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