Introduction

Manchester Citizens Advice Bureaux Service (‘Manchester CAB’) welcomes the publication of the independent Review of Advice Services in Manchester. By providing data and attending consultation events, we have contributed significant evidence to the Review. The Review provides an essential opportunity for discussion and decision-making about the direction and future of advice services in the City of Manchester.

It is clear that MCC will now wish to embark on a programme of policy development towards the creation and implementation of an advice service strategy. We support the view that Manchester should develop its own model for the future provision of advice services that reflects the priorities for the city, its history and culture. While the CLAC model proposed by the Legal Services Commission may have some relevance to Manchester, we believe it is important to await evaluation of this approach. In the meantime we hope to work with the City Council and other stakeholders to get the right strategy and delivery model for Manchester.

This response sets out our views on the Findings and Recommendations contained in the report of the Advice Services Review. First, however, we think it is important to set our comments on the Review in the context of our own vision for the future of advice services in Manchester.

Our ambitions for improving access to advice

In our own Strategic Plan, Manchester CAB recognises that it is essential that we are able to help more people and provide easily accessible information, advice and advocacy services. Our plan sets out ten core business objectives including:

• To meet the advice needs of as many people as possible
• To be a more inclusive service
• To have a greater influence on policy
• To develop new areas of preventative work
• To innovate and develop new cutting edge services
• To develop more effective partnership work with key agencies

Our hopes for the advice strategy in Manchester

For nearly 60 years, Manchester CAB has been a widely recognized high street brand and a key agency in helping people and communities in the City of Manchester to solve an enormous range of problems and challenges, including welfare benefits, rights at work, resolution of debt and housing problems, consumer disputes, legal problems, immigration, asylum rights and many other issues.

We believe that future advice services must be able to:

• Meet and respond to changes in peoples’ needs,
• Be capable of progressively helping more people,

Manchester CAB believes that this will be best achieved through:

• Aclient-centred focus on individuals’ real needs and circumstances, with appropriate redress for poor quality services.

• Integrated provision of advice by a range of providers, which provides choice for individuals seeking advice but avoids duplication. This will be done by providing a mixed economy of provision, by promoting information education and self-help, by improving the accessibility of existing services and by widening the available methods of legal redress.

• Effectivepartnership between agencies, including between public and private agencies.

• Aholistic approach to solving problems. Funding mechanisms, training and audit systems must be sufficiently flexible to encourage and enable front-line workers to provide holistic responses to meeting client needs.

• Asustainable funding framework for advice services.  More generally, in future, sustainability should be a key principle for the MCC in its approach to the management of funds and contracts.

• An emphasis, through social policy work, onwider problem solving, with proper incentives for this work by advice providers.

• A culture and approach that encourages and facilitatesinnovation.

• Providing the right incentives for the flexible delivery of services and the strategic action to tackle problems.

The Advice Services Review

Recommendation 1.

Manchester City Council should work with other key funders and current advice providers to develop an advice strategy. This should cover the period from 2008-2015. This strategy should make clear and explicit links to the contribution that advice services are expected to make to the City’s (and other funders) wider corporate objectives.

We agree with this recommendation that the City Council should work with other key funders and current advice providers to develop an advice strategy. Indeed, the lessons of local authority and NHS commissioning suggest that most effective commissioning is achieved when funders and providers work together.

We cannot emphasise strongly enough our firm belief that both a successful advice strategy and the final commissioning plan will be most effectively developed by key funders and current advice providers working in partnership. We suggest that such engagement should be through the Community Legal Advice Service Partnership (CLASP). We are, therefore, concerned at the City Council’s response, which focuses on developing a funders’ forum but makes no mention of engaging with providers.

Manchester CAB and other advice agencies have extensive and long lasting relationships with other funders such as the Big Lottery Fund (formerly Community Fund) and Primary Care Trusts who all support the provision of advice to varying degrees. Those contributions must be safeguarded at all costs, and existing relationships should be used as a platform for improving access to advice.

If it intends to make approaches to other funders, we would urge the City Council to work closely with organisations like Manchester CAB so as to ensure that any steps taken do not lead to the displacement of funding from existing, successful services. We seek reassurance from the City Council that, in approaching and engaging with other funders, they will work in partnership with Manchester CAB and other current advice providers .

Recommendation 2.

The advice sector should be represented through Manchester Partnership to ensure that the contribution that can be made by the sector to the achievement of the City’s goals is understood by the sector and by other partners.

We welcome this recommendation as a pre-requisite to achieving additional investment into advice provision across the City, and we agree with the City Council that such representation should be extended to other ’decision making structures’.

However, representation needs to be in an appropriate forum and, for the purposes of developing an advice strategy and commissioning plan, it is essential to engage a range of perspectives from advice providers. Addressing the issue of how the voluntary sector can be better represented in decision-making structures is, of course, a much wider remit than the advice strategy.

Recommendation 3

The Manchester advice strategy should include reference to ensure:

• Advice is people focused and holistic
• Residents have a choice in the ways they can access advice – face to face, telephone, web based solutions through the local authority or from independent advice providers.
• Advice is right first time – accessible and quality services at the level needed to resolve their disputes

We agree with this recommendation, which focuses on access, client demand and user experience and is consistent with the Manchester CAB model of advice delivery.

We look forward to working with the City Council to develop the most appropriate advice delivery model for Manchester. This may be based around trained generalist advisors and will certainly require investment in new technologies.

Manchester CAB is equally committed to implementing changes to our existing patterns of delivery and access and to improve the quality, of referral and signposting activity in the City . For instance, in our own access programme, and that of the CLASP (recently allocated £0.5m funding from the Big Lottery), we are already looking to develop and implement an electronic ‘Gateway Assessment’ approach to advice service delivery, a single telephone number/e-mail address and an effective on-line facility for cross-referrals between advice agencies and private practice providers. By developing these ways of accessing our advice services, we will ensure that people in Manchester get advice appropriate to their needs.

We also believe that the Review provides an opportunity to establish a consensus on common standards for commissioning that are consistent with the Government’s Voluntary Sector Compact. This in turn will raise possibilities for co-commissioning of more holistic services between agencies that are sponsored by a range of funding partners

Recommendation 4

The advice strategy should ensure advice services contribute to the delivery of Manchester’s community strategy spines:

• Reaching full potential in education and employment

Providing access to advice can enable residents to take advantage of education and employment opportunities and maintain them.

• Individual and collective self esteem – mutual respect

Enabling people to better access to advice services enables them to take advantage of education and employment opportunities and maintain them.

• To develop neighbourhoods of choice

Enabling people to engage and participate in community living and be responsible citizens, creating more sustainable neighbourhoods.

The strategy should also be clearly aligned with the corporate goals of other key funders such as the PCT, for example, contributing to their commitment to tackle health inequalities as set out in the local delivery plan.

Again, we agree with this recommendation. The advice strategy should be aligned with the corporate goals of the City Council and, in particular, with the objectives of the Local Area Agreements. Manchester CAB’s Strategic Plan clearly identifies the contribution our advice service will make in helping achieve the City Council’s corporate goals.

One area neglected by the Review is volunteering. We believe that the use of volunteers is fundamental to delivering outcomes both in economic development and in seeking to achieve safer, stronger communities. We, therefore, believe that any strategy for advice needs to be explicit about the role of volunteers.

Recommendation 5

The strategy should include an explicit set of principles or values underpinning future service provision. We suggest that this may include a commitment to:

• Equality and social inclusion – ensuring that resources are targeted to those most in need

Access to advice and meeting the needs of as many people as possible will always present a major challenge. Manchester CAB has already included these as principal objectives in our Strategic Plan. To achieve these objectives we will promote equality and diversity, and challenge discrimination.

However, with finite resources available to us, we are not able to help everyone and will need to focus our help on those who need it most. Often, they are the very people who find it hardest to access advice services.

We believe that other, no less important, principles and values that the advice strategy should commit to are:

• Free, independent, impartial and confidential advice
• Empowering people to be able to take responsibility for their actions and, where possible, to resolve their problems for themselves
• Making the voices of our clients and communities heard
• Being relevant and inclusive to all our communities and providing ‘value for money’
• Promoting volunteering as an integral part of the strategy.

We also believe that the Advice Strategy should not be based solely on areas of deprivation, although we recognise that the need for advice in these areas will be high. However, to do so, carries the risk of excluding people in poverty but living in areas of relative affluence and who may also need support and help.

• Maximise resources – ensuring that the most effective and efficient means of delivering services are applied that addresses gaps and avoids duplication, and that council resources provide a stable foundation that facilitates funding from other sources.

We agree with this recommendation since it is what we are striving to achieve through the CLASP.

We recognise that the current provision - which is fragmented, often inaccessible and provides a confusing pattern of provision - needs to change. However, we note that the Review finds that demand is out stripping current supply and, as well as reorganisation, needs additional resources.

It is important to recognise that current providers of advice services are able to use their core funding from the city council to leverage substantial additional funding from a wide variety of other sources to the benefit of Manchester residents. Much of this additional funding comes from charitable sources only available to voluntary sector providers. For example, Manchester CAB has recently led a successful bid in partnership with 22 other advice providers to secure £0.5m from the Big Lottery to fund the development of CLASP.

• A mixed economy of integrated provision – ensuring that a range of providers are available to meet different needs and ensure the future contestability of services whilst providing a seamless experience for service users.

We welcome this recommendation, although it is not clear how this recommendation fits with recommendations 7 and 9. However, in developing the commissioning plan, much work will need to done to achieve integration and seamless services while ensuring a continued diversity of providers.

Recommendation 6

The City council should seek to transfer responsibility for commissioning advice services away from Manchester advice to another part of the council as a priority or ensure that more robust arrangements are in place to minimise actual and perceived conflicts of interest between its provider and commissioner roles.

The City Council should explore the possibility of establishing a joint commissioning body for advice with other key funders in the City. This body, if established, should have a formal relationship with the wider strategic planning structures within the council such as the local strategic partnership.

We welcome the separation of procurement from the provider function as being a first step in the right direction. However, for commissioning to be fair and effective, advice providers need to start on a level playing field. This means that all advice services should be commissioned through the same arrangements and that contracts should be based on ‘full cost recovery’.

As the Review indicates, the infrastructure support that Manchester Advice receives, in terms of premises, human resource, finance and IT support etc, places them in the position to deliver more front line advice than organisations that have to build this into their costs. If the City Council retains its in-house advice service, the present perceived conflict and mistrust is likely to continue.

The combining of Legal Services Commission and local authority funding in to a single competitive tender has been tried elsewhere. We believe that a very careful appraisal of the advantages and disadvantages of such an approach, including evaluation of existing schemes, would be essential before considering its appropriateness for Manchester. We are aware that such schemes are provoking intensive discussion in the voluntary sector and in central Government (particularly the Office of the Third Sector and the Ministry of Justice) and suggest that MCC may wish to engage in these discussions

Recommendation 7

The council should encourage the existing law centres and neighbourhood advice centres to explore ways in which they could come together. The council may wish to indicate that its future commissioning intentions will be to contract with a single law centre and a single network of neighbourhood advice centres.

There may, of course, be valid reasons to suggest a need for existing law centres and neighbourhood advice centres to come together to provide a more integrated and effective service. However, we find no evidence or analysis in the Review to justify the recommendation of a single Law Centre and this recommendation seems to contradict recommendation 5, (i.e. the need for a diversity of providers).

Neither do we see any evidence in the Review to justify the separation of law centres into a category of their own. While some of the advice provided by law centres is specialist, much of their work overlaps with the advice provided by neighbourhood providers. Conversely, the Review does not acknowledge the level of specialist casework undertaken by Manchester CAB in the social welfare law categories of debt, welfare benefits and employment. Also, the recommendation does not c onsider how Manchester CAB would fit into the model being considered.

As we have already indicated, we fully accept the need for greater collaboration and partnership working. These are key objectives in Manchester CAB’s Strategic Plan and one of the key aims of the newly established CLASP.

We welcome the City Council’s commitment in their response to the introduction of 3 year contracts for advice providers.

Recommendation 8

The future commissioning model should include provision of a single point of telephone access (and possibly e-mail) to all services providing a triage function with referral to neighbourhood services. All contracted providers should be required to co-ordinate opening hours and this should include out-of-office drop in and appointments across the City. The model should also be explicit about the areas of law and the level of work required by each service provider.

We agree with the City Council that, before prescribing or signing up to a particular model, further work needs to be undertaken and other options explored and considered

In order to improve the quality of referral and signposting activity in the City, the CLASP project will seek to establish a ‘Gateway Assessment’ approach to service delivery, a single telephone number and an effective on-line facility for cross-referrals between advice agencies and private practice providers. These would be supported bya comprehensive electronic directory of advice providers in the City, containing details of the type and level of work undertaken by each agency and giving details of opening hours and access to appointment booking systems.

It seems to us that the City Council, in partnership with other advice organisations in the City, must now establish a commissioning model and process that is fit to support the delivery of the holistic client focused services that the Review is recommending.

Recommendation 9

In addition to the single telephone point of access above we suggest four other types of service.

• City Centre Service – there should be a single city centre service.
• District services – there should be six district services
• Law Centre – there should be a single service providing specialist help and legal interventions.

Whilst we generally support the City Council’s response to this recommendation, we would like to see an Advice model for the City of Manchester that is based both on greater collaboration and integration of agencies whilst at the same time sustaining diversity and contestability.

We are concerned that this recommendation is not directly supported by the evidence or analysis contained in the Review. For example, why six neighbourhood centres and what is the rationale for treating law centres differently? Also, there is a failure to acknowledge that Manchester CAB Service is both a generalist and a specialist agency.

As a starting point for discussion, we propose, the establishment of a virtual ‘Gateway to advice’, through a single telephone number and email address. We believe that this would significantly increase the capacity of advice services to deal with more clients.

The virtual ‘Gateway to advice’ would be underpinned by a number of integrated Advice Centres, situated at strategically accessible locations across the City. The Advice Centres would be capable of providing services ranging from basic information, through generalist advice to specialist legal advice such as representation and advocacy. We see a relevant City Centre service as being an additional service.

We believe that Advice Centres should be commissioned to provide a comprehensive network of locally based access points that would also include outreach (GP surgeries, Libraries, supermarkets, etc) and home visits and which would utilise electronic support such as video conferencing. Self-help tools, such as Citizens Advice Bureau kiosks and Advice Guide, would be integral to the model that we propose. An element of flexibility would be built in to enable the model to adapt to changes in need or deal effectively with crisis situations.

Advice Centres should also be commissioned to undertake social policy work as a cost effective way of resolving people’s problems.

We believe that this type of integrated approach to delivery would not only help more people, at a time, place and method of the client’s choosing, but would also ensure that those with the greatest need received the most appropriate advice.

We believe that our proposed model could be best delivered by commissioning a principal agency, such as Manchester CAB, that already has a well-established high street brand that is both well-known and highly trusted by local communities. Subcontracting by the principal agency would sustain the benefits of having multiple providers, whilst enabling strong management and co-ordination of the strategy.

Recommendation 10

The City’s wider corporate objectives attach particular priority to children and young people. Traditional advice centres are not well placed to meet these needs, as young people tend to prefer to access such support in generic youth settings. Consideration should be given to supporting a special young persons service as part of the advice strategy. This may be purely an access point to other advice providers, providers of casework services or indeed operating at a specialist level.

We accept that a low proportion of young people (those below the age of 18) use mainstream advice services. We agree that this is primarily an access issue. With additional resources to put in place innovative ‘Gateway to advice’ solutions (such as outreach sessions, effective referral systems and video conferencing facilities to link colleges, universities and other generic youth settings to advice centres), we strongly believe that Manchester CAB could provide effective support to young people who are in need of help and advice.

We do not see evidence in the Review that would make a strong case for a ‘special young persons’ service’ and therefore welcome the City Council’s response, which emphasises the need to ensure that services are universally accessible. Manchester CAB is fully committed to developing an Advice strategy that makes advice accessible and available to all groups and communities in the City, and especially those (such as young people, migrant workers, older people etc) who do not currently access them.

Recommendation 11

To this end we recommend that funding for specific communities should be targeted at information provision and referral rather than a core part of the advice strategy.

We agree with this recommendation. Advice agencies should, however, not be restricted from bidding for additional resources to undertake specific pieces of project work with marginalised communities or specific groups of people.

Recommendation 12

The City Council should examine the scope for locating advice agencies within planned capital developments relating to schools and primary care facilities.

A coherent premises strategy is, of course, central to many of the recommendations made by the Review, but can only be progressed once the desired model of advice delivery and location of services has been agreed.

Having determined those factors, the City Council, working in partnership with other funders, including regeneration teams and providers, will then be in a position to decide on the most effective premises solution. This will need to take into account whether the desired delivery of the Advice model is an integrated provision on a single site or something more flexible.

We support the idea of linking advice provision to planned capital developments. However, whilst schools and primary care facilities may provide possible locations, they are unlikely to provide high street locations and would each need to be risk assessed to take account of the likely clientele. Also, schools suffer from the major disadvantage of having limited opening times. We believe that it will also be important to look to opportunities to develop premises for advice services in commercial developments including retail (e.g. supermarkets) and housing.

In any future development it is important that advice services are seen as integral to regeneration strategies and not something that has been tacked on.

Recommendation 13

The City council and advice providers must investigate alternative methods of externally assuring the quality of advice as a priority.

We agree with this recommendation. We recognise that the City Council is under severe financial pressure and must demonstrate that what they spend achieves maximum outcomes for the investment. We also believe that all advice providers should be subject to challenge on grounds of effective delivery, demonstration of outcomes for clients and ‘value-for-money’.

However, we feel that a strategic approach to quality and outcome measurement should be adopted to ensure that agencies with several funding streams are not overburdened by excessive and repetitive requirements that detract from the primary objective of the service. Any quality assurance system needs, therefore, to be linked into existing systems, for example the CAB Membership Standard, that agencies are required to meet.

This is an important piece of work and one that will be central to the CLASP project. Our preferred option is quality assurance through peer review, although other models should also be explored.

Recommendation 14

The City Council is to establish contract based service level agreements with key advice providers and should establish appropriate monitoring arrangements to ensure compliance. These should operate for a minimum period of 12 months.

Manchester CAB fully agrees that, for commissioning to be effective, appropriate monitoring arrangements are necessary. However, the Review’s recommendation and the City Council’s response do not appear to recognise the need to encourage the full involvement and co-operation of those who actually deliver the services. To ensure the highest quality service is delivered, monitoring arrangements should be developed and implemented by a partnership approach between the City Council and Advice providers. Agencies should receive guidance and training in how to comply.

In line with Compact guidelines, contracts and SLAs should be for a minimum of 3 years.

Recommendation 15

Management training should be provided to all providers in relation to project management, reporting and tendering. The Regional Change Up Hub’s assistance should be sought to support this work.

We agree. However, access to good quality, affordable training is a much wider issue, which is not addressed in the Review. Continuous training, for all people within an organisation, is an essential component of delivering high quality services. This includes not only management training, but also high-level training for specialist caseworkers. Full cost recovery should include the costs of providing such training.

Recommendation 16

The needs assessment and recommendations for strategic priorities for advice services should be developed into a detailed commissioning intentions paper and subject to consultation with the sector and the public.

We agree. However, we would stress again the importance, from the outset of this process, of dialogue and partnership between commissioners and providers (through the Manchester CLASP). This recommendation implies that the City Council should develop a commissioning intentions paper and then consult ‘with the sector’. We would argue that it is essential for the process of dialogue to begin much earlier.

David Wilkin - Chairperson

Denis Madden - Vice Chair

Andy Brown - Chief Executive