4 The creation of the market
Opening of competition
86. On 19 September 2013 the first stage of the competition
was launched. This took the form of an invitation to potential
lead contractors (Tier 1 providers) to submit Pre-Qualification
Questionnaires by 14 November 2013 to enable the Ministry to establish
which organisations are suitable to bid at this level. In addition
to the Target Operating Model, the Ministry also produced a document
which sets out the principles that will govern the delivery of
the competition and their expectations for the conduct of prospective
bidders in developing their supply chain.
| The Government has identified three tiers of provider, each bearing different levels of financial risk:
· Tier 1 Providers:Organisations, consortia or mutuals able to bear a significant amount of financial risk who will take over the running of the Community Rehabilitation Companies (CRCs) as "going concerns". Tier 1 providers will contract directly with the MoJ.
· Tier 2 Providers: This tier could encompass larger VCSE organisations, mutuals or other private sector organisations providing services at scale to Tier 1 providers on a subcontractor basis.Organisations within this tier are still likely to have a sizeable annual turnover and be required to bear an element of PbR risk.
· Tier 3 Providers:Organisations delivering small scale specialist services and interventions to Tier I and II providers, with limited, or no requirement to bear PbR risk.
|
Developing a varied market
87. The 21 contract areas available through the competition
are valued at between £5bn and £20bn over 10 years.
The Ministry has been clear from the outset that it aims to have
these contracts—which will be for 7 to10 years with an option
to extend for a further 3 years—delivered by a wide range
of lead providers.[169]
The Government's agenda for this programme has been to design
it with a view to increasing the diversity of the market for rehabilitation
and resettlement services including the voluntary, community and
social enterprise (VCSE) sector. The Secretary of State told us
in February that he did not "automatically want to see a
prime contractor, subcontractor model" but wanted to see
"partnerships of equals as well"—for example,
partnerships between voluntary sector organisations or voluntary
sector and private organisations and mutuals--and had sought to
encourage the social investment sector to become involved.[170]
THE SIZE AND MATURITY OF THE EXISTING
MARKET
88. The majority of large justice sector contracts
are currently being delivered by a few large private sector firms.
Two of these firms, G4S and Serco, have withdrawn from the competition
to operate as lead providers of rehabilitative services in the
light of issues which have arisen in relation to other criminal
justice contracts they hold: we consider this further in paragraphs
107 to 110 below. The market for contracted-out community-based
offender services is also immature, which may restrict the number
of organisations willing to bid as lead providers. By comparison,
according to the Secretary of State, the competition for the Department
for Work and Pensions' Work Programme built on 15 years' experience
of what did and did not work in the welfare to work sector.[171]
This Programme therefore operated in a mature market with a number
of the successful providers having already been established to
compete and bid for previous Welfare to Work schemes.[172]
CAPACITY WITHIN THE PRIVATE, PUBLIC,
AND VOLUNTARY SECTORS TO BID AS PRIME PROVIDERS
89. We encountered some scepticism as to whether
there was a sufficient margin in the delivery of probation services
and the configuration of the programme to allow a broader diversity
of providers. In particular, it has been a matter of concern that
the new contracts would only be within the reach of larger, often
multi-national, organisations with significant financial reserves
to draw upon, which have considerable experience in bidding for
and securing similar contracts for provision of public services,
and are able to support themselves pending the outcomes, and that
this would operate to the detriment of the voluntary and community
sector and existing state sector providers wishing to spin off
to form mutuals.
90. The Government expects that existing Probation
Trusts, which cannot bid in their own right, will form alternative
delivery vehicles and mutuals designed by staff groups if they
wish to continue to provide services to low and medium risk offenders.
The Cabinet Office agreed to make available some funding from
its £10 million Mutuals Support Programme to help ensure
potential mutuals can compete effectively in the competition.
There is also the prospect that social investors may be able to
provide financial backing to support some voluntary sector and
small and medium enterprise organisations to bid to become a lead
provider.
91. The Institute for Government has recommended
that the MoJ must 'steward the market' to prevent domination by
a small number of players and ensure access to new providers.[173]
The Ministry has taken a number of steps to diversify the supply
base, including: facilitating access to Cabinet Office expertise
and funding to build the capacity of prospective mutuals and voluntary
sector prime contractors and subcontractors; reducing the size
of some contract areas; making the bulk of the payment a fee for
service and taking steps in the design of the payment mechanism
to mitigate problems with cashflow (as discussed in the previous
chapter); and limiting the amount of capital required for prime
providers.
92. Our witnesses praised the efforts that the Government
had made in this regard.For example, Tom Gash welcomed the fact
that that they had capped the value and volume of work going to
an individual provider, and the level of financial risk they would
be required to bear.[174]
Max Chambers believed that the need for both financial standing
and direct experience of working with offenders would force partnerships.[175]
Sue Hall said that eight potential mutuals had been very positive
about the financial support they had received from the Cabinet
Office to enable them to purchase consultancy.[176]
NCVO and Clinks welcomed the support that had been given to voluntary
sector potential primes via the Cabinet Office, the market stewardship
principles, standardised contracts and the commitment to a mix
of funding mechanisms for lower tiered providers.[177]
On the other hand there was a desire on the part of some witnesses
to see more detail, in particular about the payment mechanism
and the nature of the contracts.
93. The Secretary of State was "encouraged"
by the "very good mix of private and voluntary sector"
organisations, often in partnership, and with a good geographical
spread. Expressions of interest had been received from 35 lead
bidders, representing more than 50 organisations. He observed
that this included some "very good and substantial voluntary
sector organisations" and "staff teams", and stated
that "a good proportion of the most substantial and attractive
potential providers were partnerships".[178]On
19 December the Ministry announced that thirty of these bidders
had passed the pre-qualification questionnaire stage of the process.
A further 800 organisations had expressed an interest in being
involved at second tier level.[179]
Clinks observed that of the 1700 organisations estimated to be
currently working with offenders, fewer than 400 registered an
interest in providing services under the programme; if indicative
of the final number this would represent a considerable narrowing
of the market.[180]We
consider the wider value of the voluntary sector's contribution
to criminal justice services in paragraphs 33 and 48.
94. We would
be extremely concerned if the bidding process for prime providers
were to be dominated by the very small number of large businesses
which currently hold most of the major outsourcing contracts in
the criminal justice system. Thirty bidders have gone throughthe
first stage of the competition process and will be invited to
tender. It remains to be seen if this will prove a sufficient
number to provide satisfactory bids for a viable service in all
21 contract areas.
Confidence in the tender process
95. We have in the past repeatedly raised concerns
about the capacity of the MoJ, and NOMS in particular, to manage
contracts for outsourced services.[181]
For example, we concluded in our probation inquiry that "[t]he
experience of national contracts currently in place has not inspired
confidence that NOMS understands its business sufficiently well
to draw up robust contracts that meet the needs of future stakeholders."[182]
Parallels have been drawn, including by the Secretary of State
himself, with the Work Programme. He told us in February that
concerns about the outcomes of the Work Programme were "clearly
misplaced" but acknowledged that there were lessons that
could be learnt about the contracting process, particularly related
to the frustrations of the voluntary sector—which he believed
needed to be "more commercial"—and that the Government
needed to do more to help them "form partnerships and access
financial support".[183]
96. A crucial aspect of trust in any competitive
process is the level of transparency with which it is conducted.
As we noted in the previous chapter, several elements of the programme
are yet to be determined, including the payment by results mechanism
and the proportion of contract value that will be performance
related. Toby Eccles felt that there was an "inherent incumbency
bias" related to the lack of information and knowledge about
whether it would be worth bidding, which favours those who have
been through lots of procurement processes before.[184]Tom
Gash similarly believed that some of the smaller providers and
the mutuals would struggle to get up and running and operational,
while also putting in a bid in a process they have never gone
through before at national level.[185]
He described the benefits of a phased approach to competing services
in overcoming this issue:
In any market creation reform you are much better
off phasing these things. You would do an area of the country
at one point; meanwhile, mutuals can start to develop and get
themselves on to a sound footing. Then they can bid for the next
round that comes out in a year's time. It has been the standard
received wisdom that this is what you do when you are doing a
major national outsourcing programme, but there has been a decision
not to do it in this case.[186]
97. The Secretary of State assured us that the number
one criterion for assessing the bids will be quality. He said
he will be looking for "credible, innovative plans to bring
down reoffending" but acknowledged that they must also come
within his as yet undisclosed budget.[187]
98. The Ministry
of Justice has a questionable track record in procuring quality
services when seeking better value for money, most strikingly
in relation to the language services contract. It appears that
every effort has been made to learn from this but the assessment
of quality during a bidding process is notoriously difficult,
particularly where new providers are seeking to enter the market.
Although the Minister wishes to ensure a balanced consideration
of potential bids, an unavoidable consequence of the way this
programme is designed is that one element of the competition will
be about how cheaply providers can deliver the residual service
to enable the maximum resource to be unlocked to "reinvest"
in rehabilitative provision for short-sentenced prisoners and
others in prison and after their release.
PROTECTION FOR SECOND AND THIRD
TIER PROVIDERS
99. Most voluntary, community and social enterprise
sector involvement is likely to be at Tiers 2 and 3 of the new
supply chains. To ensure that sub-contractors are protected from
unfair levels of risk being passed down from the prime provider,
the Ministry initially stated that it would require prime providers
to commit themselves to principles laid out in the Merlin Standard
which was created as a means of providing stewardship of the supply
chain in the welfare to work sector.[188]
However, there have been criticisms from the voluntary and community
sector that despite this safeguard the Work Programme created
problems for their organisations, in particular around the amount
of cash flow sub-contractors received from prime providers, and
the level of referrals. Mr Grayling rejected suggestions that
providers from the sector had been treated as "bid candy"
and said that this had not been reflected in any formal complaints
from the sector about the commercial behaviour of prime providers.[189]
Nevertheless, he indicated strongly that he would be prepared
to take action if he felt there was such mistreatment under this
programme.[190]
100. The Ministry has identified the following core
market stewardship principles related to the supply chain: appropriate
management of risk, including not passing financial risk down
"disproportionately"; alignment of ethos of providers
in the supply chain through contractual agreement to support sustainable
relationships and build trust; visibility of participation; reward
and recognition of good performance across the supply chain; and
application of the principles of the Compact—a code of conduct
that the Government has agreed to adopt in work with Third Sector
organisations—by providers and their supply chain. They
also intend to devise industry standard contracts for lower tiered
providers.[191]
101. The key voluntary sector stakeholders that we
heard from—Clinks, NCVO and 3SC—welcomed the Ministry's
efforts to provide greater transparency in the contractual arrangements,
but felt that further detail was required from the Ministry to
give them full confidence that the programme would uphold the
fair treatment of voluntary and community sector providers.[192]
Oliver Henman of NCVO observed that the lack of clarity around
the subcontracting arrangements was "quite alarming"
given the pace of reform.[193]Clinks
wished to see: "clear stipulations on matters such as risk
transfer, fluctuations in referral volumes, support for organisations
that work towards longer-term desistance from crime, and services
for equalities groups."[194]The
NVCO and Clinks shared the belief that some grant funding or up-front
funding would be required to deliver more specialised community-based
services to counter the risk that the use of PbR throughout supply
chains would restrict the diversity of the market.[195]
102. The Secretary of State was heartened by the
level of positive responses the Ministry itself had received about
itsengagement with the voluntary sector.[196]
When we asked him to elaborate on what would constitute a disproportionate
level of risk, he anticipated that some financial risk could be
passed down but emphasised that it would need to be done transparently.[197]He
also said that he "would have absolutely no compunction about
terminating the contract immediately and re-letting it" if
he felt that primes were not treating their counterparts, or subcontractors,
appropriately.[198]
103. The Ministry of Justice's market
stewardship principles are designed to enable smaller organisations
to have the confidence to take part in the contracting process
so that their skills can be brought to bear in rehabilitation.
We will be interested to see how these principles, in particular
those related to the level of risk that will be passed down to
lower tier providers, will be integrated into the contract management
processes as well as the industry standard sub-contracts. It remains
to be seen whether prime providers will agree to these as contractual
obligations as the competition progresses, and how the Ministry
will respond if they do not. It is also not clear to us whether,
once the contracts have been let, there will be sufficient incentive
for the Department to take appropriate action against the misuse
of market power against partner providers or subcontractors.
104. Witnesses from a range of different
perspectives felt thatthere is a risk that rehabilitation will
be lost in the process of change and restructuring. A key question
for the Government is how the focus on reducing reoffending will
be maintained while the restructuring in the market that is necessary
to create efficiencies takes place. There is insufficient detail
about the final payment mechanism to determine whether there will
be sufficient incentive for new providers to offer initial upfront
investment or to reinvest their resources in rehabilitative services.
Safeguarding against post-implementation
issues
105. As we have noted throughout our report, the
ambitious nature of the Government's programme of reform poses
a variety of risks. Tom Gash observed:
The interrelationships for probation and other
parts of the public sector are enormously complex. Adding into
that a particular additional separation between an in-house provider
of probation services for higher-risk offenders and a contracted
provider for other offenders is a type of complexity that is clearly
different by an order of magnitude from that which we see in other
areas. The provider market is extraordinarily immature. You are
bringing in providers to manage these services that have not done
it before, admittedly with a work force who are experienced and
have experience of operating in this environment. To me, lots
of the signals suggest that this is an incredibly complex programme,
on a timeline that has not been achieved before.[199]
106. The Secretary of State set out what he considered
to be some of the risks involved in the implementation of the
programme:
The first is if we stopped supervising offenders
during the transition process. That is not happening. We have
been very clear about it to trust chiefs. Our probation officers
are continuing to do a professional job with the people they are
supervising. The second would be that we made an inappropriately
hurried transition of case load. I have been very clear in setting
the policy very early on. We will not do that; we will migrate
people over an extended period. […] The third point would
be if we did a sudden transition from one organisation to another,
so a different group of people took over the job one day from
the ones doing it the previous day. […] We are migrating
a team of people who are already bedded in in the public sector,
who have made the transition to the new arrangements within the
public sector and who will continue to look after the same offenders
the day after ownership changes as the day before. It will be
an evolution, not a revolution. The fourth is the transition of
information within the new system. We have specified that the
same systems for risk assessment and case management will be used
by everybody in the probation service. Finally, we ensure that
senior management teams are sufficiently equipped to manage the
transition…We have put in place additional resource, through
the expertise of the team who worked on the health service transition
[…] to make sure there is additional resource to help the
trusts with the transition.[200]
Jeremy Wright recognised that in relation to risk,
at every stage of the project, the Ministry must make sure it
does everything it can to smooth the transition process.[201]
PROBITY AND CORPORATE RENEWAL
107. During our inquirysignificant irregularities
came to light in the electronic monitoring contracts held by G4S
and Serco. Criminal investigations ensued and the Ministry has
discontinued the contracts. Both companies involved hold many
contracts in the justice sector. The Ministry made it clear that
they would not be awarded probation services contracts if evidence
of criminality is found.[202]Subsequently,
both withdrew from bidding for these contracts as lead providers.
The Secretary of State explained to the House that this did not
necessarily preclude them from being involved in delivering rehabilitative
services under the reforms:
[…] the Government has left open the possibility
of either supplier, as part of their corporate renewal, playing
a supporting role, working with smaller businesses or voluntary
sector providers in order to support our objective of achieving
a diverse market. Any proposals will be considered as part of
a rigorous evaluation process, and will take account of the Government's
wider assessment of the companies' progress in achieving corporate
renewal.[203]
108. The fact that the Ministry finds itself in this
unhappy position raises wider issues for the probation competition.
The Ministry must satisfy itself that it has done as much as it
can to prevent a similar episode from occurring. This will be
necessary both in terms of anticipating and minimising opportunities
for overcharging to occur under new contracts, and being confident
that those organisations that hold such contracts will not countenance
comparable mistakes.
109. Our evidence suggests that the Ministry has
made it a priority to address these issues. The Secretary of State
told the Financial Times that he expected to see both companies
going through a process of "corporate renewal" if they
wished to work with Government in the future.[204]
Both organisations have replaced their senior management and are
undergoing internal review.[205]
We asked the Secretary of State to explain what, in his view,
would constitute satisfactory 'corporate renewal' but he was reluctant
to do so while the criminal investigations were ongoing.[206]
He was confident that the level of interest from prospective providers
was sufficiently broad for the Transforming Rehabilitation competition
to proceed should the two organisations in question be precluded,
if indeed they wish to bid.[207]
In terms of getting the Ministry's own house in order, the Secretary
of State commissioned an internal review of contract management,
by one of its non-executive directors, "to make sure that
it is absolutely fit for purpose".[208]The
report of this review was published on 19 December 2013, as was
that of a Cabinet Office review of existing contracts held by
the two companies in question.
110. In the field of rehabilitation services, the
MoJ proposes that new providers and the National Probation Service
will be regulated through a combination of independent inspection
by HM Inspectorate of Probation, internal audit, and the potential
to involve the National Audit Office, as well as through NOMS'
account management of CRCs and SLA oversight. They note that:
"Operational contract management will differentiate
between the need for NOMS to have higher levels of assurance about
delivery of sentences of the court and public protection, where
there will be specific minimum standards and metrics, compared
to the substantial freedom providers will be given to determine
how they rehabilitate offenders and reduce reoffending."[209]
We welcome the Ministry's endeavours to strengthen
its contract management and oversight in the light of the electronic
monitoring debacle. We will study the report of the internal review,
which will assist us to hold the Ministry to account on this aspect
of its administration. We also recommend that prior to the next
stage of competition under the Transforming Rehabilitation programme
the Ministry should publish a statement setting out its expectations
of the integrity of prospective providers and the steps it will
take in holding bidders to account for the probity of their activities.
In our view, this should include greater transparency in their
publication of financial and performance data, than has hitherto
been the case. We shall return to the question of corporate renewal
with the Secretary of State once criminal investigations and any
subsequent legal proceedings have concluded.
TRANSPARENCY
111. We encountered some concerns that the introduction
of new providers seeking to outperform each other in reducing
levels of reoffending might hinder the dissemination of effective
practice, which the programme has the potential to add great value
to. Our witnesses proposed that unlike in other payment by results
programmes where best practice was not necessarily shared because
of issues of commercial confidentiality, providers would need
to be incentivised or contractually obliged to exchange information
on good initiatives.[210]
CONTRACTUAL FLEXIBILITY
112. According to a report in The Guardian,
the initial risk register, which this Committee has not seen,
warned that there was a more than 80% risk that the programmewould
lead to "an unacceptable drop in operational performance"
triggering "delivery failures and reputational damage".[211]
Our witnesses gave us various observations about how the level
of complexity and uncertainty within the programme could best
be managed. Toby Eccles argued that with the Peterborough pilot,
they had recognised the need to build flexibility into the contracts
to enable the model to be tested and adapted over time.[212]
Tom Gash believed that given the lack of certainty about how well
different providers would hold up, either financially, or in terms
of their service quality and service standards, there needed to
be flexibility to shift who is providing over time to replace
underperforming providers. He was therefore concerned that the
length of contracts that the Ministry was intending to give was
"excessively long" and would hinder this, and proposed
that in the absence of a phased approach attention must be paid
to "what service standards could trigger a change of provider
and […] how you would change a provider if they failed financially.
Stress-testing and running some scenarios on that is vitally important
before this begins. All scrutinisers should probably be thinking
about getting assurances that that process has been gone through."[213]
113. Our witnesses speculated further about what
would happen where there was evidence of under-performance. Max
Chambers questioned whether the contract in question could go
to a neighbouring provider or another provider, or to the national
probation service.[214]
Richard Johnson queried how quickly a drop in operational performance
could be recovered, given the likely contraction of the service,
and what the implications would be for public protection.[215]
CONTINGENCY PLANNING
114. We asked Ministers how they would deal with
the possibility that no suitable bids are received for a particular
geographical area. The Secretary of State believed that the strength
of the market would not result in such an eventuality, but conceded
that in that scenario there were several options. These included
the possibility of a "slightly staggered transition"
or the "ultimate fallback" of the public sector continuing
to provide the service, providing it would be financially viable
for them to take on the extra short-sentenced prisoners cohort.[216]
Jeremy Wright MP explained that the most feasible way to fund
the extension of statutory support was by releasing the savings
through competition. He envisaged "formidable practical challenges"
in having some parts of the system running and others not, in
particular in creating difficulties for the courts if mandatory
supervision for short-sentenced prisoners was not universally
operational.[217]It
is unclear whether supervision of short-sentenced prisoners for
the whole of England and Wales would have to await the successful
conclusion of bidding for all areas, and it is unclear what would
happen to the programme for supervision of short-sentenced prisoners
if one or more areas subsequently had to suspend operation of
the contract. This issue must be clarified.
115. Once a process of contracting out public services
has been undertaken, there can be a strong predisposition towards
inertia in the sponsoring Department in the face of underperformance
by the contractor. This predisposition could be even greater if
the continuance of short-sentenced supervision is dependent on
contracts remaining in place in all areas. The Work and Pensions
Committee made the following observation on the DWP's approach
to the cessation of contracts under the Work Programme: "DWP
has asserted that it is prepared to use the ultimate sanction
against poorly performing primes of terminating prime contracts.
However, we are not convinced that this could be achieved without
significant disruption to services. DWP needs to do more to explain
how this sanction could be applied effectively, and any negative
impacts mitigated."[218]While
the Secretary of State was clear that he would exercise his power
to withdraw contracts if lead providers were not behaving appropriately
towards each other or their subcontractors, he did not specify
the circumstances in which he would use this power. Jeremy Wright
explained however that inadequate performance would be managed
through contractual arrangements.[219]
116. The Ministry has high expectations
of what can be achieved in the way of efficiency savings and extension
of services through contracting out the management of low and
medium risk offenders within existing resources. It seems entirely
feasible to us that as the competition progresses and details
are refined, the attractiveness of these contracts might wane,
resulting in incomplete or inadequate provision in certain areas
or types of service. None of the possible
contingency plans proposed by the Ministry were very clear to
us.
117. We received evidence about the risk of operational
failure during the implementation of the programme.We note the
Government's efforts to test the model with shadow state-run companies
before contracting these new arrangements out to new providers,
but these are regarded by some as artificial conditions. If the
Ministry proceeds as planned it must be able to make modifications
to all aspects of the system in the light of experience. For example,
in drawing up contracts with new providers, we recommend it should
ensure the payment by results metrics are open to modification
in the event that unforeseen gaming by providers occurs.We also
wish the Ministry to provide us, and potential providers, before
the next stage of competition, with clarity about what service
standards could trigger a change of provider and how a provider
would be changed if they failed financially.
169 Oral evidence taken on 27 February 2013, HC (2012-13)
964, Q3 Back
170
Oral evidence taken on 27 February 2013, HC (2012-13) 964, Q3;
Q216 Back
171
Q250 Back
172
Q114 [Mr Gash] Back
173
Institute for Government, Making Public Service Markets Work,
July 2013 Back
174
Q121 Back
175 Ibid. Back
176
Q169 Back
177
NVCO (PPC 26); Clinks (PPC 27); Q169 [Mr Henman] Back
178
Qq220-221 Back
179
Qq211, 219 Back
180 Clinks
(PPC 27) Back
181 See
Justice Committee, Second Report of Session 2012-2013,The budget and structure of the Ministry of Justice,
HC97-I and Justice Committee, Sixth Report of Session 2012-2013,
Interpreting and translation services and the Applied Language Solutions contract,
HC 645 Back
182 Justice
Committee, Eighth Report of Session 2010-2012, The role of the Probation Service,
HC519-I Back
183
Oral evidence taken on 27 February 2013, HC (2012-13) 964, Q3 Back
184
Q120 Back
185
Q121 Back
186
Q121 Back
187
Qq187-188, Q214-215 Back
188
Merlin Standard website, About Merlin, downloaded November 2013 Back
189
Q255 Back
190 Ibid. Back
191
Ministry of Justice, Principles of Competition: Transforming Rehabilitation Programme,
September 2013 Back
192 Clinks
(PPC 27)welcomed in particular the stated commitments to 'not
passing risk down supply chains disproportionately', the acknowledgement
that alignment of ethos is vital in building relationships of
trust, and the explicit obligation on the new providers to adhere
to the Compact principles when working with the Sector. Back
193
Q175 Back
194 Clinks
(PPC 27) Back
195
NCVO (PPC 26);Clinks (PPC 27); Q171 [Mr Henman] Back
196
Q222 Back
197
Qq216, 225-6 Back
198
Q249 Back
199
Q114 Back
200
Q241 Back
201
Q239 Back
202 Investigated Serco and G4S can bid for new contracts, says Chris Grayling,
The Guardian,15 September 2013 Back
203 Written
Ministerial Statement, Ministry of Justice Contracts Update, 19
December 2013 Back
204 Grayling calls for G4S and Serco revamps,
The Financial Times, 20 August 2013 Back
205
See for example Serco press release, Serco announces the key elements of its corporate renewal programme,
25 October 2013; and G4S investors news, EM contract update,
19 November 2013 Back
206
Qq217-219 Back
207
Q219 Back
208
Q218 Back
209
Ministry of Justice, Target Operating Model: Rehabilitation Programme,
September 2013, p 39 Back
210
Q124ff [Mr Eccles, Mr Chambers, Mr Gash] Back
211 Privatising probation service will put public at risk, officials tell Grayling,
The Guardian, 24 June 2013 Back
212
Q114 Back
213
Q123 Back
214 Ibid. Back
215
Q55 Back
216
Qq213-215, 246 Back
217
Q212 Back
218
Work and Pensions Committee, First Report of Session 2013-14,
Can the Work Programme work for all user groups?, HC 162, p 5
Back
219
Q247 Back
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