The following details our response to the Welsh Government’s Consultation on the Independent Living Fund
– Future Arrangements to Support Recipients in Wales which outlined four possible options for future support and which sought opinion on these.
All Wales Forum formal response to the consultation on the future of the Independent Living Fund in Wales.
Option 1 – Setting up a successor body to the ILF in Wales
- Possibility that it secures those that are currently in the system, but not known for how long.
- The value base of the ILF, ie, putting the service user at the heart of the system and enabling the flexibility of use of payment.
What’s not so good?
- It remains an inequitable system, with the few that currently receiving potentially being the only beneficiaries.
- The cost of setting up a Wales ILF – there would need to be some initial administration costs and investment to get it going, and possibly to continue to run it.
Option 2 – Setting up a National Independent Living Scheme in Wales.
This is perhaps the most exciting and creative option that the WG has given us all to consider. The other three are fairly standard ideas, but this option asks us to consider a new model for Wales that has not yet been set up.
The concept would see some sort of system whereby existing social services would be able to access a national ‘top up’ fund for those packages of support that needed additional investment to ensure choice and independence. The Fund would probably remain independently managed, but would be accessible to all Local Authorities. How this model would work is still in need of working through. It may involve creating a threshold, whereby if a package of care exceeds a universally applied maximum level of support that LA’s offer, the top up fund would be applied to in order to meet the difference required. This is just one idea that has been floated around amongst those that are members of the ILF stakeholder Advisory group.
- The important thing to note with this option, is that while it seems harder to pin down in terms of detail at present, it is the only option that offers real flexibility when it comes to considering how we can address the equity issues, how we can ensure the ILF values are retained and applied to all who use social services, and not just those that currently access it. It also offers the chance to explore with recipients and service providers if there is a way to keep the ideals of the ILF as such, yet create a system that enables equity for Local Authorities and spreads the funding further.
- The concept is that the ‘top up’ element or ILF replacement element, would belong to the individual, and would move with them wherever they lived in Wales.
- It provides the people of Wales with the freedom to explore what is really wanted, and may provide some exciting opportunities for all that use services.
What’s not so good?
- This is not a clear model as yet. Instead it is a set of ideals that could be brought to life. Therefore there is clearly some uncertainty for those that use the ILF and the wider public. There is also ensuring that finances can meet this idea and need.
- There may need to be an alternative system in place temporarily whilst this new model is drawn up and shared with those that have vested interests. However, this alternative system could be one of the other three options on the table.
Option 3 – Transferring responsibility and funding to LAs in Wales through the revenue service grant
This option would see the transfer of meeting the needs of current ILF recipients transferred over fully to the Local Authority, with the money that currently comes in from the ILF pot being distributed equally across the Local Authorities. This would mean that there would be no separate element to individual’s packages of support. However, it wouldn’t necessarily mean that part of the support package couldn’t be provided in a similar format, as direct payments are already an option for Local Authorities to offer, and these can be managed directly by an individual. Equally, the Local Authority does have a duty of care to meet need in full where it comes under their eligibility criteria.
- It may be cheaper to run this way, as there are already existing systems in place within LAs to administer Direct Payment etc, but not the ILf at present.
- The money would go into a wider social care pot and therefore could expand the outreach to all that use services and not the few, potentially addressing inequity.
- The long-term sustainability of this model is perhaps more viable, as it assumes that the support given should become a core part of our community services.
What’s not so good?
- The money going through the revenue service grant system would mean that some Local Authorities would gain and some would lose. Currently there is wide variation across Wales as to how many ILF users there are in different counties, dependent on how many applications were made by a Local Authority in the past. This means that those who have the most users would see less money coming in that present, as the RSG assumes a different calculation per population head. Equally, those that have less ILF recipients at present could see additional monies coming into their county.
- The concept of choice under this option is a grey area. Currently ILF users are able to spend their allocation on what they think they need most to be independent. Under this model, it may differ depending on the Local Authorities own service options available.
- When the new Social Services Act becomes live in 2016, all Local Authorities will need to meet the same base regulations and expectations, ensuring that individual needs are met in a person centred way. Equally, there will be a one stop system across Wales for assessing eligibility. If the money were to be directly transferred in 2015, this system would not yet be live and therefore there is a risk that individuals may be subject to the usual postcode lottery concerns.
Option 4 –Transferring responsibility and funding to LAs in Wales via a special grant with conditions set by Welsh Government.
This is in many ways similar to the option above, but with one key difference. Essentially the assumption with this model is that the existing monies that ILF recipients in Local Authorities receive would go to the Local Authorities, but would be ring-fenced around those individuals. It is not clear how long the ring-fence would be put in place at this point, either as a longer-term idea or as a short-term approach to enable the Social Services Act to kick in at local levels. Therefore this may ensure some security for existing recipients until there are better local options available to meet their needs.
- Those that currently receive ILF could be ring-fenced to ensure some security, whether in the shorter or longer term.
- This option enables Local Authorities to start to take some management and control but in a way that offers the time for the grassroots processes and services to be set up before they actually do.
- Again, the long-term sustainability of this model may be more immediately viable due to the enabling of Local Authorities to start to plan for all individuals, alongside those that are existing recipients.
What’s not so good?
- Depending on your point of view, for example as a Local Authority that currently doesn’t have that many existing ILF recipients, it may disadvantage some counties and advantage others. However, this is also true of option 3 depending on which side of the fence you’re sitting on!
- There’s an air of uncertainty about how long this would last and if it would make that much difference in the end. The key would be the conditions placed and the requirement to enact key elements of the new Social Services Act to underpin it.
In conclusion, the All Wales Forum has serious reservations about handing the funds directly over to Local Authorities, especially without any conditions attached. However, even with conditions, there is concern about ensuring equity across the wider community and local authority areas once the conditions are lifted.
The concept of retaining a Wales ILF, although understandably appealing to those families and individuals who currently receive it, does bring with it the concern of equity for others and an issue of longevity. Having said this, we would want to see no unnecessary and detrimental impact imposed on those individuals as a result of the consultation decision, regardless of the option chosen. If another option were chosen, such as setting up a new scheme for Wales, we would advocate for retaining the existing funding model as it is during the development and transition phase, to both help reduce anxiety and ensure consistency for existing users whilst this process is undertaken. It should be remembered, that whilst we need to address the issues of equity for all, those that have both valued and needed this additional support should not be penalised for any previous UK Government decisions or indeed how active their own local authority may have been in accessing the Fund whilst it was open.
The option to set up a new scheme for Wales would bring some challenges, but it also brings with it an exciting prospect to develop a new solution that addresses the policy outcomes under the new Act and supports local authorities to continue to enable freedom of choice and independence. Whilst it’s unclear as to how exactly this model will be developed, many of the families that have responded to the consultation events have expressed a willingness to explore this option to enable others to gain from the life choices they’ve been able to experience, and to also safeguard the quality of life that their own relatives currently enjoy.
In the past Wales has been a pioneer with regards to policy and changing direction for some of the most vulnerable in our society, such as the All Wales strategy, and we have a good history of being able to work together to create positive and productive solutions. We have welcomed the ability to engage with the Welsh Government on the development of the consultation options and the document itself, and we are thankful for the opportunity to actively engage families in a meaningful dialogue about the future of the Fund. We remain committed to supporting the development surrounding whatever option that is chosen, and we would actively encourage the Minister to consider taking the risk of a new scheme that can be shaped for a new and improving social care and communities programme for Wales.