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29th January 2015

Can you afford not to?

hand with help flag sticking out of papersMore and more scrutiny of providers’ business practice by commissioners means hours completing paperwork. For smaller providers, the cost of keeping up with requirements puts a strain on their business.

This week I have mostly been struggling with deadlines. Some of these relate to the routine activity of my role; financial reports, governors’ meetings and staff matters. However, chief among headache-makers this week have been two sets of reporting requested by commissioners.

In order to ensure quality and value, it is incumbent on commissioners of care services to check that the providers of those services meet stringent governance requirements. Of course, in order to be eligible to bid for contracts in the first place, organisations have to demonstrate that they operate legitimate and quality-assured services, which are safe, cost-effective and fit for purpose. You will perhaps recall the endless forms necessary to join a preferred provider list..?

Now that we are established as preferred providers, it is important that we are regularly audited to ensure we remain of the necessary standard. However, my labours this week highlight how the responsibility of demonstrating that compliance rests firmly with the providers themselves. Self-assessment is clearly the way to go.

Good sense?

When you consider that, for some providers, there are upwards of half a dozen different commissioners placing service users, you may find yourself spending long hours completing questionnaires. Of course, good sense would suggest that once you have gathered your evidence for one provider questionnaire, you would be able to replicate the work for the subsequent compliance requests.

That would be in the event that good sense prevailed in the world of care commissioning.

So far this year I have completed six different questionnaires, each with its own requirements for evidence. These have ranged from a simple spreadsheet to a 28-page monster which required me to respond to a series of quality statements, linking my responses to evidence in the form of policy documents and giving the exact place reference in said policy that demonstrated our compliance with the quality statement. Phew!

Given that we currently provide care and education to no less than 15 different authorities, my work here will not be done anytime soon.

One way, one set of evidence

Now, I don’t wish to appear churlish; using public money wisely is something I heartily agree with, so the process of monitoring the companies with whom our taxpayer’s pounds are spent is welcomed. Of course, commissioners need to assure themselves and us that they are not putting hundreds of thousands of pounds into the hands of sharks that lock up grannies, underfeed vulnerable people or leave children at risk of harm.I just resent the fact that they cannot get together and agree a simple form of due diligence checking that will allow us to respond in one way, one time in the year, with the one set of evidence agreed across the country. If this happened, organisations would be able to manage the task within the resources they currently employ; perhaps a lead administrator or a service manager would be able to pick up this one.

Because I estimate that I will spend around 200 hours this year on meeting the quality monitoring demands of commissioners, the cost to my organisation of this aspect of service delivery is not insignificant. This does not include the administrative time involved in preparing and uploading the stack of evidence material to various websites, remaining authorised to use the websites (retaining all of the passwords is a job in itself) and planning the time to manage the deadlines in an already busy diary.

I whine about this often, so was not reticent in my response to the Department of Education when last month they asked me to participate in a research project into the way children’s social care is commissioned, funded and monitored. At last, an opportunity to propose we inject a little sense into the proceedings.

I trotted off to a workshop in some out of the way office near Westminster to join in with other providers in sharing my experiences of commissioning. It was anticipated that there would be around 12 of us, with three officers from the research team to administer the data collection. When I arrived, there was one other guy there from East Anglia, so we awaited the remaining invitees.

Struggling with the cost of compliance

After an embarrassing 20 minutes of no shows, the research team decided that they would proceed with just the two of us. My Norfolk colleague quipped that the others were probably all too busy meeting local authority commissioning deadlines to spare the time, and I at once saw a kindred spirit. He too was exhausted from jumping through hoops and, as a charity, his organisation was struggling with the cost of compliance.

One of our threads of discussion was around how we afforded the activity, which, as I say, amounts to a considerable cost in man-hours over the course of a year. The research team asked if we had considered including it in our fees; since the fee my service charges already does include an administration and corporate overheads element, which draws regular criticism from commissioners, I replied that this might be the last straw.

As a major third sector provider with considerable resources, my organisation is managing to afford the cost of compliance and could even consider a corporate officer post, perhaps attached to the procurement team, to pick this up across our regulated services. In small independents this would not be so easy to achieve. And quality-monitoring requirement does not differentiate between the multi-site players like us and the six bed group homes or two place supported living providers out there, who already struggle to meet regulatory demands.

Our QCS system is so useful in allowing us to produce the information to demonstrate excellence in service provision. We have easy access to dozens of well-constructed and tailored policies, risk assessments and procedures that allow us to evidence how we underpin the work we do. If only we could construct a data set of all of this information that would meet all of the quality monitoring demands of all of the commissioners in the UK, with a useful guide to completing the paperwork to accompany it.

Sadly, until we get some joined-up thinking in the world of care commissioning, we will all be drowning in a sea of forms and evidence at ever-increasing expense.

Ginny Tyler – QCS Learning Disability Expert Contributor

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