Wellbeing Bill Impact Assessments – NCERCC Initial Evaluation

For anyone who cares about meeting the needs of children with the right provision it’s hard not to be overwhelmed by manic anxiety on reading these. Manic laughter as a defence mechanism from thinking through the likely consequences.

Needs and the right provision are mentioned, it looks like as a defence against anticipated criticism,  but what is not addressed is the mechanism and cost by which they will be met through knowing what is needed, how much of it, and where. That is left for others to encounter at a later date, maybe in the next parliament, and is not in their theory of change.

There is a large amount of disavowal of responsibility by government, national and local. The reality is the current situation has been made over years by them, and providers. There is, in reality, a shared responsibility as procurement requires buyers and sellers, both act to make a market. Market shaping and management has not happened, so to suggest measures that do the same again is not building from strength.

Is there a nudge towards voluntary organisations running most homes, either in own name or for LAs? It is certainly possible to make that link when you add aspects that are not in these assessments. However, many voluntary organisations are small and specialist and do not open new homes speedily, or at all. The largest have had little to no children’s homes over the past decade at least.  The new type of voluntary organisations report encountering unseen difficulties in meeting needs and running homes successfully. It is to be recalled voluntary organisations exited the sector with a large reason being reputational risk. Maybe the thinking is they will meet lesser needs and others will provide specialist provision? However when it’s gone, it’s gone, as a result of these proposals will specialist and thereby costly provision remain? Maybe the thinking is ‘someone’ will open such homes? The Australian experience is not, and the USA is experiencing similar scarcity as a result of the same set of policies as Care Review/ CWB Bill.

These impact assessments are a prime example of nudge behavioural economics rhetoric that is not engaged with reality.

They describe economic activity only. The real world is absent. There are no reasons why many investors have recently invested, not through a commitment to children but to guaranteed financial return. If it’s gone, they’re gone! Disorderly exit is only considered as a result of a future cap resulting in an increased burden of debt, not because of the implementation making disinvestment sooner than later. What investor would adopt wait and see when intent is so obvious? So these measures achieve the Care Review reduction in residential use by 1/3rd by reducing numbers of providers, so called salami sliced, no targetting. The issue of tye recent reality of Family First increasing high level need, through delay and inappropriate response,and so residential solutions being needed is not addressed.

They don’t engage at all, in any of them, with the effects of any of the measures on outcomes for children, workforce, developing higher level needs, wider than children’s services provision needed in education and health ( esp psychology, psychiatry, therapy).

Two wider lens observations

This is the cul de sac that a focus on sufficiency gets you. We need specificity not sufficiency.

This shows the futility of consultations. All the constructive criticism has resulted in not a single change.

In brief the proposals