Proposed DfE standards for Supported Accommodation inherently unsafe
There is no flexibility provided by these standards, an ambition declared in the proposals, that is not possible under the existing regulations for children’s homes. The children’s homes regulations should be applied as these provide greater welfare and safeguarding for children.
Such is the detail in this section it is clear that what is being described is a children’s home. As such the Quality Standards for children’s home and inspection must be applied.
With this insight it can only be concluded that these standards are inherently unsafe.
It is incomprehensible that these standards have been afforded a critical review by experts not directly involved with the making of placements. This should have been a prerequisite prior to this consultation.
The standards show that ideology, pragmatism and price have been allowed to take precedence ahead of issues such as child-centredness, evidence, and theory and practice developed over decades. The policy context is understood as having been politicised by these proposed standards. The policy regarding care has been carefully constructed over decades outside of political perspectives. The standards are a first practical measure in the dismantling of the structures that have provided ever improving, if not yet perfect, safeguarding for children, each has been enacted often following reviews into child tragedies. The standards may be seen as a first step in the process of the ‘lessons learned’ being dispensed with a return to a ‘structurelessness’.
Whilst the definition of needs appropriate for placement in such settings is defined it does not originate in a needs audit and analysis of their use. The standards do not address current practice.
Whilst raising significant points of weakness NCERCC has also raised potential unintended consequences of these reforms
Potential unintended consequences are many and various.
In no particular order of severity – as all are significant – the listing is not exhaustive
- It is not sufficiency that is required but specificity and this will be observed in the results of a needs audit/analysis and placements planning accordingly. Part of the problem with sufficiency is that, for a variety of reasons, we routinely fail to make ‘the right placement at the right time’. Consequently, children have multiple placements and frequently their unmet needs become more acute with each placement breakdown making matching more challenging. Hence we have a high number of children moving round the system and often the country. By aspiring to find each child coming into care the correctly (assessed) placement we would reduce both ‘churn’ and distress whilst facilitating children returning home or to relatively ‘simple’ foster placements maintaining placement availability in the specialist or even more generic children’s home with the nations resource. These proposals, by providing a diversion of attention and funding, obstruct still further the achievement of this humanitarian ambition.
- The expansion of the local authority children’s homes sector is slow and slowing. The homes being proposed seem ‘more of the same’, mainstream, rather than the specialist intensive care needed. Distinguishing treatment and therapeutic is an important task for investment. Specialist care is becoming less available as large providers absorb others and speciality is lost, there are numerous examples. As a result the specialist workforce is being lost and so is the knowledge and skills. The reduction in content and availability through on-line or apprenticeship of the L3 and L5 further depletes the richness required in the workforce. One national taught training curriculum is necessary with the outcome that any worker could work in any setting.
- These standards are approached as a singularity. The effects will be systemic and significant. Destabilisation will be widespread affecting the resilience of placements. Structures are important to the operation of children’s services and these settings and standards by being inadequate (assessment, thresholds for entry, knowledge and skills, etc) have grave potential for introducing chaotic, dysregulated, challenging children for whom ever increasing complex care or imprisonment is the likely outcome.
- The introduction of a new setting and standards is seen as being deliberately designed to be disruptive of the current provision. It is a behavioural insight derived project with the intended outcome of fragmentation. The amount of variation will be at setting level yet inspection will only be a service level. This matches to an agenda of localisation of interpretation through laxity of understanding of the task by inexperienced providers and service managers, more usually derived through experience but not seen as necessary in these standards. Inappropriate exception and exemption may be applied
- The funding outlined in the consultation arises from an unsatisfactory understanding. It proposes temporary funding to mitigate perceived short-lived obstacles before smooth operation. This is a profound misunderstanding arising from the standards having been devised by those with vested interests, government and providers, and does not address the permanent damage that will ensue.
- Attractiveness to inexperienced investors and workers made possible by the laxity of requirements.
- There is potential for a reduced number of children’s homes through closure as established provider’s transfer.
- Increased recruitment challenge/crisis for residential child care – low pay and the challenge of the task makes the ‘pool’ limited and these settings will introduce more competition for a limited and decreasing number of people.
- Increase in needs being placed into regulated settings. It is already being seen that there is a double effect from early intervention; EI masks the deeper needs at a younger age allowing deep rooted needs to be unmet until teenage years when they are differently perceived, trauma and panic may be seen as infant tantrum but later is seen as ‘challenging behaviour’; EI does not allow the true need to be understood and met and allows it to increase in complexity.
- There will be an increase in the need for intensive care. The behavioural insight ambition will be reversed.
- The need for urgent access placements will escalate further as children ‘ricochet’ from settled placements, the move made on the basis of chronological age, to settings that do not offer the secure emotional base required. The child will not experience resilient environment and so will not absorb an identity (I am) as resilient and will have exploration of the external world impeded.
- Ending Staying Put and Close – there will be no evidence or expenditure case for them continuing. These have, despite the apparent limitations – which is not for this response – been rightly heralded as a step forward in accepting the responsibility of the Corporate Parent. The narrative around the proposed changes makes no reference to these schemes which appears to suggest their demise.
