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