard for
the viability of providers.
18. That the local connection requirements
associated with SP funding be updated with a view to ensuring
that no-one is prevented from receiving a service they need on
residence or other local connection grounds.
19. That short term support services continue
to be available without charge to the user through a variety of
formats appropriate to user need including floating support and
accommodation based services.
20. That CLG works closely with the Office
of the Third Sector and representative organisations such as Sitra
to develop a programme of capacity building for third sector HRS
providers. The detailed programme to be worked up in partnership
with the sector but key elements would be: (a) developing the
capacity and the structures to enable access to local strategic
decision takers such as LSPs; (b) help with the skills and capacity
needed for the third sector to compete in a tendering environment,
including developing partnerships and consortia; and (c)work to
build the capacity of organisations to support their clients in
engaging with strategic policy and decision taking processes.
21. That the CLG commission an independent
study of the use of competitive tendering for HRS with a view
to developing good practice guidelines for market testing that
is legal, proportionate and appropriate to the sector and will
deliver the best and most diverse range of services and providers.
22. That, in recognition of the significant,
but in many respects still uncertain, implications of the removal
of the ring fence, and the range of measures put forward by the
sector to respond to them, the CLG should extend the transition
package and maintain SP funding as a named but not ring fenced
grant for a second year. This will offer a measure of support
and protection to the sector while the full implications of the
changes emerge and are evaluated. It will also enable greater
monitoring of the experience of un ring-fencing in Scotland.
May 2009
29 The removal of the ring fence was trialled by 15 "Pathfinder"
authorities for six months before the final decision to lift it
was made. Back
30
The Quality Assessment Framework is the nationally recognised
tool for monitoring the quality of HRS services. The CLG has recently
asked Sitra to take on responsibility for updating and maintaining
it as a valuable tool. More information is provided in section
4.4 of this submission. Back
31
This research, published in February 2008 demonstrated that
the preventative work funded by SP prevented costs arising from
either the costs of alternative provision or later "event
costs," such as hospitalisation, criminal justice or residential
care costs that could arise if early preventative intervention
and support was missing. The report showed that the, then, programme
of £1.7 billion produced net savings to the public purse
of £2.55 billion each year. Back
32
A bundle of National Indicator chosen by the CLG as the priorities
in tackling social exclusion. Back
33
Fair Access to Care Services, the eligibility criteria for accessing
social services. Back
34
The Housing Support Enabling Unit is a partnership Initiative
between Community Care Providers Scotland and the Scottish Federation
of Housing Associations, funded by the Scottish Government Back
35
HSEU research into housing support funding levels and service
volume in Scotland from 2007/08-Moira Weir Back
36
Information contained in HSEU April 09 Housing Support Bulletin Back
37
Local Authority Preparedness: A snapshot of support providers'
views. A summary of the report to the Minister for Social Justice
and Regeneration for Cymorth members and partners organisations. Back
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