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Chamber and committees

Education, Lifelong Learning and Culture Committee, 01 Sep 2009

Meeting date: Tuesday, September 1, 2009


Contents


Public Services Reform (Scotland) Bill: Stage 1

The Convener (Karen Whitefield):

Good afternoon. I open the Education, Lifelong Learning and Culture Committee's first meeting following the summer recess. I hope that all committee members had an enjoyable summer, even though the weather was not particularly co-operative at points.

We have apologies from Aileen Campbell MSP, who is unable to join us today.

The first item on our agenda is our stage 1 scrutiny, as a secondary committee, of the Public Services Reform (Scotland) Bill. Today, we will focus on the aspects of the bill that relate to social work and joint inspections. I am pleased to welcome from the Scottish Government Val Cox, who is the deputy director of positive futures; Adam Rennie, who is the deputy director of community care; Gillian Russell, who is the divisional solicitor for health and community care; Nicholas Duffy, who is a solicitor in the legal directorate; and Shane Rankin, who is the project director in the scrutiny bodies project team. I understand that Mr Rankin will make an opening statement. We will then move to questions.

Shane Rankin (Scottish Government Primary and Community Care Directorate):

Thank you very much.

The new scrutiny and improvement bodies for social care and social work and for health care are a significant part of the Scottish Government's plans to improve the performance of Scotland's public services. The Government believes that the core purpose of external scrutiny is to provide public assurance and improve service quality. Its aim, in introducing the changes, is to create more effective and efficient bodies that can work more effectively together and with the other major bodies, such as Her Majesty's Inspectorate of Education, Her Majesty's inspectorate of constabulary for Scotland and HM prisons inspectorate for Scotland.

The Government's intention is that the creation of the new bodies will lead to reduced administrative burdens on public bodies and other service providers, and to a better focus on the greatest risks. Part 4 of the bill, which will establish the body social care and social work improvement Scotland, provides for those changes. The new body will integrate the Scottish Commission for the Regulation of Care's responsibilities for regulating and inspecting care services, excluding independent health care; the Social Work Inspection Agency's responsibility for inspecting social work services, including criminal justice social work; and HMIE's responsibilities for inspecting child protection and integrated children's services. The legislative provisions that will establish social care and social work improvement Scotland, which are critical to achieving an integrated approach, are in sections 34 to 89 in part 4 of the bill and sections 92 to 97 in part 6 of the bill. The provisions will draw into the new body—which will be a non-departmental public body—the functions, powers and duties of the existing bodies. The care commission will be dissolved and the functions of SWIA, which is a Government agency, will be carried out by social care and social work improvement Scotland.

The provisions will permit simplification of the regulation of care services, will allow for the first time the scrutiny of services along the whole care pathway, from the point of assessed need to the point of service delivery, and will focus on outcomes for individuals. A focus on outcomes as well as on standards will be enabled. Joint inspections by scrutiny bodies will provide a duty on the bodies to co-operate and will require the involvement of users of services in design and delivery of scrutiny.

The primary focus of the new body's responsibilities will be to provide public assurance on the quality of a range of often interdependent services that are provided by public, private and not-for-profit organisations. The new body's capacity to consider the complex interrelationships between services will ensure that inspection and regulation provide effective support for service improvement. The integration of responsibilities from three existing bodies—the care commission, SWIA and HMIE; the capacity to conduct simpler and more proportionate joint inspections with other bodies, such as healthcare improvement Scotland, HMIE, Her Majesty's inspectorate of constabulary for Scotland and HM prisons inspectorate for Scotland; the flexibility on inspection frequency and the greater scope to share information will enable the new body to consider more effectively and efficiently the impact of other services on outcomes. The new powers, duties and flexibilities in social care and social work improvement Scotland will enable better targeting on risks, allow scrutiny to be more proportionate, lead to more efficient use of scrutiny resources, improve public assurance and focus support for improvement where it is most needed.

The Government is determined to improve services and scrutiny as quickly as possible. Work is already in hand on how the functions of the existing scrutiny bodies can be integrated, and on how the new bodies can collaborate to provide improved public assurance and more effective support for improvement.

The Government wants to see the benefits of integration and collaboration as soon as possible. It does not want to diminish public assurance or to delay service improvement in the period to April 2011, when the new bodies will commence their work. Service users may be concerned that, in the run-up to establishing the new scrutiny bodies and in the early months of their operation, services will not be effectively regulated and inspected, and that the providers of poorly run services will not be challenged. However, the scaling back of scrutiny, the focus on risk and the co-ordination of scrutiny of local government services are already enabling more proportionate scrutiny and a high level of assurance, and are focusing attention on improving the poorest services.

The current considered and evolutionary approach to scrutiny improvement will continue as we move towards the start-up date for the new scrutiny bodies. We will work with the existing scrutiny bodies, relevant professionals, service providers and users, and with other key stakeholders to ensure that we shape the operations of the new bodies so that they maintain high levels of assurance and focus effectively on supporting service improvement as soon as they are established.

I hope that my comments have helped to explain the Government's intention in establishing the new bodies. We are happy to answer any questions that the committee may have.

The Convener:

Thank you for that. The committee has questions on a number of areas that it wants to pursue with you this afternoon.

The existing bodies all have particular remits and are responsible for scrutiny—HMIE and SWIA are examples. What difference will centralisation of the provision of services make? Do the bodies currently not co-operate?

Shane Rankin:

The bodies do co-operate, and it has in recent years been shown well how that collaboration can improve assurance on quality of services, and how it can give a better sense of how services operate and how they might improve.

However, it is also clear that some of the collaborative arrangements are quite complex. The proposed approach should, by bringing together in one body a variety of services, as opposed to their being provided by three separate bodies, allow simplification of the process of collaboration, and should also allow integration of a number of activities. As I said in my opening statement, it will allow the care pathway for individuals—right through from the assessment of need to the social work service—to be scrutinised as a whole, and it will allow the information that is gathered at every stage in that process to be considered and used to develop a sense of what is being achieved for the individuals and the quality of the service.

The Convener:

Can you give me a concrete example of the difference between the existing regulation and scrutiny and the regulation and scrutiny that we will have if Parliament agrees to enactment of the bill in its current form? I read some of the responses to the consultation: the Association of Directors of Social Work and Children 1st—they are but two examples—have some concerns. They state that although the current system might be a little complicated, it does deliver. They are not convinced that streamlining will necessarily lead to improvement in the quality of scrutiny—it might lead to a dilution of the service.

Shane Rankin:

Some of the comments that were made in evidence question how we will know whether the service has improved—the convener alluded to that in her question. I suppose there are two aspects to the answer. First, the existing bodies, some of which have not held their responsibilities for very long, brought together a number of different services into the organisations in which they currently conduct their work, and they have shown considerable success in simplifying the approach and in providing better assurance and a clearer sense of how services need to be improved. That argument for simplifying the scrutiny arrangements follows through to the proposed amalgamation of a series of functions.

Secondly, the detailed work on developing the approach to integration and simplification is in progress as we proceed with the bill. That work is being done in collaboration with the existing bodies and stakeholders of all kinds, from service providers to umbrella bodies and so on. In doing that work, we are starting to arrive at some of the solutions—some of the integrations and simplifications that might, in due course, be possible. We have not arrived at a conclusion as to how the business model for the new organisation will take shape, but that work is in hand.

The answer is also partly about whether the public will be more assured by reports from the future bodies. As the new organisations take shape and take hold of their responsibilities, we will have a sense that they can describe more effectively the outcomes that are being achieved through the collaborative work that they are undertaking and the approach that they are adopting.

The fact that the Government has moved towards a much more outcomes-based approach with local government is making scrutiny of many services much more challenging. The enabling of collaboration between scrutiny bodies that have a particular service focus—requiring that they collaborate, and simplifying that process—allows assessment of outcomes to be achieved and the quality of service to be improved.

The Convener:

I realise that you tried very hard to answer my question, but I am just a simple politician and am struggling to grasp what the Government is attempting to do here. Could you give me one concrete example of what will be different in the new streamlined scrutiny body, and tell me how the services that it delivers will be different? I fail at the moment to understand why legislation is necessary.

Shane Rankin:

I think I tried to explain how, by bringing together inspection of social work and of care services, for example, one creates the opportunity for the single body to scrutinise the range of interventions for individuals, from provision of care services to social work services and all the bits in between that go towards ensuring that someone who is in need of care is treated properly and effectively and is provided with the services that they need. In bringing those together in one body, you are simplifying the scrutiny of the range of services—

For whom are we simplifying it?

Shane Rankin:

You are simplifying it for the providers and procurers of the services, and you are providing more assurance for the public.

How will the public be more assured? Will it be just by hearing you say that the service is streamlined? How will you demonstrate that?

Shane Rankin:

I am not trying to say that streamlining will make the public more assured; rather, I am trying to explain that streamlining scrutiny of the care pathway will ensure that the services that are interconnected are provided to individuals effectively and appropriately and are of good quality.

As part of its consideration of the bill, did the Government consider whether improvements to scrutiny could be made without merging the organisations?

Shane Rankin:

Yes. The proposals are a response to the Crerar review, which resulted in a series of recommendations to which the Government has responded. A number of those recommendations—many of which are about simplification, streamlining, co-ordination and collaboration—are already being implemented and have begun to yield some benefits in the work that bodies are doing, and have had an impact on the public and service providers.

The Convener:

I had an opportunity to meet Professor Crerar when he published his report. I grasp the desire in the public sector to streamline things and make them as simple as possible. Equally, however, Parliament has a duty to ensure that any changes will improve services and scrutiny. Maybe it is just me, but I am struggling to see how the changes are going to make any concrete difference to the system, let alone improve it. I appreciate that the co-operative arrangements at the moment might be complicated, but it strikes me that that complicated co-operation is working. I need to know why the change is viewed as being appropriate.

Shane Rankin:

I will make one further attempt to shed some light on the matter. One basic principle of the Crerar review, and the response to the review, was that scrutiny should be made more proportionate for service providers.

We are already seeing the major scrutiny bodies including HMIE, SWIA and the care commission provide some co-ordination in their scrutiny of local government services. That is beginning to lead not to less scrutiny, but to scrutiny that is better targeted at poorer-quality service providers. Taking such an approach to providing more proportionate scrutiny is a key strand in all this; it will allow the new body to provide a proportionate approach to scrutiny of the local authorities. The information from care-service inspections can also be used to inform the overall sense of how services are provided in a locality. Progress on making things more proportionate is already yielding benefits and should yield further benefits in the future.

Val Cox (Scottish Government Children, Young People and Social Care Directorate):

You asked for a concrete example, convener. I am not sure that this is such an example, but it is an attempt at one. The new arrangements will pull together in one body the scrutiny of the strategic functions around the provision of a range of social work and social care services—services that rest at present with the local authorities in respect of their social work function—and the individual care pathway, as Shane Rankin said. The latter is the technical and jargonistic term that we use for an individual's use of a care service. The new scrutiny regime will enable us to get a clearer picture of the quality of the service that is provided to service users and the quality of, for example, the local authority commissioning arrangements that led to the service being put in place and made publicly available.

In essence, the new body will bring together the operational function—which is where a great deal of the activity of the care commission rests at present—and the strategic local authority function. In practice, those operational and strategic responsibilities already come together in the experience of the service user. Under the current arrangements, scrutiny of those two core components is somewhat fractured. I have not helped you, have I?

The Convener:

Unfortunately, you have not. I return to Mr Rankin's point: the new body will lead to a more proportionate level of scrutiny. Surely proportionate scrutiny could be delivered by the existing bodies? Why do we need a new agency to do that? Surely this not about having a new agency but about the existing remits and practice. If there was the will for the current inspection agencies to undertake their work in a more proportionate manner, they would do that. If that is the case, what is the driver for the new agency? What makes it different from the existing situation and what makes it better? That is what I am trying to get at.

Shane Rankin:

I return to my earlier point: this is about trying to make things as simple as possible in many different ways. We are trying to streamline the process and ensure the simplest possible line of accountability for scrutiny of care and social work, which are interconnected.

The committee has also received evidence that things would be so much simpler if there were only one scrutiny body. Although the argument has merit—indeed, Professor Crerar supported such a move—we can go only so far at any one time. As I tried to suggest earlier, several years ago the current bodies simplified and streamlined things and brought together a raft of functions that had, up until then, been fragmented. That move has led to significant improvements in a number of the areas of scrutiny in which they are involved. The bill is about going a stage further and trying to make things even simpler and more streamlined.

I am going to let my colleague Liz Smith have a shot at getting me some clarification on this matter.

Can I get some clarification on the fundamental question whether the main driver of the bill is improvement of scrutiny or simplification of and reduction in scrutiny?

Shane Rankin:

What I am trying to say is that there are a number of drivers in all this. Given that the Government's response to the Crerar review has been to simplify and improve scrutiny, we are trying, if you like, to improve scrutiny through simplification.

Elizabeth Smith:

Some of those who have submitted evidence—I can think of three such submissions—made the very strong point that they are not yet satisfied that improvements in terms of simplification of the process will result in a qualitative improvement. Some have even suggested that the process could result more in amalgamation than in integration. What is your answer to such concerns?

Shane Rankin:

As I said a little while ago, we are working through the process of ensuring that the proposed bodies will, when they are established, provide the best integration and simplification. Indeed, we are collaborating with the current bodies to find a way in which to do that. We are not suggesting that we have the perfect business model for these organisations, but we are pursuing them on the basis that we are convinced that simplification, amalgamation and integration provide a platform for improving scrutiny, which, after all, is essential.

Elizabeth Smith:

The key point, however, in some of the evidence—if I have read it correctly—is that there is a difference between amalgamation and integration. What the public and the main stakeholders are looking for is the conviction that we will be able to deliver a better service that has a quality value that, in your view, the present system does not have. I am slightly concerned that a lot of evidence that the committee has received suggests that there is confusion about what should be amalgamated or integrated, so it would help the committee, which obviously has to recommend to Parliament how it scrutinises the issue, if you could tell us where this approach will lead with regard to the quality of delivery. The key question is whether functions will be fully integrated or whether there will simply be an amalgamation of two bodies that do different things.

Shane Rankin:

We are clear about what amalgamation means—it means the amalgamation of functions that are set out in the bill. What we need to develop and work through with existing bodies and stakeholders is the exact way in which integration will flow from that amalgamation. We are not saying that we have the perfect answer and that it will work in such and such a way; what we are saying is that we do not want to lose or dilute in the process the very effective scrutiny that the existing organisations are carrying out. Instead, we want to develop from that point methodologies that allow integration around the care pathways, as they are described.

Children 1st was slightly concerned that the process might involve a reduction in consultation of key groups. Do you accept that criticism?

Shane Rankin:

Do you mean the process of developing methodologies?

Yes.

Shane Rankin:

I hope that that is not the case. I think that we have got to this point with the legislation as a result of the strong participation of and engagement with stakeholders and that is how we envisage taking the process forward. The knowledge and expertise, the alternative ideas and the best solutions lie with the stakeholders and the service providers.

Are you happy that the new body will continue to involve itself in such consultation to a full degree and that some people will not be missed out because of a simplification of the structures?

Shane Rankin:

To a degree, the requirement for user focus that is contained in the bill is about emphasising that—it is about saying that that is what the scrutiny bodies need to do. Many of them do it extremely well already. It is a question of ensuring that they do it thoroughly and appropriately for the communities or providers that they scrutinise.

I have a final question, if that is permissible. Why do we need legislation to do that?

Shane Rankin:

Because we need to change the joint inspection provisions and a number of the arrangements for the care commission. Those are the two examples that occur to me.

Gillian Russell (Scottish Government Legal Directorate):

To put it at its simplest, we are legislating because we are creating a new body with a new set of functions, and that needs to be delivered through legislation.

If your question is more whether the existing bodies could not just work more effectively together without legislation, the view has been taken that the best way of achieving that is to create a new body with a new set of functions and to put in place an appropriate legislative basis for that body to develop.

Shane Rankin:

A loosening up of some of the arrangements under which the care commission operates is critical to the creation of social care and social work improvement Scotland. The intention is not to challenge what the care commission does, but to allow the organisation to be more proportionate in the scrutiny of care services by recognising that there needs to be more flexibility with regard to how that is done and the frequency with which it is done.

HMIE and the Social Work Inspection Agency have voiced concerns about losing their agency status. Could the members of the panel say what they believe the pluses and minuses are of losing independence and becoming NDPBs?

Shane Rankin:

Do you want us to describe what HMIE and SWIA think the pluses and minuses are?

No. I want to know what the Government's position is on the pluses and minuses of those bodies losing their agency status.

Shane Rankin:

I suppose that it is not entirely a matter of the advantages and disadvantages of the loss of agency status. The agency status arrangement works perfectly well and, in the case of HMIE, it is clear that it is being sustained. The bringing together of SWIA and the care commission, and of their functions, responsibilities and staff, into one organisation is about recognising the difference in scale of the two organisations and the practical difficulties of taking the care commission into an agency as opposed to taking SWIA into an NDPB. The fact that that is probably one of the biggest drivers of the proposed change is in no way to say that there is anything at fault with the agency approach. The bill is not about diluting the status of social work inspection by bringing SWIA into an NDPB. In fact, the position is very much the reverse, as the Government's plans to make the chief social work inspector a Government post show. It is a question of ensuring that what we get from an agency that is close to Government and which provides direct policy advice to it is not lost by the arrangements that the bill puts in place.

Do you think that the new body will be able to provide policy advice in the way that SWIA currently does?

Shane Rankin:

No. I was saying that the proposal whereby there will be a chief social work adviser within Government replicates one of the roles that SWIA's chief inspector has, which is a role that cannot entirely be delegated to the chief executive of the new NDPB.

There will be a post of chief social work adviser, but it will not be part of the new body. The chief adviser will not have the advantage of being a practitioner as well as an adviser.

Shane Rankin:

But they will have an opportunity to work closely with the organisation, use the evidence that it has, sit on a board and so on.

Will the relationship between ministers and these bodies change? In particular, will there be more ministerial intervention? I believe that the bill will give ministers more powers of direction.

Shane Rankin:

I do not think that the relationship will change. I cannot see why it would. My colleagues might want to comment on that.

Adam Rennie (Scottish Government Primary and Community Care Directorate):

Ministers have the power to issue directions to the care commission, and the bill simply replicates that power in respect of social care and social work improvement Scotland.

I believe that it is a modest extension of ministerial powers. However, added to the lack of an independent state for the agency, I worry about the relationship that will exist between ministers and the new bodies.

Shane Rankin:

Could you clarify what you mean by

"lack of an independent state"?

The bodies are losing their agency status—that is the key issue.

Shane Rankin:

One of them is.

Ken Macintosh:

One of them is, yes. Further, there are other powers in the bill that could allow ministers to take decisions at a later stage—I suppose that that is a different argument, however. The point is that those bodies have expressed concerns about what the relationship will be. As advisers to the Government, have you weighed those concerns in the balance?

Shane Rankin:

Very much so. I think that I have described some of the key drivers in that argument and some of the attempts to ensure that we do not lose the benefits that exist in that close relationship between SWIA and Government.

The Convener:

Did the Government have any particular concerns about the evidence that was submitted by SWIA in relation to staffing? SWIA expressed concern that many of its staff would prefer to remain in the Scottish Government's civil service, rather than transferring to the new agency, as that would give them more opportunities for career progression and movement. Has the Government considered that issue?

Shane Rankin:

The Government continues to consider it, and discussions are taking place between the Government's human resources director, my team, the SWIA staff management and trade unions about the possibility that, if staff who have transferred to the new social work improvement body decide, within a specified period of time, that they do not wish to stay with the organisation, they can be reappointed to positions in the Government. That flexibility will ensure that the transition is not as unsettling as it might otherwise be. We want to find ways of lessening the challenge for people and providing them with a way to go back into the Government if they would prefer to do that. We are discussing a number of ways of ensuring that staff see the opportunities that are offered by the new organisation and that it does not become unduly difficult for SWIA to carry out its functions in the period leading up to the start-up date of the new organisation.

I expect that some of my colleagues will follow up on the issue of the transition later.

Margaret Smith (Edinburgh West) (LD):

There is a perception that some of the joint inspections that have been undertaken by HMIE have been helpful and have pinpointed ways in which services—fundamentally, child protection services—can be improved. Of course, members of this committee are trying to find ways in which services can be improved. The bill extends the provision for joint inspections. Can you give us some hard examples of what that extension will mean for service users and of the improvements to the service that there might be?

Val Cox:

It is important that the extension of the powers on joint inspection effectively recognises the increasing complexity of the issues that many people who use services face, and the reality that those issues can rarely be met by only one agency or service provider. By extending the joint inspection powers to include adult services, we will be better able to get a clear holistic picture of the range and quality of services that individuals use to meet their range of needs. An example might be someone with mental health problems who also has difficulties to do with their use of substances and who as a result engages in offending behaviour and therefore comes to the attention of a social work department, the police and psychiatric services. The extension of the joint inspection power to include adult services will make it possible to examine the quality of the range of services that that one individual in my hypothetical case uses. That person has a range of problems, including mental health and alcohol difficulties. They might be a parent, so there might be concerns about their parenting capacity. The extension of the power will enable all those issues to be examined and will allow the range of services that the individual receives to be examined.

I seek an assurance that there will be no diminution of the powers that are currently available in relation to joint inspections. I am thinking about issues such as powers of entry and powers to require sharing of information.

Val Cox:

I do not believe that there will be any reduction, but my lawyer might want to comment.

Gillian Russell:

The intention is to maintain the current suite of powers in relation to joint inspections. The detail of that is currently under discussion, but the expectation is that the detail will be in regulations and a statutory code of practice to which anybody carrying out joint inspections will have to have regard.

Christina McKelvie (Central Scotland) (SNP):

I will pick up some points from earlier questions. Is it fair to say that the joint inspection provisions that were put in place a few years ago stopped some of the duplication that was going on? A social work department might be inspected by one body, while its older adults unit is inspected by the care commission. Will the new agency put a complete end to that type of duplication?

Shane Rankin:

That is an interesting question. Until now, the joint inspection powers have related to children's services. Joint inspection is a way of ensuring that all the agencies that have an interest in children's services are engaged and involved in the scrutiny arrangements. That ensures that, when services are provided from a number of directions, they are all scrutinised. The bill will extend the provisions beyond children's services and child protection. In that sense, it will definitely create a different framework within which services can be inspected. Joint inspection also supports the duty of co-operation and reinforces the outcome-based approach of the concordat and the national performance framework. Therefore, it is one of a number of ways of ensuring that scrutiny looks at what happens to the individual rather than just the service—it is about looking at the outcome. Therefore, the powers should help to avoid duplication and ensure that services are examined in the holistic way that we keep describing.

Christina McKelvie:

Anybody with a background in social services will know that we should take a person-centred approach, which means that we should start from the person and work out, rather than start from the services and work in. I welcome that holistic approach.

My next question is also on duplication. How will the situation be improved for a parent who is looking after a young adult with a learning disability who is moving from children's services into adult services and who is suddenly faced with a range of agencies?

Val Cox:

The extension of the powers around joint inspection will enable the new scrutiny body to examine the interface between existing services and to deal with transitions in a better way than has been the case so far. We know that many of the problems that have arisen in the past, and which have led to tragedies in the lives of people using services, have occurred at points of transition.

It is clear that there are numerous points of transition in an individual's life. Christina McKelvie has given a powerful example. Under the existing powers it is entirely possible to examine holistically the range of services that a child or a young person accesses, but it is currently not possible to do the same once that individual becomes an adult in the eyes of the law and begins to access a range of adult-oriented services.

The new arrangements will manage that transition period, by understanding the quality of the transitions and—crucially—helping service providers to improve them. One of the powerful drivers behind the reform programme is the intention to have a strong and overt focus on improvement, and on the capacity of services to improve themselves.

Christina McKelvie:

I am sure that Val Cox agrees that to improve services it is necessary to have a highly motivated and qualified workforce. The Scottish Social Services Council has raised concerns about whether the new agency will be able to enforce the code of practice on employers, and whether it will be able to enforce and monitor continuous professional development and minimum qualification development programmes for staff who are working in care services. Will that make a difference? Will those concerns be addressed?

Val Cox:

I believe that the SSSC's concerns are being addressed. Officials are certainly considering amendments to the existing regulations on conduct.

Gillian Russell:

We are seeking to amend section 53 of the Regulation of Care (Scotland) Act 2001 to make it obligatory for social service workers and their employers to comply with the SSSC code of practice. That has been discussed with the SSSC.

Christina McKelvie:

That is a very welcome advance—I know from my background in training social care staff that it would have been welcome a few years ago, but it is good that it is happening now.

The British Medical Association has raised the same concerns about the sharing of information without consent that it raised did a few years ago with regard to the joint inspection of children's services. How will such concerns be addressed? Does the issue need to be revisited in the context of the extension of joint inspection to adult services? Should consent be paramount, or should there be a balance?

Shane Rankin:

There are two answers. First, we are not aware that the legislation that provides for joint inspection of children's services has raised any particular problems about information sharing to date. The other aspect is that the arrangements for sharing information will of course be governed by a code of practice, which will be very much open for consultation and development with stakeholders and interested parties. Those are the two protections.

Gillian Russell:

Obviously, any issues in this area will raise concerns about compliance with article 8 of the European convention on human rights. The public bodies will need to comply with the requirements of human rights legislation, so whatever they do must be appropriate and in accordance with the law. We are not changing the terms of the Data Protection Act 1998, as it is a reserved piece of legislation, so the bodies will have to ensure that they comply with it.

On the specific point about whether consent should be express or implied, as Shane Rankin said we are still discussing issues to do with consent. We will develop a code of practice that will deal with those issues and which will be fully consulted on.

Christina McKelvie:

I have a final question on that point. The BMA has suggested that anonymising information is a way forward and the Scottish Information Commissioner has raised his own concerns. Can you reassure us that those concerns will be taken on board and that the Information Commissioner and the BMA will be listened to?

Gillian Russell:

It is fair to say that their comments will be considered. I do not know whether, ultimately, their views will hold sway, because other issues must also be taken into account. There are sufficient safeguards in place for joint inspection, not least that anyone who is dealing with information must treat it as confidential and use it only for specific purposes. There are ways of safeguarding information that might not amount to anonymising it. All those issues are being considered.

Claire Baker (Mid Scotland and Fife) (Lab):

In the submissions to the committee, there seem to be two issues to do with transitions, which the convener touched on earlier in relation to SWIA. One is continuity and retaining expertise in the system. I still have concerns about the SWIA option, because the discussion earlier was about what options people might have to move back into the Government. If expertise goes with those people, how will expertise and knowledge be retained in the system? The other concern, which was raised by HMIE, is whether the transitional provisions will be robust enough, particularly in relation to work on child protection. What thought has been given to those two issues and what actions might be planned to deal with those concerns?

Shane Rankin:

You ask a number of questions. On the robustness of the transition arrangements, particularly in relation to child protection, HMIE is leading on child protection and a three-year cycle has just kicked off and, obviously, it is planned that the third year of the cycle will be led by social care and social work improvement Scotland. One cause for reassurance is that, at present, leading joint inspections involves leading a team from a number of professional disciplines that contribute to the inspection and those disciplines will still need to participate in the third year. It is the leadership that will transfer across, but the methodology need not change in any significant way.

You are correct that expertise needs to go across to the new organisation from both SWIA and HMIE. The work that we are doing to develop the business models and the sense of how the organisations work is being done openly with stakeholders and the existing bodies and is being driven by the stakeholders. We are trying to ensure not only that we get the best solution but that a sense of ownership of what is emerging develops across as wide a community as possible, so that by 2011 there will be a strong sense of how the organisation should function and people in the existing organisations will be able to see what they are getting involved with, because to some degree they will have had an opportunity to shape the new organisation. That provides a chance to spell out the opportunity and to encourage people to want to go with the new organisation.

Kenneth Gibson (Cunninghame North) (SNP):

I will ask a couple of questions about order-making powers. Section 10 enables ministers to bring forward regulations

"which they consider would improve the exercise of public functions, having regard to—

(a) efficiency,

(b) effectiveness, and

(c) economy."

Ministers can add to or remove from the list any body that has public functions. However, organisations such as Children 1st and the Aberlour Child Care Trust and Scotland's Commissioner for Children and Young People have expressed concerns about the issue. Do such order-making powers not diminish the level of scrutiny that is proposed for making changes to public bodies?

Shane Rankin:

We are not directly involved in those provisions in the bill. Although they raise some issues for bodies that are affected by parts 4 and 5, we are not directly involved in those provisions so I am afraid that we are unable to comment. We are happy to take the questions and to provide answers in writing subsequently, but I cannot answer that question at this point.

Convener, I realise that such a question could be answered by ministers, but I had thought that the bill team would have been able to answer all our questions on the bill today.

The Convener:

As long as the questions do not stray into areas of policy, the bill team should be able to answer them. I am not quite sure whether Mr Rankin is suggesting that the issue relates to a policy decision that has been taken by Government ministers.

Shane Rankin:

No, it is a question of logistics. As you rightly say, the bill team would be able to answer the question, but the bill team is currently in front of the Finance Committee to answer questions on the bill. We would need to field the bill team to answer that question. I am afraid that the issue is a matter of practicalities.

Kenneth Gibson:

We would need to ask for a transfer from the Finance Committee to get our questions answered. Have you just come off the subs bench for our committee meeting because the first team is at the Finance Committee? I am being facetious, but I hope that you will be able to answer my second question.

Section 13 will enable ministers to make regulations to remove or reduce burdens on business, the public and third-sector organisations where those burdens result from any legislation. That could include abolishing or changing the functions of a body. The power will replicate for devolved areas powers under the Legislative and Regulatory Reform Act 2006. What has been the impact of that act? What improvements, if any, are envisaged in rolling out that legislation through the bill?

Shane Rankin:

Can I be clear about what the question relates to?

Again, the question relates to order-making powers. Should we not be asking questions about that part of the bill at this stage?

Shane Rankin:

We cannot answer those questions for you. If I were to try, I might lead you into the wrong place.

The Convener:

Although this is not Mr Rankin's fault, there is a serious issue about proper and due scrutiny. The committee has a responsibility to take that role seriously, as I think all members of the committee do. We are working to a timetable that has been determined and agreed by the Government. Perhaps it might be helpful if Mr Rankin and his team reported back to the bill team leader the committee's dissatisfaction that you are unable to answer some of our questions that we have a legitimate right to pursue. I am grateful to you for your honesty in not attempting to answer questions for which you do not have the detailed knowledge to be able to answer. Equally, this is the committee's only chance to put questions to the bill team on the order-making powers in the bill. It is quite unhelpful that we are unable to pursue those issues today.

Shane Rankin:

I understand that. I can offer to take your questions and to provide full answers in writing if that is helpful. I will report your dissatisfaction to the bill team.

That would be helpful. Perhaps, when the Official Report of today's meeting is published, the bill team can reflect on Mr Gibson's questions and provide a written response.

Kenneth Gibson:

Convener, it is a bit odd that we cannot ask questions on an issue that requires scrutiny. The order-making powers in the bill are a key point that has been raised by the organisations from which we will take evidence later today. I am sure that they will also be concerned that we have been unable to get any answers on the issue this afternoon.

The Convener:

I have a question on the financial memorandum. I understand that the Government anticipates that, over a four-year period, the cost of the changes will be £5.56 million and the expected savings will amount to £6.2 million. That is a net saving of £640,000. That does not seem much of a saving, given the scale of the change. Is it really worth it?

I am not being facetious. I am just asking.

Shane Rankin:

That question was asked in a slightly different way earlier by Elizabeth Smith, who asked about the driver for change. The driver for change is improving the quality of scrutiny and public services; it is not saving money, although the intention is that it will cost less to provide the required scrutiny.

The Convener:

In that case, does the Government agree with Unison? Unison is not convinced that there will be any savings as a result of the measures. Is it possible that we will go through all the changes and find that the new system costs us the same amount of money or even more?

Shane Rankin:

We have put in the financial memorandum our sense of what the costs will be. It is estimated that the system will cost less.

But not very much less.

How does the Government view the care commission's concerns about the lack of consultation by the bill team, particularly on the financial memorandum?

Shane Rankin:

The care commission will no doubt comment on such issues later. It has been very helpful to the Government, as other bodies have been, in putting together the financial memorandum, and has provided us with a great deal of information and experience, which it has gained from establishing its own organisation. That has helped to guide the figures and the approach that we have taken.

I think that the care commission was concerned about one particular issue: the harmonisation figure. It was concerned about the methodology that was adopted, which it thought could have been more sophisticated and could have gone further at the time. We could not have gone further at the time. I think that the financial memorandum ended up with a harmonisation cost of £780,000. More detailed work has now been undertaken, and an estimate of around £350,000 has been produced. In a sense, the care commission was right. More detailed work could have been done, but it could not have been done in the time that we had. However, it has now been done to help to shed light on the figures.

I do not think that any other matters are in dispute any longer.

Kenneth Gibson:

I would like to clarify some figures. I refer to the £5.56 million cost of the changes. Are those one-off changes or will there be subsequent on-going costs? Will there be £6.2 million of savings over a specific period? Are they savings over three or four years?

Shane Rankin:

Over three years, I think.

Does that mean that there will be on-going savings year on year?

Shane Rankin:

There should be.

Kenneth Gibson:

If there is a saving of £6.2 million over three years, we are looking at year-on-year savings of around £2 million, although there might be a net saving of only £640,000 over the first three to four years. Do you hope to save around £2 million year on year?

Shane Rankin:

Yes. The savings need to go on. There are one-off transition costs and some on-going costs, but everything is essentially captured within the three-year period in the financial memorandum.

You are looking for on-going savings of around £2 million a year after that period.

Shane Rankin:

I think that that is the number.

Margaret Smith:

I want to pick up on the issue of consultation. Usually, people from bill teams or organisations who come before us have been able to look at formal consultation exercises that have been undertaken, and to see what has happened as a result of that consultation and what kind of input there has been. Obviously, the consultation has been slightly different in this case. How have you consulted on the bill?

Shane Rankin:

Much of the consultation concerned the Crerar review, which established the principle that having fewer bodies would improve scrutiny and make it more proportionate. There was a great deal of consultation on all of that.

The Government decided in early December last year that it would create a new social care and social work body and a new health care improvement body and that it wished to legislate in the PSR bill. There had been no draft legislation—no detailed proposals on the shape of the bill—and, from that point, Government officials have engaged directly with the existing scrutiny bodies and a number of the policy interests across the Government to develop the necessary detail of the proposed legislation.

At the same time, officials have engaged directly with key stakeholders from the social work side through the ADSW, as well as from the Convention of Scottish Local Authorities and the Society of Local Authority Chief Executives and Senior Managers. They have also engaged with the 11 trade unions that are affected by the proposals, engaged with a formalised reference group, published bulletins on the progress of the work and developed draft legislation that was tested with as many of those groups as possible as it moved forward. Those structures have been sustained to carry us through into the rest of the work as the bill passes through the Parliament and the development of business models takes shape and progresses.

The Convener:

That concludes the committee's questions to you today. I thank you for attending. We look forward to receiving further written evidence on the points that Mr Gibson pursued.

The committee will suspend briefly to allow for the changeover of witnesses.

Meeting suspended.

On resuming—

The Convener:

We return to our continued consideration of the Public Services Reform (Scotland) Bill.

We are joined by Alexis Jay, who is the chief executive of SWIA; Jacquie Roberts, who is the chief executive of the care commission; Graham Donaldson, who is senior chief inspector with HMIE; Harry Stevenson, who is an ADSW executive committee member; Geraldine Doherty, who is depute and registrar with SSSC; Tam Baillie, who is Scotland's Commissioner for Children and Young People; Ruth Stark, who is a social worker representing the British Association of Social Workers; and Annie Gunner Logan, who is the director of Community Care Providers Scotland. We had understood that John Fair, who is a regional officer with Unison Scotland, would join us this afternoon, but he has not arrived yet. He may show up and join the panel later.

Most of the panel members sat through our evidence from Government officials and so have had the opportunity to guess which questions we are likely to ask, and perhaps to prepare their answers. We will not allow you to make opening statements, which might mean that we would be here all day, so we will move straight to questions. You have submitted written evidence in advance, which committee members have had an opportunity to read.

I am conscious that you will all have wide and varied views on many of the subjects, but I wish to keep the discussion reasonably focused so that you are not here for an overly long time and so that the committee can deal with the other items on today's agenda. It is fine if you want to follow up on a point that someone else has made, but you should do that only if you have something additional to say, rather than simply to echo your agreement, unless you think it is important that you do so.

I begin by asking you about your general views in relation to the merger of your organisations, and whether you think that the change will deliver improvements.

Jacquie Roberts (Scottish Commission for the Regulation of Care):

It is helpful to consider the issue from the point of view of members of the public. I will put myself in the position of the grandparent of a child who is living with drug misusing parents. As that grandparent, I would want to know that there was good scrutiny of the multi-agency system, and whether health, education, social work and the police were working well together. I would want that to be checked. I would also want to know that social work services were being delivered and checked. If the child went to a childminder or a family centre, I would want to know that the quality of those services was checked and that good services were being delivered to the parents.

From that point of view, we can see why it would help if the checking of all parts of the system was done by one body. There would be communication and working out where the greater risks were and where more checking was needed. That example might help you to understand why it might be good to put everything together.

Thank you—at least I have an example at last.

Annie Gunner Logan (Community Care Providers Scotland):

I will give another example, but from the service provider's point of view. At present, the care commission assesses the quality of a service pretty much in isolation from anything else that happened before the service was provided, whereas a person who uses the service has had their needs assessed, a commissioning and procurement process for the service might have been undergone and a care management process goes on for the individual, with a care plan being put together. At present, separate bodies examine those things. From our point of view, it would be a real change to have one body, which I hope would use the same set of measures and standards, to hold all parts of the system to account for what Mr Rankin earlier called the care pathway. There is the potential for that to happen but, in our submission, we raise questions about whether the bill will achieve that or whether it will be achieved through the business model that the new body employs.

The Convener:

That leads me on rather nicely to my next question Do we need legislation to make the various people work collaboratively within one organisation, or can that collaborative working be achieved without legislation? Is the driver for change the right one? Is legislation necessary? I do not mean whether it is necessary in order to create a new body or to abolish other ones, but whether the establishment of a new body is right and the only way in which to deliver co-operation and collaborative work in a way that is much clearer and easier for people to understand.

Alexis Jay (Social Work Inspection Agency):

As someone who has been responsible for leading multi-agency inspections of adult services—which are the parallel to joint inspections of children's services but without the underpinning legislation to enable and facilitate them—I can certainly say that the lack of legislation has led to many practical difficulties. Different approaches are taken and different legislation governs access to health records and other types of records. There are different ways of following up action plans and different approaches to checking what is done. I say that as someone whose organisation has led multi-agency inspections of services for older people, people with learning disabilities and people with addictions, as well as inspections of criminal justice social work services. With so many bodies, it is difficult to rationalise the process when there is no underpinning legislation to compel people to do so. The parallel in the inspection of children's services is pursued more easily because of legislation: with adult services, everything must be done by co-operation, which does not always achieve what is required.

Jacquie Roberts:

To return to my example of the grandparent of a child with drug-misusing parents, it would be helpful for the grandparents to know that there was one body that was responsible for overseeing the whole system. A reduction of the number of bodies will make sense to some members of the public.

The Convener:

In an answer to me, Mr Rankin said that the new body would lead to a more proportionate level of scrutiny. Are you confident that that will be the case? Are you equally confident that we will get the balance right and that services will be scrutinised properly? Can we say confidently that what could or should be inspected will be inspected?

Alexis Jay:

The Social Work Inspection Agency always intended, after completing its first round of performance inspections of councils, to be more proportionate, to reduce the amount of inspections and to target its work at organisations that were most in need. That was the plan, regardless of whether the PSR bill existed. That might well be true of other organisations.

It is true that we are focusing more on improvement, key to which is the competence and ability of providers to evaluate themselves. It is quite right that they should be responsible for improvement. However, in response to your question whether we are targeting the right areas, I think that we need to recognise that organisations are at different stages of being able to self-evaluate accurately. As a result of that, we will continue to require some professional scrutiny. I am sorry to say that some of the worst performers are those who are least good at telling whether they are any good at providing services. That is the fairly general view across scrutiny bodies: providers still have a fair bit to go to be able to self-evaluate accurately, and we will still have to verify or test things to be confident of the appropriate amount of scrutiny to be carried out.

Graham Donaldson (HM Inspectorate of Education):

As the question implied, organisational structures alone do not automatically deliver the kind of improvement that we are seeking. If the tests are about ensuring proportionality, coherence and better outcomes for the people who are in receipt of services, I have to say that we are moving to a better position on all those criteria. However, there are undoubted rubbing points and areas where organisational difficulties have made outcomes more difficult to achieve. The process could be facilitated by tidying up the structure, although whether or not we achieve change will be determined by the behaviours that lie behind it.

Harry Stevenson (Association of Directors of Social Work):

Organisations work in slightly different ways; for example, some focus on outcomes, some focus on standards and others are still working on outputs. As a result, they are starting from different positions. If the proposals are to have any benefit, it should be the recognition that, as we deliver services in an integrated way in communities and people's homes, it makes sense to integrate the scrutiny of such services. Indeed, that has been a benefit of child protection inspections.

Information sharing was mentioned earlier. In that respect, I have to say that, in the move from the Crerar review to the bill, we are now missing one of the key players: the health service. I think that that might prove to be a lost opportunity.

How might the bill be amended to include health boards? How would you envisage any such proposal?

Harry Stevenson:

I am no expert on drafting bills, but I feel—given how reports carried out in communities not only provide elected members, councils and the public with the assurance that they seek, but help with improvement—that much of this should actually be about collaboration rather than about requiring people to co-operate. If the bill is to strengthen scrutiny in any way, it must ensure that everyone is held to account. I think that the Crerar review envisaged a more rounded body to take that work forward. In that respect, I am talking about key professionals who support and protect vulnerable children and adults in our communities.

How will SWIA's role change, particularly given that it will lose its agency status?

Alexis Jay:

When the question was raised with the previous witnesses, the committee was right to highlight that the relationship between ministers and agencies is different from that between ministers and NDPBs. As chief inspector, I am also, at the moment, chief professional adviser to the Government on social work issues. I feel that a key issue is access to evidence.

As Mr Rankin pointed out, the Government intends to create the post of chief professional adviser when the new body is created. That role will be akin to the role of the chief medical officer or the chief nursing officer, but it is recognised that there will be difficulties in that. There is an important issue around access to the evidence base that backs up the policy advice that is provided. It will be important to ensure that that continues to be available.

I should say that any suggestion in the Crerar report or anywhere else that the relationship with ministers is anything other than wholly independent and respectful is simply not accurate, in my experience. I have worked with previous Administrations and the current one and I can say that ministers are always entirely proper and do not interfere in the process of independent inspection.

Jacquie Roberts:

From my experience of being the chief executive of an NDPB, I can say that it is possible to use evidence from scrutiny to inform policy departments, officials and ministers directly. It is not impossible to have a good and informing relationship, even though the NDPB is an independent body. However, we support the creation of a chief social work adviser on the same level as the chief nursing officer and the chief medical officer.

Will your organisations' relationships with ministers alter as a result of this merger?

Alexis Jay:

If you are referring to the relationship that we have in terms of policy advice, I expect that the relationship probably will change. I meet ministers regularly to update them on our findings and to give them my views and advice on key social work issues. I think that that relationship would not be the same for the chief officer of an NDPB.

Harry Stevenson:

I support that view. One of the features that has emerged since the inception of SWIA has been the maturity of the relationship with our senior politicians in Scotland. Some difficult and tough conversations have been had about issues that we sometimes cannot control in social work in Scotland. It will be important to retain access to ministers if we are to maintain the current level of confidence in that relationship.

Ken Macintosh:

The background to this issue concerns not only the bill's merger of the two organisations that we are discussing, but also the fact that the bill will create ministerial powers to amend or possibly even abolish a lot of other public bodies. We did not quite get into that before the summer recess.

There is an implication that the relationship between public agencies and the Government might be shifting. Is that to be welcomed or to be worried about? Are you concerned about that possibility, or is it simply a practical measure that will be to the advantage of all?

I am sorry if that is a bit of a speculative question.

Tam Baillie (Scotland's Commissioner for Children and Young People):

I offered comment on the scope of the powers in part 2 of the bill, particularly those in section 10. Earlier, someone asked whether ministers having such powers would limit parliamentary scrutiny: I say that it would. That is one of the key issues with regard to the changing relationship between Government ministers and bodies. I answered the question in respect of my position as commissioner and am mindful of the fact that the office that I hold was set up directly by the Parliament's Education, Culture and Sport Committee, rather than by the Government. Recently, we went through a protracted in-depth review that was conducted by the Review of SPCB Supported Bodies Committee. That review resulted in a bill, which will go through Parliament in parallel with the Public Services Reform (Scotland) Bill. I have concerns about whether there will be sufficient time for scrutiny of the order-making powers.

My other concern is that one of the central tenets of my office is that it must be seen to be independent from Government. The international yardstick that is used for that is the Paris principles. In my view, the inclusion of my office under schedule 3, which is part of the reference in section 10, would compromise that. I can understand the Government looking to be nimble and light of foot by not having to go through full parliamentary processes to make changes in our public bodies, and I can understand its desire for expediency, but I am mindful that there needs to be sufficient time for parliamentary scrutiny. A balance must be maintained and, in my view, the balance has moved too far towards expediency at the cost of parliamentary scrutiny. That is the answer to the question that the convener asked earlier.

Thanks for pre-empting my question. Mr Gibson has some more questions.

Kenneth Gibson:

Do not steal my thunder, Tam. I was going to ask you that question more or less directly because your submission expressed considerable concern about the issue. I asked the bill team the question effectively on your behalf, given that the committee is an appropriate public forum in which to do that.

I will play devil's advocate and look at the issue from the other side. One of the points that the Scottish Government would make—although the officials who were at the committee today did not—is that the committee would be able to debate the issue for up to 90 days, so there would be parliamentary scrutiny, and that changes would be made only if they were

"proportionate to the aim of delivering more efficient, effective and economical public functions".

If a proposal did not meet those criteria, ministers would not be able to make the changes; if the criteria were met, the committee could still debate the issue for up to 90 days and take it into the parliamentary chamber if necessary. Given that no party has a majority on the committee or in the chamber, that is surely a built-in safeguard in respect of scrutiny. How do you feel about that?

Tam Baillie:

Safeguards are built into the arrangements in respect of proportionality, any necessary protections being deemed to be affected by the making of the order, consultation that would have to be carried out, and the parliamentary process. However, it is not 90 days; it is 90 minutes.

Sorry. We could debate a proposal in committee for 90 minutes.

Tam Baillie:

We are already just past 90 minutes in today's discussion. That gives you some idea of the limited parliamentary scrutiny of what could be the exercise of very sweeping powers under section 10.

Annie Gunner Logan:

I will comment on the same point. I am extemporising slightly because I did not think that we would get into this territory, but when the Regulation of Care (Scotland) Act 2001 went through the Parliament, we had all kinds of arguments about who would be consulted about what and when as different developments took place. It occurred to us when we read this part of the bill that, although parliamentary scrutiny is certainly an issue, as far as I am aware there is no provision for consultation with anybody about anything before proposals come forward. From our point of view, we are always keen that when there is any change to the regulation of services there should be consultation with service providers, groups of service users and so on. That is also missing from the bill, which is a slightly different dimension.

Tam Baillie:

There is a requirement for consultation, but there is a lack of specificity about what that would constitute. My understanding is that the recent process of the Review of SPCB Supported Bodies Committee would constitute sufficient consultation with respect to the use of these powers, and that there would be no need for a parliamentary bill; in the case of SPCB-supported bodies, a bill is about to go through in parallel with the Public Services Reform (Scotland) Bill. There are serious concerns about that.

Are the witnesses of the view, collectively or individually, that there should therefore be greater clarification of exactly what form any consultation should take?

Tam Baillie:

Regardless of the consultation, because of the concerns that I have with regard to my own office I would press for the removal of offices such as my own from schedule 3 on two grounds: first, the lack of scrutiny in comparison with the process that established my office and endorsed its independence; and, secondly, the strong desire among parliamentarians for my office to be seen to be independent. The powers would seriously compromise that independence.

I am keen to hear from one or two others on the issue, convener.

Harry Stevenson:

I was involved in the stakeholder reference group. We are at the stage of looking at implementation, the timescale for which—from the change management point of view for the organisations that are directly affected—becomes a driver. The ADSW has made the point about the need for more consultation and the lost opportunity in that respect in terms of the process. There needs to be a fix between the two. Uncertainty is a big distraction. As others said about the scrutiny process, business continuity is required. We need to assure both politicians and the public about the good quality of the services that are being delivered in Scotland every day of the year.

I did not notice Ruth Stark indicating earlier that she had something to say. Before we move on to questions on the extension of joint inspections, I will bring you in. I do not want you to think that we had forgotten about you.

Ruth Stark (British Association of Social Workers):

The point that I was trying to make earlier for BASW was about the difference that having one body in place of several would make. Practitioners on the ground think that current inspections are complex, repetitive and time consuming. No one in any social services department wants a bad review; everyone works towards getting a good report. Evidence from my members shows that, during review periods—this is a significant point—contact with service users drops from 12 per cent to 6 or 7 per cent. That is a significant loss to people out there in the community. The bill should bring together functions so that more emphasis can be placed on service improvement and not on working towards an inspection in a way that reduces the delivery of day-to-day services.

Geraldine Doherty (Scottish Social Services Council):

My focus is on what we will gain. I represent the workforce regulator. I was pleased to hear the committee's questions on the codes of practice. Through the proposal for only one regulator, the bill gives us the opportunity to gain a better interface between the workforce regulator and the service regulator. The SSSC has a good relationship with the care commission and SWIA. Gillian Russell spoke of moves to introduce a requirement that employers and workers comply with the codes, but that is already in the regulation of care legislation. We want to go further than that.

At the minute, if a registered worker does not adhere to the code of practice for workers—I am talking about a serious situation—the SSSC takes action. However, the same action cannot be taken against an employer. As the committee will know, it is seldom the case that one worker is the source of poor practice. It is more often the case that infrastructure issues are involved, such as the way in which employers recruit their staff and how they safely manage, supervise and support them. We argue strongly that the bill should contain a clear requirement on the new body to take account not only of the codes but to take action where employers do not adhere to their code of practice. If they do not follow the code—for example, in not supporting their workers properly—they endanger service users.

The expectation is that information sharing is done informally. We should make better use of information. When we investigate the conduct of individual workers, we often find information on service quality and management. Equally, when the service regulator looks at service provision, it often pinpoints the poor practice of individual workers. We share information informally, but that should not be done informally. The bill needs to include not only the right but the responsibility to share information. That would ensure good services for vulnerable people.

Ruth Stark:

The code of practice for employers needs to be scrutinised and enforced. Ultimately, if we want a confident, competent workforce, employers have to be made to fulfil their side of the bargain by supporting front-line staff.

I was interested to hear in the first evidence session this afternoon an almost risk-averse approach to the scrutiny of what we do. Those who work in social work services continually balance need, risk and rights. It is much better to think of the work as a balancing of those things, rather than thinking of ourselves as watching our backs all the time and being risk averse, because that does not help people to move, change and achieve a better quality of life.

Margaret Smith:

I want to pick up the issue of the extension of joint inspections. Your views on that are implicit in quite a lot of what you have already said this afternoon, but I would be interested to hear anything more specific that anybody wants to say about it.

Harry Stevenson:

I reinforce the point that I made earlier. We deliver services to people on an integrated basis in their own homes and their local communities. It makes sense that we take a more rounded view of the types of service that we deliver and the parts that we all play in that. In particular, good communication between different disciplines and different agencies and provider organisations is required and has been beneficial.

In my experience, child protection inspections still feel like inspections of social work services, because the case for a reading links in and follows through. Nevertheless, they highlight important issues between agencies and between professionals, and, importantly, the views of the service user and their carers or parents in the process as well. There has been a step forward in how we respond to the complex way in which we need to deliver services.

Graham Donaldson:

Thinking back to the questioning from the previous committee when the current legislation was going through, the legitimate concerns that existed at that time were well addressed in the codes of practice. I am clear that the most powerful aspect of inspections is the way in which child protection inspections can work, with a common, rather than individual, view of all the information that is available. An inspection team can bring the information together and share it within the team. That approach allows us to work from the child outwards rather than from the service inwards, because we can look at the totality of the information that is held on any individual child.

Looking back over 32 child protection inspections, the legislation that was passed in 2006 has proved to be a powerful contributor to the success of those inspections.

Christina McKelvie:

Good afternoon. I say to Tam Baillie that I think we are into extra time now, because we have gone past the 90 minutes.

I want to pick up a point that Geraldine Doherty made earlier. When I was in a social work training section, I delivered the regulation of care stuff for members of staff who needed that minimum qualification, and we looked at the code of practice quite a lot. I did not accept their evidence for their qualification unless they knew the code of practice for workers back to front. I was quite a hard taskmaster on that.

I think that the feedback that I got earlier was that section 53 would be amended to compel employers, but perhaps I picked that up wrongly. I wonder whether you picked that up as well.

Geraldine Doherty:

I want more assurance about that. At present, in relation to the regulation of care, employers are compelled to take account of our codes, and we have the ability to compel registered workers to take account of them. If they do not do so, we will take action. However, there is no duty on the new body to enforce the codes. Enforcement is needed. It is not required for the majority of employers who take their responsibilities seriously, but the current position is that, if I go to the care commission or SWIA and say that an employer is ignoring the code, is not supervising their staff properly and is not training them properly, those bodies do not have the right or ability to do anything about that.

We have had good informal liaison, and the care commission does thematic inspections in relation to the code, but that is not the same as employers being absolutely clear about it in the way that registered workers are. As you know, the whole point of having a shared code was that workers and employers should have responsibilities. At the minute, we can enforce the code in relation to workers, but there is no enforcement in relation to employers. It would be an awful lost opportunity if such enforcement were not included in the bill for the very small number of employers for whom it is required. The majority of employers work well with the codes, but we and the new body need to be able to take enforcement action. A duty to co-operate on the regulation of services and the workforce is also important.

Christina McKelvie:

Thanks for that.

I spent much of my social work career working in learning disabilities services so I understand what it is like to take young people through transition—I still bear the scars. It was horrific for some of them to move into adult services and then not get the services that they thought they would get. Does anybody have any concrete examples of how the new agency will address transition? Shane Rankin said that the new agency would enable better-quality transition that would allow it to pick up any gaps in the service and sort them out. Are panel members able to expand on that?

Jacquie Roberts:

It would be much better to bring together investigation of the young person's file with looking at the care assessment and care management arrangements, the service that has been commissioned, the quality of service provision, and links with the young person's family and with health, education and perhaps higher education or an employer. The new agency would make the system more understandable and coherent for the family of that young person.

Christina McKelvie:

In lots of cases, it is the parents or identified carer who develop the care plan when the young person does not have the capacity to understand why things are being done in that way. It is my impression that a single-agency approach would be more helpful to families in that situation.

That leads us to the BMA's concerns about consent. Consent has always been an issue in learning disabilities services and it is also an issue for people with mental health problems and other medical conditions that inhibit their capacity for either a long period or a short period. Can the witnesses shed some light on the BMA's concerns about consent and tell us about their experience of how it works in children's services? Earlier, Shane Rankin said that no problems around consent had been raised in the past couple of years of joint inspections of children's services. How does viewing records without consent work in adult services? Can the witnesses give us any examples of that?

Jacquie Roberts:

From the care commission's point of view, only a medically qualified person can access medical records and therefore interpret them. They use the same professional principles that apply to the medical practitioners who help the person.

Alexis Jay:

Children and adults cannot necessarily be put in the same category, given that we are talking about adults who, in some instances, intermittently have capacity—for example, people with dementia or mental health problems can be very capable. We must be sensitive to individual rights.

I am not sure that anybody around the table would want their health records to be read indiscriminately by any inspector or scrutiny body. The regulations must be clear that viewing someone's medical records without consent must not be an open-ended blank cheque—I am mixing my metaphors. There will need to be restrictions on viewing records without consent so that it can be done in a way that will give comfort to those who have genuine concerns about the issue. That would include, for example, not sampling medical records of the population in a certain age group—people should do that only if they have a reason to do so.

Harry Stevenson:

I return to transitions. If we are to make the progress that we hope to make in relation to the getting it right for every child agenda, there should be an integrated assessment framework for every child. I would like to think—and I am certain that the ADSW agrees—that we are working to remove practice issues such as barriers to moving on from being a child to adult life and moving towards working in a different way. Uncertainty is an issue for families, as is funding for long-term support arrangements. Integrated assessments are the way forward for every child as they move into adulthood. That is the way in which to give them the support that they require.

I think that we all agree on the principle, rightness and importance of information sharing. However, if we look at the major inquiries—even those that were held in the past year or so—we see concern about the reality of practice on the ground. Challenges remain for all agencies in that regard. We must win the argument on the need for information sharing and then see practice develop on the ground. Professionals will then have confidence in information sharing.

Some good work has been done in Scotland on gold standard information and electronic data sharing. I refer to the single shared assessment. We have made good progress, but more needs to be done.

You will remember as well as I do the case in the Borders and the concerns that were expressed in the inquiry. Central to the issue was the fact that, because the person involved was an adult, information on risk was not shared properly.

Graham Donaldson:

Shane Rankin made a point earlier about child protection inspections, which follow a different process to that which applies in care commission inspections. I want to reinforce that point. In the former, a single inspector can look across and make connections between files from various sources, including medical files. Instead of sharing the information by way of reporting what is in a file, one person looks across the board at a child's records. There is no automatic read across to the process for adults, however. Prior to the passage of the Joint Inspection of Children's Services and Inspection of Social Work Services (Scotland) Act 2006, concerns were raised with our inspectors. Since then, as Shane Rankin said, no issues have been raised with us during the 32 inspections. That is a reflection of the way in which the code of practice was written and how inspectors have observed it.

Christina McKelvie:

I have one further question on the need for motivated and qualified staff. For many years, the cry from social work service staff has been, "Oh no, not another change." Change can demotivate people. How do you, as providers, supporters and employers, use change as a positive experience and not one that leads people to say that?

Annie Gunner Logan:

That largely depends on how the business process is taken forward once everything is set up. Providers have expressed concerns, including on whether they will have to make another application to register their service. There is a lot of support among staff in the voluntary sector for the grading system that the care commission is operating. We want that to continue.

I return to the original point about the codes of practice. If I may, I will briefly go off on a slight tangent. Geraldine Doherty pointed out the anomaly in the enforcement powers—she said that one code is enforceable, but not the other. We are also concerned about another anomaly, which is whether the care commission's enforcement powers in relation to services will be transferred to the new body so that it can take significant action if it finds poor practice.

Also, will what I might describe as the non-enforcement powers of SWIA also be transferred to the new body? The care commission can issue improvement notices and enforce them. It can ensure by way of making return inspections that change will happen. However, none of that can happen in the bits that SWIA looks at. That is the real anomaly in bringing things together into the new body. That slight imbalance is an issue.

I am sorry for having taken the first question and not answering the second one. I wanted to highlight the issue, which is significant in that it disrupts the idea of having an integrated and cohesive scrutiny system. The proposed system is neither integrated nor cohesive.

Harry Stevenson:

In reality, things are going on. Last week, a meeting was held in my area as part of the new approach to SWIA inspection. Every year, we have to deal with 70 care commission inspections, including in the area of child protection, which was looked at a year ago. From talking to colleagues across Scotland, I know that a sense of proportionality and a reduction in the burden of regulation are required, particularly given the data that we have to report to Government in other ways.

There are also the internal systems through which we look at quality, best value and how to become more effective in service delivery and in responding to the needs of the public.

Work is going on and at this point I do not think that the issue has any resonance with our workforce. There is an issue for the ADSW, in that we have rightly moved more towards self-evaluation and skilling up organisations, but there is also clearly a capacity issue in various organisations throughout Scotland. We offered the view that, given that the situation is changing and there is a greater burden on local authorities and others to provide self-evaluation approaches, which are more complicated because of the outcomes approach, there should perhaps be a shift in resources to recognise that.

Ruth Stark:

We welcome these moves; we advocated that they should be in the Regulation of Care (Scotland) Act 2001 when it originally came through; we said that there should be only one body. We are excited by the fact that there will not be repetitive inspections and that people will be able to get down to the work that they want to do. The other outcome that we seek is a cultural change so that there will be no corporate move to work towards inspection and we will be able to work towards improving services on the front line. We hope that the bill will achieve that.

I am conscious that Mr Baillie has to leave by 4 o'clock. You explained that you have another appointment. Do you want to say anything before you go?

Tam Baillie:

Yes, I have one other comment. This is not a self-imposed consultation guillotine—I really do have another appointment and I apologise, but I thank you for giving me leave to go at 4.

I will comment on user focus, because it is tremendously important. I am pleased that the requirement to involve users is included in the bill. Both SWIA and the care commission have done useful and innovative work. I understand that the bill does not mention specific groups because it covers all groups, but there are considerable challenges in involving users in the scrutiny process. Although I pay tribute to the organisations' efforts to do that, there must be an acknowledgement of the additional resources that are required to have proper user involvement in the scrutiny process. It will be invaluable to us to have that perspective, and to have it recognised within the capacity of the new organisation. I do not think that an adjustment to the bill is required, but such involvement needs to be properly recognised through guidance and there must be acknowledgement of the capacity in the organisation to be able to do it properly, because it will be to all our benefit.

Now that I have said that, can I go?

Yes, Mr Baillie. Thank you for your attendance at the committee. We will continue in your absence.

Geraldine Doherty:

There will also be a lot of change for the staff of the existing organisations. An interesting point is that we currently register care commission officers, and a requirement of their registration is that they have both a relevant practice qualification and a qualification in regulation and inspection. Tam Baillie made a point about good inspection and the involvement of service users. Inspection is a very skilled activity so we urge that there be clarity about what the inspection and regulation requirements will be for the new body and that consideration be given to how we support the staff who are being merged and will have shared activities.

Jacquie Roberts:

To answer the question about the impact on staff, the vast majority of staff in the care commission think that the proposals make sense and they are keen to get going in making our work more integrated with the work of SWIA and HMIE to deliver multi-agency child protection. Indeed, without pre-empting any decisions about the bill, staff are out shadowing people doing the other work. I think that the aim of the proposals makes sense, but we will all have to undertake quite a significant programme of organisational development to achieve that aim, so that there is added value and a truly integrated system rather than a group of bodies put together under the same logo or management. We must work quite hard on that.

Alexis Jay:

I want to follow up on Tam Baillie's point. We believe that we have involved service users and carers in our inspections in a non-tokenistic way, but that has a cost attached to it. We have not only trained people and supported their involvement—we have developed courses for carers, in particular, with the Glasgow College of Nautical Studies—but have paid people who have been involved, to give them proper recognition of the value of their contribution. We have not assumed that they can be involved in their spare time. If the bill and the new body are serious about involving service users and about having a user focus in general, it must be recognised that that does not come cheap.

The Convener:

That leads us nicely on to the financial memorandum. It states that the bill will result in net savings, but they are not predicted to be particularly significant. Do you have any concerns that the drive to make savings might come at the expense of the quality of the service that the new inspection authority will have responsibility for?

Jacquie Roberts:

That is why I talked about the need for extremely careful planning. A lot more time needs to be devoted to looking at terms and conditions and ensuring that we avoid any equal pay claims. Without presuming that what the bill proposes will definitely be agreed, I believe that a lot of work needs to be done with HR and finance experts. That is why the current bodies—including NHS Quality Improvement Scotland, which is to become healthcare improvement Scotland—must work together closely and share information to ensure that any reduction in activity takes place where there is less risk. That has been the basis of the change in the frequency of our inspections: our ability to provide evidence that there is less risk. We need to carry on that work and link it with the work that is being co-ordinated by Audit Scotland so that we have a shared risk assessment process to determine where more scrutiny is needed and where less can be tolerated. I presume that that would lead to some savings in the overall cost of the scrutiny regime.

The Convener:

In response to Mr Gibson, Mr Rankin suggested that the Government anticipated that, after the initial implementation period, £2 million-worth of savings would be made annually. If that is the case—and bearing in mind that a number of you said that, having done your first round of inspections, you plan to adopt a more targeted approach anyway—are you confident that the Government's target of making £2 million-worth of savings is realistic and can be delivered without jeopardising the quality of the service that we need to ensure that our care and child protection services are properly scrutinised?

Jacquie Roberts:

More careful work needs to be done to link a reduction in activity to lower-risk services. I could not give you a guarantee that that work is ready at the moment, but I understand the external climate. It is worth looking at where, collectively, we can make efficiency savings.

Alexis Jay:

Yes. We believe that SWIA, which has a very small budget, would be able to deliver the current saving of 5.5 per cent and still maintain the quality of our work. If further savings were sought, some of the extremely important high-quality work on development and the engagement of users and carers could begin to suffer.

Annie Gunner Logan:

I want to raise a related issue. The driver is savings and efficiencies. At present, service providers pay fees to the care commission, and it is proposed in the financial memorandum that that system will continue.

The committee would be hard pushed to find a more inefficient use of public money than we have in the current system, particularly in relation to publicly funded services. The independent service providers have to build the fee into the cost of their service and their contract price, only to hand it straight back to another public body. That has always seemed to us to be hugely inefficient, and the creation of a new body presents an opportunity to scrap fees and fund regulation centrally.

There is a tenuous link with the fees in a system in which there is just the care commission, in that service providers pay for the service that the care commission provides. However, providers will be a relatively small part of the new body, so what their fees are used for will become even more opaque than it currently is. I am aware that I have been banging on about the subject for about 12 years, but I will not stop doing so because some of our members are paying up to £300,000 annually for care commission fees, which is public money that they require to get from their purchasers and then pass back. The bill presents a great opportunity to end that system once and for all and to fund the work centrally, which would cut out all the transaction costs along the line. Here endeth the lesson.

Jacquie Roberts:

Such an approach would mean that at least £11 million would have to be found from somewhere in central Government. Some 39 to 40 per cent of our income comes from fees.

Annie Gunner Logan:

My point is that the money comes from central Government in the first place, through the settlement. By the time that the money has finished its journey through local authorities and providers and come back to the regulator, it has probably lost quite a lot of value.

I am sure that we will want to raise the issue with the minister.

Harry Stevenson:

If we embed improvement and are sure of the quality of services in organisations, the task of preparing for inspections should take care of itself. Best practice should result in a good inspection. I think that we all agree that we are not trying to get out of having inspection reports.

The issue to do with resources is not about potential financial savings. I was trying to make the point earlier that we are in a world in which we consider outcomes and the difference we make to people's lives. Do people feel safer and more confident? Do they think that we are doing the right things to support them to be independent? We are in a world of self-evaluation. The issue is where the resource will sit, how much will stay in the central scrutiny organisation and how much will be used locally, to build local organisations' capacity to deliver on those outcomes. Tam Baillie made that point well.

As Alexis Jay said, it takes time to involve service users and carers in any process. It is necessary to build confidence, so that people can contribute and feel that we have listened and can respond to them. All that takes more time and effort, so self-evaluation takes more time and effort. The issue for ADSW is where the resource lies rather than the financial savings that can be made in the process.

Do the witnesses want to comment on the consultation on the bill and say whether you have been able to put your case to Government?

Jacquie Roberts:

I represent one of the bodies on which the bill will have a major impact. Along with the other scrutiny bodies, we have had a lot of opportunity to talk to Government and its officials about the matter. It is important now to convey what is intended to members of the public, providers and organisations such as ADSW. The engagement of stakeholders is important.

Harry Stevenson:

As I said, ADSW thinks that we have moved quickly from Crerar to implementation of the bill. Perhaps more time could have been spent on considering the wider implications. The role of some key players in the delivery of services to the public may have been missed.

Someone said that the various organisations operate differently in relation to standards and outcomes. Does anyone want to expand on that point?

Jacquie Roberts:

It may be a reflection of the different reasons for the setting up of the different bodies. The care commission was set up by the Regulation of Care (Scotland) Act 2001 on the back of the issuing of national care standards. We use the national care standards and have to take them into account. The Social Work Inspection Agency was set up for a different purpose.

There is a task for us in getting together to discuss language, methodology and the fact that, when it comes down to it, the work of the child protection inspections, SWIA and the care commission is all about getting better outcomes and experiences for the adults and children who use the services. It is part of our organisational development work to find more shared language and a shared understanding of what we can do in a similar way.

Annie Gunner Logan:

I have highlighted before the difference in enforcement powers between what the new body will be able to do in relation to services and what it will be able to do in relation to anything else—commissioning, care management, assessment and so on.

There are also big differences in the way in which the two bodies currently deal with complaints from the public, which will continue in the new body. The new body will be able to deal with public complaints about care services, but it will not have the power to deal with public complaints about anything in social work services other than its own operating procedures. In terms of the public perception, it will be quite difficult to address that. If we are talking about an integrated scrutiny system for all social work services and the whole system, it will be problematic to tell the public that they can complain to the new body only about a little bit of the system and not about the rest. The committee might want to consider that when it comes to amending the bill at stage 2. As a principle, it is important.

Do other members of the panel agree with that?

Alexis Jay:

SWIA does not currently deal with complaints. It is not that we deal with them differently; it is not part of our legal responsibilities to deal with them at all. Each council has its own statutory complaints procedure that works in parallel. Crerar was absolutely right to say that it is extremely difficult for the public, when they have a problem, to know how their complaint goes through the system. It is a complicated and bureaucratic process, and I would support anything that simplified it.

Jacquie Roberts:

It is important to recognise that members of the public trust an independent body to investigate a complaint when they fear reprisals from a service provider. That is something that the public hold dear, and that is what is being carried forward for care services in the bill.

Ruth Stark:

I echo that point not just from the public's point of view but from the perspective of members of front-line staff. When they see their colleagues providing a poor service, they find it difficult to report that. The issue is the culture of how inspection takes place and how accessible the complaints procedure is, not just to the public but to people who work in the industry.

Geraldine Doherty:

To state the obvious, we also deal with complaints from the public about staff who work in the services. If the bill could achieve a good complaints procedure, that would be wonderful. The procedure needs to be streamlined and people must know whom to make complaints to. It is important not just that it is worked out in relation to the new body but that the interface with the workforce regulator is understood, not only for efficiency and effectiveness but for the service user. The service user must understand whether they have to complain to one body about the worker, another body about the care service and not to anybody about the infrastructure. The workforce regulator aspect must be dealt with as well.

Mr Macintosh has a brief final question.

Ken Macintosh:

Having identified the problem with the commissioning of services in local authorities recently, Community Care Providers Scotland has suggested that local authorities should have

"a duty … to take SCSWIS reports into account".

That might help to redress the balance of regulation. Do any of the other witnesses have a view on that suggestion?

Harry Stevenson:

I do not think that local authority services would have any difficulty with that. Any scrutiny and transparency of processes is important. I will not stray into discussions that are taking place in other parliamentary committees, but I do not think that there would be any concern about that. We all have the same intention in how services are commissioned and procured in Scotland.

Annie Gunner Logan:

The proposal in our written submission was about how to deal with the issue at the micro level. Local authorities would be asked to have regard to the grading that a particular service received when it made decisions about it. Something similar could also be done at the macro level, joining those things together. For example, the duty could be tied in with national performance frameworks and single outcome agreements, and local authorities could have a responsibility to increase the proportion of services in their areas that had gradings of a certain level and above. That would take the link between scrutiny and commissioning to the strategic level as well as the level of specific services. There are a number of different ways in which that could be done; it all depends on how the new body sets up its business model when it starts. None of that is a given in the bill.

The Convener:

I thank our witnesses for their attendance at the committee today. I will suspend the meeting to allow them to leave and to allow members a brief comfort break. We still have a substantial item on our agenda to consider today. The committee will reconvene at 25 past 4.

Meeting suspended.

On resuming—