Cynulliad Cenedlaethol Cymru
CYP(3)-AS-04
Consultation on a New Service Model for Delivering Advocacy Services for Children and Young People
Response Questionnaire
The closing date for this consultation is 23 July 2007 Your comments must reach us by that date
Plant A Phobl Ifanc - Gweithredu’r Hawliau
Children And Young People - Rights To Action
March 2007
G/583/06-07 March ISBN 978 0 7504 4134 6 CMK-22-12-094 © Crown copyright 2007
Consultation On A New Service Model For Delivering Advocacy Services For Children And Young People
The closing date for this consultation is 23 July 2007. Your comments must reach us by that date.
The information you provide in your response will be subject to the Freedom of Information Act 2000 and Environmental Information Regulations, which allow public access to information held by the Department. This does not necessarily mean that your response can be made available to the public as there are exemptions relating to information provided in confidence and information to which the Data Protection Act 1998 applies. You may request confidentiality by ticking the box provided, but you should note that neither this, nor an automatically generated e-mail confidentiality statement, would necessarily exclude the public right of access.
Name: Sharn Annett
Organisation (if applicable): Blaenau Gwent CYPP (on behalf of Blaenau Gwent County Borough Council
Email/Tel number: sharn.annett@blaenau-gwent.gov.uk 01495 355584
Address: Heart of the Valleys Integrated Children’s Centre, High Street, Blaina. NP13 3BN.
If your enquiry is related to the consultation, you can contact Patrick Harper on: 02920 825296, e-mail: patrick.harper@wales.gsi.gov.uk.
General |
|
| Are the areas covered by the Draft Consultation on a New Service Model for Delivering Children’s Advocacy Services comprehensive and pertinent? Are any critical issues not covered? | |
| Should any part of the draft document be changed and, if so, how? | |
| Are the key Actions proposed appropriate and relevant? Are there other Key Actions that could be included? | |
| We would welcome any practical examples that can be used to illustrate the text. |
Response:
We support the principle of establishing a universal advocacy model, however, if there is a move towards regional commissioning, smaller organisations, who may be delivering high quality services, will be vulnerable as they won’t have the capacity to bid to deliver large regional service provision, or they may be tempted to expand beyond their expertise/capacity.
Establishing a generic specification and standards for advocacy services should be key to the establishment of a new service model, and then the way in which this is commissioned should be the subject of local determination.
Chapter 3:Background and rationale for change
| Q1. | Have we accurately summarised all the key national drivers for change and their findings or conclusions? |
| Q2. | Are there any that we should add, or give more weight? |
| Q3. | Do you agree with our vision and overall aims for advocacy services for children and young people in Wales? |
| Q4. | Should the key aspects be strengthened or amended in any way? |
| Q5. | Do these arrangements meet the requirements for accessibility and independence? |
Response
Q1 The document provides a useful comprehensive overview.
Q2 We believe that there needs to be a greater linkage to the participation agenda.
Q3 The document lacks a concise vision and overall aims need to be more explicit.
Q4. The key aspects referred to would apply to all services and it is not clear what is specific to advocacy.
Q5 It is not clear to whom the issue of accessibility and independence is addressed
Chapter 4 : The New Service Mode
l
| Q6. | Do you agree with the proposed staged approach to collaborative commissioning and have we correctly identified the areas which require priority attention within the New Service Model? |
| Q7. | Do you agree with the principle of moving towards a more integrated model of provision? |
| Q8. | In what circumstances do you consider advocacy services should be available to schools? |
| Q9. | How can we define a serious complaint and in what circumstances do you feel advocacy support would be important? |
Q10. |
Are there other groups of children and young people that should be included in the service model two? |
Response
Q6 The separating of stage one and two is too artificial, therefore we disagree with this approach. We believe that all Children in Need should just be classed as stage 1.
Q7 We support the proposal to establish an integrated model of provision, but there needs to be clear roles and responsibilities amongst partners. CYP partnerships are not a legal entity and can’t itself take on the financial role of commissioning. This means that one partner would have to undertake the role and the risk. Also all partnerships are at different stages of development so the capacity to undertake joint commissioning may be different in each area. The document also needs to acknowledge that there are services already in place – what happens to existing advocacy services?
Q8 The service should be universally available to all children – the focus should not be on the service/professional setting. Emphasis should be given to empowering the child and enabling their voices to be heard in a whole range of settings.
Q9 All complaints should be considered serious because it is obviously a major issue for the child. Advocacy is important if the child felt they need additional support.
Q10 Young carers, children affected by substance misuse and domestic abuse need to be added.
Chapter 6: A Framework to Implement the New Service Model
Q11. |
Is the proposal for collaborative commissioning across local areas the most realistic and best way forward to achieve improved access to, independence and quality of advocacy services to children and young people? |
Q12. |
How might collaborative partnerships be defined across Wales? Are there any existing partnerships relevant to your area and/or to advocacy services that could be used or further developed for this purpose? |
Q13. |
What other influences on commissioning or commissioning drivers relevant to children and young people’s services do we need to take into account? |
Q14. |
How might the lead Children and Young People’s Framework Partnership for collaborative commissioning be selected? |
Q15. |
What are the barriers to establishing a lead CYPFP and lead commissioner for advocacy services, and how might they be overcome? |
Q16. |
Which structural model outlined in section six do you prefer and why: model one or model two? |
Q17. |
Are there any other models that you think we should also consider, and what are their key characteristics? |
Q18. |
Are the roles and responsibilities of key commissioning partners outlined in section six sufficiently clear and robust? |
Q19. |
Are the commissioning principles outlined in section six sufficiently clear and robust? |
Q20. |
Are the proposals for governance and performance management sufficiently robust? Are there any that we have missed? |
Response
Q11 It is essential that the process is robust and it may be best in some circumstances for a service to be provided as a National Independent Service which is centrally funded to ensure equity of access and standards of provision.
Q12 Owing to different counties contracting with various advocacy service providers cross boundary commissioning of advocacy services could prove problematic.
Q13 It is imperative that we are aware of the workforce implications and the resources needed to implement this service.
Q14 If a collaborative model is to be implemented then it should be left down to local agreement on the basis of which CYP Partnerships have the capacity/expertise to undertake the lead commissioning role.
Q15 Differences in expectations, resources, expertise and capacity.
Q16 Model 2 is favoured as this ensures that a steering group consisting of all parties are equally engaged and there is a clear direction and purpose.
Q17 We believer that WAG should consider establishing a National Advocacy Service that is centrally funded especially for low volume high need groups e.g. minority groups as asylum seekers. Individual local contracts to meet local needs should also be a model for consideration..
Q18 They only address the lead CYPP and commissioner, not all partners to the process. There need to be clear understanding of what this entails and what ‘teeth ‘ the process should have.
Q19 Yes
Q20 Issues about accountability, non compliance etc. What happens if one element of the structure is performing badly?
Chapter 7: Role of a Children’s Advocacy Unit
| Q21. | Do you agree that we have identified the support and development needs to ensure the delivery of the service model proposed? |
| Q22. | What additional forms of support might be necessary? |
| Q23. | Are the timescales for implementation of commissioning service under the New Integrated Service Model (by 2008 for Stage One and Two)achievable? Are there any constraints? |
| Q24. | What will be the impact and cost implication on your business in introducing the New Service Model? |
| Q25. | Do you consider we should set up an Advocacy Unit as suggested above? |
| Q26. | Would it be advantageous to set up a Board, i.e. to monitor progress and advise Assembly Government Ministers? |
| Q27. | What do you feel would be the minimum representation membership on the C&YP Advocacy Advisory Board? |
Response
Q21: Our overwhelming view is that this needs to be integrated with participation/CYPP support unit proposals and that they must have the power to instigate sanctions. There also needs to be a clear quality framework.
Q22: If you see advocacy as a key right, then it doesn’t matter what setting the child requires help in. For example specialist services for specialist children commissioned through Health Commission Wales.
Q23: We do not believe that the timescales are realistic, given the immaturity of the new CYPPs and the work of producing a single Children’s Plan.
Q24: If there is a move towards universal provision of advocacy services then the costs will be significant, as currently advocacy services are only available for Children in Need. Services will need to grow to meet increased demand – cost/resource implication. Also there is a lack of evidence to support future service planning on demand/future usage of a universal service so it may be a very expensive underutilised service, or too small to meet the large demand. The real impact is difficult to estimate at this point.
Q25: Not independently of other support functions. Needs to be integrated with participation, joint commissioning, partnership etc.
Q26: Needs to be integrated and have a clear purpose.
Q27: All key stakeholders including children and young people.
Chapter 8: Workforce
Q28. |
Should advocacy services/providers be regulated? |
Q29. |
Should advocated be a recognised profession? |
Q30. |
What are the implications to your service in requiring registration and regulation of advocacy providers? |
Response
Q28: Yes, without question it is essential that advocacy services/providers are appropriately regulated given their key role with children and young people.
Q29: Many benefits could be accrued from establishing a clear training portfolio of recognised skills to ensure consistency.
Q30 : We would need to be clear who is expected to regulate the providers. If partnerships are required to do this it would have a significant implication on workforce capacity.
