Ofsted Inspection of Children's Services - Children, Schools and Families Committee Contents

Examination of Witness (Question Numbers 1-19)


20 JANUARY 2010

  Q1 Chairman: May I welcome Dame Denise Platt to our deliberations and say what a pleasure it is to see you. You are in splendid isolation there; normally only the Secretary of State is so isolated, but then he has a phalanx of supporters behind him. It is very good to see you.

Dame Denise Platt: Thank you.

  Chairman: As I said outside, I hope you will be gentle with us because, in a sense, this is an area in which we are least experienced as a Committee, so we are looking for your help and experience to guide the Committee in what is a new—short but new—inquiry looking at the capability and capacity of Ofsted to inspect children's services. Dame Denise—do you mind if we revert to Dame Denise, rather than your full title?

  Dame Denise Platt: Denise would be equally okay.

  Q2 Chairman: Denise is fine—that is excellent. We always give our witnesses a chance to say something. Perhaps you could do it in the form of telling us a little bit about your experience of the changing nature of inspection in the area that we are looking at—give us some background.

  Dame Denise Platt: I am Denise Platt and you have me as a member of the Audit Commission, but that is a recent role and not the prime reason for my being here. I was the founding and closing chair of the Commission for Social Care Inspection, which was set up in 2004 and abolished in 2009. Prior to that, I was the chief inspector at the Social Services Inspectorate, based at the Department of Health. Before that, I was the social policy adviser of the Local Government Association, and before that I was the director of social services for Hammersmith and Fulham, during which period I was the president of the Association of Directors of Social Services.

  Chairman: You have been around.

  Dame Denise Platt: I have been around, yes. I am now retired—ish. I am a qualified social worker by background, although I am no longer registered. My whole background is in social care, in local authorities and in the health service. I trained as a hospital social worker and did part of my training at Great Ormond Street, so I have a knowledge of children with disabilities, too. I go back a long way.

  Q3 Chairman: Could you tell us a little bit about the way you have seen inspection go, from your period between 2004 and 2009, and take us through to the time when there was this translation into Ofsted having responsibility for the inspectorate?

  Dame Denise Platt: Yes. The Commission for Social Care Inspection was set up in 2004—it began its work in 2004. It was established to bring together all inspection of social care services—both adult and children's services—across local government, public and private sectors, and the voluntary sector. That in itself was a bringing together of three different inspectorate functions: the Social Services Inspectorate out of the Department of Health; the children's registration functions of what was then the National Care Standards Commission, which was the registration of adoption and fostering services and children's homes; and the capacity that had been held jointly between the Social Services Inspectorate and the Audit Commission to look at value for money in social care services. So, the intention was to have one social care inspectorate, for the first time looking across the piece, and partnering its sister inspectorate, the Healthcare Commission, as well as working alongside Ofsted. Times change—as they did before we had reached the end of our first year. We got within 17 days of the end of our first year, which was luckier than our predecessor commission, the National Care Standards Commission, which had been in existence only 17 days before it was abolished and the formation of the Commission for Social Care Inspection was announced. We got within 17 days of the end of our first year, but the evening before the 2005 Budget, the heads of the different public service inspectorates were phoned to say that as part of the Budget announcement—I think we were in an election year—there was going to be a rationalisation of public service inspectorates and the 11 would be reformulated into four. For most public service inspectorates, that involved bodies amalgamating with other bodies, but for the Commission for Social Care Inspection, it meant that half our functions—those to do with children's services—were to be transferred to Ofsted, and the adult social care functions, together with the Healthcare Commission's functions, were to be transferred to an entirely new inspectorate: the Care Quality Commission. However, that separation was on a different time scale. So, the announcement was made in 2005, and the transfer of children's services to Ofsted took place in 2007, while the formulation of the new inspectorate, which included adult social care, did not take place until 2009. That does have a bearing on the level of resources transferred to Ofsted, because it was not a separation down the middle. It was a carving out of resources and of people who spent more than 50% of their time working on children's services. The separation also coincided with the development of Every Child Matters. There was a desire in government to have just one inspectorate focusing on that policy area, and focusing on the development of children's trusts, which were bringing together organisationally, in local government, education services and children's social care services. The intention was to have one inspectorate, which could focus on that policy and its development and progress. As you can imagine, we in the commission had views about that.

  Q4 Chairman: What sort of views?

  Dame Denise Platt: We felt that we had not been given a chance to get going as an inspectorate before change was on the cards, and there had already been change in this area. We also felt that, although there are good arguments for focusing one inspectorate on one policy development, you could also argue otherwise very plausibly. If the service was in turmoil and being restructured, and a lot of new people were getting used to new roles, responsibilities and duties, and doing things in new ways, the last thing you needed was to throw up into the air a regulator that knew about children's services and social care and put it into the same reorganisational turmoil. From my experience as a director of social services—a director who came into post following an incident involving a child death—I knew that reorganisations are the maximum point of risk in these services, because files are being moved around, people are being moved around, and continuity with individuals is lost. So, we felt that it was the wrong time. We also felt that the way in which the Department for Education and Skills, as it was at the time, wished to carve up what we did so that some of our support role was to go to children's services advisers in the government office, and our inspection role solely, together with responsibility for the performance assessment, was to go to Ofsted, also dissipated that expertise and meant that there were two organisations that were in their infancy in the government offices and in Ofsted—and in the service, so in fact it was three—and trying to find their feet on new ways of doing things at a moment of very high risk for those services. We also felt that if there was going to be a reorganisation of public service inspectorates in their entirety, there might be another way of doing this, and that consideration might be given to having a children's services inspectorate just focusing on children, whether those children were in the criminal justice system, the health service, local authorities or wherever. If you look at the research and the statistics, children with disabilities are heavy users of the health service, and children in care quite often find themselves involved with the youth justice services and are often to be found in prisons or youth offending institutions. They are the same population of children, and Every Child Matters was focusing on the same outcomes for children wherever they were. We felt that if people really wanted to be radical, they might give some more thought to the process and look at an inspectorate that was not focused on institutional arrangements but that focused on children's experience and tracked them through some very complicated systems, rather than having inspectorates that focused on systems that the children had to pass between.

  Q5 Chairman: The Government were keen for this overall rationalisation of inspectorates across the piece, weren't they?

  Dame Denise Platt: Yes. So the rationalisation came before the policy was developed, I think—certainly in adult social care.

  Chairman: I think that has warmed us up, Denise.

  Q6 Annette Brooke: However we carve it up, we seem to lose some essential relationships, and I wonder if you could comment on whether you think we have lost everything in terms of looking at the whole family—from the time when you were looking at the whole of social services to now—when there is focus on children's services within the local authority.

  Dame Denise Platt: That is one of the other points that was made. The link between children's services and adult services in local government is absolutely critical. I would not say that the change is to have a separate emphasis on children's services and a separate emphasis on adult services in local government.[1] I think that it is foolish to comment on structural arrangements at local level. I am a firm believer in bodies at a local level determining structures that make the most sense to them locally. Structures do not really solve problems, but they can certainly get in the way of issues. However, I think that it helps to have an external body that can look at how children's and adult services relate and integrate their approach to families. When children's and adult services were together, some people always lost out in that arrangement, but the arrangements for children with disabilities to get independence in adulthood and make the transition to adult services are notoriously difficult. As the Commission for Social Care Inspection, we were able to focus on that, point out the difficulty of that transition, and exert pressure to try to make the transition easier. We also focused on the social care needs of adults, where there were children at risk. Information is kept very specifically about the risk factors that place children on risk registers, but in my view insufficient information is held about some of the problems and challenges that families and parents face in those situations—the mental health and drug problems that many parents face, for example, and the domestic violence issues that exist in families. You need to be able to look at all those circumstances and form a view. One of the things that we were able to highlight as the Commission for Social Care Inspection was that the eligibility criteria for adult services did not include risk to a child. They should have, but very often they did not, so if a children's service was looking for support in adult services for a family, there were sometimes unhelpful barriers within those services, which meant that parents would often have to wait quite a long time for the assistance that they needed. Therefore, they did not improve, and their child's situation deteriorated and there was a spiral. The child had solutions devised for them while the adults were still waiting for some of the assistance. As a social care inspectorate, we purposely focused some of our attention on those issues so that we could look at the family.

  Q7 Annette Brooke: Thank you. We recently saw the very sad case of a mentally ill mother, so your comments are pertinent. Considering your long experience, are we steadily becoming more risk-averse nowadays, or is it just part of a pattern of everybody reacting to a high-profile case at the time only for things to settle down after a while?

  Dame Denise Platt: Particularly focusing on child protection, or indeed any social care issue, part of what you are dealing with is trying to assess the risk in the situation in which you as a professional are trying to intervene and do things differently. There is a limit to how far process and procedure can take you. What I have seen is that when we have an incident, we create a process and a procedure in an attempt to nail down the particular issue. It is almost like squeezing a balloon: you batten down one bit and suddenly another bit blows up. You cannot deal with the services in that way. The process and the procedures do not make good decisions. They have to be there because it is proper that you have a systematic way of supporting children and families in difficult situations, but the processes and procedures should prompt thought and deliberation, because the situations that we are dealing with are all about judgment, and you have to balance a whole range of factors to make those judgments. You really have to understand children and you have to understand family dynamics. You have to be able to talk to children—and talk to them separately from their parents. You have to understand the dynamics of family behaviour. You have to understand all the circumstances and you have to make a judgment. Procedures can prompt you to think about things, but they cannot make the decisions for you. I think that the scarcest commodity in the day of any professional—be they a social worker or a health visitor—is time. That is the most precious of commodities and it is the scarcest. You need time to reflect and think, and you need time to spend with the children who are the focus of your attention. You also need time to talk to the services that you are trying to put in place to support a family. If the procedures are about diminishing risk, I do not think that they can ever do more than prompt you to think. The pursuit of the perfect process gives people a very false sense of security. In some cases I have seen, the process and procedures are followed to the letter but incidents still happen, because nobody has asked the "why" question or asked what, how or why something is happening. They have just recorded that these things are happening, not what that means and what it is this telling them. How to interrogate the information that you have in front of you is an absolutely critical skill. It is the same for an inspector. You look at all the information that you have about a department or a service—whatever that service is—and you have to ask: "What is this telling me? How does this inter-relate? What is the analysis that I can add to this that is more than just adding up these figures and saying this number is met. How are they getting there?" Just looking at the information doesn't tell you anything about the experience of the children and their families. You have to start with their experience of services and of you.

  Q8 Annette Brooke: Are we making progress in creating that time for social workers? Are we making progress with the training of social workers?

  Dame Denise Platt: No. The new training of social workers and the new social workers degree have only just provided a cohort of social workers who are in their second or third year of practice. We have not got enough experience of the new degree to know how that assists people. I think the social work task force said all the things about social work that need to be said. I am a big supporter of its analysis and its conclusions. I think departments are very preoccupied. There are significant staff shortages—probably in those areas where departments are having the most difficulty. No professional social worker in the current climate will put their reputation and their expertise on the line in a chaotic department. If a department isn't going to have proper processes in place, isn't going to support you in a very difficult task, isn't going to supervise you properly and isn't going to assist you to come to grips with some very complex situations, in those circumstances no professional will put their professional reputation on the line. Departments have to be prepared to support professionals to do an extremely difficult task, rather than just using them as cannon fodder. I know that that is an emotive thing to say, but it is something that front-line workers have said to me. I am a governor of a university that runs a social work course, so I hear what social work students say quite a lot.

  Q9 Chairman: Which university is that, Denise?

  Dame Denise Platt: The University of Bedfordshire.

  Q10 Mr Chaytor: Could you describe the different types of inspection that CSCI used, particularly saying something about the frequency of those inspections?

  Dame Denise Platt: The frequency of inspections—goodness. That is forever changing really. There were a number of different processes that the commission had in place. We registered and inspected for the purposes of registration those services such as children's homes which the Government decided needed to be registered, and they were services across the piece: public, private and voluntary sector. So there would always be an inspection as part of that process—a discussion and an inspection. That could be an unannounced inspection; sometimes announced, but quite often unannounced. We also carried out service inspections, which were an in-depth look at how a council was organising its children's services and during the course of those inspections you would look at the quality of casework. So you would look at the files and you would track what happened to children. When I became chief inspector in 1998 there wasn't a pattern of regular inspections of those services. We instituted a pattern of service inspections that were to take place every three years so that you could get a baseline of understanding. It was not possible to say which departments were doing well and which were not. The Government introduced the joint area review process round about 2003, which was a process involving all inspectorates, including the Commission for Social Care Inspection and led by Ofsted to look at all the children's service in a particular area to see how well children were being served across the piece. There is another very important process that the Commission for Social Care had, which was the assessment of performance. The inspectorate had what we called a business relationship manager who had regular contact, at least a monthly meeting, with the council. If you were a good council and had done well, it might be a quarterly meeting; the minimum was a monthly meeting. If you were in real difficulties, you might have a meeting with the inspectorate every fortnight. The purpose of that meeting was to discuss the annual performance assessment and to find out the council's priorities for improvement in these services, how it was going to go about it and whether it seemed to have a realistic approach to going about it. The council would then engage with improvers—the improvement and development agency—to effect that improvement or link with other councils. We would be sent information about progress, which was challenged. For instance, "You said you were going to do this. Have you? What are the problems you have encountered? What are the difficulties? Where are you at? Let's look at what is holding you back, how you might do it differently. Have you talked with this council? Have you talked with that organisation?" There would be that process of regular engagement, which would be formally recorded and be part of the inspectorate's information about a particular council. It is really important to understand what happened to that role when we handed over our responsibilities to Ofsted. Government said, "We want the government offices of the region to take on that role." So that role was transferred to children's services advisers in the government office of the region. It was a continuing debate and discussion between us and DfES, because we felt that was singularly unsatisfactory; that you could not do an annual performance assessment on a council based on receiving information and one meeting a year. You could not. You needed the context, the engagement and the discussion. The annual performance assessment that we did in adult social services brought together a volume of information. We would agree with the council that it was satisfied that the information that we had, the information set, was sufficient for us to draw a judgment about them.

  Q11 Mr Chaytor: But since the transfer to the regional offices, does the process still exist, the same frequency of engagement?

  Dame Denise Platt: I don't know; I doubt it. It might. In many cases, the children's services adviser is not there just discussing children's social care. It took almost until March 2007 to separate out where the serious incident notifications would go. Councils were only notified of that within two weeks of the actual transfer. It relies very heavily on the transfer of information from the children's services advisers to Ofsted to do the annual performance assessment. It was one organisation giving information to another. Whereas in the commission, we had the totality of the relationship: the context, the understanding and we knew how to interpret the regular monthly information because we had had the conversation.

  Q12 Helen Southworth: Can I ask about how you manage the balance of self-assessment within local authorities and the on-site assessment by CSCI?

  Dame Denise Platt: Yes. I think the self-assessment process is very useful and helpful. I thought that councils always felt that that particular process was rigorous for them and was helpful for them to scrutinise the way that they worked and did business. It was the role of the inspectorate to have a really tough discussion about that self-assessment. If you have had regular contact with the council, you will know whether the self-assessment is on the ball—there are fewer opportunities to be bamboozled—and you can have a conversation about the self-assessment. In adult social care, when it came to having the discussion on the self-assessment and all the information that we had about a council, we would ask the council to demonstrate some of what it had said by taking us to a centre where these things work or talking to the people who have benefited to prove it. Give us real evidence, other than the bits of paper, that what you have assessed is an okay experience for the children and families. It would be quite a dynamic process. How councils organised that was always interesting. Sometimes children were bussed in to see you in the town hall and sometimes you went out to see children somewhere else, but it always told you something about a council. You have to know what makes a council tick to come to a conclusion about how they do business and to be the independent challenge. We would try, in the performance process, to balance those sorts of self-assessment challenge and visit arrangements. It is also important to say that the inspectorate has to be accountable to the council for the validity and the consistency of the judgments about it. They cannot just be based on a relationship. It cannot just be, "I know you and you know me and I think you're okay." It has to be rigorous. The inspectorate also has to have some rigorous quality-assurance processes. In the commission, when this process was going on, it was a concerted process of a three or four-month period starting in June or July—not very easy for councils and probably very difficult for education services. There would be internal challenges in the inspectorate at local level about whether all inspectors involved were all using information that they received in the same way and interpreting the indicators in the same way. That would go to regional level so there was a regional consistency. Are different regions using information in the same way? Can we be sure that we are comparing Lincolnshire with Cornwall? Is the information being used correctly? Then that process would be repeated at national level, particularly if there was a significant change or a worry about a council. There would then also be an appeals process, if a council wished to appeal against a judgment, where we involved independent people who had been directors of social services. In carrying out the process with the council, whether it is a self-assessment or a performance assessment, it has to be quality assured within the inspectorate. There cannot just be one inspector and their supervisor. It has to be robust and withstand scrutiny, and other councils have to be able to recognise the validity of it.

  Q13 Helen Southworth: You are touching on what I wanted to go on to for the next question. Certainly my experience when making inquiries across local authority areas about children who have run away or gone missing, either from home or from care, has been that you can get very variable responses. Some local authorities will tell you that there is an issue in their area and what work they are doing across agencies to deal with it. They can be very rigorous and look like they have problems, which they are dealing with. Sometimes other local authorities might say that there is no problem. That can either be because there is no problem or, more likely I'm afraid—

  Dame Denise Platt: We haven't spotted one.

  Helen Southworth: They haven't spotted one, and maybe the police in that area are saying that there is a significant problem. How do you manage that? It is about those people who are self-aware, rigorous, identifying areas that they want to improve, constantly striving to do better and honest about near misses. How do you make sure that their self-assessment is not poorer than the authority's that says, "There is no problem," "We are doing everything well," and "We are excellent"?

  Dame Denise Platt: You have to test it. You have to have the discussion. If someone says there is no problem, you have to ask them how they know—"What analysis have you done? How do you know?" You would have to ask them, if the police were complaining and they were not, "What is the discrepancy?" You would have to interrogate it. You could not just accept it and say, "Tick, done. Self-assessment received. Looks okay." You would have to interrogate and discuss it and, if necessary, ring up the police and ask them. You would have to do all the things you would expect a canny social worker to do when dealing with a family that says there is no problem—"I am going to do a bit more exploring and find out." None of these processes should just arrive on your desk without some questioning around them, which can be a difficult process for the council concerned. If you are experienced, you can tell a good self-assessment. If you are looking at performance indicators, sometimes they are so good you have to ask questions about them because you have to know why. You have to say, "hang on a minute. Why are you out-performing everyone else? Have you added it up right or are you really out-performing everyone else? If you are, I want to come and see how." So I think there has to be an engagement rather than just taking things at face value. One of the most critical and improving things an inspectorate can do is challenge and follow-up. When the Commission for Social Care Inspection did a service inspection, it would go and present its findings to whatever council committee was appropriate. It would do it in public and present findings and take questions. Similarly, when the Audit Commission has done an audit, it will present and take questions. That scrutiny is part of your process, but it is also part of getting the council to understand the issues that you are raising and having councillors hear that directly. How do you challenge this? Let me give you an example. I will not name the council, because I will not say which year, but I do remember, as chief inspector, having an inspection into children's services in a council that had just been nominated council of the year. Their assessment of themselves was very good. Our inspection had found they were not very good. Not only were they not very good, we were going to place them on special measures as a result of their not being very good. Part of the process that I would then have would be to call in the leader of the council, the lead member, the chief executive and the person responsible to go through and say, "This is why we are doing this, and this is why I think what I think." I had one of these meetings with this particular council and two days later I got a phone call from the leader saying, "Denise, you're wrong." So I said, "Okay. Tell me how I'm wrong." The leader said, "I have investigated what you have said and we are even worse than you found. I have been to have a look myself and the situation is awful." So even we can get it wrong when we do not discover the depth of it. As an inspectorate you cannot offer guarantees. Most of the process is about getting the service and the council to get a grip, to actually start solving the problems themselves. A process that makes people hide information from you, or a process that gives false assurance, or that is not robust in its discussion, is of no use to the public, because the services are not getting the scrutiny that they need. They are of absolutely no use to the council, because all it is doing is trying to defend its position.

  Q14 Helen Southworth: How important do you think it is to involve the children who are experiencing the service in the inspection process?

  Dame Denise Platt: It is where you start. When we were in the commission, we developed a project called LILAC, which we ran with A National Voice, the organisation for young people in care, where we trained young people to talk to those who were receiving children's social services to find out their experiences. Talking to children is where we start. It was very successful. Ofsted struggled to find the funding for it. I am not sure whether it did, but it was keen to support the initiative that involved children as experts by experience in inspection teams. It was a process that we used in adult social services, too. The young people were absolutely brilliant; those in the system would talk openly and freely with people who had had the same experiences. Inspectors learnt a lot. It did not get in the way or replace inspectors doing what they had to do, but it added value. The children's rights director was located with us. He is now within Ofsted, but he used to orchestrate consultations with large groups of children whom people said it was not possible to consult, such as the under-fives. Well, we can find all sorts of ways of finding out through games what children under the age of five think. We took about 400 of them to Legoland and found out an amazing lot of things from them when they were there.

  Chairman: Legoland leads us naturally to Graham.

  Q15 Mr Stuart: Thank you so much, Chairman, as ever. You remain sceptical about the transfer of the inspection of children's services from CSCI to Ofsted. Have your fears been borne out? Have there been any benefits from the transfer?

  Dame Denise Platt: I guess that any arrangement can be made to work, if we know the essence of what made what we are receiving work. For us, the continuous engagement made the difference, and I suspect that that might be a system that Ofsted may be looking at. The majority of people who transferred to Ofsted were our front-line inspectors and some business relationship managers, but no one from third tier, second tier upwards.

  Q16 Mr Stuart: What proportion of your staff did transfer?

  Dame Denise Platt: About 300 staff transferred. At least 282 people had spent more than 50% of their time on children's services. They would have been our analysts across the piece. The bulk of them were inspectors, but not many analysts with experience of interrogating data in children's services transferred. Ofsted was inhibited by not having senior experience. It did not appoint anyone in a senior position with a social care background until very recently. It would acknowledge that it was the lack of strategic expertise as well as practitioner expertise. Some of the ways in which Ofsted has been asked to look at serious case reviews have put a new process in place. Clearly, the ability to look across education and welfare services, and see things in context is helpful, but it is not the totality of a child's experience. If we could bring together the intelligence across child minding and those services that are very important for under-fives, we would have a very useful picture. Ofsted was asked to do a difficult thing; it was asked to take on the adult learning inspectorate at the same time as we were transferring children's services. From my perspective, I felt that their emphasis should have been focused on learning and education across a whole range of disciplines and that child welfare was a bit of an uncomfortable partner in that bigger inspectorate. These are services about which you have to be vigilant.

  Q17 Mr Stuart: Do you think by Ofsted having this area of responsibility, it has led to a loss of focus? The Committee, in our report, said that it feared that this area would be lost within it.

  Dame Denise Platt: Yes, it has. I think it has taken it a while to get to grips with what it has inherited.

  Q18 Mr Stuart: You have said that process isn't procedures, and does not provide you with the right decision. It provokes, hopefully, thought—a series of interesting ones. But going back to the need for engagement and the need to challenge and follow, for the inspection of those critically important services, is the current situation in a worse position in terms of resources or focus?

  Dame Denise Platt: You would have to ask the people who are on the receiving end of inspection; I know that you are going to see them later. In children's services generally, I think the service has improved in dealing with many situations that are encountered, but quite often, these are situations where there are straightforward solutions. Where the services struggle is where there are very complicated family situations and a number of different agencies involved. Sometimes the behaviour of people in families towards each other is almost beyond comprehension, and those situations are very complicated and need a lot of skill, time and attention. I think that the services are still grappling with how they can be effective in turning around those families. It needs co-operation with mental health services and child and adolescent mental health services—a whole range of disciplines—which need to do more than monitor, but develop effective intervention that can get to grips with some of those family circumstances and change situations.

  Q19 Mr Stuart: A point about children's trusts, which were formalised in the Apprenticeships, Skills, Children and Learning Act, strikes me, and probably others members of this Committee. Again and again, we talk about the need for integrated services, and yet, practically no witness who came before us has talked about the very organisation, now in statute, which is supposed to provide that precise integration that you're talking about. Can you comment on children's trusts, and whether they are taking a wrong road, or are they just too early for us to judge?

  Dame Denise Platt: I can put on my Audit Commission hat at this point and draw your attention to a report by the commission called "Are we there yet?", which looked at the governance and the use of resources in children's trusts. It demonstrated that the organisation called the Children's Trust was not producing any difference in outcomes for children, and that in the governance of many children's trusts, partners were not sufficiently senior, the oversight and management of an integrated budget was not doing much that was different, and the relationship of the children's trust and local strategic partnerships was not clear.

1   Note by witness: I intended to convey that the change to have a separate emphasis on children's services and a separate emphasis on adult services in local government is not necessarily a bad thing-although it does create different challenges in collaboration across services. My main point was to underline that local services need to design local structures which make sense to them when delivering the outcomes required of national policy. Back

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