Archived decisions

CPA - the next steps 22 May 2003

Consultation on single tier and county council CPA strategy

General comments

While Hampshire County Council welcomes the continuing involvement of local authorities in the development of Comprehensive Performance Assessment, this must be balanced against the keen disappointment at the disproportionate level of inspection activity in relation to local government service delivery. This is particularly noticeable for those authorities, like Hampshire, who having achieved `excellent' status, anticipated complete freedom from inspection for a period of at least three years. The advent of the whole regime of improvement planning and improvement reporting has set in motion a new industry to ensure that the current status is maintained, rather than exploiting the freedom to innovate. In conclusion, questions must be asked about whether the significant additional spending on inspection would not be better spent on the delivery of front-line services, where it could contribute directly to meeting performance targets.

In considering the future CPA strategy the Council is pleased to note the recognition of the local community leadership role and the consequent need to measure performance in relation to effective contribution within partnerships. However, there remains an overall tendency to measure excellence against national priorities and standards. In the spirit of `new localism', it must be recognised that local authorities exist to prioritise the needs of their communities, not those of central Government. In many cases these will be the same: an effective CPA strategy and framework will assess the strength of evidence and the rationale to support local policy decisions, whether or not these follow national targets. In this context, performance indicators drawn form user satisfaction surveys should be given greater weighting within the framework.

Specific comments

To avoid repetition of discussion points, the Council has developed its response to the future strategy by highlighting issues connected with:

    1. Understanding the full range of local authority activity in addition to public service delivery

    2. The diversity of local communities and the need to develop priorities that address their needs

    3. Measuring contributions to performance through partnerships

While comments on the framework cover:

    1. The assessment cycle

    2. The thorny issue of progression and regression through the categories

    3. Concerns about the overall credibility of the framework.

The comments and suggestions in respect of the framework are based on the following assumptions:

    · The role of the Relationship Manager should be pivotal in determining re-categorisation - to balance the simplistic approach triggered by passing thresholds

    · There should be a differentiated approach to re-categorisation based on previously assessed performance

    · Synchronised re-assessment leading to publication of league tables is the main cause of `chasing CPA points' rather than striving for improvement

    · The credibility of the framework lies in openness and a recognition that since everyone makes mistakes, an appeal process is vital

I Measuring the whole of local government activity / focus on service improvement

Local Government has a three-pronged role that is not adequately portrayed by the traditional perception of local public service provider. While the service provision role has in itself transformed to include commissioning services from other providers, to this must be added:

    - Community leadership / arbitrator - a role to negotiate and influence outcomes in partnership with and between a wide range of stakeholders

    - Regulator - an enforcement role that does not fit happily with the model of citizen as customer

    - `Rationer' of resources - the policy making role arising from the need to match scarce resources to greatest need; saying `no' and making difficult decisions on appeal are not `customer-led' services.

In this context, the Council does not agree with the objective that `increases in category should reflect better service performance'. However, given that this objective is in respect of short-term development, a more acceptable objective would contain an explicit reference to timescale, perhaps as follows:

`increases in category prior to 2005/06 should focus on better service performance to maintain the stability of the framework'

In the longer term the framework must develop to reflect the whole range of local government activity, particularly so that annual improvement reporting is not only geared to measuring performance in delivering front-line services.

II Arriving at priorities

The following comments are made on the objectives defined in paragraph 12, on the basis that the framework must better reflect the conflicting priorities that face local government; the way these competing priorities are managed by local government; the need to continue pressing for more joined up working from those organisations setting standards and national priorities.

    - The Council strongly agrees with the bullet point `CPA needs to measure performance against national and local priorities, providing an appropriate balance between the two.' This statement sums up the dilemma faced by local government and correctly suggests assessment should measure not only performance against priorities but also how competing priorities are balanced.

    Since solutions must be locally determined it is implicit within this statement that there is no single `right' structure or approach. The Council would prefer to see this assumption made explicit, since there is a tendency for some assessors or inspectors to measure against a known or preferred `standard'.

    - Closely aligned to the above statement is the second bullet point highlighting the role of the `shared priorities', clearly an example of another set of priorities to be balanced. To ensure this is more than a duplicate objective and can stand the test of time, it should be made more generic, citing the current agreement as a step on the path to seamless government and public service, rather than a separate objective in itself.

In order to give due emphasis to local needs, the Council strongly urges that greater weight is given to the results of consultation with local residents. To ensure consistent data it is vital that surveys have a robust methodology, drawing on representative samples of the community. User satisfaction performance indicators offer obvious opportunities to develop this approach, as do bespoke surveys of residents.

III Measuring achievement through partnerships

The Council endorses the approach to measure the impact of councils in their locality and looks forward to further consultation on this issue, given the significant difficulties faced when there are different priorities for partners, even though they share some common goals. A key factor in assessing the effectiveness of partnerships is that in the early stages considerable effort is needed to negotiate and agree common goals and an approach to working together. The methodology must not rush to test improvement `on the ground' at too early a stage and undervalue the importance of these early negotiations.

In principle the Council accepts the aim of undertaking county and district council CPA at the same time, but can see no real distinction between this partnership and that with other public sector agencies, beyond the opportunity to employ a more cost-effective approach to assessment. Therefore a methodology, which exploits opportunities to ask views of the same groups of stakeholders at a single time, or to share inspection resources, would be acceptable. On the other hand, an assessment framework that measures the effectiveness of all parties as if they were a single body with a common set of objectives, would not take account of the impact of different political administrations on policies. Furthermore, in citizen terms, it is doubtful that they would consider this to be a joined up approach unless other key players such as health and social security were included in the same frame.

IV The assessment cycle

The Council sees the distinction between a short-term strategy and a medium- to longer-term strategy as offering opportunities for a structured approach, which can manage significant improvement or deterioration in performance, while maintaining robust comparative information.

The Council can see the value in maintaining a stable framework for assessment, with major changes scheduled on a planned but infrequent basis and therefore accepts the proposal for major revisions of the framework to take place in 2006 and 2010. However, the Council strongly believes there is no value in perpetuating the synchronised re-assessment of all authorities for the following reasons:

    - a significant drawback associated with the 2002 corporate assessment related to the delay in publishing the report: Hampshire County Council was in the first tranche of local authorities to be assessed and received a draft report in early May. The final report was not published until December, by when the messages were stale and although work had already begun on reacting to the broad thrust of the recommendations, there was always a concern that key factors might change.

    - The Council strongly agrees with the stated objective that `improvement reporting is about real service improvement, not just chasing additional CPA points'. This aspiration will not be helped by a repeat of the media hype around a single published league table. While this served well to ensure commitment to the new framework, it should not be a feature of a more measured approach to long-term improvement.

    - The OFSTED model of re-inspection demonstrates that phased re-assessment can enable clarity of reporting to the public and the compilation of comparative data via an annual report.

    - Phased re-assessment would spread the workload for both the Audit Commission and local authorities

    - The timing of re-assessment could be on a differentiated basis, according to previous performance.

    - The CPA framework for District Councils allows for phased assessment.

Clarity about how phased assessment might work in practice is offered below:

    - 1 full assessment per local authority to take place during the lifecycle of each appraisal model

    · no requirement for assessments to occur within a single year, although there will clearly be a peak period each year that would enable effective linkages with the annual service information updates. For this the Council agrees with the December publication date, so that judgements are published within reasonable timescale of assessment

    · comparative tables to use latest CPA judgement. Where this is more than 1 year old, it should be accompanied by the latest annual improvement report.

    - option to re-categorise prior to full re-assessment triggered by:

    · Automatic: significant variation (up or down) arising from annual improvement reports - December publication date should apply.

    · Ad hoc: on recommendation from the Relationship Manager

      resulting in:

    - interim full assessment being carried out (using the appraisal model in current use) in the following circumstances:

      1. when the categorisation is under appeal by a local authority, or through the moderation process

      2. to monitor progress in developing corporate ability, for example in weak or poor authorities. There could be a presumption made about frequency of re-assessment in respect of different categories or lack of improvement over time.

      3. where there is significant improvement or deterioration not covered by the automatic rules but agreed by a `roundtable' of the relevant regulatory bodies as needing review.

    In this case the Council agrees with a February publication date, consistent with the general phased approach.

V Progression and regression

National and local government face the same dilemma of meeting increased demand for high quality public services, while reducing the burden on the taxpayer. It is not surprising that the theme of modernisation pervades all recent Government initiatives as the only route to achieving both objectives. But modernising demands creativity and the courage to take the risks associated with trying something new. Therefore, the long-term success of CPA is intrinsically bound up with creating the space and freedom to innovate, allowing for the probability that there may be a short-term downturn in performance before improvement takes hold or as mistakes are rectified. The Council fundamentally believes that there should not be an annual risk of downward categorisation, on the grounds that this would tend to direct scarce resources to maintaining evidence of good performance and more importantly encourage a risk averse culture and stifle innovation.

While acknowledging the potential for short-term fluctuations in performance, publicly recorded aspirations for the CPA process indicate it will result in an underlying trend of improved performance in all local authorities. This aspiration is supported by the investment in improvement planning, the extensive capacity building programme and the `carrot' of additional freedoms and flexibilities. Implicit in this belief is the absence of quotas of authorities in each category.

The Council, therefore, concludes that there should be a differentiated approach to re-categorisation, recognising that rewards for significant improvement should be short-term, while penalties for deteriorating performance should have a built-in time delay (at least two years) to allow for self-correction.

The Council sees the key role of the annual monitoring and refreshing CPA information as an early indication of improvement or deterioration in performance, rather than a trigger for re-categorisation. More important is the need to balance the service information with a considered opinion from the Relationship Manager about whether re-categorisation should be taken further and in what timescale. This approach relies on:

    - the Relationship Manager's opinion being based on a `roundtable' approach, similar to that used for improvement planning and being linked monitoring progress with the corporate assessment recommendations through the annual audit.

    - a distinction being made between automatic re-categorisation, triggered according to rules outlined in the consultation document, and ad hoc re-categorisation, which brings flexibility into the process to allow for exceptional circumstances.

    - the annual improvement report developing to include wider activity measures as well as service based information

    - Significant improvement or deterioration being linked to change in performance being sustained over more than one year.

    - In the case of sustained deterioration in performance at an excellent council, the annual improvement report should initially provide a stimulus for revising the improvement plan in liaison with the relevant regulatory bodies. The Relationship Manager's view should be pivotal in determining whether re-categorisation follows.

VI Credibility of the framework

An additional objective is needed to continue initiatives to join up audit and inspection approaches. The use of the term `comprehensive' implies that there should be no assessment outside the CPA framework. This is an important objective for the framework, aiming to establish credibility by joining up regulation in the same way that local government is being asked to work in partnership and corporately.

Following criticism about the varying calibre of corporate assessment teams and the initial lack of openness about the moderation process, a further explicit objective should be included:

`to ensure open and effective moderation and appeal processes, leading to consistent judgements and comparative information about performance'


The Council accepts there are pragmatic reasons, associated with workload and allowing authorities time to respond to recommendations, for limiting the times a corporate assessment is refreshed. In addition there is the fundamental goal of developing a culture of real service improvement, rather than CPA points chasing.

The Council therefore proposes streamlining and clarification of bullet points 2 and 7 in paragraph 12, along the lines of:

- Stability and certainty in the CPA assessment framework are important to sustain focus on improvement priorities. Therefore:

    - Assessment of corporate ability will only take place once during the assessment cycle to enable effective comparative data to be compiled

    - Minor improvements to the framework will only be possible as long as they do not significantly change the methodology

    - In the short term, interim re-categorisation will result from better service performance, other than in exceptional circumstances

The Council agrees with the objective that CPA needs to be aligned with existing performance frameworks. Unfortunately, the wording in paragraph 12 gives a strong emphasis to the two examples used. Either they should be introduced as examples or a more complete list included - or appended. Notable omissions are: Beacon Status; Best Value.