CYP(3)-AS-17

10 Coopers Yard
Curran Road
Cardiff
CF10 5NB

SNAP Cymru is the foremost independent provider of Parent Partnership Services in Wales, regionally structured, delivering services within local communities across Wales. Founded in 1986, our trained staff and volunteers have supported parents, carers, young people and professionals working with families for over 20 years.

SNAP Cymru seeks to promote a partnership between families and service providers, supporting families to build skills in self-advocacy, negotiation, and partnership working. SNAP Cymru can also provide representation and advocacy for those families who need and request a higher level of support.

The needs of children and young people are paramount and are central in the development and delivery of all services provided. SNAP Cymru encourages partnership, listens to children and gives families a voice in the planning and development of services and in decision making processes affecting children and young people. SNAP Cymru services are available for children and young people from birth to twenty-five years of age.

Mission Statement

This sets out our primary function:

SNAP Cymru will empower families (parents, carers, children and young people) to have their voices heard within the area of Special Educational Needs and support them to influence policy and practice in the planning and delivery of services at both local and national levels

Organisational Aim

• SNAP Cymru’s charitable aim is to advance the education of people in Wales including those with additional learning needs/disability (SEN) and in order to achieve this aim and make this mission statement a reality have set their charitable objectives.

SNAP Cymru response to the Welsh Assembly Government (WAG) consultation on a New Service Model for Delivering Advocacy Services for Children and Young People

SNAP Cymru agrees with the vision and sentiments set out in the introduction. However the language, framework and an agreed definition of disability must be addressed. Furthermore the document does not clarify a proposed timescale implementation of each stage.

Definition of 'disability’

A disabled person is defined in the Disability Discrimination Act 1995, as someone with a:

"…physical or mental impairment, which has a substantial and long-term adverse effect on his ability to carry out normal day-to-day activities.”

The legislation is open to differing interpretation by accompanying statutory guidance, which provides information on matters to be taken into account in determining the definitions of disability.  There is no single definition of disability which encompasses all the elements from sensory and communication difficulties to mental and physical disabilities.  In considering the differing models

Social model:

"Disability is the loss or limitation of opportunities to take part in the normal life of the community on an equal level with others due to physical and social barriers.”

Disabled people are marginalised by the slow progression of inclusion in Wales and are often not afforded the same opportunities as their peers regardless of ability or disability.

Medical model: Focuses on what is wrong and how medics and other professionals can put it right rather than how we can all make reasonable adjustments to achieve inclusion.

Presently the definitive model is in the hands of each individual in society and within each agency and discipline. Criteria for assessment and access to services are a postcode lottery. What is important is to consider how the disability affects each individual in each circumstance and to deploy services to meet need. WAG should not allow discrimination between one child and another but ensure consider to their perception, feelings and circumstance.

Complaints - There is too much focus toward the making of complaints rather than real participation, listening to children and allowing them to confidently have their voice heard and views openly considered in policy and service development and planning and in decision making which directly affects them.  The registering of complaints should not be the only opportunity where CYP are able to access an advocacy service. Advocacy needs to be readily available to improve participation, to foster a sense of ownership and avoid disagreement and conflict. This focus would reduce the need to 'complain’.

Q1. Agreed summary of key drivers

Q2. More weight to partnership and participation for all children. There is also a need to prioritize advocacy for children and young people being excluded from school as well as for LAC. School exclusion can lead to disengagement, family or placement breakdown. The longer-term issues of social exclusion are well documented in Home Office statistics.

Q3. Agreed but need a commitment to all children within an agreed timescale

Q4. Sufficient weight must be given to promoting the rights of children to be involved and to have their voice heard and their views given due respect. Planning to allow children and young people to make representation on all corporate issues is to be applauded. Promoting these rights to children and the wider audience is vital if we are to achieve change.

Q5. Implementing and monitoring national standards will achieve equity and quality. Monitoring arrangements must be in place to measure accessibility, quality and independence.

Q6: SNAP Cymru cannot agree as models of access leave CYP outside of the priority groups feeling that they cannot complain. CYPs in all 'categories’ live their lives in very individual circumstances; differing levels of need, ability and opportunity. Advocacy needs to be made widely available to all CYP a timeframe for achieving this would be more acceptable.

Q7. Agreed

Q8: Advocacy should be made available under any circumstances in schools where a CYP requires support to participate in decision making, have their views heard, rights respected, etc. Making it more widely available will eventually increase the number of CYP self-advocating, self-referring, building skills to participate. CYP should not be permanently excluded without advocacy and representation. More school closures will add to the exclusion of children from communities when they are excluded from their local school. Loss of education provision and poorly developed education outside of school is proving great disservice to children. School exclusion, both fixed and permanent is too serious a matter for children and society. Children need  advocacy and representation at the highest level.

Q9: All complaints must be taken seriously and advocacy must be available where decisions, which affect CYP, are being made, in particular but not exclusive LAC Placement changes, Out of County LAC, School Placement, Key annual reviews, out of county education, Formal Complaints about service provision from all agencies- Health, SSD, Education, Schools, not for profit providers and private providers.

Q10: Whilst understanding the starting point of  "Severely disabled” a change to "Disabled” would lessen criteria issues and interpretations. Again the model is prioritising - excluding groups of children from accessing advocacy.

Q11. The proposal will support accessibility and drive development as well as quality standards through benchmarking.

Q12. Collaborative partnerships could be defined within existing consortia e.g Education which takes in up to 6 CYP areas.

SNAP Cymru have been developing advocacy services for the last 8 years via grant funding from Children in Need. A new course has been designed awaiting accreditation September 2007 NOCN.  The course specializes in Additional Learning Needs (SEN Framework), Exclusion from school or other educational establishments and appeals to SENTW. SNAP Cymru have experienced staff and volunteers able to support CYP at informal and formal complaints/advocacy stages.

SNAP Cymru has considerable expertise in supporting CYP with additional learning needs, particularly around SEN Framework and school exclusion. Development has been supported by Big Lottery and work piloted within South East Wales. Reports available.

Q13. Realistic costing and a continuum of service accessible for all children.

Q14. This may be achieved through collaboration with all disciplines and Heads of Services, identifying proven ability within CYPs to lead and manage effectively.

Q15. Joint funding arrangements between all disciplines.

Q16. Model 2 is the preferred option as the steering group could play a vial role in monitoring quality standards and benchmarking as well as disseminating good practice and ensuring that in relation to service delivery, progress is made and lessons learned from the information gathered.

Q17. Regional collaboration over a larger area will avoid duplication and be more cost effective

Q18. Yes

Q19. Yes

Q20. Yes

Q21. Yes

Q22. This should be reviewed annually

Q23. The timescales are achievable. Additional timescales for all CYP required.

Q24. SNAP Cymru would be interested to develop services across consortia areas within Wales. Considerable development has already taken place.

Q25. Yes

Q26. Yes

Q27. Advocacy Providers, CYP, Health, Education, SSD, Childrens Complaints Officers, Primary and Secondary Heads, GPs,

Q28. Yes they should

Q29. Not necessarily, what is vital is there are minimum standards for training and service provision and a code of practice to adhere to.

Q30. SNAP Cymru would work with new proposals as necessary

Call For Evidence Dec 2007

1. There seems to be a widespread consensus that advocacy services should be independent. How do you think advocacy services should be commissioned to ensure a level of independence that gives children and young people confidence and builds trust in the system at the same time as providing services which are flexible and responsive?

Whilst SNAP Cymru agrees with the consensus re 'independence’ we would put more weight to services which are also 'impartial and objective’ listening and encouraging participation in planning and decision making. Children and young people need to make representation of their views, being fully informed of options and choices available to them.  For this to happen they need Advocacy providers who could support them to understand rights, roles and responsibilities of parents, professionals, agencies and themselves.

Advocacy Providers must work in partnership with all agencies to be able to provide services which are flexible and responsive to Children and Young people’s needs and circumstances.  A rights base provision without the understanding of 'duty of care’ would be a great disadvantage to children, young people, families and society.

CYPPs would need a framework, regional collaborative planning and the support of a National advocacy Unit to ensure consistency in commissioning and monitoring and evaluation of service and standards. It is vital that Wales develops a 'caring advocacy model’ that incorporates the 'right to be heard their views and concerns taken into consideration’. There is a strange anomaly which appears to allow some advocacy services to deliver without 'the duty of care’ thinking - that is 'rights’ based as opposed to considering the best interest or needs of the child or young person. Commissioners of the New Model of Service should ensure that all providers are bound by the same duty under the Children’s Act i.e. the needs of the child or young person being paramount.

There is a need for locally based services, services which can operate cross county, regional and cross regional basis as well as national access to specialism when required.

2. The Welsh Assembly Government has consulted on a New Service Model for Delivering Advocacy Services for Children and Young people.

(i)  Did you respond? Yes

(ii)  Are you prepared to share your response with the committee?   Yes see above

3. The Assembly Government consultation document suggests a New Service Model which places responsibility for local and regional planning and commissioning of Advocacy Services with Children and Young people’s partnerships in each local authority area. The document also proposes the establishment of a Children’s Advocacy Unit. The unit will not have commissioning responsibilities or powers of inspection or enforcement. Rather it will be a national resource support to oversee the ew Service Model and ensure compliance with the national Minimum Standards for the provision of Advocacy services.  

(i) Do you think the service model as outlined is adequate to meet its stated aim of ensuring more independent and accessible advocacy services in which children and young people can have confidence?

Whilst local CYP’s could be a good model for commissioning, at the moment they are not an experienced  commissioning body,  other than for the Cymorth funding stream. CYPPS across Wales are not consistent in their development and approach, which is why regional collaboration will be important in early development and benchmarking. The CYPP teams would need commissioning guidance and training in order to understand legislation, the complexities of need, provision, policy and practice when commissioning advocacy services.

(ii) What are your views on the Children's Advocacy Unit,  as outlined in this consultation document? What role and function would you like to see a national advocacy unit taking?

The National Unit, will be essential in order to guide/monitor and evaluate the CYPP’s commissioning role and to lead on quality assurance systems.