The reassuringly expensive burden of regulation.

Also a shout out to respond to the consultation on the Supported Housing Guidance

Tim Keilty, one of the elected member representatives talks about his experience of monitoring working in a support provider organisation.

Is what really matters what is checked and counted?

Also Tim asks do think about these ideas in a response to the Supported Housing consultation

Imagine the scene.  It is 4.15 on December 22nd, the last Friday before Christmas.  The local authority monitoring team are scrambling to finish their last big piece of work before they break for Christmas.  “OK we are good to go – hit send” says the Chief Superintendent Commissioning, Compliance and Monitoring Officer.  They close their laptops, grab their party hats and head off for some well-deserved cocktails.

Meanwhile in support provider land, the little Microsoft tone pings…The evil incompetent providers don’t notice it at first, they are making sure that everyone is sorted, taxis are booked to get staff to people’s houses on Christmas Day and Boxing Day, The finance team are wrapping the last of Tony’s presents, and the Registered Manager is making sure that there are extra staff available in Ola and Mary’s team so we can visit Ola if she has to stay in hospital over Christmas, even though the second she is admitted we don’t get paid.  The Registered Manager returns to her desk, “You are not going to believe this” she shouts down the corridor…

“Dear Colleague,

Please find attached your PQM KPI SA Contract Compliance and Associated Spreadsheets 2025/26. (PQMKPISACCAS25/26) You’ll see that there are quite a lot of attachments this year.  The number of spreadsheets directly correlates to our lack of trust in your abilities. The deadline for submission is Jan 4th 5pm.

If you miss this deadline the consequences will be really, really bad.

Have a great Christmas!”

Obviously that is a bit extreme, and I don’t mean any disrespect to our friends in our local monitoring teams, I know they work their butts off.  It’s also a bit funny, and it’s also a bit true!

It’s monitoring season again! PIRs and KPIs.  We work in three local authorities who all ask slightly different things. 

One local authority wants a policy on Assistive Technology, if we’ve got one we get a tick. Get in the bag.  We have got one because we had to write one for the tender to get on the framework, so I blew the dust off it, reviewed it and resubmitted it, remembering to change the date on the top.  The two other authorities don’t ask for one so they can’t have it.  If the CQC ask for one, I’m covered.  Phew.

If I was a monitoring officer interested in assistive technology I’d ask someone like me to give them some examples of how we support people using assistive technology.  When I came to visit I’d ask to meet someone who uses it, just to check that it works for them and probably to check that I wasn’t lying.

We tell the Government every month via the Capacity Tracker, our sickness levels, staffing info and ‘voids’ Then we get asked to break that down per ‘service’ over a 12-month period.

Q. How many days sickness has there been at 26, Compliance Avenue in the last 12 months?

A. 9.

Q. How many agency hours have you used the last 12 months at 26, Compliance Avenue.

A. 0

Q. As an organisation, how many Safeguarding Initial Enquiries have you submitted in the last 12 months?

A.  You should know we submitted them to you

Q. Don’t be cheeky, that’s a different department.

A. Why don’t you pop down the corridor and ask them?

Q. If you continue with your cheek the consequences will be really, really bad.

A. Sorry, I’m forgetting myself, I won’t do it again…next question please.

Q. How many hours of support do you deliver weekly at 26, Compliance Avenue?

A. You should know, you commissi…sorry 143.5.

I’m beginning to think that by writing this, the consequences might be really, really bad.

I recently sat in on a national meeting with Commissioners, where I was sharing something we do that nobody commissions (Citizen Armies) the conversation got on to monitoring, particularly relating to Individual Service Funds.  “We need to ask better questions…” “we need to find out people’s experiences…” “we need to…”

“We ask that, we’ve got loads of information like that” I offered meekly – knowing that it is unlikely the information we offer would be given much credence because somewhere, on both sides, there is a lack of trust.

Here’s one more frustrating example – We have developed a brilliant programme of training here, putting the skills needed to support everyday citizenship on an equal footing with the skills needed to administer medication etc, much of it co-designed and co-delivered by people we support.  You would think that in such a heavily regulated and monitored system there would be a straightforward list of what staff needed to be trained in, detailing what is mandatory and telling us how frequently staff should staff be trained.  If you did think that you would be very, very wrong.

I started to write this blog in response to a consultation on the Supported Housing (Regulatory Oversight) Act 2023, where one of the unintended consequences may be that housing providers become responsible for the quality of support provided by organisations like us in Supported Living.

I was going to urge other providers to complete the consultation – which you can do here if you are quick (closes 15th May 2025);

https://www.gov.uk/government/consultations/supported-housing-regulation-consultation/supported-housing-regulation-consultation

Then I thought ‘oh sod it’ one more random monitoring exercise won’t make that much difference.  I’m not that convinced that any of this monitoring really impacts or improves the lives of people we support, and actually one of our jobs as providers is sometimes to shield people we support from the insanity of the system.

What I think would be really helpful is a grown-up conversation about how this monitoring and regulation could be done in a way which;

  • Improves people’s lives
  • Measures what matters to people and families, on their terms.
  • Builds trust
  • Saves money
  • Could the CQC be the only regulator?
  • Could local authorities work together to come up with some common questions to ensure contract compliance?
  • Could providers be more proactive in sharing their data?
  • Could we abandon commissioning altogether and give people the money and allow providers to be accountable to them? In partnership with local authorities? I’m sure that is possible (I know it is)

If anyone is up for that conversation, I’d be very interested in taking part, perhaps even leading it.

But we’d better be quick, because someone will co-produce some ‘I statements’ or have a new ‘charter’ or a new set of ‘commitments’ for us all to sign up to and that will be tagged onto the end of the framework documents.  Alongside all of the others.

If not – I’ve got plenty KPIs to be getting on with – Good Lives guided by the Keys to Citizenship.

Apologies to my local authority monitoring colleagues, you know that I only ever want to be part of the solution, I can’t help it if I am pompous and self-righteous.

If you want a conversation about this you can contact Tim and other members via info@LDEngland.org.uk