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4. Views of Key Stakeholders

4.1 Introduction

Interviews were conducted with a range of key stakeholders involved with the coordination of information and advice provision in Scotland (see Appendix 1). A workshop was also held with members of the National Information and Advice Providers Panels. This section outlines the key issues arising in the discussions. It considers some general issues mainly around the operation of the accreditation framework, the level of uptake and potential barriers, funding of accreditation, particular issues for local authorities and governance arrangements for accreditation. As with the previous section, issues of perception are reported as conveyed to us.

4.2 General Issues

While there are mixed views about the impact that the National Standards have been having and the best approach to developing the framework, there is strong support for the existence of the Standards. There is also satisfaction that the principle has been established and a perception that there is broad support for the Standards among advice providers.

Establishment of the Standards was described as a major achievement. It was felt that recognition of their importance is improving and that this is a strong basis for raising the profile and level of uptake of the Standards.

Consultees were also clear that the National Standards and accreditation framework have led to tangible improvements in the quality of services and organisational efficiency. It was also argued that accreditation is the only way to get organisations to consistently adopt the Standards.

Stakeholders raised the issue of potential duplication with other quality frameworks. Concerns were raised, particularly by officers at local authorities, that there is a lack of recognition of other standards that they have to meet. One consultee felt that there is a need for a mapping exercise to assess the level of overlap with other regulatory frameworks.

Some consultees said that when the National Standards were developed it was felt that the main focus should be on the standard of service received by customers. Efforts to improve organisational procedures would be driven by this. Some people that we spoke to were concerned that this focus on customers was being lost. One criticism was that the Standards don't cover individual advisor competencies. Concerns about customer-focus also relate to a lack of publicity or public recognition of the Standards (or the areas of competency that different organisations are accredited in).

In terms of the audit process, some consultees suggested that there should be a clearer distinction between the audit requirements for Type I accreditation as opposed to Types II or III. These consultees felt that there were greater opportunities for reducing the audit requirements for organisations that only provided information services and were not undertaking any casework.

Several consultees suggested that the audit process could be streamlined. In particular, there were concerns about the process for reaudit. It was unnecessary to undertake a process audit every three years as organisational procedures rarely change significantly within that timeframe. In particular, stakeholders were aware of concerns among providers about the need for (and cost of) an interim validation. It was suggested by a number of consultees that there was the potential to move to a more risk-based approach to re-accreditation where, for example, major staff or organisational changes could trigger an audit rather than a fixed cycle.

Consultees expressed some general concerns about the way in which the audit is conducted. There may be issues for providers about the use of consultants - and a perception that the audits do not match with the ethos of the advice sector. There were specific concerns about auditors' understanding of the sector and the environment in which advice providers are working. Specifically, there were questions asked about auditors from advice backgrounds' understanding of the local authority environment.

There was also concern among stakeholders about the procedures for agencies to give feedback to an accreditation body or make complaints about the audit process. Currently, there is no systematic procedure for giving feedback and it was felt that comments / issues should be fed into the structures for governing the accreditation framework.

Another issue raised was the process for reviewing the content of the National Standards and ensuring that they are up-to-date and relevant to all advice providers. There was concern that there is no robust procedure for reviewing the Standards (for example there have been no consultations undertaken) and it was suggested that there should be a stronger role for the National Panel on this issue.

A number of consultees stated that there is uncertainty about the position of central government in relation to the National Standards framework. Stakeholders are waiting to see the level of support behind the framework and there was some concern that any cooling off accreditation for the National Standards would be unhelpful in encouraging organisations to seek audit. The introduction of Single Outcome Agreements (and removal of ring-fencing) means that there is some uncertainty as to whether it is a Scottish Government or local authority responsibility to support organisations to meet some or all of the costs associated with National Standards accreditation.

4.3 Uptake and Potential Barriers

The principal concern for stakeholders is the comparatively low uptake of accreditation. It was felt that there are issues at a national level, in terms of direction and the issue of funding, and at a local level in terms of process and building momentum behind the accreditation system.

Consultees felt that the lack of direction from the Scottish Government was leading to inconsistent approaches across local authorities. As such, there is no consistent approach being taken to funding the audit process. Several consultees would like to see a stronger link between funding and accreditation in order to create a greater compulsion for organisations. While one local authority is moving towards including accreditation as a condition of grant (and providing financial support for audit), this approach is not being adopted across the country. It was suggested that some local authorities may be lacking enthusiasm about accreditation due to costs and concerns about duplication. In some cases, local authorities were encouraging independent agencies to work towards audit but had not made significant progress themselves towards accreditation.

Consultees stated that the process of preparing for audit requires a significant commitment of time and resources particularly for smaller organisations. Currently there are not enough incentives (through perceived benefits) or compulsion (through the funding mechanism) to undergo audit. Given the limited drivers to take up audit, organisations have been reluctant to allocate the time or funds to the process. Key to improving the accreditation framework is tackling the issues of complexity and cost that are off-putting to organisations.

Stakeholders felt that while the Standards have been broadly supported there is a need for champions within organisations to take the process forward. This has proved more difficult in larger organisations where the staff member driving accreditation forward may be far away from funding decisions.

There was also concern that accreditation was not building momentum due to limited publicity of the scheme to date. So far there had not been much use of the accreditation logo above the door at advice providers. It was suggested that advice providers, many of whom are struggling with high volumes of clients and tight budgets, may be reluctant to actively market their services.

4.4 Funding Accreditation

Although costs are highlighted, it was not felt that this is an issue for all organisations - and is less of an issue for larger organisations. However, it was accepted that costs may be prohibitive for smaller organisations - particularly those with a single funding source.

Some stakeholders felt that the peaks and troughs of meeting the costs of audit made the process particularly difficult and there may be scope for a more consistent approach of a registration fee followed by an annual subscription. Other stakeholders did not support this idea on the grounds that providers were more concerned with actual cost than method of payment. It was also felt that a move towards a fixed fee would take accreditation towards being a membership scheme which would not be desirable.

Stakeholders also expressed disappointment that accreditation for information and advice providers had not been taken up by the National Lottery in Scotland. It was felt that this type of charitable support would be appropriate since the accreditation scheme works to put better assurances in place for the public - and particularly for vulnerable groups.

There were concerns among stakeholders about highlighting cost as a significant barrier to accreditation - where local authorities and other bodies have made funding available for audit there has only been a limited uptake. As such, barriers seem to be a combination of complexity and cost.

4.5 The Position of Local Authorities

Stakeholder consultations revealed a number of issues which were considered particularly important to local authorities. Local authority staff were particularly concerned about a lack of recognition of other standards and their operating environment. There is also a lack of trust amongst some local authorities over the use of consultants and contracted auditors. Some consultees were concerned that consultants are driving the process and may be responsible for the perceived lack of flexibility in the process. Concerns were also raised that consultants may not understand the local authority environment or have sufficient experience of the money advice / welfare benefits sectors. An issue was also raised about a possible conflict of interest, where local authorities have had previous dealings with the team of consultants undertaking the audit.

In terms of undergoing audit, one local authority has been involved in a considerable debate over the quoted cost of audit. This has reverberated around the sector and has caused a significant amount of concern among other local authorities. Concern was also expressed by some local authorities about the consequences of failing an audit coming into the public domain. These issues may be discouraging local authorities from applying for audit. Some consultees from local authorities said that they had received conflicting advice about what would be involved in the audit process.

In terms of creating a stronger link between funding and accreditation, some local authorities are not prepared to make accreditation a condition for fear of having to meet the cost. One local authority was considering accreditation becoming a requirement as part of a service level agreement for money advice organisations that they fund. However, they have got cold feet for a number of reasons including: the cost; the perceived lack of flexibility of the audit process; and concerns over duplication with other standards.

Consultees also feel that the transition to Single Outcome Agreements is changing the environment in which they are operating. Single Outcome Agreements which see a move away from ring-fencing and towards more outcome-based performance frameworks will change the way local authorities prepare delivery plans and budgets. The move to more outcome based working may also mean a greater requirement for research and evidence-gathering from local authorities.

4.6 Governance of the Accreditation Process

There was some discussion among stakeholders about the governance arrangement for the accreditation framework. It was suggested that the National Panel has become too distant from the audit and accreditation process. HomePoint, having developed and established the Standards, put delivery out to contract. This, in effect, left the contractor to develop the process. It was stated that the National Panel is currently "managing a contract, rather than managing a process". It is also worth pointing out that there was limited awareness among consultees (and particularly advice agencies) of the National Standards Panel and its role / remit.

There was also concern expressed by stakeholders (reflecting the comments of providers) that the process for accreditation is too narrow and controlled by one team of consultants.

There is scope for the National Panel to become less of a steering group and develop its role as an accreditation body with direct responsibility for the accreditation of providers.

Stakeholders were keen to stress that accreditation is different from regulation. The National Standards are separate from government in that they are not a statutory or formal regulatory framework. However, it has been valuable that they have been part of Communities Scotland, and now Scottish Government, rather than being left to wither on the vine. Members of the National Panel felt that if there is to be an accreditation body for the Standards, support would need to come from the Scottish Government, as it is unlikely that the market would fund it.

4.7 Growing Participation

Stakeholders felt that growing participation was key to developing the accreditation framework. There were four key areas that need to be addressed:

• Complexity and cost - where possible the process should be streamlined. In terms of time and resource commitments, there needs to be greater support to smaller organisations on working to the Standards and preparing for audit (principally through local support networks);
• Building momentum - as well as greater competition as a result of more organisations becoming accredited, there may be scope for greater promotion of accreditation for the National Standards and the accreditation badge;
• Creating drivers - there may need to be more incentives for organisations to become accredited and some level of compulsion through financial mechanisms; there is a need for direction from central government, and a clear steer for local authorities; and
• Reviewing governance - there is scope for more robust management of the accreditation process.

4.8 Summary

• There is strong support among stakeholders for the National Standards. Whilst some have raised issues over specific Standards, it is clear that the Standards have a high level of credibility within the advice sectors.
• Stakeholders feel that the Standards and accreditation have brought tangible improvements in services. They also said that accreditation is the only way to get organisations to consistently adopt the Standards.
• There is scope for more streamlining of the audit process and the potential to move to a more risk-based approach to re-accreditation (rather than a fixed cycle).
• There were some concerns about the way the audit is conducted. The use of consultants may not match the ethos of the sector. There were also questions asked about auditors' understanding of the local authority environment. Some concerns were raised about specific aspects of the audit process.
• Currently, there is uncertainty about the position of central government in relation to the National Standards framework.
• A key concern is the low uptake of accreditation to date. It was felt that there are issues at a national level, in terms of direction and the issue of funding, and at a local level in terms of process and building momentum behind the accreditation system.
• Stakeholders did not feel that costs are an issue for all organisations but may be prohibitive for smaller organisations. There were mixed views on whether a subscription would be preferable to the current peaks and troughs in charging.
• Consultations with local authority stakeholders revealed concerns about a lack of recognition of other quality standards and their operating environment. There were also concerns about the cost of audit and the consequences of failing an audit coming into the public domain.
• Stakeholders felt that the National Panel has become too distant from the audit and accreditation process. There is scope for the National Panel to become less of a steering group and develop its role as an accreditation body with direct responsibility for the accreditation of providers.

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