As a public sector organisation, LAs are expected to deliver VFM high standards of service delivery and subject to inspection, public sector scrutiny etc. we are expected to deliver a publicly accessible service and along with that comes accountability, transparency and the need to demonstrate a sense of reasonableness in our charges, and to some extent we should be prepared to justify when challenged, but not only that we should actually in the spirit of open government proactively share our charging framework and our policy approach towards fees & charges There are Statutory requirements to consider. Las have discretionary powers to charge for domicillary care services. Section 17 of the health & Adult and Community Services and Social Security Adjudication Act 1983 (HASSASSA Act 1983) gives Councils the power to charge adults for non-residential services that they receive. There has been guidance issued by the Secretary of State on how Councils should charge for non-residential services and this is referred to as Fairer Charging Policies for Home Care & other non –residential Adult & Community Services. Council’s charging Policies for that service area are expected to reflect such guidance It is also a known fact that as Council officers we are accountable to a number of key stakeholders, members, Inspection agencies, Audit Commission, Central govt, and with the advent of FOI, we should already be prepared for a greater level of transparency 7 openness than we ever envisaged, and it will only increase further as our public, the press and other interested parties hunger for more information (or juicy stories) There are Ethical issues to consider, on whether it is appropriate/ethical to charge particular groups of clients for certain services either from a moral stand point, or grounds of compassion, patriotism, fidiciary duty etc. Politically, this could also be a hot potato, so it is important to state up front that one think we must do as Council Officers is to ensure that all Charging Policies are approved in some way or the other by members. Now it might look as if that should be obvious, but we come to discuss the pros & cons of a corporate charging policy v individual service charging policy, it is easy for some service areas to end up with an officer approved policy. Now if that is covered in your Constitution’s scheme of delegation, then that’s fine, but if not then one could be exposed to challenge. One way of covering that aspect is the Annual process for setting fees and charges, which always goes before members. And this is where our fidiciary duty comes in as officers, it is not just about ensuring public money is well spent, but that opportunity to attract funds to the Council’s coffers is maximised. Not in a commercial sense, but to ensure that we are not subsidising the provision of particular services where we haven’t had the political mandate to do so.
Complexity: need to ensure that the general public can understand this and sometimes it is important to test it out with service user groups or key stakeholders, like advisory groups (CAB & other similar organisations, Age Concern, DABD, Childrens centres etc) Also get their input at an early stage Affordability is a key issue. We need to decide early on whether this is a service we want people to take on compulsorily, and then if so, what if any are you going to do about affordability. Remembering though that introducing elements of means testing adds to the process and could potentially add to complexity, but could still be the appropriate thing to do, in terms of our duty of care. However, we do need to balance this against the Council’s dwindling financial resources, and the current financial climate Another factor is demand and that can go either way, because there is increased demand that could present an opportunity to review the charging structure and if it is going to cost the council more to meet that increased demand for the service, then one could say there is a legitimate reason to reflect that in the fees charged for the service. Are there alternatives, that we would like Clients to go for, and does that justify charging a premium level for customers who choose a more expensive access channel for that particular service. Strategic considerations we will cove r in detail later on – but it is important to state here that in coming up with Charging Policies we need to take cognisance of issues like the Council’s Access Strategy (no point in having a Charging Policy that will require clients to pay in small weekly amounts when we are due to close down our cashiers & self service facility for payments will not align to the service design, or no self service in place yet) Will charing users for a service mean that they will stop using that service, their situation (health, accommodation independence) the deteriorates and it ends up costing the Council more to deal with the residual position. Examples here in Homelessness vis a vis a Housing Advice Service, Home care & meals on wheels service vis a vis residential care service, Early intervention & preventative services in Childrens & Adult Services vis a vis longer term care services etc
I suppose the 1 st thing to say here is that it will be easier to address any disjoints in policy links corporately You will be able to rein in 2rebel” service areas from going off script. The Council will be fully accountable as they will have taken a fully informed approach in developing the resultant Charging Structure What is our preference as Income Collection professionals? Better to have one single framework as opposed to numerous inconsistent approaches?
Will this stifle innovative service areas? How this help proactively responding to changing customer profile or service conditions mid year Is there any direct link (proven) between service led Charging Policies and better collection rates. Does it mean the service areas will own the billing process more and more engaged therefore i.e. ownership of the income levels and income targets?c
Recession Working Group – Councils would want to be seen to support people through tough times
Just like with Taxes, local authority fees & charges are subject to the same issues around Perception of fairness as that has a direct correlation to the client’s willingness to pay What influences perception? It is information, clarity of that information and the ability of the authority to engage with such groups and get that info across to them in a way they can understand and appreciate. If it is statutory, doesn’t make it any easier (especially if it is complex), which I suppose is where shared services opportunities or joint working comes in. ALL Las would be in the same boat and one of the 160 or 400+ Councils (depending on the service) may have worked out the best way to get the message to their client group. Yes, of course each Council may have some differentiating aspects to our clients (every Council Officers feels they have more demanding clients than the LA next door – not always true I think, but we need to allow for the fact that one size doesn’t fit all) Customer Info – Depends on billing process and how well originating process is owned by the service area. Plus of course corporate data structures and validating processes. But get this bit right and you have a fighting chance of collecting the money. Get it wrong and you are starting behind the line. Risk based service provision – a bone of contention in some areas, and not everyone in favour. Explain and Gauge reaction – invite comments at the end Customer focused payment options. Self service DDs, SOs or regular payments. If Cs can do it by themselves, they much prefer that. Recovery & enforcement You need to own and manage the process To key services in use the SLAs (but it is not the paper that matters, it is the working relationships, the operational alignment in processes, the feedback loop, service improvement circles, senior management leadership and the corporate values that matter
I’d welcome comments from the floor about good practice examples that people are aware of.
Charging Policies Presentation To Irrv Misc & Inc Collection Conference Apr 2010
Charging Policies Bola Odunsi BSC Consulting Ltd
My Background <ul><li>20 years local govt career across a number of London Councils </li></ul><ul><li>Revs & Bens, Corporate Customer Services </li></ul><ul><li>Last LA role was in LB Barking & Dagenham as HoS – Track record of service transformations & improvement </li></ul><ul><li>Now self employed, providing consultancy & interim management support to clients </li></ul>
Overview <ul><li>Definition of Charging Policies </li></ul><ul><li>Context for Local Government </li></ul><ul><li>Factors that Influence Charging Policies </li></ul><ul><li>Service areas covered by Charging Policies </li></ul><ul><li>Corporate Charging Policy? Yes or No </li></ul><ul><li>Context of Charging Policies in Social Care </li></ul><ul><li>Areas of discretion in setting your charging policy </li></ul><ul><li>Underlying principles to be taken into account </li></ul><ul><li>Impact on Collection </li></ul><ul><li>What does good practice look like? </li></ul><ul><li>Questions & Answers </li></ul>
Factors that influence Charging Policies <ul><li>Avoiding complexity </li></ul><ul><li>Affordability </li></ul><ul><li>Pressure on LA’s financial resources </li></ul><ul><li>Rising Demand </li></ul><ul><li>Strategic Considerations & alignment with existing policies </li></ul><ul><li>Implementation & Administration processes </li></ul><ul><li>Consequences of Charging Users </li></ul>
Examples of Services that have Charging Policies <ul><li>Home Care, Day Care & Other non-residential social services (Fairer Charging) </li></ul><ul><li>Libraries </li></ul><ul><li>Schools (meals, transport, trips etc) </li></ul><ul><li>Registrar Services </li></ul><ul><li>Land Charges </li></ul><ul><li>Pest Control </li></ul><ul><li>Licence fees </li></ul><ul><li>& much more!!!! </li></ul>
Corporate Charging Policy? Yes! <ul><li>Joined Up strategic thinking across the Council </li></ul><ul><li>Linked to outcomes – corporate impact assessment considerations </li></ul><ul><li>Aligned to MTFS & income budgets </li></ul><ul><li>Perception of equity & fairness by the public </li></ul><ul><li>Corporate sharing of information, processes & approaches </li></ul><ul><li>Customer Centric Approach & ease of self service – less complex </li></ul>
Corporate Charging Policy? No!! <ul><li>Service independence </li></ul><ul><li>Charging policies can be better tailored to service users </li></ul><ul><li>One size doesn’t fit all!! </li></ul><ul><li>Better collection rates? </li></ul><ul><li>Ability to manage impact assessment process and take proactive measures </li></ul>
Charging Policies for Social Care <ul><li>Residential Services - strongly influenced by national regulations & guidance (CRAG – Charges for Residential Accommodation Guide) </li></ul><ul><li>Non residential services – national guidance </li></ul><ul><li>LAs can apply discretion through local charging policies </li></ul>
“ Fairer Charging” Requirements ( Non-residential care services for adults) <ul><li>Minimum level of disposable income </li></ul><ul><li>Levels of DLA & AA can be included as income but take account of other services & support plus additional living expenses arising from their disability </li></ul><ul><li>User’s property not treated as capital asset for assessment purposes </li></ul><ul><li>Cumulative charges for complimentary services need to meet above criteria </li></ul>
Areas of Policy Discretion <ul><li>Disregarding capital value </li></ul><ul><li>Disregard some element of partner’s income, if spouse remains at home. </li></ul><ul><li>For temporary care or short term care, there is discretion on whether to undertake a financial assessment </li></ul><ul><li>Potential to seek contribution from a 3 rd party if cost of residential accommodation is higher than what LA expects to pay. </li></ul><ul><li>Whether to apply a maximum charge. </li></ul>
Underlying Principles To Be Considered In Setting Charging Policies <ul><li>Alignment with Corporate or Service objectives </li></ul><ul><li>Reasonable, fair & transparent to all . </li></ul><ul><li>Charge to be assessed according to frequency, cost & ability to pay </li></ul><ul><li>Service user to be left with sufficient money to meet their needs (Social care cases where financial assessment done) </li></ul><ul><li>Discourage perverse financial incentives </li></ul><ul><li>Consistent with other charging policies within the Council </li></ul><ul><li>Efficient & expedient Reviews & Appeals procedure – not to be confused with the complaints process </li></ul><ul><li>Flexibility to cope with changes in circumstances </li></ul>
Impact on Collection <ul><li>Perception of fairness & equity </li></ul><ul><li>Accuracy of customer information </li></ul><ul><li>Consider linking risk profile to service provision or payment terms </li></ul><ul><li>Payment options – Customer centric </li></ul><ul><li>Recovery & Enforcement </li></ul><ul><li>Links with Service area & SLA requirements </li></ul>
What is Good Practice? <ul><li>Examples? </li></ul><ul><li>Who decides? Government or the customer? </li></ul><ul><li>Possible indicators; </li></ul><ul><ul><li>Customer satisfaction & customer feedback </li></ul></ul><ul><ul><li>Access to information & ease of understanding </li></ul></ul><ul><ul><li>Levels of self service activity </li></ul></ul><ul><ul><li>Complaints & appeals data </li></ul></ul><ul><ul><li>Independent recognition of excellence </li></ul></ul><ul><ul><li>Collection levels or write off volumes?? </li></ul></ul>
Questions & Comments <ul><li>Thank you for listening </li></ul>