Devolution of Community Care Grants and Crisis Loans: Analysis of consultation responses

3 Delivery arrangements

3.1 The consultation paper proposed that the successor arrangements operate Scotland-wide, but could be organised either as a centralised system or be locally delivered. A centralised system was seen as offering the advantages of standardisation and lower implementation costs, potentially to the detriment of a client-focussed and more joined-up approach capable of being sensitive to local circumstances. Whilst local delivery may offer these features more readily, it would also introduce local variation.

3.2 The paper noted the relationship between the Scottish Government and local authorities through the Concordat and suggested that, with additional funding, local government would be well-placed to provide local delivery arrangements that would provide a client-focused and integrated package of support. It also noted that local authorities have experience of making emergency payments under Section 12 of the Social Work (Scotland) Act 1968 and Section 22 of the Children Scotland) Act 1995.

3.3 The paper acknowledged that whilst funding to local government is not ring-fenced, it might be possible to agree common parameters for eligibility with local government. It also signalled that other national and local delivery partners would be likely to be involved in service delivery, including health and third sector organisations, to deliver client-focused support.

3.4 The paper sought views about appropriate delivery channels, whether in a centralised or local system, including online, telephone or face-to-face. These were noted to present different administrative costs and risks of fraud, and to raise issues of access for applicants, particularly those who are disadvantaged.

Overview

3.5 Table 3.1 shows that around two-thirds of all respondents expressed a clear preference for either central or local delivery arrangements, with a majority of those giving a clear view in favour of local delivery.

Table 3.1: Do you favour centralised or local delivery of the successor arrangements?

Respondent type	Local	Central	No preference/ both	No Data	Total
Third sector	9	11	6	3	29
Local authority	9	-	2	2	13
Other public sector	1	-	-	2	3
Individual	2	1	-	1	4
Social Fund Commissioner	-	-	-	1	1
Total	21	12	8	9	50

3.6 Views about the relative merits of central or local delivery were frequently hedged by reference to a need for adequate and safeguarded funding. Table 3.1 also shows that 17 respondents did not give a clear view about whether central or local delivery would be most appropriate; rather the relative merits of both approaches were discussed. Others did not address the question directly and it was suggested that there was insufficient information to make a judgement particularly around the level of funding to be available:

"It would be useful to see some proposals of how each approach could be implemented and the possible cost implications of each. Whatever approach is adopted it needs to be efficient to ensure the maximum amount of grant money goes to the people who need it." (Third sector)

3.7 One non-local authority respondent queried the loss of potential economies of scale if a single system were to be devolved to 32 local authorities. This respondent raised questions about whether the contributions of other partners would be included within existing contracts or new commissions and how the costs of administration would be met. Uncertainty amongst respondents was attributed to the lack of a clear statement in the consultation paper about whether local authority administration costs would be funded under any arrangements for local delivery. In addition, respondents were concerned more broadly about the wider impact on local government resources.

3.8 Reference was also made to the changing broader welfare reform context which would have local implications, including housing benefit changes, the introduction of Universal Credit and limiting of Crisis Loans.^[20]

3.9 Central or local delivery were not always seen as mutually exclusive options. A number of respondents, who broadly favoured local delivery as a way of ensuring a client focus, suggested that there should be a national framework to ensure consistency across local authorities with flexibility for local specific variations.

3.10 The point was also made that the costs of delivering the successor arrangements may vary across Scotland particularly in remote and rural areas.

3.11 General principles that should apply to social care or welfare provision were summarised as:

• The provision of high-quality support
• Transparency about the type of assistance which is available
• Clarity about the situations in which help can be given and who to approach
• Consistency of objectives across locations, so there is actual and perceived fairness between different groups of citizens and
• Safeguards to protect the needs of vulnerable people.

Arguments in favour of local delivery

3.12 Amongst those prepared to indicate a choice between central and local delivery, the option of local delivery was preferred, particularly for local authorities, none of which clearly supported central delivery.

3.13 Local delivery was seen to offer less scope for economies of scale, but better value for money:

"Although implementation costs could potentially be reduced in a centralised system, any system that does not achieve a client focused outcome cannot be argued to give value for money if it does not successfully reach the group it has been set out to target." (Third sector)

3.14 Local delivery was widely cited as the best way to ensure a more client-focused or person-centred approach, linking clients' needs to locally available services and support, whether from the local authority or third sector organisations. This approach would be more adaptable to specific local circumstances and be able to address the needs and priorities of local communities. This view was adopted by a range of types of organisations.

3.15 Respondents felt that deployment of such local knowledge and discretion could also play a role in ensuring better judgements and targeting, potentially avoiding misuse of funds (for example, in relation to transport issues in rural areas). Greater help at the point of application to advise on eligibility would reduce appeals, and hence administrative costs, thus allowing more funds to be available to applicants.

3.16 Whilst either approach might allow for a variety of delivery channels, only local delivery offers the prospect of face-to-face contact and was seen as vital for ensuring equity of access, improving the quality of customer service and decision-making. A local service was cited as a potential gateway to a wider range of services and support and offering the prospect of a more holistic and tailored response to needs.

3.17 Those supporting local delivery thought local organisations could also play a larger role in assisting with administration than at present: the Post Office was given as an example of a trusted intermediary agency that would be able to take on a role in verification of identity.

3.18 On the other hand, they also acknowledged that a local approach would bring added layers of bureaucracy and costs, and a risk of inconsistency and lack of clarity for clients.

Arguments in favour of central delivery

3.19 Table 3.1 shows that 12 out of 50 respondents favoured central delivery. Whilst there was no consensus amongst third sector respondents about the most appropriate form of delivery arrangements, almost all of those clearly favouring central delivery were third sector organisations, largely those working at a national level.

3.20 The main arguments in favour of central delivery suggested that it is likely to be a more cost-efficient and fairer model. Central delivery would consequently allow greater funds to be available to meet need and would avoid a 'postcode lottery'. A number of respondents made reference to plans for England:

"To avoid variations between localised schemes, we urge the Government to create clear, national eligibility criteria and the right to an independent review of decisions on whether the criteria are met. This will make centralised delivery a more cost-effective option, particularly in relation to the review function. Any system will need to make creative use of community organisations throughout Scotland to facilitate access to the scheme for all. Whilst the phrase 'postcode lottery' is chronically overused, it seems to be the only apt description of the picture emerging of the plans for a replacement scheme in England from 2013". (Third sector)

3.21 It was also noted that this approach was the one most likely to be able to be implemented by April 2013.

3.22 The current centralised system was said to be 'efficient, fair and gives a speedy response; [ensuring that] a substantial proportion of the money reaches the needy'. A contrasting argument was also made that, whatever its merits, the existing centralised model does not actually produce equitable outcomes in different parts of the country because these are the result of local budget constraints rather than a response to distinct local factors.

3.23 A centralised system was thought to potentially allay concerns that local funding would not necessarily be ring-fenced for the Fund. It was also suggested that unless eligibility criteria changed radically, it would be unlikely that the types of needs would vary significantly across the country. However this situation would need to be monitored to ensure local needs, for example, in rural areas, were being appropriately met.

3.24 Central delivery was also seen as easier and more efficient to regulate and to adjust, than 'a proliferation of local schemes and providers'. It would also offer greater opportunities to develop data verification protocols, for example, with DWP, to avoid the need for applicants to repeatedly provide the same information.

3.25 It was proposed that any adoption of a centralised approach should not simply be a reproduction of the existing system:

"It is important that the devolved system isn't simply a rebranded version of the existing system with large, impersonal call-centres dealing with applications producing the same frustrations and inconsistencies that people experience engaging with the current system". (Third sector)

3.26 It was suggested that some of the noted difficulties with the existing centralised system, including the need for better quality in decision-making, could be tackled by staff training to ensure consistency and fairness in implementation. Within a centralised system, there could be a role for local partners to provide face-to-face advice and support. This was seen to be particularly important for people for whom a national gateway (primarily suited to telephone and online applications) is not easily accessible.

Appropriate local delivery organisations

3.27 In considering how local delivery might operate, local authorities were most widely cited as being suitable or obvious vehicles to take on the successor arrangements. Most of the local authorities responding thought they would be the most suitable local delivery vehicle, noting that this could be done in partnership with local Community Planning Partnerships and Credit Unions. Third sector organisations that supported local delivery did not necessarily propose that local authorities should take this role on. Other suggestions included the third sector, Credit Unions, local job centres and Her Majesty's Revenue and Customs (HMRC).

3.28 One local authority suggested that they had insufficient information about staffing and financial resources to make this judgement and raised a number of concerns about possible conflicts of interest in relation to public sector staff who currently assist people to claim from the Social Fund.

3.29 It was less common for respondents to suggest that the delivery role should be taken on solely by third sector organisations:

"Several charities or organisations already exist in most geographical areas, whose focus or purpose is the recycling and refurbishment of household items. It would make sense to use and develop these to meet the local needs. This would also help to increase volunteer and employment opportunities in-line with the increase in skill requirements." (Third sector)

3.30 Respondents did not always explicitly identify who they thought should deliver local arrangements, although potential benefits were identified.

3.31 The rationale for such a role for local authorities related to access and consistency across Scotland; the experience of administering financial payment systems and cash transactions, including out-of-hours emergency payments; quality and assurance issues; and the link with social work.

3.32 Issues of implementation for local authorities that were highlighted included training needs:

"Delivery organisation(s) need to be chosen carefully. On the whole councils seem best placed to deliver given their extensive network of offices, but only if those offices are equipped to operate the system. This means that all staff must be trained in inequalities sensitive practice." (Individual)

3.33 Local authority delivery seemed to enable a fit with local solutions and local policy agendas. At the same time there were concerns about the inability to ring-fence funding and any potential deterrent effect of social work services involvement.

3.34 The point was made that existing discretionary payment schemes show that eligibility and the exercise of discretion can vary widely across local authorities. Therefore, if local authorities were to become delivery agents, there would be an issue of defining the limits of discretion within national parameters, leaving sufficient scope for them to take into account local factors, such as rural poverty.

3.35 In supporting the idea of common parameters for eligibility across local government, a third sector respondent raised the issue of the need for monitoring and analysis of how grant payments are used and the levels of need recorded.

3.36 Whilst some respondents urged the government not to consider local delivery at all, others saw it as an opportunity for co-production through the involvement of a consortium of organisations, including Credit Unions and the Third sector, delivering services for the Community Planning Partnership. Local authorities also already have mechanisms for communication with all households in their area which could help to address low take-up amongst certain groups.

3.37 Other comments suggested that regardless of who delivers the service, local delivery should not be fragmented, but channelled through one organisation for simplicity. The need for inclusive communication to ensure full accessibility for disabled people was also identified.

3.38 As before, the issue of resourcing in relation to delivery by local authorities was an important caveat:

"If Local Government is the preferred delivery mechanism for Community Care Grants and Crisis Loans under the consultation on successor arrangements, the Scottish Government must work to further explore and discuss detailed proposals for delivery arrangements that meet the concerns of Local Authorities - this should include detailed consideration of financial risks and liabilities, quantified costs and resources for delivery arrangements, and confirmation of funding levels and distribution rationale." (Local authority)

Ensuring a client-focused approach with central delivery

3.39 The consultation paper asked those that supported central delivery how a client focus would be maintained. Respondents linked the issue of client focus to the adequacy of overall funding for the successor arrangements and the need for clarity about where these costs will fall. There was an expectation that even within a centralised system, a number of local authority services and other support providers would still be involved.

3.40 It was suggested that clear national standards for eligibility, procedures for applications and decision-making, and a right of appeal should all underpin a client focus under a centralised system. Delivery and administration could then be locally based:

"....national criteria setting out how local conditions should impact on decision-making, coupled with support with applications for those who need it in their local area will maintain a better client focus than a vaguely defined duty, with the potential to be interpreted differently in different areas." (Third sector)

3.41 The challenge of a central system was seen as the need to design simple, effective and proportionate processes that can ensure people are not disadvantaged by any lack of face-to-face contact. There was a clear view across a range of organisations that this should be achievable. A centralised system could offer online and postal applications for those able to apply independently, backed up by a central, dedicated customer service team offering telephone support. The existing tax credit system was cited by one respondent as appearing to be working well in this respect. A centralised system was also seen as being able to provide tailored local information to both successful and unsuccessful applicants.

3.42 A client focus would need to be based on strong links with local service providers including Social Work Services, Housing Services (through local authorities and Registered Social Landlords (RSLs)), Community Health Partnerships and the Voluntary Sector. Respondents made the case for a local support structure, including advocacy support, within a centralised system:

"We see a key role for an effective system of advocacy support, to ensure that everyone is able to access the system. This kind of support would help to ensure that the clients needs were communicated effectively, and that the clients understood fully the decisions that were being made." (Third sector)

3.43 Respondents felt that local support organisations were able to offer more bespoke support, particularly, face-to-face support for people unable to navigate the central system independently or for those who might choose to seek assistance with an application or appeal. These organisations would have a key role to support vulnerable customers in making applications or acting as the channel through which applications should be submitted:

"....such agencies would interface with their clients, as well as with the central delivery team; thus each agency would have not only the relevant knowledge of their clients, but also well-developed personal relationships with both parties. This would mean 'getting it right first time' since each agency would send in only effective applications, thereby saving time, money, appeals and client stress." (Third sector)

3.44 Staff training was also seen to be key to providing a client focus. Respondents felt that staff involved in the delivery of the fund should have the required skills and values, and should have flexibility in the exercise of their discretion. Other suggestions for improving central delivery included use of named officers to handle a person's claim all the way through. All organisations involved in delivery, whether central or local, should adhere to principles of Inclusive Communication.^[21]

3.45 Within such a 'hybrid' approach, respondents suggested that local channels might also offer additional benefits as trusted individuals or organisations. Roles might cover the opportunity for local verification of identity or documents; expedited referrals; delegated decision-making; acting as alternative payees; or in cases where they are already giving considerable support to an applicant, Social Work Services may be authorised to act an intermediary for the applicant or do a 'supervised shop' with the applicant.

Channels for delivery: local or central

3.46 Views on the issue of delivery channels were linked to the ability to maintain a client focus. Respondents commented that, in light of the vulnerability of people who will apply to the Social Fund, it will be important to offer a choice of access methods. In general, respondents advocated the idea of a blend of delivery channels to ensure that a tailored service could be provided to assist the most vulnerable, as well as to comply with equalities legislation.

3.47 Whilst online applications may be efficient and cost-effective for organisations, some people are likely to engage better with other methods of access. Having a range of ways in which to access the Fund was seen as particularly essential for disabled people including those with sensory impairments, learning difficulties and mental health problems.

3.48 Respondents also suggested that there would need to be continuous publicity about how to apply.

3.49 The issue of adequate resources for local support and the risks of false economy by a failure to resource local support were also raised:

"Any central delivery which fails to resource localised face-to-face support, increases demand levels within local money advice services which are already stretched." (Local authority)

3.50 Face-to-face delivery was valued as allowing for a full assessment of needs in both routine applications and emergencies. This could also reduce the number of applications because the applicant can be made aware of other options for support. It was also valued as a way to 'humanise' the service and ensure all need are met.

3.51 Respondents' experience with the current system suggested that there were clear benefits of providing one-to-one assistance:

"Experience with the current system indicates that although clients can fill in the application form, more often than not it is a struggle, therefore one-to-one help is a guaranteed way of ensuring an accurately completed application is submitted. This in turn could contribute to a reduction in the number of refusals and ultimately appeals." (Third sector)

3.52 In this way, face-to-face services can be more cost-effective than telephone applications, which can be time-consuming and more open to potential fraud. Face-to-face options were also favoured as allowing better access to translating and interpreting services, independent advocacy and support for those with sensory impairments.

3.53 However, respondents consistently emphasised the need for flexibility and choice. The diversity of needs means that face-to-face delivery does not suit everyone. Some people find it a good way to put across their case; for others the interaction can be intimidating and stressful. Given this, there is still scope for misunderstanding and people may not get the support they need. Some people with mobility needs or with care support may find it physically difficult to attend a face-to-face meeting. Those living in areas without accessible public transport may need a home visit. Others may have communication problems which may mean that both face-to-face and phone delivery are unsuitable, while others may have limited dexterity which will make online or paper applications difficult.

3.54 It was suggested that special attention would need to be given to enabling access in remote areas of the country and for particularly vulnerable claimants. Local services such a Citizens Advice Bureaux and Credit Unions could help to make paper applications.

3.55 Respondents also stressed the importance of making telephone access more reliable by ensuring it is suitably resourced so there is less difficulty getting through (than is presently the case) and so it can be free for all, including mobiles. The issue of staff training was seen to be particularly important in relation to telephone applications:

"...telephony has its problems; in particular it is easier to be rude to claimants on the phone than when dealing with them face-to-face. This could be overcome by training. Training could be provided on how to deviate from a script when necessary." (Local authority)

3.56 The cost-effectiveness and efficiency advantages of online applications were acknowledged. Respondents proposed a number of ways of making good use of online services. Such services could help make the application process clearer to claimants, allow them or a professional working on their behalf to access up-to-date information on their claim or review and speed up the delay between initial decisions and the receipt of decision notices.

3.57 However, access to and use of IT can also be a significant barrier to claims, particularly for older people.

"Although it has been suggested that an online approach is cheaper, it could be argued that it is a barrier to making a successful application for certain client groups. Older people are a group who have already been identified as less likely to apply for a grant or loan under the current system and are often unlikely to have access to the internet." (Third sector)

3.58 Although applicants may not always have access to the internet, respondents felt it was important to retain the option to apply online, in combination with other methods which include support. These include telephone access, face-to-face, home visits, access to British Sign Language signers, postal applications to a freepost address and faxed applications. There should be a range of alternative formats, including Easyread and Braille.^[22]

3.59 Respondents suggested that those most likely to need assistance will struggle with both online and telephone applications. These access issues could be addressed by linking face-to-face services with support, alongside local facilities for applicants to access online or phone channels, ideally with people on hand to help, for example at advice centres. It was noted that services do not always have computers in the rooms where meetings with clients take place.

3.60 Access to online services by advisers or intermediaries might also provide the potential to link the application to available support and refereeing or endorsement for applications, thus allowing them to be processed more quickly. Concerns about the potential for fraud with online applications could be addressed by the inclusion of local verification checks, perhaps by Registered Social Landlords or social work services. A further advantage of a blended system of delivery channels is that it could link to local IT systems allowing real-time booking of appointments and data gathering, such as financial information or caseworker notes, ahead of face-to-face meetings. This would allow decisions to be made at the face-to-face appointment as well as facilitate exploring other options.

Summary of views on central or local delivery

3.61 Around two-thirds of all respondents expressed a clear preference for central or local delivery arrangements. However, discussions of the relative merits of central or local delivery were frequently hedged by reference to a need for adequate and safeguarded funding. About a third of respondents gave no clear view on this aspect of the successor arrangements. Further information and clarification on the level of funding to be available were widely requested to inform judgements about the best way to deliver the service.

3.62 Overall where a view was given, the option of local delivery was preferred, particularly by local authorities, none of whom clearly supported central delivery. Overall, 12 out of 50 respondents favoured central delivery. Whilst there was no consensus amongst third sector respondents about the most appropriate form of delivery arrangements, almost all of those clearly favouring central delivery were third sector organisations.

3.63 Key points were:

• Central or local delivery were not always seen as mutually exclusive options. There was an expectation that even within a centralised system, a number of local authority services and other support providers would still be involved.
• A client focus under a central or local system was seen to be inextricably linked to the issue of adequacy of funding and the need for clarity about where these costs will fall.
• Central delivery is likely to be a more cost-efficient and fair model, allowing greater funds to be available to meet need and avoid a 'postcode lottery'.
• Local delivery was seen to offer less scope for economies of scale, but better value for money by achieving a client-focused outcome.
• A range of types of organisations cited local delivery as the best way to ensure a more client-focused or person-centred approach.
• Only local delivery was seen to offer the prospect of face-to-face contact, vital for ensuring equity of access, improving the quality of customer service and decision-making. A local service was often cited as a potential gateway to a wider range of services and support and offering the prospect of a more holistic and tailored response to needs.
• Local authorities were most widely proposed to take on the successor arrangements at the local level. A number of issues of implementation for local authorities were highlighted included training needs.

3.64 Clear national standards for eligibility, procedures for applications and decision-making, and a right of appeal should all underpin a client focus under a centralised system.

3.65 In relation to delivery channels, under a central or local system, respondents endorsed the idea of a blend of delivery channels to ensure a tailored service to assist the most vulnerable, to promote accessibility of the service, to give choice and to meet a variety of needs. In light of the vulnerability of people who will apply to the Social Fund it will always be important to offer a choice of access methods. Having a range of ways in which to access the Fund was considered to be essential for disabled people including those with sensory impairments, learning difficulties and mental health problems.