Armed Forces Covenant Annual Report 2018: Government Response to the Committee’s Eighteenth Report of Session 2017–19

First Special Report

On 25 September 2019, the Defence Committee published its Eighteenth Report of session 2017–19, Armed Forces Covenant Annual Report 2018 [HC 1899]. The Government’s response was received on 4 February 2020.

The response is appended to this report.

Appendix: Government Response

Recommendation 1

We welcome the establishment of the Office for Veterans’ Affairs and the shared responsibility between MoD and the Cabinet Office. We are, however, keen to see a balance in the implementation of the Covenant between the needs of veterans and those of serving personnel. It is important that the Office makes a real difference and does not add another layer of bureaucracy to the delivery of the Covenant. In response to our report, the Government should set out how this Office will operate across MoD and the Cabinet Office, including the role of the Office within the broader Covenant governance structure, the role of each Minister, the long-term vision for the Office, the funding that will be made available to it, and the approach it will take to ensure a coordinated and consistent level of service is provided across Whitehall to veterans. (Paragraph 13)


The single biggest step the Government is taking to further improve the delivery of the Armed Forces Covenant is the commitment made in the Queen’s Speech to strengthen its legislative basis, for which the Ministry of Defence is the lead Department. The Strategy for our Veterans, and the ambitious vision it has set to make the UK the best place to be a veteran anywhere in the world by 2028, remains the foundation of the Government’s approach to veterans. The Office of Veterans’ Affairs (OVA) has been established at the centre of Government in the Cabinet Office to champion veterans across Government. It will drive forward the realisation of this vision, working in concert with Departments, Devolved Administrations and the wider veterans’ sector. Its role is to lead and co-ordinate the Government’s overall strategy for supporting veterans and developing the services which they require to ensure successful transitions back into civilian life. In doing so it will work closely with many Government Departments, including the Ministry of Defence, who fund and deliver services and support directly to veterans; the OVA’s budget of £5m for 2020/21 reflects this role and relationship. The OVA reports to Oliver Dowden MP in his capacity as Minister for the Cabinet Office and the Minister in Cabinet responsible for Veterans and to the Minister for Defence People and Veterans (Johnny Mercer MP), a joint MoD and Cabinet Office Minister, who oversees the OVA in his Cabinet Office capacity and the wider Covenant agenda, which covers serving personnel and their families as well as veterans, in his MoD capacity. The statutory duty to report annually to Parliament on Covenant progress remains with the Defence Secretary.

The Government published its response to the Veterans Strategy Consultation Report and an accompanying action plan in January 2020. This action plan contains commitments from a number of Government Departments to actions which will improve services and support for veterans; these will begin to realise the Government’s vision for veterans and the Office for Veterans’ Affairs will lead the coordination and oversee the delivery of these actions. The creation of the OVA represents a clear commitment from the Government to improve services and support to our veterans and this is why the OVA has been established at the heart of Government in the Cabinet Office which is the right place from which to deliver its leadership role for veterans in Government. The Covenant is a vital tool in ensuring that no one who serves in, or has served, in the Armed Forces, or their family, faces disadvantage as a result of their service and the Ministry of Defence will continue to be responsible for the Covenant. However, the Government is clear that there are instances where it is right that we provide dedicated or advantageous services to veterans which recognise them and the circumstances of their service and in doing so goes beyond the Covenant; this includes, for example, our Manifesto commitments to introduce a guaranteed interview scheme for public sector roles where the veteran meets the essential criteria and a railcard for veterans.

Recommendation 2

We are concerned that the collapse of the Executive in Northern Ireland has impeded full engagement with, and implementation of, Covenant principles within Northern Ireland, thus creating a disparity with other parts of the UK. We welcome the duty placed on the Secretary of State to report on the progress of preparing legislation confirming the application of the Covenant in the provision of public services in Northern Ireland. The Government should also consider amending the guidance provided by the Northern Ireland Office to the Northern Ireland Civil Service, under the Northern Ireland (Executive Formation and Exercise of Functions) Act 2018, to ensure that, in the absence of a devolved Executive in Northern Ireland, a representative from the Northern Ireland Civil Service attends meetings of the Veterans Board. (Paragraph 20)


Following a DUP amendment to the Northern Ireland (Executive Formation and Exercise of Function Act) 2018 in July 2019 the following clause was enacted: s.3(15) of the EF Act 2019 which states:

Before making a report under subsection (1), the Secretary of State must publish a report on or before 4 September 2019 on progress made towards preparing legislation confirming the application of the Armed Forces Covenant in the provision of public services in Northern Ireland.

This report sets out the UKG position that “The Government remains open, as it has always been, to considering whether any further legislation is required at any point to help deliver any aspect of the Covenant, what this would achieve, and how this could be enacted. Because the existing covenant legislation is UK-wide, any changes to it would also be made on a UK-wide basis.”

The Secretary of State for NI is delighted that political leaders have agreed the New Decade, New Approach deal and that devolved government has now been restored to Northern Ireland. This agreement makes clear the UK Government’s commitment to introduce UK-wide legislation to further incorporate the Armed Forces Covenant into law and support full implementation of the Armed Forces Covenant.

The agreement also includes a commitment to appoint a Northern Ireland Veterans’ Commissioner to act as an independent point of contact to support and enhance outcomes for veterans in Northern Ireland. The UK Government will provide financial support for the Veterans’ Support Office and funding for the new Veterans’ Commissioner over three years.

In addition, the Ministry of Defence will initiate a review of the Aftercare Service in Northern Ireland (ACS) which will consider whether the remit of the ACS should be widened to cover all HM Forces veterans living in Northern Ireland with service-related injuries and conditions.

The EF guidance referred to is no longer in effect. It will now be a matter for the NI Executive to consider the appropriate membership from the Devolved Administration.

Recommendation 3

We are disappointed that the situation in Northern Ireland has delayed full membership on the Veterans Board for the Scottish and Welsh devolved administrations. We note that the MoD believes this has not affected their working relationship with the devolved administrations, but we are concerned about the message this sends. The MoD should give full membership to the Scottish and Welsh Governments immediately. It should also explain its reasoning for withholding full membership to date, which should include any negative implications of granting full membership that have been identified. (Paragraph 21)


The relevant elected officials from the Devolved Administrations have been invited to every meeting of the MCVB alongside Westminster colleagues, and continue to be key partners in delivering the Armed Forces Covenant. Membership of Cabinet Committees and sub-committees is a decision for the Prime Minister, and secretariat for such Committees and Boards is provided by the Cabinet Office, not the Ministry of Defence.

Recommendation 4

We were pleased to hear the positive feedback from Service charities regarding the transition to the Covenant Fund Trust. We welcome the Fund’s new independent status, the involvement of representatives from the Service charities as trustees for the Fund and the additional funding for Veterans’ Mental Health and Wellbeing needs. However, with the introduction of additional funding beyond the core £10 million fund, we are concerned that the appropriate safeguards may not be in place to ensure that operational costs are kept to a minimum. (Paragraph 28)


The Armed Forces Covenant Fund Trust reviewed comparable operating costs from other grant-making organisations as part of a benchmarking exercise. Operating costs are capped at 5% for any of the funding streams, such as the additional £10m on Veterans Mental Health and the additional £3m on the Veterans Community Centre programme. This compares very favourably with other grant makers. The Trust is transparent in its activities and its annual report and accounts are available publicly.

Recommendation 5

In response to our report, the MoD should provide details of any other funds it expects to channel through the Covenant Fund Trust and the safeguards being put in place to ensure that running costs are kept to a minimum. This should include any planned increases and how the cost will be shared amongst the funds. (Paragraph 29)


In addition to the £10m Covenant Trust Fund, the Trust administers the £3m Veterans Community Centre Programme and the £10m Veterans Mental Health and Wellbeing fund.

There are currently no additional funds that have been agreed to route through the Armed Forces Covenant Trust Fund.

Recommendation 6

We are pleased with the progress in developing an Outcomes Measurement Framework for Covenant funding that will help ensure maximum impact for the Armed Forces community. We are also encouraged by the MoD’s commitment to share data on the disparity of Covenant delivery at the local level in comparison with the general population later this year. (Paragraph 36)


The Armed Forces Covenant Fund Trust will be implementing the Outcomes Measurement Framework from March 2020 which will allow grant funded organisations to measure the improvement in the wellbeing of their beneficiaries and the Trust will to be able to measure the improvement in the wellbeing of their beneficiaries and the Trust will to be able to measure the overall impact of grant programmes.

The MoD funded a question to identify veterans for the years 2014 to 2017 in the Office of National Statistics’ Annual Population Survey. This provides estimates on the size and socio-demographic characteristics of the UK Armed Forces veteran population residing in Great Britain. The MoD has undertaken data matching to the England and Wales 2011 Census, and published estimates, including comparisons with the general population, on the size and socio-demographic characteristics of the working age UK Armed Forces veteran population residing in England and Wales at a lower geographical level; equivalent data matching studies are underway with Northern Ireland and Scotland 2011 Census data. The MoD is working with the statistics agencies (Office of National Statistics, National Records of Scotland and Northern Ireland Statistics and Research Agency) towards inclusion of a veteran question in the 2021 Census.

Recommendation 7

It is important that identifying disadvantage in the Armed Forces community and measuring the delivery of Covenant initiatives are based on accurate data. The Department should also use current forms of data gathering more effectively. This includes the information captured by Service family surveys such as FAMCAS which reflects modern family structures. We therefore expect the MoD to review current data-gathering tools across Covenant themes to identify gaps and ways of capturing data using new and existing tools. The results of this review should be shared with the Committee. (Paragraph 37)


The MoD is continually identifying new data that will provide evidence to support the delivery of the Armed Forces Covenant and the metrics appeared in the 2019 Covenant Report. The MoD is also monitoring the health, wellbeing and welfare outcomes among various cohorts of veterans through an academic longitudinal study with Kings.

The MoD, in collaboration with Other Government Departments (OGDs) and the Devolved Administrations (DAs) and based on advice from the Prime Minister’s Implementation Unit, has devised an overarching framework for the Armed Forces Covenant that incorporates the Covenant Strategic aims. The MoD will be co-ordinating with OGDs and DAs in the delivery of metrics within the framework that will highlight any gaps. With the agreement of OGDs and the DAs, the MoD will continue to provide updates on the development of metrics including assessments of current data opportunities.

The MoD’s Continuous Attitude Surveys (CAS) are not always the most appropriate mechanism by which to collect data for policy evaluation. The purpose of the MoD’s CAS is to monitor, over time, personnel’s attitudes towards Terms and Conditions of Service (TACOS) and how these might impact satisfaction levels, retention and operational effectiveness. They are intended to examine the broad scope and spectrum of TACOS rather than specific areas which should be understood through the use of alternative research methods and efforts appropriate to the issue at hand. When assessing policy changes it is important to consider the most appropriate method of data collection for the question. This may, for example be in the form of more periodic pulse surveys to monitor in year changes, or qualitative methods such as focus groups and interviews to collect more in-depth data and provide narratives on the lived experiences of Service personnel.

Recommendation 8

We are very concerned with the treatment of Commonwealth Service personnel and their families which the Army Families Federation has described as “immoral”. There has been a failure adequately to acknowledge the contribution these individuals and their families make to the defence and security of the UK. We recognise that the issue of Minimum Income Threshold (MIT), Visa fees and Indefinite Leave to Remain (ILR) are Home Office policies; but the MoD must do more to record relevant family data, in order that the extent of the problem across the Armed Forces can be fully understood. The MoD must ensure that the financial requirements laid upon personnel and their families when moving to the UK are effectively communicated at the point of recruitment. It must also ensure that high quality advice and guidance is available to those currently serving. (Paragraph 53)

Recommendation 9

In response to our report the MoD should set out its plans for improving its collection of the relevant family data of serving personnel. It should also set out in detail an improved communication strategy to fully inform non-UK personnel, who are both serving and at the early stage of the recruitment process, about the financial requirements for dependants to be able to join them in the UK. We encourage the new Defence Secretary to continue discussions with the Home Office in order to resolve this issue quickly. (Paragraph 54)

Combined Response

The MoD continues to help non-UK Service personnel and families understand how policies affect them. MoD is improving its understanding of the non-UK community through better awareness of numbers and the issues faced to, in turn, improve communication and the support we offer. MoD has ensured correct and clear information about the costs of visas and minimum income requirements for non-UK personnel is now on the single Service recruitment websites. The Army, which has the largest number of non-UK service personnel, has produced comprehensive guidance for units, and the Families Federations also have dedicated information for non-UK personnel on their websites.

MoD’s Directorate for Children and Young People (DCYP) are currently working to improve the integrity of Service child data within the Joint Personnel Administration system (JPA) to ensure we have accurate data on the number and location of service children. This information is required from a safeguarding perspective and to inform policy and planning. MoD will continue to exploit the findings from the Tri-Service Families Continuous Attitude Survey to gain an understanding of the impact of Service life on Service families. In addition, MoD will continue to support OGDs/DAs to develop metrics relating to Service families for the Armed Forces Covenant, and to exploit findings from the Tri-Service Families Continuous Attitude Survey to understand the impact of Service life on families.

Recommendation 10

We welcome MoD initiatives to modernise Armed Forces employment. However, we are concerned that the MoD is not adapting access to its support mechanisms to accommodate the effects of these changes. Dispersed families are reporting that the distance from the parent unit creates barriers to available support. Given that the number of dispersed families appears to be growing, the MoD must ensure that these families are not disadvantaged in their access to support services. Addressing these issues will be vital if the Future Accommodation Model (FAM) is to succeed. (Paragraph 61)


The first Future Accommodation Model (FAM) trial commenced on 30 September at Faslane, with further trials due in Aldershot Garrison and RAF Wittering in 2020. FAM is likely to result in increasing numbers of personnel choosing to live in the private rental sector. Our ongoing evaluation of the FAM pilot, which will involve hearing from Service families and welfare staff, will reveal any impact to personnel or their families’ well-being, and will determine any action we may need to take in response—bearing in mind that as a pilot policies are expected to change as we ascertain where issues arise. Of course, we are also aware that many families choose to get support out with the Armed Forces and they have access to the full suite of civilian support available to all citizens.

Recommendation 11

In response to our report the MoD should clarify what data it has on the number of dispersed families within the Armed Forces. It should take steps to ensure that dispersed families are aware of and have access to support services. The MoD should also continue to monitor whether its flexible working initiative has a positive impact on dispersed families. (Paragraph 62)


Dispersed families are an important and growing group across all three Services. We can track this through declared data on the Joint Personnel Administration (JPA) military HR system, and through the Office of National Statistics Annual Population Survey. As more and more families choose to live in either their own properties (which the Government is supporting through the Forces Help to Buy scheme) or in the private rented sector, we will continue to seek innovative ways to ensure that families continue to receive the support they need.

Recommendation 12

We are concerned that the mobile lifestyle expected of Service personnel may disadvantage their children. Data in the Armed Forces Covenant Report 2018 suggested that a career in the Armed Forces may negatively affect Service children’s attainment levels since they have to move schools often. The challenge of finding and securing a suitable school, especially at critical stages of a child’s education or for those who have special educational needs or disabilities, is understandably a “key source of anxiety for Service families”. (Paragraph 74)


Although the average performance of Service children as a group is on a par with or better than those of non-Service children, the report did indicate that while the performance of all children who move schools regularly is lower, Service children perform better than their non-Service counterparts who also moved schools.

Family mobility is not compulsory. Some families choose to buy a house and remain geographically stable, while others may choose to claim Continuity of Education Allowance (CEA) and place children in state or private boarding schools. The role of the MoD’s Directorate of Children and Young People (DCYP) is to provide professional direction, support and advice in order to ensure that Service children and young people are provided with every opportunity to achieve the best possible outcomes and fulfil their potential. DCYP seek to ensure that Service children and young people receive their full entitlement to statutory services and support and suffer no disadvantage because of their parent’s Service status; this is the underpinning principle of the Armed Forces Covenant. The aim is to provide support which is practical and preventative as well as being responsive to emerging needs.

As an example of this, DCYP manages the MoD’s Education Support Fund (ESF). The ESF is available to support UK maintained schools with Service children of frequently moved or deployed parents in embedding practices that can benefit Service children and the school. The 2019 ESF allocated £3 million to 76 successful applicants directly benefitting approximately. 32,000 Service children across the UK. The 2020 ESF allocated £2 million to 87 successful applicants directly benefitting approximately 25,000 Service children across the UK. Result letters have been circulated (November) and payments will be made no later than 5 April 2020.

DCYP has also commenced work on developing a funded programme of research. The themes of this research will be informed by a UK literature review currently being conducted by an independent researcher, alongside the findings of an international literature review being conducted by SCiP.

Recommendation 13

We agree with the recommendation made by the Service Children’s Progression (SCiP) Alliance that a coherent Government approach should be developed to track the number and location of Service children across the UK and internationally which can be shared with researchers seeking to understand the causal relationship between the mobility of Service life and the effect on educational attainment. The Department should also set out the steps it has taken in coordination with the Department for Education and local authorities around the UK to improve the admissions process for Service children, especially those with special educational needs, so they are not disadvantaged. This should include an update on the review into the provisions for Service children in the School Admissions Code. (Paragraph 75)


The MoD has been working with the Department for Education (DfE) to explore options around school admissions and Service children. As a result of this work, the MoD has now joined the DfE School Admissions Group (which inputs advice and recommendations to the DfE around the School admissions code), and attends these meetings advocating for Service children. Currently, there is a great deal of work taking place focussing upon ‘in-year’ admissions and the Fair Access Protocols, with draft proposals to be outlined in early 2020. The purpose of Fair Access Protocols, which are aimed at admissions authorities and schools, is to try and ensure that, outside the normal school admissions rounds, unplaced children (especially the most vulnerable) are found and offered a school place quickly, to keep the amount of time any child is out of school to a minimum. These proposals will look to offer greater support to all children who often find themselves moving school, of which Service children will be one of the beneficiaries. Through membership of the DfE Schools Admissions Group, MoD will now be able to raise the profile and lobby on behalf of Service children as DfE reviews and updates the School Admissions Code.

A set of principles for the transition of service children with SEND has been agreed with the member local authorities of MODLAP. This sets out an enhanced process in these local authority areas to mitigate the potential challenges service children with SEND can face in securing appropriate provision to meet needs.

Recommendation 14

There is evidence that children from Service families are disadvantaged in accessing higher education compared to the general population: this is unacceptable. In response to our report, the MoD should set out in detail what actions it is taking both unilaterally and in coordination with the Department for Education to address this disadvantage. This should include plans to collect data on Service children post-16. Data and analysis of this cohort should be included in future Covenant Annual Reports. (Paragraph 78)


Evidence shows that Service children are underrepresented in higher education, but, to date, there has not been evidence that Service children are disadvantaged in accessing higher education. Work is underway to understand this gap. The 2019 Annual Covenant report will include, for the first time, data from the Department for Education that will show destination data for Service children at age 16 and 18.

Following collaboration between the MoD, the Universities and Colleges Admissions Service (UCAS) and the Service Children’s Progression (SCiP) Alliance, UCAS has published a specific advice page for potential students from Service backgrounds who are applying for a University place, to advise on specific issues affecting them. This is a direct response to the underrepresentation of children from Service family backgrounds in Higher Education and a first move to addressing this disparity.

The Chief of Defence People has written to all vice-chancellors of universities and colleges about the under-representation of Service children in Higher Education, asking them to make specific reference to Service children in their widening access and participation plans. We will see the results of this engagement in early 2020 through data generated by the Office for Students.

The former Secretary of State for Defence, the Right Honourable Gavin Williamson MP, asked Andrew Selous MP to conduct an independent review into the support provided to Service families which plans to report in early 2020. This will include the impact of mobility on Service children’s education. The findings of this review will help to inform the new Families’ Strategy action plan, which is being developed.

The MoD is working through the MoD Local Authority Partnership (MODLAP) and direct engagement with Local Authorities, to identify and generate best practice and guidance in the support of all local authorities’ work with Service children.

Recommendation 15

We welcome the MoD’s extension of the Education Support Fund and its guidance for schools on how to spend Service Pupil Premium effectively. However, we would like to see more examples of best practice which include schools with low numbers of Service children—the majority of schools receiving Service Pupil Premium. In response to our report, the MoD should provide additional guidance and case studies of best practice for schools with low numbers of Service children. These examples should be circulated to all schools with Service children and made easily accessible to Service families. (Paragraph 89)


In October 2019 the MoD wrote to all 10,500 state schools in England who are receipt of the Service Pupil Premium (SPP). We are looking to develop a new good practice guide for schools, and the letter specifically asked for examples where there were only a very small handful of Service children at the setting, although the deadline for responses to this letter has not yet elapsed. We are very much aware that for some schools, it can be difficult to identify the best means of using the SPP, especially when there are only one or two Service children on roll. The current guide for schools on was updated in December 2019.

The MoD is working with DfE to identify the best way to improve training for teachers at schools attended by service children.

Recommendation 16

We commend the publication of the ‘Welcome to’ packs for families moving between devolved administrations. However, we are concerned that the key information contained in these documents is not reaching Service families. We are also concerned at the lack of data from devolved administrations about Service children presented in the Covenant Annual Report. In response to our report, the MoD, in coordination with the devolved administrations, should improve its outreach processes to Service families to ensure that they are fully informed of differences in the way support is provided for Service children across the devolved administrations. The MoD should ensure data from the devolved administrations is collected and incorporated into future Covenant Annual Reports. (Paragraph 90)


The ‘Welcome to’ packs, which are available on the Covenant website, have been highlighted in communications with single service Armed Forces Covenant Champions, who are responsible for disseminating information to Service Personnel. In addition, the MoD has regular engagement with the Families Federations that provide further opportunities to disseminate such information via a trusted source.

The Armed Forces Covenant Annual Report includes all data available from across the UK, including the Devolved Administrations of Wales, Scotland and Northern Ireland. Education is a devolved responsibility across the UK, and each Devolved Administration makes its own decisions on how best its resources should be used to collect data, and how that data should be analysed and presented.

The Welsh Government funds the Supporting Service Children in Education Cymru project, which as well as providing a dedicated officer to work with schools, families, Local Authorities and partner organisations to improve support for Service children, also conducts and commissions research into areas of Service children’s experiences in education. Work is continuing in Wales to enable the collection of data on Service children in schools through the Pupil Level Annual School Census.

In Scotland, education authorities have a statutory responsibility for providing additional support for learning which children, including Service children, require in school. Education authorities need to do evidence-based analysis to understand what is working well and what needs to improve. The Association of Directors of Education in Scotland and the Scottish Government agree that data about Service children should not be collected at a national level, but at a local (school/ local authority) level, where it can best be understood and acted upon.

The Association of Directors of Education in Scotland has developed a dedicated website for Service families with information to help make the transition to Scotland’s schools as easy as possible. The wealth of guidance for parents includes the National Parent Forum Scotland’s ‘Transitions for Armed Forces Children’, and ‘Transitions into Scottish Schools; Early Stages’. The association is working with the MoD to promote the website to Service personnel and their families.

We continue to work very closely with the devolved administrations to enable the continued support of Service children and are exploring the means where specific data sets, relating to Service children, can be collated and analysed.

Recommendation 17

We are concerned that we are still hearing about continuing difficulties in understanding and implementing veteran priority access to NHS medical treatment when injuries or ill-health are attributable to their military service. There continues to be confusion within Government as to how priority treatment should be implemented. We conclude that the only way to give priority to veterans is to establish dedicated NHS pathways and facilities for veterans. Otherwise, there will continue to be an understandable reluctance within the NHS for anyone to receive priority treatment on the basis of anything other than current clinical need. (Paragraph 97)


The NHS in England has already established several dedicated veteran services, which include the Transition, Intervention and Liaison and the Complex Treatment Services (both for veterans’ mental health), prosthetic service and the Veterans Trauma Network. NHS England and Improvement have plans to extend the suite of services by commissioning a veterans’ mental health High Impact Service to capture those individuals nearing crisis. This is dedicated, to veterans. However, they will also be developing an Armed Forces Family support service, after consultation, in 2020.

Recommendation 18

We call for an update on the Department’s work with the Department of Health and Social Care and the devolved administrations to develop a clear definition of priority treatment for veterans and practical steps to ensure veterans with Service attributable conditions have clinical priority. We expect this work to be taken forward urgently and in their response the Government should include a timeline for its completion. (Paragraph 98)


Veterans in England, Scotland and Wales can access priority treatment from the NHS for service attributable conditions subject to the clinical need of others. It is recognised that more can be done to strengthen the understanding of priority treatment and how this can be balanced with the NHS ethos of providing access to healthcare based on clinical need. The Health Partnership Board (between the MoD and the Departments of Health for each of the nations of the UK) is working towards developing a clearer definition for 2020, which will more readily be understood by the NHS and veterans alike, and more easily tied to specific actions and improvements.

The UK Government’s Department of Health and Social Care have set up a working group (See recommendation 20) made up of members from across the UK, including the MoD, NHS, patients’ representatives, service charities and clinicians. This working group met at the start of September and will meet again in November reporting progress back to the Partnership Board of MoD and Departments of Health officials in November, with the aim of taking an initial proposal to the Covenant Reference Group in spring 2020.

Recommendation 19

The disruption of care pathways for families of serving personnel who are relocated is a clear disadvantage and is contrary to the values of the Covenant. This will affect retention in the Armed Forces, especially of families with complex medical needs. This issue must be addressed if the Armed Forces is to be an attractive employer. (Paragraph 104)


The MoD recognises the importance of continuity of care for service families when relocating and the potential impact on retention. The MoD continues to work with the Departments of Health across the UK to establish how best to ensure continuity of medical and/or social care, especially for those with complex needs or who are otherwise assessed as especially vulnerable. However, MoD remains cognisant that the devolved nature of healthcare, both to devolved governments and at a regional/local level to Clinical Commissioning Groups (in England), means that some clinical treatments available in some areas may not be available in others (or available more slowly). We continue to work with partners to address the issues this creates for our highly mobile workforce and their families and to look at ways of balancing the need for mobility with continuity of care.

Recommendation 20

The MoD must establish an effective system in coordination with NHS England, the devolved administration and local authorities to ensure that Service families receiving ongoing care are provided with equivalent support when re-located. (Paragraph 105)

Health and social care are devolved to either individual nations or regions for those not registered with Defence Medical Services (DMS). For routine healthcare, where the treatment is brief and the waiting time is short, there is seldom an issue. There are also good appeal mechanisms where issues do arise. Serving personnel have a responsibility to share their familial care issues with their chain of command or posting officer, to permit the MoD and the families to plan and anticipate needs wherever possible within the requirements of operational capability.

The Department of Health and Social Care has established a UK wide “Health of our Service Families” working group. This sub-group of the MoD/UK Department of Health’s Partnership Board has been set up to drill down and find actions to resolve the issues raised by the Families Federations in relation to accessing healthcare across the UK. The working group is made up of representation from NHS England and Improvement (NHSE&I), all the devolved administrations, MoD and all three Families Federations.

Recommendation 21

We welcome the work of the MoD in coordination with health departments in the UK on the introduction of veteran-specific specialist mental health services. However, we repeat the recommendation made in our report Mental Health and the Armed Forces, Part Two: The Provision of Care that a National Mental Health Residential Rehabilitation Centre that is exclusively for either serving or ex-serving personnel should be established and co-located with the new state-run Defence Medical Rehabilitation Centre (DMRC) for physically injured serving personnel at Stanford Hall. In response to our report, the MoD should update us on any consultations, so far, between the Department, the NHS and DMRC on establishing this vital facility, and on the timeline proposed for doing so. (Paragraph 112)


The MoD, the Department of Health and Social Care, and NHS England and Improvement have closely scrutinised the recommendation to develop a National Mental Health Residential Rehabilitation Centre, and developed various options including the possibility of establishing a Virtual Centre of Excellence, which is being considered by the Defence Healthcare Delivery Optimisation programme.

Alongside this and as part of their Long-Term Plan, NHS England and NHS Improvement are increasing the provision of veterans’ mental health services which includes commissioning their Veterans’ Mental Health High-Impact Service for veterans who are in a mental health crisis and need urgent and emergency care and treatment.

This has been informed by veterans and their families, who have emphasised the importance of having community-based services close to where a patient lives and works, with in-patient services used for the stabilisation and treatment of individuals who are at risk of harm to themselves or others. They have also highlighted the importance of services being integrated with the rest of the NHS and wider emergency services, as well as the need for all involved organisations being clear on their roles and working together with the patient and family to plan, co-ordinate and deliver care. These views, together with clinical best practice and evidence, have helped to inform a proposed service model.

This will commence with pathfinder services launching in April 2020, which will offer crisis care, therapeutic acute mental health inpatient care, continuous care coordination and family support. Findings from the pathfinders, together with a programme of engagement, will inform the final service model that will launch in April 2022. This new service will go considerable way to addressing concerns about veterans in crisis and the functions of a dedicated network of mental health centres for veterans. NHSE&I are also considering how these can link more closely to facilities for the serving population and the network of national (physical) trauma centres.

Recommendation 22

The poor record of satisfaction with repair and maintenance issues for Service Family Accommodation has been a failure of the National Housing Prime (NHP) contract as well as of Amey. The Department must learn lessons and ensure that contracts under the Future Defence Infrastructure Services (FDIS) programme have a customer-focused approach. We are encouraged that the Department has consulted the Service Families Federations and other stakeholders on rethinking its approach to contracting. The MoD should set out in detail its new approach to contracting under the FDIS programme and outline the lessons learned from the NHP which have been incorporated into this new model, including robust Key Performance Indicators. We also expect an update and timetable on the award of new contracts under the FDIS programme and how the contracts are going to be actively managed. (Paragraph 123)


The Department recognises that the underperformance of the National Housing Prime (NHP) contract in its early years, especially for response maintenance and move-in preparation, resulted in low levels of customer satisfaction. To address this, we have worked hard to improve service delivery and have achieved improved levels of response maintenance performance. Key performance indicator targets are now met on a more regular basis, and complaints have reduced significantly, with the intent that continuous improvement efforts will reduce these still further.

The new approach to contracting through Future Defence Infrastructure Services (FDIS) will enable further improvements to the housing service that our Armed Forces and their families receive. We have considered the best housing contracts available in both the public and private sectors and consulted extensively with a range of stakeholders, including the single Service Housing Colonels, who represent the views of Service personnel, and Families Federations for Service families.

The FDIS approach will break the over-reliance on a single supplier, promote competition, and improve supply chain resilience. A more flexible and responsive maintenance policy, subject to Departmental funding, is a real opportunity to materially improve the experience of Service personnel and their families.

Key changes include:

The FDIS contracts have also been designed as a flexible contracting arrangement pending more certainty of the funds available for maintenance in future years. The new contracts will enable MoD to implement additional preventative maintenance works if funds are available. Whilst the contract is designed to incentivise the right contractor behaviours, ultimately funding remains a constraint. The FDIS housing contracts are due to come into service in late 2021.

Recommendation 23

We are also very concerned with the low level of satisfaction with the Defence Infrastructure Organisation (DIO), specifically DIO Service Delivery (SD) Accommodation and their inability to listen to customer views and act upon them. More needs to be done to ascertain where and why the dysfunction within DIO exists. In response to our report, the MoD should set out the actions it is taking to rectify the low satisfaction rate with the operation of DIO SD Accommodation and set out the steps planned to address these issues, which should include a timetable for completion and how improvements will be measured. (Paragraph 124)


The Department is committed to improving the accommodation offer and customer satisfaction. However, previous underinvestment in the estate has resulted in the level of modernity and condition of some homes being below the level we aspire to. The situation is improving; more than 97% of Service Family Accommodation (SFA) now meets the Government’s ‘Decent Homes’ standard, and only homes that meet this standard are allocated to Service families.

During financial year 2018/19, the Department invested substantially more than originally planned to improve the quality of SFA (an additional £57.5M was injected in-year), to deliver improvement works in more than 3,800 SFA, and to purchase 112 additional SFA. This investment has continued, with £123M being invested in improvement works in the current Financial Year.

To measure the impact of this work, DIO engages regularly with the single Services and Families Federations. We also canvass the views of SFA occupants directly through an independent monthly survey. The sustained delivery improvements achieved over the last 12 months are reflected in the DIO Customer Satisfaction Survey results for Q1 2019–20 which confirm that 70%] of customers are satisfied with the quality of their home; this compares favourably with 65% as at Q4 2018–19.

Satisfaction results for ‘the way the contractor deals with repairs & maintenance issues’ have increased to 49% at Q1 2019–20 from 42% at Q4 2018–19 (with those dissatisfied reduced from 46% to 41%), whilst those for ‘listening to customer’s views and acting upon them’ have increased to 43% from 39% (with those dissatisfied reduced from 35% to 31%). These two aspects have traditionally scored lowly. It is therefore pleasing to note that both improved response maintenance performance and more focused communications are being reflected in satisfaction levels. Whilst these satisfaction levels remain well below those desired, the direction of travel is positive.

We are not complacent and are working with Amey, our Industry Partner, to further improve results in these areas. DIO has formal ‘Holding to Account’ sessions with its partners and regular meetings with the Chain of Command, and their housing and welfare staffs, where these results are examined.

DIO places a high priority on further improving customer satisfaction and has invested significant resource in this area over the last 12 months, resulting in an increase in overall satisfaction with SFA from 62% in March 2018 to 64% in March 2019. DIO’s Chief Executive made a commitment to the Public Accounts Committee in May 2019 to increase satisfaction levels to 68% by March 2020 and DIO is on track to meet this with a rolling 12-month average of 67% as at December 2019.

We have also published a Service Family Accommodation Customer Service Charter as our commitment to Service personnel and their families to provide quality accommodation and excellent customer service. We are proud to have launched this publication, a copy of which will be provided to all Serving personnel and their families as part of the SFA move-in pack. It is also available via the MoD’s GOV.UK web page for SFA, and the Families Federations.

Recommendation 24

The upcoming negotiations with Annington and the continual delays to implementing the Future Accommodation Model (FAM) pilots have left Service personnel and their families with a high degree of uncertainty. In response to our report, we would like an update on progress in the Department’s negotiations with Annington. We would also like to see the project objectives of the FAM pilots and details of the assessment criteria. A communication strategy should be established to ensure that Service families are regularly updated and informed on progress. This should include structured consultations with families throughout the process, so they can contribute to any findings and help shape the pilots as they develop. (Paragraph 133)


Annington Negotiations

The Department is concerned that Service personnel and their families are troubled by the Annington negotiations and believes this may have been brought about by media interest in the issue. The Annington negotiations will not affect the Department’s undertaking to provide access to subsidised accommodation. In addition, the negotiations will have no impact on the charges paid by Service personnel to the MoD for occupation of Service Families Accommodation (SFA).

MoD Accommodation charges are assessed by the Armed Forces Pay Review Board, an independent body, and are the most heavily subsidised in the UK. There is no intention that this position will change, and through our regular, high level engagement with the single services, we are seeking to allay any concerns and reassure Service personnel and their families about the Annington Homes negotiation process.1

As part of its commitment to seek to secure better value for money for the taxpayer, in March 2019 the Department agreed an accelerated process with Annington Property Ltd to carry out the formal Site Rent Review, which had been due to start in 2021. This review will determine a new site by site rent adjustment to replace the blanket 58% abatement the Department currently receives. The Department aims to have concluded this process within the next 12–24 months. The agreement provides financial benefits to the Department through savings of up to £24M on dilapidation costs over a 7-year period.

Part of the agreement with Annington Properties Ltd allows the Department to return 3,500 properties to them over the course of the next 7 years. This arrangement has allowed the DIO Chief Executive to set an ambitious target for the Department to achieve a reduction in the number of empty properties to the required management margin of 10% by Autumn 2021. As well as returning properties to Annington Properties Ltd, the number of empty properties will be reduced through widening the sub-let programme and increased eligibility for Service personnel.

Project objectives of the FAM pilots and assessment criteria

The delay to the Future Accommodation Model Pilot from last year has allowed the MoD additional time to fully evaluate the scope of the Pilot and better understand its impact on Service personnel, with a view to delivering the most effective model.

FAM will more flexibly accommodate a Service population with evolving and diversifying housing needs and preferences. Through use of the private rental sector and support for home ownership, personnel will have greater choice of where, how and with whom they wish to live.

FAM policy will ensure that, during the pilot, those Service personnel who are entitled to a larger property under the current policy, due to rank, are not disadvantaged. In the longer term, if FAM rolls out permanently, properties will be allocated on the basis of need rather than rank. Service Personnel may request a larger property and if available it will be offered, but they will be required to pay more.

Evidence generated will test key Success Factors, such as ease of use and attractiveness to Service Personnel and availability and response of the private market. We will also measure behaviours and demographics of Service personnel to understand their accommodation preferences.

Qualitative and quantitative data will be gathered from a wide range of existing and new pilot-specific sources and tracked and analysed across the Pilot’s 3 years to build the evidence base.

The pilot evidence will also inform future (post-pilot) FAM policy and options for its implementation. At the heart of our planning will be the impact to Service personnel and their families, to ensure wider FAM implications, such as children’s schooling and access to welfare provision, are duly considered.

Communication Strategy

We have actively consulted Service personnel, their families and Families Federations to understand their preferences and used this information to help develop the Pilot and refine the policy.

This has not always been a smooth road. Some Families Federations have been concerned about a perceived lack of timely information as such a significant policy change draws nearer.

We have responded to this concern by actively increasing our communications with families, and continue to engage regularly with our stakeholders, developing and implementing a full communications plan in collaboration with the Services and key stakeholders—including Help and Information Volunteer Exchanges (HIVEs), Naval Service Family and People Support and the Families Federations for each Service.

The FAM page of GOV.UK is now the key place for Service personnel to access information about FAM. To support this, a new section called Discover My Benefits was also launched, giving personnel information on the FAM payments and allowances that apply to their personal situation.

Recommendation 25

In our previous report, we said that the MoD needs to develop a robust plan to improve Single Living Accommodation (SLA). We are very disappointed that we are still hearing serious complaints about the condition of SLA, despite the injection of additional funding. We are further concerned to have received evidence that this situation is directly affecting morale and the ability to recruit and retain personnel. In response to our report, the MoD should outline urgent plans to improve SLA plans which should not proceed until it is clear that the single Service Chiefs and their organisations have learnt from, and will not repeat, past mistakes. We will also be asking the Comptroller and Auditor General to examine the provision of SLA in depth and in detail. (Paragraph 140)


We recognise that the condition of Single Living Accommodation (SLA) varies across the UK and we are working with the Services to develop a comprehensive picture of the condition of SLA to provide a benchmark for an improvement plan, particularly to reduce the worst pockets of SLA. Part of this development work relies on access to accurate Management Information on SLA, in terms of condition, location and utilisation, which is a key enabler to efficient and effective management of the SLA estate. To achieve this, the Department has commissioned an SLA reporting and allocation solution, known as the Single Living Accommodation Management Information System (SLAMIS), which will deliver the necessary data to enable the single Services and Strategic Command to make strategic decisions on SLA investment and the provision of future requirements. It will provide the capability for Defence to utilise and manage SLA in the most effective way possible, including optimising its use across the estate and improving the standard and quality of accommodation.

SLAMIS will provide timely and accurate SLA management information, enabling the single Services and Joint Forces Command to make informed investment decisions on the management of the SLA estate and to undertake a targeted approach to improving the quality of SLA accommodation. Initial Operating Capability, mainly conditioned related data, will be delivered by March 2020.

Existing SLA datasets (Facilities Condition Management, or FCM, and updated 4-tier grading assessment data) will form part of the SLAMIS solution. FCM has assessed most of Defence’s Level 2 (building) assets and there is now more granularity regarding the SLA lived experience. These revised datasets are already providing the single Services and Strategic Command with more detailed information on the condition of SLA to inform improvement and investment planning through a targeted approach.

Recommendation 26

We fully support the work of the Department in developing the Veterans Strategy. We look forward to seeing the outcomes of the consultation phase and the implementation plan. In response to our report, the MoD should detail what the Office for Veterans’ Affairs will do to improve delivery of the Covenant, particularly through the implementation of the Veterans Strategy. (Paragraph 146)


The Government published its response to the Veterans Strategy Consultation Report and an accompanying action plan in January 2020. This action plan contains commitments from a number of Government Departments to actions which will improve services and support for veterans; these will begin to realise the Government’s vision for veterans and the Office for Veterans’ Affairs will lead the coordination and oversee the delivery of these actions. The creation of the OVA represents a clear commitment from the Government to improve services and support to our veterans and this is why the OVA has been established at the heart of Government in the Cabinet Office which is the right place from which to deliver its leadership role for veterans in Government.

The Covenant is a vital tool in ensuring that no one who serves in, or has served, in the Armed Forces, or their family, faces disadvantages as a result of their service and the Ministry of Defence will continue to be responsible for the Covenant. However, the Government is clear that there are instances where it is right that we provide dedicated or advantageous services to veterans which recognise them and the circumstances of their service and in doing so goes beyond the Covenant; this includes for example our Manifesto commitments to introduce a guaranteed interview scheme and a railcard for veterans.

Recommendation 27

It is a positive step that one of the Covenant priorities for 2019 includes increased support for War Widows and Widowers, and the wider bereaved community. However, it is shameful and disgraceful that no progress has been made with the Treasury in addressing the reinstatement of the War Widows’ Pensions of the small cohort who fell outside the scope of the change of policy in 2014. We encourage the new Secretary of State for Defence to press this issue and engage urgently with the Treasury to resolve this matter. We encourage the new Secretary of State for Defence to press this issue and engage urgently with the Treasury to resolve this matter. It has remained unresolved for far too long and, in response to our Report, the Government should set out a firm and final timetable for rectifying this injustice. (Paragraph 153)


The MoD recognises the unique commitment that Service families make to our country and remains sympathetic to the circumstances of those widows who remarried or cohabited before 1 April 2015. This is a complex policy area and the Government must carefully consider the potential options within both financial and legal constraints.

Recommendation 28

The Veterans Gateway is a crucial resource for veterans and their families who are seeking advice and support on a wide range of issues. It is also a key source of data for understanding the needs of the veteran community. It was therefore alarming to hear that there is an unresolved issue over the future financial sustainability of the Gateway. In response to our report, the MoD should set out its plans for future funding, which should include detailed consultation with the Service charities sector and an update in the next Covenant Annual Report. (Paragraph 160)


Since June 2017, the Veterans’ Gateway has provided a single point of contact for veterans, and their families, seeking advice and support and is a collaborative project between Government and the third sector. It puts veterans and their families in touch with the organisations best placed to help with the information, advice and support they need. These organisations must sign up to be a Veterans Gateway partner, and mostly comprise charitable organisations. The Veterans Gateway is delivered by a consortium of major charities, with initial seed funding of £2M over 2 years provided by the Covenant Trust Fund. The Government recognises the existing value and immense potential of the Veterans Gateway model and is in discussions with the Gateway consortium to understand its long-term funding plans for the service and how these can be placed on a sustainable footing.

Recommendation 29

We recognise as a success the large number of businesses signing up to the Covenant; but we are concerned that there are no clear guidelines for such firms on how to implement their pledges. We agree with the Forces in Mind Trust report that the MoD should produce a “suite of toolkits” for organisations of difference sizes and sectors to help them implement their commitments to the Covenant. We also agree that the MoD should commission research into the impact of organisational pledges on the Armed Forces community. An update on the “suite of toolkits” and the research into organisational pledges should be included in the next Covenant Annual Report. (Paragraph 168)


MoD’s Defence Relationship Management (DRM) works closely with those organisations that are most willing and best able to deliver a range of support for the Armed Forces Community. At both regional and national levels, DRM’s account managers help these organisations to develop their own Armed Forces Covenant pledges to ensure they are meaningful, practical and deliverable. They then support these organisations on a journey, which begins with the signing the Covenant, and progression is encouraged and monitored as organisations mature through the Employer Recognition Scheme. In order to progress from bronze to silver and on to gold, and then to retain these awards through the five-year revalidation process, these organisations must be able to evidence that they are continuing to deliver against their Covenant pledges.

The department has not commissioned additional research into the impact of organisational pledges, however, to improve its support to these organisations, MoD is updating its existing online toolkit and producing a new pledges template which will help all employers improve the quality and delivery of pledges

Recommendation 30

We are disappointed still to be hearing about significant disparities in local authorities’ delivery of, and engagement with, the Covenant. We recognise that the Covenant principles will be shaped by local circumstances; however, there must be assurance that local authorities are supporting the needs of the Armed Forces community. In response to our report, the MoD must show that it has an effective system both for identifying local authorities that are less effective in Covenant delivery and for improving standards of good practice across the UK. (Paragraph 176)


The MoD recognises that disparities in delivery remains a concern. Legislation will be introduced during this Parliament to further incorporate the Armed Forces Covenant into law.

The annual Covenant in the Community Conference brings together Covenant practitioners and stakeholders from around the country and most recently focussed, among other issues, on new initiatives such as the Defence Transition Services and the Map of Need project. These are annual events which, in addition to the many similar locally organised seminars and workshops, have done so much to promote the Covenant around the UK and to enable best practice to be shared. In addition, the MoD publishes a guide to help Local Authorities deliver the Covenant and support their local Armed Forces Community. It sets out what the Covenant is and what we are aiming to achieve through its delivery, providing clear advice and guidance on the areas where their work could be most beneficial. There are individual sections looking at the principles underlying the Covenant; their role as employers; the benefits of internal Covenant champions and the types of activities that they could pursue; communications and stakeholder management; Remembrance and Recognition; and the Covenant Fund, among others. Separate annexes are provided to address the different policies and processes in place for each of the Home countries. There is also an extensive list of useful contacts who they should approach for further information. Included in this package of guidance—available from the Covenant webpage—is the report “Our Community Our Covenant”, published by Forces in Mind Trust, which using research from local partnerships themselves, sets out numerous examples of good practice, recommendations for positive outcomes, and tools to help them assess their own delivery and where improvements could be made.

Recommendation 31

Written evidence from the Local Government Association expressed concern that local authorities would not be able to maintain the current level of support for veterans when priority Covenant grants awarded in 2016/17 and 2017/18 come to an end. In response to our report, the MoD should ensure that veterans will not experience a decline in the current level of support. (Paragraph 177)


The Armed Forces Covenant Fund Trust can only distribute grants for time limited projects on an annual basis and in accordance with the priorities given to it by the Covenant Reference Group. The Trust will continue to work with the Armed Forces community including veterans within its annual budget and is seeking to ensure a legacy from these grants. All grants awarded by the Armed Forces Covenant Fund Trust are based on the ability of the project or organisation to sustain the effect of the project beyond the period of grant, which is usually to provide initial set-up funding.

In many instances when these projects have come to an end enough will have been done to allow existing staff, many of whom who have had the Covenant officially added to their responsibilities, to continue to support the Covenant using the new resources or connections funded through the Trust. However, in other areas, such as Warwickshire, Wiltshire and Renfrewshire among others, we have seen local authorities stepping in to employ officers, initially funded by the Trust, to continue their Covenant role if they consider this to be the best solution for their local community.

4 February 2020

1 Report corrections:
Para 127. Under the arbitration agreement, we do not pay £7,000 in dilapidations per property, we will receive an abatement of up to £7,000 on dilapidations per property.
Para 128. There are 511 sites, not 488.

Published: 9 March 2020