Written evidence submitted by the Chief
Fire Officers Association (CFOA)
EXECUTIVE SUMMARY
1. Fire and Rescue Authorities (FRA's) are positioned
within the local government family given their duty to provide
an effective prevention, protection and emergency response service
to local communities and to mitigate the risks to life and property
as identified through Integrated Risk Management Plans (IRMP's).
FRA's were subject to Comprehensive Performance Assessments for
the first time in 2005 and were included in Comprehensive Area
Assessments (CAA) up until the demise of the CAA assessment regime
in 2010.
2. The Chief Fire Officers Association (CFOA)
broadly supports the submission made to this Select Committee
Inquiry from the Local Government Association, particularly in
relation to the principles of sector led performance assessment,
self regulation and sector led improvement.
3. CFOA believes that Integrated Risk Management
Plans form a key foundation by which value for money, performance
and risk mitigation should be measured given the underpinning
principle of IRMP's, namely allocating resources according to
risk.
4. CFOA supports a sector driven approach to
operational assessment and performance given the particular considerations
associated with the delivery of an emergency response service
in what are often hazardous and risk critical situations. The
fire sector has developed and implemented a robust and effective
Operational Assessment Toolkit, in conjunction with the LGA and
the Chief Fire & Rescue Adviser, which has helped to guide
improvements in operational performance and delivery. CFOA believes
this approach should be encouraged and supported and should add
to the body of evidence produced by individual FRA's to demonstrate
effective service delivery to the communities they serve.
5. Over the next few years the financial resources
of FRA's are to be cut significantly due to the pressures on public
spending announced in the Spending Review 2010. Any future audit
arrangements, either commissioned locally or nationally, need
to have regard to the ongoing financial resilience of Authorities
especially given that FRA's are required to contribute to overall
national civil resilience in the event of widespread threats e.g.
from extreme weather or terrorism.
6. As yet there is little clarity on the future
triggers for Secretary of State intervention in any one Authority
or any details of who would carry out any such directed inspection/intervention
where the impact of failure of any one Authority could be very
high. CFOA would support the LGA view that intervention should
only be initiated once the sector has first had the opportunity
to provide improvement support to those Fire and Rescue Services
at risk of failure. CFOA believes that the triggers for intervention
need to be clear, transparent and communicated to the sector.
THE CHIEF
FIRE OFFICERS
ASSOCIATION
7. The Chief Fire Officers Association (CFOA)
is a professional membership association and a registered charity.
CFOA members are drawn from all UK Fire & Rescue Services
representing the senior executives and managers of the Service.
Through the work of its members the Association supports the Fire
and Rescue Services of the UK in their aspiration to protect the
communities they serve and to continue to improve the overall
performance of the fire sector. CFOA provides professional and
technical advice to inform national fire policy.
THE SUBMITTER
8. Susan Johnson OBE was elected to the CFOA
Board in 2009 with responsibilities for strategy, policy and guidance
relating to performance improvement, resources, governance and
statutory responsibilities as they affect the fire sector. Susan
is Chief Executive of County Durham and Darlington Fire &
Rescue Service, appointed in 2005, prior to which she spent a
number of years working at strategic levels in the private and
public sectors.
DETAILED RESPONSE
Context and Introductory Remarks
9. The Fire and Rescue Service (FRS) is a locally
delivered service and falls within the local government family.
CFOA has been developing a sector led improvement framework for
the fire, in partnership with the LGA, for over a year in anticipation
of a reduction in the regulation and inspection burden and a move
to risk based inspection and sector driven performance assessment.
The fire sector has delivered year on year improvements in performance
and value for money since the introduction of Comprehensive Performance
Assessment into Fire and Rescue Services in 2005. However the
burdensome approach under Comprehensive Area Assessments had begun
to negate any positive benefits of external inspection as the
focus had to moved more towards "feeding the inspection regime"
rather than on driving improvement. Previous performance regimes
have also assumed that one size fits all, have been heavy on process
and light on outcomes and have resulted in the law of diminishing
returns. The sector must be trusted to develop mechanisms which
are fit for purpose, which respond to the public need to have
visibility on how its service is performing and which takes account
of local context. CFOA submitted a detailed review of the fire
sector's experience of CAA to the Audit Commission in February
2010.
10. CFOA welcomes the scaling back of the performance
framework and believes that a new approach to assessment, performance
and improvement must be owned by FRS's themselves and be based
on robust Integrated Risk Management Planning, provide transparency
to communities, be informed by professional judgment, encourage
sharing experience and good practice, and be guided by effective
leadership and commitment to driving sustainable improvement.
11. The key principles of a sector led approach
to performance and improvement are:
Sector inclusivity- Every FRS should benefit from
the sector led improvement framework and have access to identified
support structures to maintain value to communities and the reputation
of the sector.
Community First - FRA's are accountable to the communities
they serve and strive to understand their needs and mitigate their
risks. Therefore FRS's should be given the first opportunity to
address a slowing or adverse change in performance. This organic
approach is more likely to be effective, sustainable and less
expensive than central intervention.
Constructive (critical) friends - From peer reviews
to specific interventions must be underpinned through relationship
building, openness and trust.
Collective ownership of the reputation of FRS UK
- FRA's as a whole need to take responsibility for sector wide
successes and problems.
Ownership- Improvement is the responsibility of the
individual Fire & Rescue Authority. No central organisation,
or Government, should replace this responsibility.
12. The fire sector has developed a self assessment
approach to reviewing the effectiveness of operational delivery
through the Operational Assessment Toolkit. Given the risk critical
and potential hazardous environments within which the Fire and
Rescue Service operates and the contribution which the Service
makes to national civil resilience, continuous improvement in
operational service delivery and professional standards should
be encouraged and form part of the body of evidence that provides
assurance to the public of the efficiency and effectiveness of
their local fire and rescue service.
Audit of local authority expenditure
13. External audit is important to demonstrate
effective stewardship of public funds and sound corporate governance.
However, the "whole of government accounting" and the
published final accounts produced by public services are totally
unreadable by the layperson - and are increasingly too complex
even for finance professionals. Whilst it is incumbent on local
authorities and other public agencies to present these in a way
which is meaningful to the citizen, the recent national prescription
on how agencies do this, ie publishing every item of expenditure
over £500, could lead to "scrutiny of the weeds rather
than the forest".
14. Over the next few years the financial resources
of FRA's are to be cut significantly due to the pressures on public
spending announced in the Spending Review 2010. Any future audit
arrangements, either commissioned locally or nationally, need
to have regard to the ongoing financial resilience of Authorities
especially given that FRA's are required to contribute to overall
national civil resilience in the event of widespread threats eg
from extreme weather or terrorism.
15. The proposals that are likely to be implemented
following the closure of the Audit Commission regarding the local
appointment of auditors are welcomed. However FRS's should not
subsequently be disadvantaged in procurement because of size of
Authority and any collaborative Treasury management or commissioning
of audit services needs to ensure both transparency of individual
agency expenditure and accountability of each agency to the communities
they serve.
Oversight and inspection of local authority performance
16. The principles set out in paragraphs 9-12
above should apply to the monitoring, reporting and accountability
for performance of Fire and Rescue Services. CFOA encourages sector
benchmarking informed by sector determined measures, leadership
of continuous improvement and fostering a culture of sector support,
peer challenge and sharing of support resources and good practice.
17. Since the abolition of national standards
of fire cover, the former centralist approach, FRS's have been
better able to provide more effective local solutions to match
local risks and needs. The approach to risk management has led
to very local solutions and integrated risk management plans (IRMP's)
drive the allocation of resources to risk through a consultative,
evidenced based process. IRMP's have also led to improved community
outcomes and stronger partnership working. CFOA believes that
Integrated Risk Management Plans form a key foundation by which
value for money, performance and risk mitigation should be measured
given the underpinning principle of IRMP's, namely allocating
resources according to risk.
18. Whilst CFOA recognizes there may be circumstances
where central inspection or intervention is necessary to safeguard
the public, as yet there is little clarity on the triggers for
Secretary of State intervention in any one Authority, who would
carry out any such directed inspection/intervention and who pays.
CFOA would support the LGA view that intervention should only
be initiated once the sector has first had the opportunity to
provide improvement support to those Fire and Rescue Services
at risk of failure. CFOA believes that the triggers for intervention
need to be clear, transparent and communicated to the sector.
Ministers will also require assurance that national interests
are protected, e.g. adequate measures to counter terrorism, adequate
protection of critical national infrastructure. The parameters
of this assurance also need to be clearly articulated.
Value for Money studies
19. Sector commissioned and sector owned vfm
tools, that are informed by sector professionals, provide a valuable
mechanism to assist robust benchmarking. These have to date been
provided by the Audit Commission, albeit with somewhat insufficient
input from the sector, and should not be lost to FRS's. Maintaining
these at a national level requires the appropriate level of national
funding support to the sector and CFOA and the LGA are carrying
forward the discussions with CLG officials as part of the National
Functions debate for the fire sector.
20. In recent years some, but not all, of the
studies undertaken by the Audit Commission on value for money
in the fire sector have resulted in heavy criticism because of
the lack of evidence, flawed data, lack of understanding of the
fire and rescue service, contrary to other published material
and driven by a desire to promote the Audit Commission rather
than improve the sector. Other studies, often commissioned by
CLG, have taken so long to report that their usefulness in driving
vfm or performance improvements has been limited. CFOA would support
the commissioning of sector reports, in partnership with the LGA,
that are focused on the areas which the sector believes would
derive shared benefit and which complement locally commissioned
studies. Consideration needs to be given to how these will be
funded and CFOA believes that the savings accrued from the reduction
in the national audit and inspection regime should be channeled
through the sector to deliver these studies.
January 2011
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