Mainstreaming Supporting People: What Does It Mean? Alison Smith Tells Us
An analysis of the Government's Response to the Communities and Local Government Select Committee Report into the Supporting People programme: Is it the end of Supporting People as a distinct entity, where ‘mainstreaming' means ‘diluting out of recognition'?
On November 3rd 2009, the House of Commons Communities and Local Government (CLG) Select committee (the Committee) published it's report on the Supporting People (SP) programme, looking at the extent to which the Government has delivered on it's commitments in the 2007 Supporting People strategy (Independence and Opportunity) and the implications for the removal of the ring-fence.
The Committee drew 36 ‘conclusions and recommendations' based on the four key areas of the 2007 Supporting People Strategy; lifting of the ring-fence; issues specific to sheltered housing and the Supporting People Distribution formula. In its response, the Government regrouped some of the Committees conclusions/recommendations and gave its response to each recommendation or group of recommendations.
Overall, the Government agreed with the majority of the Committees conclusions but rejected or disagreed with half of the recommendations.
This critical review of the response looks at which of the conclusions the Government
- agrees with;
- which it does not;
- those recommendations it accepts and
- those it rejects
then examines the response to uncover any underlying messages and implications.
As an extension to the Transition package announced in July 2008 (when it became quite clear that the intention was to include Supporting People funding in Area Based Grant) the Government has established a Supporting People Transition Board made up of ‘key stakeholders' and representatives from Local Authorities (LAs), service providers and umbrella organisations to take work forward.
Keeping people that need services at the heart of the Programme
The Committee originally drew 6 conclusions and recommendations in this section, although in its response the Government included an additional 4 from other sections of the report and considered and responded to 10 of the conclusions & recommendations as 5 groups.
The Select Committee concluded Supporting People had achieved a lot but that some needs are still not being properly addressed and recommended that CLG take steps to ensure that an evidence base demonstrating the effectiveness of different types of intervention is developed. The Government said that they will ‘establish whether it is appropriate to commission research into the benefits of different types of service configuration'.
The Government rejected three recommendations that the SP Quality Assessment Framework (QAF)/Outcomes Framework should be mandatory for all LAs. The Committee recommended this to ensure continued quality, client involvement, high levels of client satisfaction, consistent commissioning and protection of dedicated SP teams. The Government argued that this may result in a form of ‘ring fencing' and that ‘quality frameworks', rather than a specific SP framework would be more conducive to joint commissioning.
The Government recommended that it would be better to work with the Care Quality Commission (CQC) and the Department of Health (DH) to extend the QAF to take account of the new CQC standards where applicable, and develop a framework that could work for both SP and Adult Social Care funded services (diluting it out of recognition?), whilst noting that it will not be feasible to move towards implementing a single framework as the CQC will need to keep its own set of standards for inspecting fully funded care services.
Similarly, Government sees it more appropriate to work with the DH to explore similarities between the SP Outcomes Framework and the DH Outcomes Framework in order to look at how to align them in the future rather than endorsing the existing SP Outcome Framework. (Note that the ‘Guidance on Integrating housing related support across health, social care and housing at a regional level' issued in November 2008 as part of the transition package recommends clearly that: (Recommendation 3): "The National Indicator Set and Supporting People Outcomes Framework should be used by commissioners to provide a basis for commissioning joined up services that deliver outcomes relevant to housing, health and social care." See here.
Somewhat arbitrarily, the Government supports and recognises the merit of all local authorities using the same version of the QAF but cannot currently require local government to do so, and recognises the value of having dedicated SP teams but cannot mandate or require local authorities to do that either.
The Government accepted the Committee's recommendation on the need to take a more joined-up approach to regulatory issues, and CLG committed to working with the DH, the Audit Commission and the CQC towards a more joined-up approach to the regulation of housing and social care services in the context of the Comprehensive Area Assessment. This has to raise questions as to the future of Supporting People as a distinct entity.
Recommendations to prioritise the implementation of Charters for Independent Living, with a particular focus on clarifying complaints handling mechanisms, and to extend the Individual Budget pilots to learn more about how personalisation works in practice, were accepted, noting that this work is already underway and that Individual Budgets may not be the most appropriate way of delivering personalisation for all. A working group which includes representatives from umbrella organisations and LA representatives has been established by CLG to consider how personalisation and choice can best work for recipients of SP services. A report on the work of the group will be published in early 2010.
The Committee concludes that progress in including housing and housing-related support in the Common Assessment Framework (CAF) for Adults is a positive development (although currently it has been included in only two of nine pilot areas). The Government agrees and is supporting developmental work in, and increasing the coverage of, housing related support in the CAF.
Enhancing Partnership with the 3rd Sector
The Government considered and responded to a total of nine conclusions and recommendations into this section as three ‘groups':
The Government agreed that the third sector has a major role to play in delivering services under the ‘SP brand', and recognises the need for the sector to have continuity of funding, but are not able to mandate that LAs must pass on the certainty of three-year financial settlements to third sector providers, as recommended by the Committee. It states: "It must remain the decision for local authorities to determine the length of contracts based on local needs and priorities and the need to ensure maximum efficiencies across all funding streams". Instead they note that the Supporting People Transition Board in conjunction with other national organisations should continue to promote the approach to supporting the third sector laid out in the SP Strategy.
The Committee makes a number of recommendations relating to best practice in commissioning and procurement, concluding that there is a huge burden on small providers and those that work across local authority boundaries, and recommending a role for the Regional Improvement and Efficiency Partnerships (RIEPs) in tackling the complexities, and for the Government in issuing clear guidance. The Government agrees, and notes it is already taking work forward on commissioning and procurement as part of the transition package. The Supporting People Transition Board has identified the need to work more closely with the Office of the Third Sector, the DH, the Office of Government Commerce, CIPFA and the IDeA to ensure consistency in this approach. The Government also notes that it is not their role to tell the RIEPs what to do, and that the SP Transition Board, the Local Government Association and the London Councils are already looking at this issue and will disseminate best practice.
The Select Committee concludes that there is a very strong argument to keep the existing Commissioning Body and associated service user involvement structures established under the SP Programme, recommending that LAs retain SP governance and delivery structures and that the Government further promote these structures more generally as models of good partnership working for LAs and their partners. The Government disagrees with this conclusion and rejects the recommendations, stating that SP needs to ensure that it is embedded within the new structures or has direct links into the structures if it is to retain a high profile across council business, citing examples of LAs that have begun to integrate the SP teams within the Adult Social Care teams in order to ‘share the experience and good practice of the SP staff'. CLG will identify where this is working well and disseminate information about how they are achieving this and ensuring the learning from SP is being integrated into other areas of LAs' work. Although the committee felt that the maturity of some local strategic partnerships (LSPs), and consequently the ability of some LSP partners effectively to commission services jointly, are in doubt and that Supporting People services require some continued protection as LSPs continue to develop, the Government disagreed.
Delivering in the new government landscape
The Government responded to eight of the Committees conclusions and recommendations in this section, agreeing with most but not all of the conclusions but rejecting all of the recommendations!
The Committee recommended that CLG ensure guidance is drawn up and disseminated for delivering housing-related support in two-tier areas. The Government and Local Authority associations share the view that further guidance may not be the most effective and helpful approach for authorities in two-tier areas at this stage, pointing to evidence of good practice in two-tier authorities identified by the Audit Commission which can be disseminated.
The Committee recommended that the development of Joint Strategic Needs Assessments (JSNAs) be accelerated as a priority in planning for the provision of SP services and specifically that a reference to housing-related support be included in the JSNA guidance - but the DH has no plans to issue revised JSNA guidance, although the Government comment that the DH has agreed to work with CLG to ensure that housing related support and the needs of vulnerable adults and not just PSA16 are taken into consideration.
The Committee felt that with greater local freedoms, improved accountability is needed - concerned that additional freedoms in the spending of SP funds could be misused and uncertain how well the new Comprehensive Area Assessment (CAA) will identify where the needs of vulnerable people are not being met. Similarly they expressed concerns that, with the lifting of the ring-fence, LAs may seek to rationalise current arrangements for service user engagement, commissioning and procuring SP services within LSP and wider arrangements for social care or corporate procurement. The Committee believe that the continued existence of such structures is critical in the absence of a ring-fence on SP funding. The Committee suggested that, to allay concerns, there should be a requirement for strategic commissioning and contract monitoring frameworks to be in place in each administering authority so that inspectors know where to look for the information they need for CAA. They specifically recommend that the Outcomes Framework should continue to be a requirement in all LAs to provide a clear focus for CAA inspectors' assessment of the effectiveness of SP services in an area and that the inspectorates should develop clear guidance and procedures for inspectors on ensuring user input to inspection results. The Government disagree, noting that now the first year of the CAA has reported, there are a number of local authorities where housing related support matters have received a red flag which highlights that the CAA can and does identify where the needs of vulnerable people are not being met. After conversations with the Audit Commission, the Government will write to the Committee setting out how they can respond further to the recommendations made.
However, all things considered, the Select Committee concluded that there is at present no strong case for putting SP services on a statutory basis- which the Government agrees with, promising to monitor the provision of SP services and high level outcomes through the local government national indicators and continuing to encourage authorities to submit data on client outcomes via the SP local systems.
Increasing efficiency and reducing bureaucracy
The Government only consider and agree with one committee conclusion under this heading - that the CLG needs to take a stronger ambassadorial role amongst other Government Departments and agencies to promote housing-related support in the context of the health and social care policy areas to ensure the continued recognition of SP services and effective partnership working at local levels. Accepting this ‘recommendation', the Government note that it will be important to ensure that the preventative role of housing related support is recognised in the ongoing work on the future of the care and support system, including identifying and taking forward work to ensure housing related support is included in the JSNA.
The joint DH - CLG housing policy forum, which considers matters of cross-cutting interest to both departments, will be used as a strategic forum to address cross-cutting issues important to both departments and draw in other departments as necessary, such as the Ministry of Justice. In particular, the Government will use the forum to raise the profile of, and take forward work to look at amending the QAF to take account of the CQC standards which are due to be implemented in April 2010.
The Government also agree that CLG has a responsibility to act as an ambassador for housing related support for Government, and to ensure that the benefits of investment into housing related support are recognised, particularly through promoting the results of the Capgemini financial benefits research. They also intend to carry out further analytical work to build on this model.
There is currently a ministerial Sheltered Housing Working Group considering the issues arising in sheltered housing. The Select Committee recommended that, based on the evidence received, this group should focus on:
- reviewing whether sheltered housing should stay within the SP regime
- improving needs analysis so that evidence is available of what older people want
- developing a more coherent strategy for the provision and funding of housing and support services for older people, clarifying the role of sheltered housing
The committee also recommended that the group consider the effect of splitting ‘accommodation' and ‘support' under SP on builders of supported housing, and make recommendations about how to ensure that capital investment in new supported housing is not threatened by the risk of ongoing revenue funding being unavailable.
The Government accepts that a review is needed but that the ministerial group may not be the best forum considering the financial and possibly legal implications linked to the recommendation. There are a number of cross-cabinet sub committees and the Government will decide which is best placed to investigate and resolve the issues.
Supporting People Distribution Formula
The Government responds to 5 conclusions and recommendations in this section.
The Committee recommended that there should be accelerated movement towards the needs-based allocations but the Government has reservations, noting that, because of the inclusion of SP in the area based grant from April 2010, the outcome of any acceleration towards full needs-based allocation will not be measured. The Government considers that any decisions about accelerating towards full needs-based allocations will need to take place as part of the discussions on the next Spending Review which will determine the overall size of the SP budget for the next period and indicate how LA budgets would be affected if the amount of grant available nationally were to change.
The Committee also recommended that the commissioned study of the SP Distribution Formula considers issues of rurality and population growth and take steps to address those issues. The Government state they are considering recommendations ahead of the determinations for allocations for 2011-2012, and will consider whether the formula should be further amended to take account of these issues.
The Select Committee conclude that it would not be appropriate at this stage to put SP on a statutory footing, nor that there is a need to compel local authorities to adopt mandatory Performance Indicators for housing-related support. However, retaining the SP ‘brand' and championing its purpose will be very important in the absence of other protections. The Government agrees, (no surprise there!) - noting that through the work of the Supporting People Transition Board and national representative organisations, they will continue to use and champion the SP ‘brand' (watch this space) alongside the need for development of housing related support services.
The Committee concludes that the SP programme has achieved a great deal and any avoidable threats to its continued success must be averted. The Government agrees and commits, as mentioned, to continuing to demonstrate the value of SP through encouraging the use of the local financial benefits model and the national Capgemini research work to demonstrate the ‘invest to save' nature of the programme. (Ideally this would take account of benefits achieved by enabling services as well as of savings achieved through prevention)
The Committee recommends continued transparency in the allocation of SP funding in the area-based grant. They suggest that LAs should not be required to spend funds allocated on the basis of assessed need for housing related support on those services if they consider that it would be better spent elsewhere. They should, however, be required to justify, and account for, any decision to do so.
The government supports the recommendation for transparency in the allocation of the SP funding within the area based grants, and it will continue to provide LAs with details of the SP allocation when SP is placed within the area-based grant and monitor the provision of housing related support services through the national indicator set and through the quarterly SP local systems data (although data collection by been ‘streamlined' recently), but it will not be able to tell how much of the SP allocation is spent on housing support services.
The Government considers and responds to just 2 final conclusions and recommendations in this section.
The Committee concludes that pressure on LA budgets is a potential threat to the future of some existing SP services and to the likelihood of currently unmet need being addressed in future, and although the government accepts this, both parties note that the question is how best to address that threat, particularly in the current economic climate, recognising that it applies equally to other LA services, and that LAs working with their partners are well positioned to determine how best to allocate resources.
Finally, the Committee state that they do not recommend the re-imposition of the ringfence on SP funding (no surprises there either) and the Government welcomes the committee's endorsement for the lifting of the ring-fence for the SP programme, agreeing that the re-imposition of the ring-fence would restrict the flexibility of LAs to offer better, more innovative services that are more tailored to the needs of the individual and hinder the mainstreaming (dilution?) of the programme in LAs' service delivery.
The Government will continue to raise the profile of the SP programme through dissemination of good practice and by highlighting how it can help support and deliver across a wide range of government agenda and local authorities' priorities.
The ring-fence was never going to be retained - this became apparent in March 2005. As SP funding constitutes one third of Area Based Grant, the "new" funding stream which is intended to fund Local Area Agreement targets in specific terms and, in general terms, the entire new local government framework introduced by central government, the government would never allow that degree of inflexibility over a full third of its revenue pot for local services. We think that Supporting People won't be retained either - the CLG will probably only continue to give details of their SP allocation until 2011, which is when it will officially cease to exist.
We referred to the CLG report as a ‘missed opportunity' in our briefing on the day it came out. It would have surely been better had the sector's representative organisations dropped the un-winnable ring-fence argument and concentrated on the need to secure one third of Area Based Grant for preventative and enabling services, the ones that demonstrably save the government money and improve the lives of vulnerable people and the communities within which they live - the ones the sector has always strived to provide.
It's still possible for providers to make the case for their preventative enabling services. There are economic and social arguments to support them: prevention is always better than cure and it's cheaper, but making that case would have been so much easier had the sector representatives not allowed themselves to be encouraged by the Government to bark up the wrong tree for the last few years.
Trainer & Consultant
(Added to site Wednesday, July 14th, 2010)
Other Articles In This Issue
Briefing 10 Home
Revenue: There May be Trouble Ahead
The Evolution of the Personalisation Agenda
Tendering: What Should you do Before you Tender?
Tendering: What Should you do When You've Won?
Revenue: Strategies for Providers of Housing Support & Social Care
Hoarding: What Lies Beneath it All?
Volunteering: Still an Important Contribution
Responding to the DWP Consultation: Housing Benefit Reform - Supported Housing "Sincere thanks to Michael Patterson for an excellent presentation on the HB Reform issues in Leeds last week, and for all the very helpful info and links. I do intend to respond on behalf of our organisation, Caring For Life, but feel that Support Solutions' response is excellent." E.S. - Caring for Life