Consultation on National Commissioning Framework

1 Comments

1.1 CIPFA welcomes the guidance on the process for planning and commissioning learning provision for young people in England for the academic year 2011/12 drawn up by the LSC. Given the significant impact on the 16-19 sector following the machinery of government changes, it is particularly valuable. We are pleased to offer the following comments on its content. CIPFA has responded to the questions in which it has a particular interest in its role as a professional accountancy body.

1.2 CIPFA supports the intention of the framework that it should provide a coherent national model whilst allowing for local flexibility. We broadly welcome the principles on which the framework is based. In our view, the principles of transparency, consistency, sustainability, impartiality and value for money are key. We believe, however, that there needs to be greater detail on the criteria that will underpin these principles to ensure their achievement in practice.

1.3 We remain concerned that the complexity of structures and number of authorities and separate agencies involved in the commissioning process could lead to an increase rather than a reduction in bureaucracy. If this becomes the case it could be difficult to achieve value for money.

1.4 We welcome the notion of a core data set to underpin the commissioning processes for provision provided to local authorities by the YPLA.

1.5 We are pleased to see that the harmonisation of success rates for use in schools is underway and expected to be available by 2012

2 Answers to specific questions

Section 1.1

Does the document make it clear how the absolute essential processes, roles and responsibilities to ensure that education and training places for young people will be commissioned on time, to quality and within budget for 2011/12?

2.1 In our view the document is clear about the essential processes and roles, however we believe that the accountability of the agencies and partners is less clear. The process includes three levels of scrutiny and learner choice which have to be reconciled with local, regional and national priorities within a stringent budgetary control regime and we are unclear about where the final decision making power lies. For example, if one partner or partners wishes a type of provision to be undertaken differently, who will make the final decision on how it will operate in future? Who will ultimately be held accountable and how will challenge be exercised? In our view, it would also be helpful for the role of YPLA staff generally to be clarified in this regard.

Section 1.2 - Key contributors to the commissioning process

Are the roles and responsibilities of each of the partners clear?

2.2 In CIPFA,s view the roles and responsibilities of each of the partners are generally clear. However, we believe that the role of colleges – as strategic partners with local authorities – could be outlined in more detail.

Section 1.3 – Key elements of the commissioning process

4 Are the elements of the commissioning process clear?

2.3 Although the Framework supports the principle of learner choice and notes that it will operate in the interests of the learner, we are unclear whether there will be sufficient safeguards to ensure that the commissioning process is ‘provider neutral’.

Section 2 – Planning, allocation and funding

Is it clear how each of the processes below will operate within the NCF and are they workable and deliverable?

- Planning
- Allocation
- Funding

2.4 CIPFA is unclear whether the proposals means that the system will be workable and deliverable. It would be helpful for the responsibilities and the proposed structure to be mapped out. To operate effectively the constituent parties will need to work as a group. This may not be practicable. In CIPFA’s view, it would be helpful for the Framework to set out further detail on the composition, operation and representation on 14-19 partnerships and regional planning groups.

Section 3 – Funding, payments and assurance

Is it clear how payments and assurance processes will operate within the NCF and are they workable and deliverable?

2.5 In CIPFA’s view there remains scope for very different payment and reconciliation processes to operate across neighbouring authorities which will impact on colleges that operate across local authority boundaries.

2.6 With regard to assurance, CIPFA welcomes the aim of one provider: one assurer. In our view this should help limit unnecessary bureaucracy. However, we note that consistency across assurers cannot be guaranteed and we recognise that there could be diversity. Some local authorities may also want additional assurance which may prevent the principle of one provider : one assurer being realised.

2.7 It remains difficult to see how the complex payments and assurance process can deliver value for money.
Is a system of in-year adjustment to allocations desirable and practicable?

2.8 In year adjustments to allocations can be a useful tool for lessening lags. Their practicality and desirability, however, depend on timing and scale. In reality, it can be difficult for institutions to reduce expenditure on resources – such as staff – in-year and this could potentially lead to instability. Small providers could be particularly vulnerable. In general, we would prefer for allocations to be adjusted in the following year. It should also be borne in mind that, currently, in the school funding system (the Dedicated School Grant (DSG) there are no adjustments for changes in pupil numbers (unless there are exceptional increases in the number of pupils) which is deliberate DCSF policy to enable schools to adapt to reduced funding.