Proposed Children and Families (Wales) Measure
Consultation response
CF6 (Annex) - Children’s Commissioner for Wales
Stronger Families
Supporting Vulnerable Children and Families through a new approach to Integrated
Family Support Services
Written response on behalf of the Children’s Commissioner for Wales
3rd October 2008
The Children's Commissioner for Wales is an independent children’s rights institution established in line with the Paris Principles. In exercising his functions, the Children’s Commissioner for Wales must have regard to the United Nations Convention on the Rights of the Child (UNCRC).
The Commissioner’s remit covers all areas of the devolved powers of the National Assembly for Wales insofar as they affect children’s rights and welfare.
Children's Commissioner for Wales
Oystermouth House
Charter Court
Phoenix Way
Llansamlet
Swansea SA7 9FS
Tel: 01792 765600
Any enquiries about this response should be directed to:
Peter Hosking, Senior Policy and Service Evaluation Officer
Email: peter.hosking@childcomwales.org.uk
We have no objection to this response being made publicly available.
Outline Proposals - Service and Legislative Change
Q 1. Do you agree with the proposed categories for IFSS support, that is parental substance misuse, mental health problems, learning disabilities and domestic abuse?
Yes but, if IFSS is found to be successful, we would suggest that it be extended to other categories in future.
Q 2. o you agree with the principles of the IFSS teams as agents of change to bridge child and adult services and agencies to focus on families and across agencies?
Yes. There is a great need for integration between services and particularly between adult and children’s services. As we stated in our report "Somebody Else’s Business:
In other areas though, there was little confidence that adult services and children’s services had sufficiently robust procedures for communicating with each other in order to ensure that children were safeguarded. Indeed, except in one or two areas, there was little confidence that GPs had protocols to ensure the safeguarding of children whose parents misuse substances.
Q 3. Do you agree that the IFSS should operate primarily at tiers three and four?
During my initial reading of the document I was a little confused at section 2.7 to come across the first reference to "tiers” and wondered whether this referred to the tiers of "Everybody’s Business” - the CAMHS strategy. This was explained later at section 2.9 but you may wish, in the final guidance, to make this clearer.
You may also wish to use a slightly different terminology to avoid any ambiguity or confusion with CAMHS tiers.
Yes as set out in the document I would agree that IFSS should operate at Tiers 3 & 4. I am, however, concerned that there seems to be a general trend towards "curative” services rather than "preventative” services. No one would argue that the children in these more problematic families do not either need or deserve the specialist interventions of the IFSS. I am also concerned that you suggest at 5.1 that "there is little evidence of the efficacy and effectiveness” of universal and targeted approaches (Tier 1 & 2).
Given the emphasis on early intervention and prevention in so many other areas of service delivery, can we really justify concentration resources on the higher end of the spectrum of need?
In order for the IFSS to provide services to the proposed groups, adequate measures for assessment and referral will need to be in place and this will depend on the skill of the Tier 1 & 2 services to make a referral.
Q 4. A. Do you agree that health authorities should have a duty to jointly provide the IFSS with local authorities?
B. Are there other partners that should or could be included?
Yes, there is a clear role for health authorities and they should have a duty to provide IFSS.
We are concerned though that the policy doesn’t explicitly identify the role that schools could play in identifying those children who may be at risk. The role of the family GP could also be crucial in this respect
Q 5. Do you agree that the accountability for IFSS should lie with the Director of Social Services?
Given the multi agency nature of the IFSS, we question why accountability doesn’t lie with the Lead Director for Children’s Services.
Q 6. Do you agree that the initial priority should be with children whose families have substance misuse problems?
Yes
Outline Proposals - Piloting Integrated Family Support Services
Q 7. A. Do you agree with the categories and circumstances in which children and families may be eligible for an IFSS?
Yes.
We would welcome clarification on how and whether advocacy for children will be built into the operation of IFSS. Reunification of children with parents may sometimes be against the wishes of the children concerned. Will children who may be neither looked after or children in need be able to access advocacy services?
Children’s advocacy services will also be important in "maximising opportunities for participation by children and young people” as envisaged in section 4.10
B. What other circumstances do you feel would benefit from targeted IFSS?
There may be occasions when some children who act as young carers may well benefit from IFSS - particularly when parents refuse services which would reduce the level of care required from the young carer.
The emphasis on "families” in the document may be misleading and we would suggest that there should also be a specific reference to pregnant women who abuse substances - thereby putting the unborn child at significant risk.
Q 8. Do you agree that the strategies for intervention should be subject to systems of approval at a local and national level?
We would agree that local evaluation is important but question how Welsh Assembly Government will monitor implementation across Wales and ensure that there is no "post code lottery” in the delivery of IFSS as there is in many other services.
Q 9. Should we require services for adults to review their eligibility criteria for services to reflect the priority given to supporting families?
We refer again to our report "Somebody Else’s Business” in which we reported health professionals’ views:
In other areas though, there was little confidence that adult services and children’s services had sufficiently robust procedures for communicating with each other in order to ensure that children were safeguarded. Indeed, except in one or two areas, there was little confidence that GPs had protocols to ensure the safeguarding of children whose parents misuse substances.
We would suggest that the provisions of the Children Acts that "the welfare of the child is paramount” apply equally to those providing services to adults. It is self evident that the welfare of the children in any family should be considered whenever there is a suggestion that their parents or carers need services.
Q 10. Should we make requirements about eligibility or leave these to local agreements?
Local agreements are better able to meet local need but there is a danger of a "postcode lottery” or having services based on available resources rather than on assessed need. Eligibility criteria should be assessed and compared nationally to ensure that no single authority has vastly different criteria. This could be part of the remit of the national CoE. They would be in a position to advise and support local authorities in drafting their criteria.
Supporting evidence Based Interviews
Q 11. How can we ensure that existing systems for disseminating knowledge are used more effectively?
This begs the question of whether the existing systems are effective. Through calls to our Advice and Support service, we are aware of vastly different approaches from one local authority to another. If best practice were effectively shared, we would expect there to be greater consistency across Wales.
Q 12. Do you agree that a National Centre for Excellence is needed?
Yes - but the success will depend on how closely it is possible to monitor whether the interventions it promotes are used and whether the availability of knowledge actually improves services for families.
Who will monitor the interventions and decide whether there is an evidence base for their effectiveness? Will there for be an interface between the CoE and CSSIW?
Workforce
Q 13. A. Are the areas of expertise identified for consideration the appropriate core support services?
We would suggest that, in addition to health visitors, school nurses (proposed to be renamed as Family Nurses in a current consultation) would have a major role to play - provided that the school nursing service is sufficiently resourced. Several reviews commissioned by Welsh Assembly Government over recent years suggest that currently it is not.
B. Are the proposed developments in the social work role and related supports considered appropriate to strengthen the social work role to support children and families?
Clearly the developments outlined here will strengthen the social work role of the proposed IFSS teams but this may only be at the higher tiers of need. We remain concerned that the social work role is strengthened across the board to ensure that early intervention and preventative work prevents an escalation of problems to the higher tiers.
Social Work Role
Q 14. A. What are your views of the proposed Career Structure provided at Annex 1?
The "possible” career structure outlined in Annex 1 would be better evaluated by practitioners rather than by this office. However, it is surprising that such a major development is being consulted on in this document. Surely this would be worthy of a separate, more clearly titled, consultation?
B. Are there any other models that could be considered?
See above.
Inspection of Integrated Family Support Services
Q 15. Do you agree that the IFSS should be inspected as part of the multidisciplinary framework rather than a separate function of local authority social services?
This would seem sensible. However, the multidisciplinary framework for the inspection of children’s services has yet to be developed and it is therefore difficult to judge. Will it have the same powers to ensure compliance with national standards as currently lies with CSSIW, Estyn and HIW?
Importantly, will the proposed enhanced enforcement powers outlined in section 9 below extended to CSSIW equally apply to all partners in the multidisciplinary approach to intervention?
Miscellaneous Proposals - Enhanced Regulatory
Q 16. Do you agree with the proposal for a new provision to vary/impose or remove conditions urgently by notice?
Yes
Q 17. Do you agree with the proposal for a new power to impose a penalty notice (fines) where a person has committed an offence under the Children Act 1989?
Yes
Q 18. Do you agree with the proposal for an extension to the time limit in section 79 x of the Children Act 1989 in which criminal proceedings must be brought, from 6 months to 12 months?
Yes
Q 19. Will the proposal to link commencement and completion of post qualifying training at specified levels for specific posts strengthen children’s social work?
We are not best placed to comment on this.
Children’s Commissioner for Wales
3rd October 2008
