NCERCC is republishing its analysis and evaluation of government proposals for reforms to unregulated provision for children in care and care leavers.
The reason for doing so is because the situation is more complex than is presented by the government in its proposed standards. What is being presented is a pragmatic response divorced from principles and evidence. It is a simplification of a sophisticated situation.
The issue is not solely about placements, it is about children’s needs, stages of development, necessary care, and love.
The government is rushing and has truncated the necessary process.
We have not had the systemic analysis is required upon which to base sound policy. In other times and on other occasions the sector would be united in demanding deep research and due process.
A Community Care article shows that government, Ofsted, local authorities, ADCS and provider representative organisations are signed up to the direction. Sector split on unregulated placements overhaul as under-16s ban looms | Community Care Children’s organisations would not be needing to campaign if the process was as needed. Indeed, as it has been before. These child-centred culture carriers are continuing the challenge what are described as ‘careless’ standards. The standards look only for support not care.
It is not possible to address the situation regarding unregistered and unregulated settings without also addressing the individual elements that go to make the wider strategy that is necessary. This is a longer and wider project. The problem comes to be understood while exploring solutions. It is not a task and finish project. A scientific method is to seek the fullest evidence that contradicts a hypothesis. A consultation may then seek confirmation. Currently we have a conclusion, that many pointed to being the destination at the start, seeking a confirmation.
Understanding unregulated settings requires more detail and evidence than is currently available. The research for the consultation, given the time, data available and the small project team, was far from being able to be exhaustive. For example, the history of, and the role and task both operationally and culturally of unregulated settings must be understood. As NCERCC found in working on this document this is a time-consuming task, necessary to know of and speak with many who have been culture carriers of children’s services thinking, and who have been involved in developments over decades. The development of children’s services in England has been ad hoc and the institutional memory of what it was that precipitated a change, or not, and why the changes were as they were is all important to be understood. In addressing any one thing in children’s services many others are affected. Every change counts significantly. The situation is not static but dynamic, because of complex interdependencies, the effort to solve one aspect reveals or creates other problems.
The complexity of the situation is being diminished, even discarded. It is being done so knowingly.
At even this late stage it is not too late for government to decide to take more time to appreciate the factors involved are deeper and wider and require more consideration.
The worst situation will be to enact inappropriate standards and for children to suffer the consequences. That is not a future that should be able to be contemplated by anyone.