Memorandum from Women's Aid
(SPP 113)
1. Introduction and summary of key issues
1.1
Women's Aid
1.1.1 Women's Aid is the national domestic violence
charity that co-ordinates and supports an England-wide network of over 370
local organisations which provide over 500 services working to end violence
against women and children (see Appendix 1 for more details). Women's Aid
services support more than 350,000 women and children every year[1].
1.1.2 This submission is
informed by consultation with Women's Aid member services and other agencies as
follows:
§ Evidence from a telephone
survey of 280 Women's Aid member services in each Government Region carried out
during March, April, May 2009 - the aim of this survey was to seek facts and
the current views of our member services in relation to security of contract
and experiences of tendering for services.
§ Evidence from Women's Aid
Annual Survey 2008.
§ Feedback from domestic and
sexual violence service providers and representatives of other statutory and
voluntary sector agencies in a series of Regional Seminars conducted during
February and March 2009. These seminars were promoted and delivered by Women's
Aid in partnership with representatives of the Home Office Interpersonal
Violence Unit and the Audit Commission Housing Inspectorate and Regional
Government Office Domestic Violence lead officers.
§ Evidence gathered in
September 2007 for the Home Affairs Select Committee Inquiry into Domestic
Violence and Forced Marriage. This evidence was gathered through an on-line
survey of Women's Aid member services with 300 responses from across England
(see excerpt relevant to this consultation in appendix 2).
1.2. Domestic Violence
Domestic violence is physical, sexual, psychological
or financial violence that takes place within an intimate or family-type
relationship and that forms a pattern of coercive and controlling behaviour.
This can include forced marriage and so-called 'honour crimes'. Domestic
violence may include a range of abusive behaviours,
not all of which are in themselves inherently 'violent'. Research shows that
domestic violence is most commonly experienced by women and perpetrated by men [2]and
affects every community regardless of race, ethnic or religious group,
class, sexuality, disability or lifestyle. One in four women experience
domestic violence in their lifetimes, and between 6-10% of women in any one
year[3].
Research demonstrates that women who have experienced domestic violence have a
variety of short and long-term support needs. Practical and emotional support
to enable survivors to rebuild their lives can best be given by specialist
domestic violence services within the women's voluntary sector, and survivor
feedback has repeatedly attested the value of these services over the last 35
years[4]. The estimated total cost of domestic violence to society in
monetary terms is £23 billion per annum[5].
1.3 The Supporting
People Programme
The implementation of the government's Supporting
People programme in 2003 afforded housing-based specialist domestic violence
providers the opportunity to properly cost their services and even enabled the
expansion of some services and creation of new ones. Supporting People funds
not only refuge services but also 'floating support services', providing
re-settlement and outreach support to families in their own accommodation, but
does not fund children's or other outreach services and helplines. Evidence gathered from Women's Aid member
organisations in September 2007 showed that 78% were funded by Supporting
People to some extent. 90% of these received funding for refuge provision, and
54% for floating support services.
1.4 The Supporting People Quality Assessment
Framework (QAF)
Whilst many local services
complained about the additional administrative burden that came with Supporting
People funding, most Women's Aid services agree that the Quality Assessment
Framework introduced with Supporting People has ensured a consistent basic
standard of service provision. The Office of the Deputy Prime Minister funded
Women's Aid to develop model policies and procedures for Women's Aid member
services in order to assist services meet the requirements of the Supporting
People Quality Assessment Framework. Supporting People have also implemented a
generic outcomes based monitoring assessment tool to evidence the work achieved
with service users.
1.5 The National Service Standards for Domestic
and Sexual Violence and Guidance
Women's Aid has worked since 2005, along with the government and partner
agencies to develop the National Service Standards for Domestic and Sexual
Violence (NSSDSV). The
NSSDSV form part of a wider quality framework which also include National
Occupational Standards (NOS) and development of a UK wide accredited domestic
violence training programme that will support both the implementation of the
NSSDSV and the NOS. The aim of the NSSDSV is to ensure that services
commissioned are compliant with safe, recognised good practice guidelines in
relation to delivering services to survivors and their children.
The next stage of implementation of the NSSDSV will
include:
- piloting the NSSDSV within some local services and local
commissioners;
- agreeing with government and the Audit Commission how they will
form part of the process commissioning local domestic and sexual violence
services;
- providing support to enable local services to meet the requirements
of the NSSDSV;
- developing and implementing guidance for Local Strategic
Partnerships and all agencies involved in developing and delivering coordinated
community responses to domestic and sexual violence.
Women's Aid expects the NSSDSV to become a key tool in
the future process of commissioning quality domestic and sexual violence
services.
1.6 Summary of key issues
1.6.1
Women's Aid welcomes the opportunity to submit evidence to this
Inquiry.
Since 2003, Supporting
People has been the main funding source for the provision of refuge based
domestic violence services and community based domestic violence floating
support services. Women's Aid worked with the Supporting People Implementation
Team nationally to develop guidance for commissioning local services and to
enable domestic violence services to meet the criteria for quality assurance
required by Supporting People. Feedback from Women's Aid organisations suggests that the programme has had
a significant impact on the sector - at best services have been sustained and
subject to an accreditation and a quality assurance process. In other areas
services have found the programme bureaucratic and challenging to administer,
and many local services have had their funding - and hence capacity to deliver
services - cut, and some services have been forced to merge, or have been
closed or taken over by larger Registered Social Landlords.
1.6.2
Women's Aid is particularly concerned that:
§ There are no
National Indicators requiring the provision of domestic violence support
services.
§ The removal of ring fenced
funding, along with the move to identifying priorities (and therefore where
funding is allocated) locally, will result in domestic violence being
de-prioritised and specialist services lost. This is compounded by the lack of
input that the women's sector have into local strategic planning processes[6].
§ The current move to
commissioning through competitive tendering has resulted in the closure of some
independent specialist domestic violence services who are unable to compete
with larger organisations, particularly specialist services for black and other
minority women. Commissioning practices are inconsistent and often not compliant
with the Compact Agreement[7].
§ The competitive tendering
environment and insecurity of contracts is having an adverse effect on
partnership working and is resulting in high staff turnover or inability to
replace staff when contracts are short term.
§ Where domestic violence
services are commissioned, there is a tendency to favour cost over quality of
service provision. Larger organisations with little or no expertise are being
awarded contracts and gender neutral services are favoured, despite what
evidence tells us about the need for women only services[8]
and the requirements of the Gender Equality Duty[9].
§ There is an assumption that
recent developments aimed at supporting survivors through
the criminal justice system and increasing domestic violence related
prosecutions[10] are sufficient to meet
the needs of survivors in some areas. These initiatives only address the needs
of 24% of women affected by domestic violence however[11].
Specialist domestic violence support services respond to the needs of all
survivors, regardless of whether they are engaged with the criminal justice
system.
§ Despite the recognition
that children and young people are adversely affected by domestic violence and
that there are more children than adults staying in refuges each year[12],
there is still no dedicated funding stream to meet the needs of this vulnerable
group.
§ Existing outcomes
and quality assessment frameworks are not fairly representative of the work
that takes place with survivors, nor do they ensure that services are provided
in line with recognised good practice.
2. To what extent has the Government delivered on the commitment
it made in Independence and Opportunity?
2.1 Keeping
people that need services at the heart of the Programme
2.1.1 Women's Aid welcomes that:
§ Domestic
violence survivors are acknowledged within the definition of 'vulnerable
people' who need housing-related support.
§ Service
user participation is integral to development and provision of Supporting
People services. Service user participation underpins the Women's Aid model of provision of support for women and
their children and is based on enabling women and children to regain control of
their lives in a safe and supported environment, whether in a refuge service or
outreach service.
§ That
cross-boundary groups are acknowledged in the Programme.
§ There
are National Indicators for housing-related support.
2.1.2
Women's Aid is concerned that:
§ Domestic
violence survivors are no longer at the heart of the programme, since there is
no longer a requirement to ensure that local authorities use Supporting People
to fund provision for domestic violence survivors or any other people who are
included in the 'vulnerable people' category.
§ While
the provision of Individual Budgets may keep older people and disabled people
at the heart of the Programme, they are not aimed at or appropriate for
domestic violence survivors and their children.
§ Demand for refuge accommodation is still greater than supply, with the
recommended 1 refuge bedspace per 10,000 population[13]
to meet the needs of women and children escaping domestic violence still a
distant hope for the future. For women who require culturally appropriate
specialist service provision, or with additional support needs, or with no
recourse to public funds, the likelihood of finding a bedspace lessens further.
§ Few services have the capacity to meet the needs of women escaping domestic
violence who have additional support needs (e.g. substance misuse, mental
health issues). Therefore, the most vulnerable women often end up in the most
vulnerable situations. The needs of these women are less likely to be met by
generic services with a low unit cost per service user.
§ Supporting
People does not provide for children who need housing-related support, although there are more children living in refuges than adults. Research
tells us that domestic violence and child abuse are linked[14]
and that children may be affected by domestic violence in a variety of
problematic ways[15].
§ Some local authorities are looking to provide mixed sex services as a way
of 'ticking all the boxes' and domestic violence services are feeling pressured
to provide mixed sex services rather than lose out on contracts altogether. We
know from years of experience, research and statistical data that men are
overwhelmingly the main perpetrators of violence, and that violence against
women is a direct cause and effect of women's historical inequality within
society.[16] In order for survivors to
feel physically and emotionally safe, and to enable them to recover from the
effects of domestic violence, they require access to women only services.
Whilst some men do experience intimate violence, we know that the reasons for
this, their experience of it and their needs[17]
are very different to women's.
§ Some
Supporting People strategies are focused on people from within their area and will
not accept survivors from outside of their Local Strategic Partnership area.
This is not appropriate for domestic violence survivors, many have to move in
order to increase their safety and many perpetrators track their victims in
order to perpetrate further harassment, violence and in some cases to kill them
and their children. A woman may arrive
in a refuge service and then be required to return to where they came from, or
find a service in another area that will support them.
2.2 Enhancing partnership with the Third Sector
2.2.1 Women's Aid welcomes that:
§ Supporting
People has engaged with Women's Aid at a national level. Women's Aid participate
in the Supporting People Expert Reference Group and CLG Supporting People
officers participate in Women's Aid activities, such as Annual Conference and National
Housing Group meetings.
§ Supporting
People has engaged effectively with some specialist domestic violence services
at local level worked with them to identify, develop and expand service
provision to meet local need.
2.2.2 Women's Aid is concerned
that:
§ Supporting
People has not engaged with specialist domestic violence providers consistently
at local level. In some areas this results in a lack of understanding of the
prevalence and needs of domestic violence survivors and their children, and the
need to engage with specialist domestic violence service providers. This is not
only within the Supporting People partnership but other relevant local
strategic bodies such as the Crime and Disorder Reduction Partnership and Local
Strategic Partnership. In some areas the consequence is an over focus on
criminal justice provision, combined with a tendency to favour generic service
providers for housing-related support, often with little or no domestic
violence expertise.
§ Whilst women's
organisations represent around 7% of the total voluntary sector, they are
severely under-represented on Local Strategic Partnerships, comprising only 1.8%
of voluntary sector representatives[18].
Without sufficient participation in local decision-making bodies, women's needs
are not represented or prioritised in planning and funding strategies.
§ Small
specialist voluntary sector services often lack the experience or resources to
compete fairly against larger organisations in the tendering process. In some
cases specialist services have chosen not to submit a tender, even for services
that they currently ran, as they did not have the resources to do so.
§ The tendering process creates competition and hence, sometimes distrust and
conflict between previously cooperative organisatuions. This poses a threat to
effective partnership working to meet the needs of survivors and their
children.
§ Funding is outcome based and does not provide for
participation in local strategic bodies or allow full-cost recovery of core
costs.
§ In general, local tendering and commissioning processes are not complying
with the principles of the Compact agreement[19].
For example, in some cases, services have only learned that their service is at
risk after being told by a competitor who has been invited to tender for it.
Others are expected to submit bids within very short timescales.
2.3 Delivering in the new Local Government
landscape
2.3.1. Women's Aid welcomes
§ The
continuation of the Supporting People Programme until March 2010
§ Government proposals to
develop and implement a national Violence Against Women Strategy that will be
implemented locally. This provides an opportunity to provide more effective
support services for women and children that can build on the success of local
domestic violence fora and Supporting People work on domestic violence
and bring together health, housing and community safety.
2.3.2 Women's Aid is concerned
that:
§ The new commissioning
framework, including the requirement for many to tender for continuing
Supporting People funding, means that specialist domestic violence services are
under threat. It seems that our concerns are shared by many of our member organisations,
three-quarters of whom were concerned about a tendency to fund generic rather
than specialist domestic violence services. A significant proportion are also
concerned about the loss of specific women-only and BMER services.
§ Many
local authorities have not selected the National Indicators for housing-related
support and, although there are some statutory duties in relation to provision
for older people and disabled people, there are no requirements for statutory
provision for 'vulnerable people' and the specialist voluntary sector services
that support them.
§ Since
the removal of BVPI 225[20],
there are no National Indicators requiring the provision of domestic violence
support services. Although many local authorities did their best to meet the requirements
of BVPI 225, Women's Aid Annual Surveys show there
were still not enough places to accommodate all the women and children who
wanted or needed a service.
§ Feedback from the Regional Seminars shows that,
although some specialist domestic violence services are engaged in their local
strategic partnerships, there is no clear strategy for ensuring the full
engagement of the domestic violence sector in the setting of local priorities.
Engagement in local strategic partnership working is inconsistent and
non-existent for some providers. There are a variety of barriers to influencing
local strategic decision making and ensuring specialist domestic violence
services are able to participate and ensure that the needs of survivors are
represented, including:
- Lack of resources
- Lack of knowledge of
meetings etc
- Feeling that the provider
input is ignored and so it is pointless
- Being unable to access the partnerships (despite
efforts)
§ Some areas focus their service responses on criminal
justice when in fact a minority of survivors report to criminal justice
agencies[21]. The effectiveness of the Government's
emphasis on criminal justice responses and resulting service developments[22] is undermined by an
under-emphasis on other issues which are of equal importance in supporting
survivors of domestic violence and ensuring their safety - including specialist
gender-specific services to meet the immediate and long-term support needs of
women and children who experience domestic violence. Domestic violence specialist
services continue to attempt to meet the needs of survivors and ensure their
safety without the secure funding to do so.
§ Evidence
suggests that contracts are being awarded based on lowest unit cost than
quality and this can be dangerous in domestic violence especially since two
women are killed every week by a current or ex-partner.
2.4
Increasing efficiency and reducing
bureaucracy
2.4.1 Women's Aid welcomes that:
§ Supporting People aims to
increase efficiency and reduce bureaucracy.
§ Some Supporting
People areas have worked with local providers to introduce relevant, service
specific outcomes for domestic violence.
2.4.2 Women's
Aid is concerned that:
§ There is no quality
framework to ensure that services are commissioned on the basis of recognised
good practice in working with domestic violence survivors and real value for
money.
§ The generic QAF is not
wholly appropriate for specialist domestic violence services.
§ The generic framework for
evidencing outcomes achieved with service users is not wholly appropriate for
specialist support work with survivors.
§ Women's
Aid
services have found the client record cumbersome and prefer to keep relevant
information and measure success on appropriate outcomes for domestic violence
survivors as evidenced by the NSSDSV.
§ With lack of guidance, some
commissioners are ignorant about domestic violence - consequently, in some
cases, legal requirements had not been met in the procurement and commissioning
process and decisions have been challenged.
3. Implications of the removal of the ring-fence
3.1.1 Women's Aid is opposed to the removal of the
ring-fence. Local Authorities have a range of competing priorities and a very
limited budget. Local spending will follow the setting of local priorities
through the strategic partnerships. All evidence tells us that domestic
violence exists at similar rates of prevalence within every community and
therefore, services are needed within every community. Domestic violence must
be a local priority in every area and have a dedicated stream of funding to
ensure that services are provided.
4. What needs to be done to ensure that the
successes of the programme so far are not lost, or services cut, following the
change?
4.1 Women's Aid welcomes this Inquiry into Supporting
People and the fact that the Government is still
considering the Supporting People Programme and does not want to lose the success of the programme. In
order to do so however, lessons must be learned and positive steps taken to
ensure the continuation of services for domestic violence survivors.
4.2 Women's
Aid recommends that:
4.2.1 All
Local Authorities are required to adhere to the principles of the Compact
agreement with immediate effect and that compliance is monitored by central
government, and that there are penalties for non compliance.
4.2.2 A commissioning framework is
developed with guidance to ensure that quality is not lost to low unit cost.
This should take account of and value the expertise that has accrued within the
domestic violence sector, particularly in working with harder to reach groups.[23]
4.2.3 Minimum National Service
Standards for Domestic and Sexual Violence Services are required for the
commissioning of such services. National Occupational Standards appropriate to
the domestic and sexual violence sector workforce should be developed and implemented
and required to ensure a quality workforce. A National Accredited Training
programme (currently being developed by Women's Aid for all domestic violence
services), should also be funded and rolled out to support these standards.
4.2.4 Any tendering and
commissioning proposals undergo a Gender Impact Analysis as is required by the
Gender Equality Duty (which recognises the need for safe, separate services for
women) to assess the impact of any decisions made upon women survivors, and
that this process is monitored centrally.
4.2.5 A clear strategy for ensuring the full engagement of the domestic
violence sector in the setting of local priorities is developed, implemented
and monitored. This must include consideration of resource issues and ensure
that the voices of survivors are represented.
4.2.6 Steps are taken to build the
infastructure capacity of small organisations to meet current strategic demands
and and grants awarded take account of strategic development and training needs
as part of full cost recovery.
4.2.7 There is a central
government-led, long-term plan to ensure security of funding for domestic
violence services and the commitment to ensuring appropriate services in each
area is supported by nationally dictated performance indicators.
4.2.8 There is recognition that
abused women and their children seek support in a range of settings, including
refuges, drop in centres, outreach services and support groups, and that these
are properly and consistently funded in all areas.
4.2.9 Funding is provided to
ensure that women survivors of violence against women from black and other
minority communities can access specialist provision in every local area and refuges are provided with adequate 'last
resort' funding to enable them to support women with no recourse to public
funds.
4.2.10 Domestic violence service
provision is expanded and resourced to ensure that any women needing assistance
can get it regardless of her support need and/or financial status.
4.2.11 A funding stream is identified
for dedicated, therapeutic work with all children and young people who come
into contact with domestic violence services, to address the impact of domestic
violence upon their well being and development.
4.2.12 Women's
Aid, in partnership with its member services, survivors and government, is
funded to develop an appropriate, outcomes-based framework for evidencing work
with survivors and their children and these become a commissioning requirement.
4.2.13 CLG
develops guidance for the provision of housing related support in order to meet
the needs of domestic violence survivors and their children and other people
who fall into the 'vulnerable people' category.
4.2.14 CLG
Guidance is developed with the Audit Commission to ensure that Local Strategic
Partnerships are competent to identify the needs of local people and can
develop community profiles that address domestic violence and are not based on
police statistics, but on wider community consultation.
5. What opportunities the change in the funding
mechanism will offer for innovation and improvement of housing related support
services?
5.1 In Women's Aid current
experience, opportunity is limited because of the lack of a secure funding
framework, competitive tendering for services, lack of indicators for domestic
violence/violence against women support as described in the responses to the
questions above.
5. 1 Women's
Aid would welcome the opportunity to work with Government however to:
· Identify
innovation and good practice in domestic violence/violence against women
service provision
· Develop
a secure funding framework for provision of domestic violence/violence against
women support services in all local areas and, if necessary, develop a National
Indicator for violence against women.
· Develop
guidance for the provision of housing related support in order to meet the
needs of domestic violence survivors and their children and other people who
fall into the 'vulnerable people' category.
· Implement the National
Service Standards for Domestic and Sexual Violence (NSSDSV) for use in commissioning
and assessment of service provision.
· Develop an appropriate, outcomes-based framework for
evidencing work with survivors.
· Provide training to
relevant professionals to ensure a good understanding of domestic violence
underpins any decision making processes.
May 2009
[1] See:http://www.womensaid.org.uk/downloads/WA_survey_dv_service_findings.pdf
. Data from our Annual Surveys show that 19,836 women and 24,347 children
were provided with refuge-based services in 2004-5, and a further 196,205 women
and 129,193 children accessed outreach, floating support and other services.
[2] See Walby, Sylvia and Allen, Jonathan (2004) Domestic
violence, sexual assault and stalking: Findings from the British Crime Survey (London: Home Office
Research, Development and Statistics Directorate). Their research showed that -
while 45% women and 26% men had experienced at least one incident of
inter-personal violence in their lifetimes - women are much more likely than
men to be the victim of multiple incidents of abuse, and of sexual violence:
i.e. women constituted 89% of all those who had experienced 4 or more incidents
of domestic violence.
[3] Council of Europe
(2002)
[4] See Abrahams, Hilary (2007)
Supporting women after
domestic violence: Loss, trauma and recovery (London: Jessica
Kingsley Publishers); Humphreys, Cathy and Thiara, Ravi (2002) Routes to safety: Protection issues facing
abused women and children and the role of outreach services (Bristol:
Women's Aid); Bossy, Jeanine and Coleman, Stephen (2000) Womenspeak: Parliamentary domestic violence
internet consultation (Bristol: Women's Aid Federation of England);
Parmar, Alpar, Sampson, Alice, and Diamond, Alana (2005) Tackling domestic violence: Providing advocacy
and support to survivors of domestic violence
(London: Home Office Development and Practice
Report 34).
[5] Walby, Sylvia (2004) The
cost of domestic violence (London: Women and
Equality Unit)
[6] See for example, Gudnadottir, E., Smith,
S., Robson, S., and Corry, Darlene (2007) Where
are the women in LSPs? Women's representation in Local Strategic Partnerships
(available at www.wrc.org.uk)
[7] The Compact is the agreement
between government and the voluntary and community sector to improve their
relationship for mutual advantage and community gain and includes codes of good
practice.
[8] The importance of women-only services - not only
refuge accommodation - has been emphasised by a research report by the Women's
Resource Centre. 97% of women supported a women's right to choose a woman-only
support services following sexual assault; 90% of women think it is very or
quite important for women to be able to choose to see a woman professional when
reporting crimes of harassment or domestic/sexual violence; and 78% of women
think it is very or quite important for women to be able to choose to see a
woman professional when accessing counselling or joining a support group on
personal issues. Women's Resource Centre (October 2007, forthcoming) Why women-only? (London:
WRC)
[9] The Equalities Act 2006 requires Local Authorities to
publish Gender Equality Schemes and carry out gender impact assessments on
all current and new policies. Providing an 'equal' service for men and for
women in one location will not necessarily promote gender equality - if women
are disproportionately affected by domestic and sexual violence and then
reallocating funding from their services can actually do the opposite.
[10] For example, Independent Domestic Violence
Advisors, Multi Agency Risk Assessment Conferences, Specialist Domestic
Violence Courts.
[11] Only 24% of survivors report the violence to justice agencies - Allen & Walby BCS 2004
[12] Statistics collected by Women's Aid from local
domestic violence services show that on a typical day 3648 children are resident
in refuge accommodation in England.
[13] Government
Select Committee on Domestic Violence 1997
[14] Humphreys &
Thiara, 2002
[15] Royal College of Psychiatrists (2004)
[16] See for example, Walby and Allen (2004) "Domestic violence, sexual
assault and stalking"
[17] See Amanda Robinson and James Rowland (2007) "What do men want?" Safe
Summer 2007
[18] Gudnadottir, E., Smith, S., Robson, S., and Corry, Darlene (2007) Where are the women in LSPs? Women's
representation in Local Strategic Partnerships (available at www.wrc.org.uk)
[19] The
Compact is the agreement between government and the voluntary and community
sector to improve their relationship for mutual advantage and community gain
and includes codes of good practice.
[20]
The aim of Best Value Performance Indicator 225
(BVPI 225) was to assess the overall provision and effectiveness of local
authority services designed to help victims of domestic violence and to prevent
further domestic violence. This indicator is no longer in use.
[21] Only 24% of survivors report the violence to
justice agencies - Allen & Walby
BCS 2004
[22] For example, Independent Domestic Violence Advisors, Multi Agency
Risk Assessment Conferences, Specialist Domestic Violence Courts.
[23] There is a range of evidence that older women, younger women, women
with mental health and/or substance misuse issues, disabled women and women
from BME communities may find it particularly hard to access services
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