Scottish Government

2. The Development of the Audit and Accreditation Process

2.1 Introduction

This section looks at the development of the framework for the National Standards. It describes the background to the Standards and their content. It goes on to look at the accreditation programme and the process for undergoing audit and

re-accreditation. The section also looks at progress made to date (in terms of numbers of organisations audited / accredited); the changing context for the accreditation framework; and lessons from other accreditation systems working in the UK.

2.2 Background to the National Standards

Research undertaken in 1993 showed that the availability of advice services and the quality of advice provided across Scotland varied considerably. Responding to this, Scottish Homes ² established HomePoint within the organisation in 1993 to help improve the scope and quality of housing information and advice in Scotland. Over the years HomePoint has commissioned research, produced a range of publications and guides, and generally sought to support the housing advice sector across Scotland.

Early on, HomePoint - working collaboratively with the sector - started to quantify what constituted quality in housing advice provision. They developed a set of National Standards for Housing Information and Advice Providers that were launched in 1995. The Standards were developed to be able to "serve as a common quality framework for all information and advice services, whether they were located in local authorities, voluntary organisations which also provided other support services, housing associations or advice agencies providing generic advice" ³.

In 2000, a pilot was established to draw lessons from the implementation process that could inform and assist the wider adoption of the Standards across Scotland. Seventeen housing advice agencies participated in the pilot including local authorities, Registered Social Landlords ( RSLs) and voluntary organisations.

Based on the pilot, feedback from advice providers and changes to legislation, the Standards were revised and re launched in the same year. As well as having clear performance indicators for the delivery of advice services, the revised Standards also included comprehensive requirements for advisers in nineteen areas of housing law.

An evaluation of the pilot was published in 2004 ⁴. It examined the experiences that agencies had had in implementing the National Standards. The evaluation set out:

• the impact of the implementation process;
• lessons learned from the process;
• the value of HomePoint support; and
• the impact on the user.

The evaluation showed that the level of work and resources needed to implement the Standards are not to be underestimated. Some of the main findings were:

• many organisations found the process to be more difficult than first predicted and involved considerable extra work;
• several said that there had to be a corporate commitment to the Standards;
• implementation of the Standards was costly;
• nearly all pilot agencies said that without the support of HomePoint, they would not have been able to implement the Standards; and
• the difficulty in measuring the impact on service users was also highlighted.

But there was wide spread recognition of the benefits the implementation of the Standards had had upon services:

• once the implementation process began, many agencies realised that they already had many of the required policies and procedures in place - just not systematically gathered or reviewed;
• there was a general consensus that implementation of the Standards had a real impact upon the delivery of services;
• the user-focused approach of the Standards had encouraged several agencies to consider how to develop feedback and participatory processes;
• the emphasis on quality was seen to be particularly useful; and
• many organisations said that they had undergone a cultural change as part of the implementation process.

Between 2004 and the summer of 2006 HomePoint, in partnership with the then Scottish Executive Financial Inclusion Team, and supported by a national stakeholder steering group, started working towards expanding the Standards to cover a wider range of advice topics. Eighteen agencies who provided debt, money and welfare benefits advice volunteered to test the revised Standards, and were subsequently offered the opportunity to be audited if they were ready. In the event, around four of them proceeded. In November 2006, a new composite version of the Standards was launched - and included guidance for:

• debt counselling;
• housing information and advice;
• money advice; and
• welfare benefits information and advice services.

2.3 The National Standards

The National Standards framework is divided into three parts:

• Part I - the organisational Standards
• Part II - the topic specific Information and Advice Competencies
• Part III - the Good Practice Guidance - a self assessment checklist is provided separately to agencies electronically.

The organisational Standards are split into five key areas:

• General Management
• Planning of Services
• Accessibility and Customer Care
• Providing the Service
• Competencies for Staff and Agencies

Each of the Standards is followed by a set of indicators that highlight the measures required to evidence compliance with specific Standards. The Standards recognise that organisations provide a wide range of services that need to be able to be taken into account. Indicators - and the activities related to these - are therefore broken down into three categories (also known as types of intervention):

• Type I - Indicators relevant for those services that provide active information, sign-posting and explanation (Information Providers).
• Type II - Indicators that are used to show compliance from agencies that offer case work services.
• Type III - Indicators for those offering representation, advocacy and mediation at Tribunal or Court Action Level.

Agencies can be accredited at different 'types' in different areas of law.

2.4 The Development of Accreditation of the National Standards

During the consultation with advice agencies that led to the revised Standards in 2000, an encouraging number of agencies indicated that they were using the Standards as a guide to quality. At the same time, it also became clear that agencies wanted some recognition for this. Others also pointed out that they wanted a more formal assurance of the quality of services that they may be referring clients to. They therefore supported the introduction of accreditation.

HomePoint were also clear about the advantages that accreditation could bring in terms of building confidence and assurance for:

• Customers - who could be more confident about choosing an agency that provided quality of advice;
• Funders - who could be more assured of getting a high quality of service for their investment; and
• Providers - who could refer cases to other agencies and be more confident that they would be provided with quality of service.

Subsequently, HomePoint developed a process whereby information and advice agencies could be audited for accreditation against the National Standards. As a continuation of the pilot that began in 2000, a number of housing information and advice agencies piloted the audit process between 2003 and 2005. And following the 2005 pilot that tested the Standards' ability to extend to the money advice and welfare rights sector, a number of agencies from these sectors went through the same audit process. Following the evaluation of the pilot and the audit process, an official accreditation process was launched in 2005.

To deliver the audit and award accreditation, HomePoint appointed an external contractor - Michael Bell Associates ( MBA) - following a competitive tendering process.

2.5 National Standards for Information and Advice Providers Panel

In 2005 the National Standards for Information and Advice Providers Panel - known as the National Standards Panel - was established by HomePoint, as the appointment of the external contractor was being concluded.

The current membership of the Panel includes representatives of:

• Scottish Consumer Council;
• Citizens Advice Scotland;
• Money Advice Scotland;
• Scottish Federation of Housing Associations;
• Advocate (housing law);
• Scottish Legal Aid Board;
• Scottish Association of Law Centres;
• Shelter (Scotland); and
• Scottish Government.

In addition, a representative of the Scottish Housing Regulator attends as an adviser and HomePoint staff provide secretarial services.

• Its remit includes:
• monitoring the accreditation process by reviewing reports from the accreditation contractor;
• recommending any changes to the Standards to HomePoint following evidence from the accreditation contractor;
• being the final arbiter in any appeals arising from decisions made by the accreditation contractor on the awarding or withholding of certificates;
• publishing an annual report;
• advising on the strategic direction of the audit process; and
• agreeing any changes to the panel membership.

The Standards Panel has no responsibility for monitoring the implementation of the contract to provide audit services. Nor are they the accreditation body, a responsibility that lies with the contractor appointed to undertake the programme of audits.

An early decision the Panel took was to ensure that all audit reports were publicly available - whether or not the organisation was successful in achieving accreditation.

2.6 The Accreditation Programme

All agencies that apply for accreditation must be ready to undergo the audit. The self assessment checklist provided to accompany the Standards manual is used by agencies to do an initial assessment of their compliance with the Standards. The checklist is then used as the electronic record of progress, agencies update it as each gap or weakness in compliance is addressed. When they are satisfied that they are compliant, and HomePoint offer assistance to agencies throughout this stage, the self-assessment checklist is used as part of the application for audit.

Organisations are advised by HomePoint that they should only apply for accreditation when they themselves have judged that they have implemented all relevant aspects of the National Standards.

There are 15 areas of housing law and 32 money-related areas of law that can be accredited. Agencies are free to choose which areas of law they apply to be accredited for - depending on the services that they offer - and the type of accreditation for each.

Although adviser competencies are tested in the audit process, accreditation of the Standards is awarded to services rather than individual advisers. What sets the National Standards apart from many other quality assurance frameworks is its Quality of Advice element.

2.6.1 The Audit Process

The audit process is divided into several stages:

Agency Application

An application is submitted that details for example, remit of services, areas of law, case breakdown and the identification of members of staff. A number of key documents are also submitted. All information is entered into the audit service database. In reviewing the processes, the self assessment checklist has been combined with the audit application form. This has resulted in less paperwork, making it easier to apply for accreditation.

The Quality of Advice Audit Visit

The next stage includes a visit to the agency. This stage focuses on quality of advice and outcomes for services users. This part of the process is undertaken by peer assessors who are practitioners in the relevant areas of law. They receive training by MBA and are accredited to SQA Level 9, the equivalent of an ordinary degree. There are around eighteen peer assessors who are employed by MBA on a sessional basis. The visit normally involves two quality of advice auditors who are each on site for two days. It entails:

• interviews with staff including discussion of case scenarios;
• assessment of a sample of case files;
• observation of advice sessions; and
• reviewing key documents.

The Process Audit Visit

This part of the audit looks at the organisational arrangements that agencies have in place. The purpose of the audit is to review evidence of documented process and procedures. The Process audit is split into two parts:

• A desktop audit that is undertaken when the initial application pack is received;
• An on-site visit involving both a review of key documentation and interviews with staff to assess the understanding and application of procedures. Areas for scrutiny take into account any feedback received from the Quality of Advice audit and any issues highlighted from the desktop audit.

This is undertaken by the consultant's own staff.

Audit Reporting

The findings are then gathered into a full audit report. The organisation is given the opportunity to comment on any factual mistakes. The final audit report is then produced. It will indicate the results of the audit. Agencies will either be:

• immediately accredited;
• not accredited; or will receive a
• Not Yet Fully Compliant status ⁵. (This means that the agency has been very close to receiving full accreditation and will be given up to six months to meet any further requirements).

2.6.2 Passporting

The Standards recognise that many services may comply with other quality frameworks. Where the service complies with other appropriate standards, it can use evidence of this to minimise any duplication of work. At the moment, the accreditation process that is recognised by the Standards is that of the Citizens Advice Scotland's membership scheme for Citizens Advice Bureaux. This 'passports' Bureaux through the organisational process audit.

2.6.3 Interim validation

Eighteen months after the date of the final audit report, accredited agencies are required to undergo an interim validation process. A paper-based self-validation is submitted to the auditor. If this is satisfactory, a mystery shopping exercise may be completed where it is appropriate. Where this is not appropriate, for example, in an organisation serving only its own tenants, or does not generate sufficient confidence in the agency's compliance with the Standards, a limited audit will take place.

An organisation that passes the interim validation will have its certification accreditation extended. If any problems have been highlighted, selective parts of the audit will be carried out. These will then be assessed and the organisation will either receive an immediate extension; a conditional extension; or will have its certification accreditation removed. If the changes to be made are substantial or if an agency has undergone important changes, it may be referred to undergo the full audit programme.

2.6.4 Re-accreditation

Currently, all agencies need to re-apply for accreditation every three years. They are required to undergo a similar audit process as with initial accreditation.

2.6.5 The Role of HomePoint

HomePoint provides a range of direct support and resources for agencies that are aiming to implement the National Standards. This currently includes:

• offering help in interpreting the Standards;
• giving advice in planning the implementation of the Standards;
• delivering a seminar programme (relating to the organisational Process Standards);
• facilitating peer support groups to ensure sharing of good practice;
• guidance to applicants on preparing for audit and the audit process;
• access to the Standards Training Programme for Housing Advisers;
• holding pre-application seminars; and
• referring the agency to the accreditation service contractor when they are ready for audit.

HomePoint has also developed a set of practical resources to be used when implementing the Standards. These include:

• a template for planning implementation, such as identifying key people;
• templates for setting out service remit, staffing and areas of advice covered;
• guidance to understand the links between the Standards; and
• a self-assessment pack to assist agencies to identify areas for improvement.

A series of publications are also produced, including a quarterly newsletter. On site visits and ad hoc advice is provided as required.

Since the National Standards were first developed, HomePoint has adapted the support it provides in response to feedback and its own experience. Some of the views expressed by a number of our case study organisations reflect the kind of feedback that has led to support arrangements evolving.

Shelter currently delivers a training programme for agencies seeking accreditation for areas of housing law. Training on topics including money advice and welfare benefits is delivered by MATRICS, the Child Poverty Action Group, the Legal Services Agency and Rights Advice Scotland.

2.6.6 Paying for Audit

When the audit process was initially piloted, the full cost was met by HomePoint and agencies were not expected to make any direct financial contribution. However, following the pilot, Communities Scotland took a decision that agencies would have to contribute to the cost of the audit. This is based on a sliding scale, dependent on the number of areas of law being audited and the size of the organisation. A lower fee is payable by CABx in recognition of the fact that the findings of their membership review provided evidence of compliance with the organisational standards. A separate process audit is therefore not required. Accredited agencies have to pay for interim validations and re-accreditation.

The Scottish Government currently subsidises the economic cost of audit by meeting half the cost and paying for the core costs of HomePoint support.

The introduction of a charge during a financial year was the source of concern for a number of agencies. Some had anticipated undergoing audit but had not budgeted for the cost. Others that had participated in the pilot had not anticipated that they would be expected to pay for interim validation and re-accreditation. Charging is a significant factor that is perceived as contributing to the relatively low take-up of accreditation at the outset.

Subsequently, support towards the cost of audit has been provided from elsewhere. CAS secured funding to meet half the remaining cost for CABx during 2007/08. Glasgow City Council has been offering to meet the costs for money advice organisations to be audited during 2007/08. Dundee City Council had also offered to meet these costs but, due to low take up, is paying for training and support to money advice organisations in the hope that this will lead to them becoming ready for audit in due course. In all these cases they hope to be able to extend this arrangement in 2008/09, dependent on the availability of funds.

All have found that the take up of funding has not been as great as anticipated. However, this may simply be a reflection of the time it takes an organisation to prepare for audit from making an initial commitment.

2.6.7 Progress to Date

To date a total of 29 agencies have been through the audit process. Of these:

• twenty two agencies have received accreditation or 'Not Yet Fully Compliant' accreditation; and
• seven agencies have failed accreditation.

The majority of organisations achieving accreditation are in the voluntary sector.

In terms of re-accreditation:

• four agencies have undergone interim validation; and
• one organisation has been through full re-accreditation.

There are currently 15 agencies accredited to the National Standards. Of these:

• three are local authorities;
• eight are voluntary organisations; and
• four are CABx.

Six organisations who were accredited are no longer so. Of these, one is a local authority, one is a housing association, two are CABx and two are voluntary organisations.

Three of the organisations had their accreditation withdrawn after merging with other organisations. One local authority also had its accreditation suspended due to significant internal reorganisation. A CAB refused to pay the cost of an interim validation and a housing association withdrew from the process.

At the time of undertaking fieldwork HomePoint records suggested a total of 21 organisations were working towards audit. However, during our consultations we spoke to eight of these organisations, of which only two appeared to have plans to undergo audit within the next 12 months. We also spoke to a number of others that may seek accreditation in the coming year. There are currently 15 organisations that have applied to be audited before the end of March 2008. These include five local authority services; three CABx and a variety of voluntary organisations. More recent indications from HomePoint suggest that around another 15 agencies will apply before the end of October 2008.

The figures demonstrate the difficulty of predicting with any certainty what the rate of uptake from new organisations seeking accreditation will be. However, what is clear is that the level of commitment can change. Attendance at training courses or contact with HomePoint staff is not, in itself, an accurate indication of the level of interest at any time.

2.7 The Changing Context

The context in which the information and advice sector operates continues to change since the National Standards were first published in 1995. At a national level there have been - or potentially will be - a number of drivers that influence the extent to which accreditation is taken up by agencies.

The Housing Act (2001) placed new duties on local authorities to provide sound housing advice. Specifically, Section 2 of the Act required all local authorities to ensure that information and advice relating to the prevention of homelessness and the services available to support homeless households was made available free of charge in their area. Scottish Executive guidance that followed the Act stated that, "whilst there is no single model for the delivery of advice and information services, local authorities should ensure provision meets the standards set out in HomePoint's Scottish National Standards for Housing Information and Advice Services" ⁶.

Local authorities and RSLs are expected to meet Performance Standards ⁷. The current standards published in 2006 include a requirement that social landlords should "provide or secure effective information and advice, in line with the National Standards for Housing Information and Advice Services".

The introduction of the Debt Arrangement Scheme in 2004 (see section 2.7.3) has resulted in discussions between the money advice sector, the Scottish Government and HomePoint regarding accreditation to the National Standards.

Whilst the Scottish Government had previously indicated a general expectation that agencies providing money and housing advice and receiving public funding should be working towards complying with the Standards, current proposals go further. These propose that, from early 2008, money advisers applying for certification under the Debt Arrangement Scheme will need to be working in agencies that can demonstrate that they are working towards compliance with the Standards. The Scottish Government has indicated that it expects those agencies to be accredited against the Standards in future, but has yet to conclude what the timescale for this will be.

Following consultation on publicly funded legal advice in Scotland ⁸, the Legal Profession and Legal Aid (Scotland) Act 2007 was enacted. This includes amendments to the Legal Aid (Scotland) Act 1986 which introduces additional powers for the Scottish Legal Aid Board ( SLAB). These powers enable SLAB to support the provision of publicly funded legal advice by a range of methods. These include grant funding provision by non-solicitors and the extension of the Advice and Assistance Scheme to cover work carried out by advice organisations. This extension would apply in certain circumstances which would be prescribed by the Scottish Government in regulations.

The Act establishes the concept of a Register of Advice Organisations in relation to the provisions for the extension of Advice and Assistance. Initial work undertaken by SLAB included the drafting of an Adviser Code as required by the Act. The Code would apply to all organisations wishing to register with SLAB to be paid for work under the Advice and Assistance Scheme. The draft Adviser Code was developed with a risk-based approach in mind, including an intention to explore ways of recognising achievement of other sets of quality standards. This would include recognition for achieving accreditation against the National Standards where appropriate. The relevant provisions in the Act have been commenced, but implementation is dependent upon further steps being taken by the Scottish Government. It is currently not clear when these provisions are likely to be taken forward.

The publication of the Independent Review of Regulation, Audit, Inspection and Complaints Handling of Public Services in Scotland (The Crerar Review) published in 2007, is intended to lead to reduce the burden of regulation through a greater emphasis on self-assessment rather than external scrutiny in the future.

More recently, the Scottish Government and COSLA have entered into a concordat for the three year period 2008/09 to 2010/11 which includes a move to a Single Outcome Agreement ( SOA) with every local authority in Scotland, based on national outcomes and indicators. As part of this package, the Government has committed itself to annually reducing the proportion of local authority funding that is ring fenced. This potentially offers local authorities greater flexibility in determining their own priorities based on local needs. However, one consequence is the uncertainty this creates as to whether it is a Scottish Government or local authority responsibility to support organisations to meet some or all of the costs associated with National Standards accreditation.

As the national context is changing, local authorities have, to date, been responding in different ways. For instance, Glasgow City Council is moving to contract money advice services from the voluntary sector, for which National Standards accreditation will be a pre-requisite. It recommends housing advice organisations to become accredited. But, to date, it has taken no corporate decision with regard to accreditation and the advice services it directly provides.

Edinburgh City Council's Housing Advice Strategy ⁹ recommends that the National Standards are adopted as the quality assurance framework for delivery of housing advice in the City. All partner agencies participating in the Housing Advice network are required to work "towards adopting and implementing the Standards". However, no timescales have been agreed for achieving this and no mechanisms are in place to monitor progress. Meantime, the Council has achieved accreditation for a number of the advice services it provides.

Some other local authorities are silent on the issue of the National Standards in terms of their services and voluntary organisations that they fund.

2.8 Examples of Accreditation Schemes

There are numerous quality assurance schemes covering a wide range of sectors and services. We have looked more closely at five of these. All have been specifically developed to improve the provision of information and advice.

2.8.1 CLS Quality Mark (England and Wales)

In an attempt to improve access to civil legal information and advice, the government launched a major initiative - the Community Legal Service ( CLS) - in April 2000. Covering England and Wales, the initiative was set up as a network of organisations to provide and fund civil legal services. The aim of the CLS is to ensure public access to quality information, advice and legal services through local networks of services. The development of partnership working was also intended to make sure that customers' needs were being met. The CLS brings together CABx, legal aid solicitors, law centres and local authority networks.

To be able to assure the quality of information and advice provided through these networks, a quality certification scheme - Quality Mark - was developed. All members of the CLS are required to reach the Quality Mark standard. Organisations do not currently have to pay when they apply for the Quality Mark. The scheme is fully funded by the Legal Services Commission which is the accrediting body. It can be achieved in three different categories, depending on the services provided:

• Information (Self-Help Information or Assisted Information)
• General Help (General Help or General help with case work)
• Specialist Help.

The Quality Mark is underpinned by seven principles:

• Access to service
• Seamless service
• Running the organisation
• People management
• Running the service
• Meeting client's needs
• Commitment to quality.

Organisations, who have applied for the Quality Mark at the Information level, only go through a desktop audit. The organisation submits the required documentation to be checked by an auditor. If the organisation passes the desk top audit and is awarded the Quality Mark it will continue to be audited on a random basis.

Those who apply for the General Help or Specialist levels will also be assessed through a desk top audit. If successful, this will be followed by a preliminary audit visit, during which the organisation will be assessed against the Standards. This is to ensure that the organisation is either meeting the Standards or very nearly meeting them. If any changes are needed, a credible action plan needs to be presented and implemented within 28 days. At this stage, the organisation will be provisionally awarded the Quality Mark that will allow it to use the CLS logo. One year later, an audit visit will be carried out. This visit intends to establish whether all the Standards are now being met. If the organisation fully complies, it is awarded the Quality Mark in full and will then be audited annually.

Quality Mark has quickly become the industry standard in England and Wales. However, during 2007/08 the CLS decided it would only offer audits to organisations it currently funds as a result of the ongoing cost. Discussions are currently underway to find another mechanism for providing audits.

Like other accreditation systems, the CLS Quality Mark is intended to reassure the public and other providers of the quality of services provided by an organisation. There may also be benefits in terms of funding, where funders can be assured that they are investing in quality services.

The limitations of the CLS Quality Mark as a quality assurance scheme have, however, been raised by stakeholders in the advice sector. The fundamental issues relate to measuring quality of advice - or indeed lack of. There are concerns that the Quality Mark is unable to measure quality of advice and whether it - as a quality assurance framework - actually improves quality.

The criticisms that have been raised are explained by the processes that underpin the accreditation scheme:

• There is an over reliance on input that focuses on organisational management, such as statement of intentions and policies and procedures. Neither of these directly measure quality of advice. And the assumptions that good organisational arrangements lead to good advice have been questioned.
• The Quality Mark has also been said to be excessively bureaucratic for organisations that go through the audit process. The application process has been seen to be particularly time consuming for staff. This poses a specific problem for smaller community-based organisations that may struggle to find the time and resources to put an application together. Fears of funding cuts, however, are forcing these organisations to apply.

Instead, some members of the advice sector have argued for a shift towards the monitoring of outputs (the quality of advice and support provided) and outcomes (the end results). And by putting in place effective tools for measuring and improving quality of advice, several of the perceived shortcomings could be addressed. It would be possible to introduce adviser competencies into the framework. This is a tool that pro-actively encourages the development of individual adviser skills before the advice is given. And many people involved in quality work agree that peer review is the most accurate and best mechanism to evaluate casework performance and quality of advice.

¹⁰

The Legal Aid Board are currently planning to make peer review an integral part of the accreditation process. So far, however, this only involved the Specialist Quality Mark and it remains to be seen whether there will be a move towards peer review for all Quality Mark levels.

There is also the risk that by adding on additional layers without simplifying other processes the accreditation process will become too cumbersome for organisations - with less time spent on giving advice.

The application and assessment process of CLS Quality Mark are currently being reviewed and the outcomes of the review will be made available in early 2008.

2.8.2 Quality Mark (Scotland)

Following the publication of the 'Modern Markets: Confident Consumers' White Paper which highlighted inconsistencies in the provision of consumer advice and information, the Department for Trade and Industry ( DTI) commissioned the Local Authorities Co-ordinator of Regulatory Services ( LACORS) to develop a Consumer Support Network ( CSN) initiative in 1999. Consumer Support Networks were intended to improve the quality of consumer advice across the UK, through local Trading Standards, CABx and other independent advice agencies coming together to form networks.

The DTI asked LACORS to develop a Quality Mark standard that set out standards of consumer information and advice provision to which all CSN members had to adhere. At the same time, some means of monitoring the quality of information and advice was needed. And the 'Quality Mark Scotland' scheme was therefore developed in 2000. To ensure consistency across the UK, the framework was based on the CLS Quality Mark.

To build on the experience of the CLS Quality Mark, consultations were held with users of the scheme, with the aim of avoiding pitfalls that had become apparent in the CLS scheme. Subsequently, some changes were made to make it simpler to understand and implement. The Standards were designed to make sure that an organisation is well run and that it has its own quality control procedures in place. The scheme covers all agencies that provide legal consumer information and advice - from libraries to consumer advice agencies. To do this, there are four levels to each Standard.

As with the CLS Quality Mark scheme, the Quality Mark (Scotland) was developed to be free of charge for advice agencies and was funded wholly by the DTI. Estimated costs for delivering the scheme were around £40,000 each year. It was governed by a Committee made up by representatives of relevant bodies.

Certification was offered for a period of three years with ongoing inspection visits in between audits. For each audit, three auditors would be contracted. Auditors would be specialists in consumer advice and would have received training in auditing techniques. Each agency would also get two days free consultancy services as an incentive for organisations to work towards accreditation. Upon a satisfactory audit, auditors would recommend certification which would be decided by a review panel.

In 2007, funding for the scheme was withdrawn. This led to certification of further organisations being placed on hold. By then, 58 agencies had been awarded accreditation.

In an attempt to save it, the Society of Chief Officers of Trading Standards in Scotland ( SCOTSS) have recently taken over the governance of the Quality Mark (Scotland) scheme and are currently reviewing its future. One possibility it is looking at is providing a joint inter-authority auditing process whereby local authorities would peer assess other local authorities. This would keep the scheme free of charge but would exclude all other voluntary advice organisations - focusing on Trading Standards advice services only.

2.8.3 Citizens Advice Scotland ( CAS) Membership Scheme

Citizens Advice Scotland ( CAS) and its member bureaux ( CABx) offer free, confidential and independent advice to any person. To become a member of CAS, a bureau has to comply with quality standards set by CAS. Compliance is established through an audit process.

The current membership scheme became operational in April 2002. This scheme was aimed to be more robust than previous schemes. CAS wanted to introduce peer assessment into the audit process. There are currently four peer review assessors. Two are paid by CAS to undertake assessments and two carry out the assessments on a voluntary basis. The assessment process is verified by a panel made up of appointed experienced advisers from CABx and has an independent legally qualified Chair who is a member of the Writers to Her Majesty's Signet Society ( WS).

The process is governed by a Membership Committee - made up of elected people from member bureaux. Before the current scheme was introduced it had to be approved by the Membership Committee and then by CAB members at an AGM.

The membership scheme is divided into two parts - organisational and quality of advice. In recent years, CAS has also introduced an adviser competency scheme, that each CAB is responsible for delivering. This includes providing training for advisers and making sure that each adviser is assessed according to the scheme.

As part of the Quality of Advice audit, each CAB is asked to show that they have put the adviser competency scheme in place and that advisers are trained and assessed accordingly.

There are five criteria that CABx have to comply with:

• diagnosis and information gathering;
• information given to client and options discussed;
• overall effectiveness;
• case recording and management; and
• recording information sources.

To comply with the standards, CABx have to achieve a minimum of 60 per cent compliance against each criteria and 80 per cent compliance overall. These proportions have already been increased twice since the scheme was introduced - as CAS is keen to encourage bureaux to continuously improve.

If a bureau fails the audit, they are responsible for developing a corrective action plan that is submitted to the Membership Committee. The Committee decide whether they think the plan is achievable - and agree on the timescales it should be achieved by. Each bureau then undergoes a verification audit.

CABx are re-audited every three years. All are required to submit a portfolio of evidence. The way that the organisational part of the assessment is carried out depends on any changes within an organisation. All are required to submit a portfolio of evidence, but it is possible to re-submit a portfolio from the last accreditation if the organisation deems it has undergone no or few changes. In such circumstances, the bureau will have to submit details regarding policy reviews and evidence that policies have been kept up to date. It is also possible for CABx to submit new portfolios. All bureaux are also required to submit details about current policies and documents such as accounts, business plans and minutes from meetings. In terms of the Quality of Advice element - all CABx have to undergo this element of the audit process every three years.

At the moment, the system is not set up to take into consideration differences in the type of services that are offered by bureaux. Time spent on the audit visits, however, will be reflected in the size of the bureau.

Currently, CABx are 'passported' through parts of the Scottish National Standards

for Information and Advice. CAS worked closely with HomePoint and their consultant auditors when they revised their standards and the membership scheme. At the onset CAS felt that their standards met The National Standards and had hoped that CABx would receive full 'passporting'. However, they subsequently recognised that their quality of advice assessment did not go to the same level as the quality of advice assessment conducted for HomePoint by the accreditation service contractors - and are therefore required to undergo the full quality of advice audit. However, CABx 'passport' through the process audit visit. They are required, however, to submit written documentation relating to case recording and case management. This is because it relates to quality of advice and it helps the quality of advice auditors understand CAB policy and procedures.

To date, no CABx have applied for Type I accreditation under the National Standards. This is because CABx offer slightly more information and advice than that level suggests - most would fit between Type I and Type II.

CAS recognises that some CABx offer more specialised services, such as in court representation and would like to incorporate these differences into their membership scheme. It is currently in the process of piloting a more flexible scheme. This includes a specialist add-on to the assessment process where CABx offer more specialised information and advice. It is currently proposed that the specialised areas will be within welfare, benefits and housing. CAS is keen to make sure that this add-on is in line with the National Standards and is hoping that they may result in full 'passporting' for some CABx.

2.8.4 The Fife Rights Forum

The Fife Rights Forum is an umbrella body for advice and rights agencies operating in Fife. Their aim is to:

• help improve the quality of advice services;
• promote co-operation between agencies; and
• increase community involvement across the sector.

The Forum was set up in 2001 by a number of voluntary and statutory services and is funded by Fife Council. As part of a best value review in 2002, the Council felt that the Forum could become more pro-active in the way it supported advice and rights agencies. In particular, the Council felt that agencies should be able to confidently refer customers to other agencies.

Subsequently, the Forum developed a quality standards framework in 2002 for all organisations offering rights advice and information. As the name suggests, the Forum targets agencies based in Fife - and assessment is offered free of charge for all agencies operating here.

In developing the standards, the Forum looked at other quality assurance frameworks that were currently operating. It incorporated those elements it felt were appropriate.

The award system was piloted by a number of money advice agencies. In 2003-2004, the Standards were updated and another pilot was carried out. The Forum has recently developed a third version of their framework to minimise crossover between the Standards.

There are thirteen standards that have been designed for both the statutory and voluntary sectors. They assess four criteria:

• organisational development;
• accountability;
• best practice casework; and
• child protection and rights.

Each standard has three levels and agencies must achieve at least level two to become awarded. The levels are not linked to the type of service that the agency provides, but rather to the extent that the standard has been implemented. This makes the standards more flexible. The certification is awarded for a period of three years when re-assessment is required.

The assessment is broken down into two parts. First, the agency seeking the award self-assesses against the thirteen standards. To support this, they put together a portfolio of evidence. Secondly, two assessors from external organisations look at the evidence and make an on site visit. They then pass the assessment on to a Board of Certification, consisting of representatives of the advice sector, who review the assessment and recommends the award. In addition, to ensure that assessments are consistent between individual assessors, the Forum has appointed an independent external verifier that examines a sample of assessments made. The accreditation process can take up to nine months.

The assessment process also takes into account other quality standards that an agency may have achieved. To try to avoid duplication of work during the assessment, they have developed a 'passporting' system - although there are no mutual agreements with other quality assurance systems.

The assessment process relies on a pool of voluntary peer assessors. Peer assessors are recruited from agencies that go through the assessment. Each agency that is awarded the Quality Standards must volunteer one member of staff to become an assessor. Each new assessor receives a half day training on how to carry out the assessment.

The standards are intentionally less rigorous than some other quality assurance frameworks. They were developed and designed in such a way that they would help agencies become better and possibly prepare them (build capacity) for larger, formal audits. They also take account of what voluntary peer assessors are able to cope with. And they recognise that many smaller agencies are unable to fund the costs associated with some other quality frameworks. The fact that the assessment is free seems to have encouraged small organisations to apply.

The Forum has experienced an increase in the number of agencies that have applied for the award. And as more and more organisations go through the process, the capacity to carry out more increases as the pool of assessors grows. To date eight agencies in Fife have obtained Fife Rights Forum Quality Standards and about eight more are currently being assessed. They have had some enquiries from other local authorities and are reviewing whether it would be possible to license the standards for use elsewhere.

Despite having the Fife Rights Forum accreditation system in place, a number of agencies have seen it as a stepping stone to National Standards accreditation. This is generally because the National Standards are perceived to be more challenging and comprehensive. There is also a view that the link between the National Standards and accreditation will strengthen over time. To date three organisations have sought and achieved accreditation to the National Standards (two have which have subsequently merged).

2.8.5 The Debt Arrangement Scheme and MATRICS

Our final case study example is the only where accreditation applies to the individual rather than the organisation.

The Debt Arrangement Scheme ( DAS) was introduced by the Scottish Executive in 2004. It is a scheme that offers protection from court action and personal bankruptcy to individuals with multiple debts. Following agreement of a single regular payment to an approved payments adviser, there is the opportunity to freeze interest, fees and related charges.

Because DAS effectively restricts the rights of creditors, there is a strong public interest in how the scheme operates. Legislation therefore specifies that money advisers who operate under DAS have to be regulated. There is a requirement for money advisers to undergo a certification process to become approved under DAS. The certification process is carried out by MATRICS (Money Advice Training, Resources, Information and Consultancy Services) - a partnership project between Citizens Advice Scotland ( CAS) and Money Advice Scotland ( MAS). The project receives Government funding. As well as undertaking assessment of competence and certification MATRICS provides training and training support.

In most cases, there is a requirement that advisers seeking DAS accreditation attend an approved training course. MATRICS provides this training for MAS and CAS members, and is responsible for approving courses provided to others.

Approved Money Advisers are regulated by the DAS Administrator - the Scottish Government. To become an approved adviser, an individual firstly has to be certified that they can provide the required standard of advice through a practical demonstration of competences. This includes six casework reviews. The assessment is undertaken by a panel of peer assessors. Secondly, they must be approved by the DAS Administrator as a fit and proper person to undertake the work in terms of legislative requirements.

Assessors are appointed and certified by MATRICS. At the moment, around nine people from CAS and MAS have become qualified assessors. The Scottish Government intends to establish a Verification Panel to help ensure consistency between assessors.

When an adviser passes the certification, the DAS Administrator approves the adviser. MATRICS conducts spot checks on three cases every six months to ensure that the quality is consistent. Renewal of DAS approval is required every three years when advisers need to submit a further six cases to MATRICS for review.

Currently there are around 88 approved DAS advisers located in 42 organisations across Scotland.

Money advice agencies that employ DAS money advisers are expected to follow the MATRICS code of good practice which is referred to in the National Standards. The code of good practice incorporates standards for agencies and advisers in relation to DAS, some of which are more specific than the National Standards. The National Standards are consequently being amended to fully replace the Code of Practice.

However, as described in section 2.7, the Scottish Government has recently indicated that it expects money advisers applying for accreditation to be working in agencies working towards compliance with the Standards. And a requirement that agencies must be accredited against the Standards will be introduced at some point in the future.

2.8.6 Key lessons

Governance

Each of the schemes have developed their own governance arrangements to meet its objectives. In the case of three of the frameworks, service providers and representatives of the sector are involved in the accreditation body - whilst ensuring that this does not undermine the audit process. In the case of the CLS Quality Mark, service provider involvement is currently being considered at a policy level.

The advantage that has resulted from service providers is that those seeking or achieving accreditation generally feel a sense of ownership of the Standards and audit process. This is arguably something that has not been achieved with the CLS Quality Mark.

Costs

Cost is likely to have an impact on the ability and willingness of organisations to undergo an accreditation process - unless there are other drivers such as a link between accreditation and funding. Services will balance costs with potential gains. This balance needs to be carefully considered. All of the accreditation schemes we have looked at offer the audit and accreditation process free of charge. And an element of training to support accreditation is also provided at no cost.

Flexibility

The extent to which accreditation bodies are able to offer flexibility in the audit process and take account of other quality management frameworks is relatively limited.

Where accreditation models have been established to allow agencies to be accredited at different levels according to the services that they offer, different approaches to audit have been established. But beyond this, the size or nature of services delivered is generally only considered on an informal basis.

It is not uncommon for agencies to be accredited with other assurance frameworks. Of our case studies, Fife Rights Forum is the only one able to offer any form of 'passporting'. However, this Standard has been developed to be less challenging than others. But CAS members are able to 'passport' part of the National Standards accreditation.

Adviser and Agency Accreditation

Of our case studies, DAS is the only scheme that certifies the advisers as opposed to the organisation. However, any agency that employs a DAS approved adviser is required to give the adviser a working environment that is flexible to accommodate the extra resources spent around the DAS scheme.

There are positive aspects in both systems. By accrediting an adviser, it is easier to ensure consistency. Where an agency is accredited, high staff turnover may have an impact upon the continued implementation of the Standards and necessitates a more rigorous re-accreditation process. On the other hand, the audit process that an agency undergoes may be good for team-building and may result in a culture change for the way the organisation works. Approved money advisers under DAS depend on an un-regulated environment to support them in offering these services, although this will change in the future Fife Rights Forum is currently thinking about how they could incorporate an adviser certification element.

Measuring quality of advice

All the quality assurance systems that accredit organisations involve an element of measuring organisational management. However, the CAS scheme is the only one that specifically addresses quality of advice - which has resulted in CABx being able to achieve a degree of 'passporting' when they undergo National Standards accreditation.

2.9 Summary

The National Standards and development of Accreditation

• Since its establishment in 1993 HomePoint has been working to improve the quality of information and advice services in Scotland. A key feature of this activity has been the development of National Standards for Information and Advice Providers, together with an audit and accreditation process.
• The Standards have evolved since first published and today include: debt counselling; housing information and advice; money advice; and welfare benefits information and advice services.
• The Standards look at competencies across three types of intervention:

• Type I - services that provide active information, sign-posting and explanation (Information Providers)
• Type II - agencies that offer case services
• Type III - services offering representation, advocacy and mediation at Tribunal or Court Action Level.

• Following a pilot the official accreditation process was launched in 2005. An external contractor was appointed to deliver the audit and award accreditation.
• The National Standards are overseen by the multi-agency National Standards Panel although the Panel has no responsibility for monitoring the implementation of the contract to provide audit services. Nor are they the accreditation body, a responsibility that lies with the contractor appointed to undertake the programme of audits.

The Accreditation Programme

• There are 15 areas of housing law and 32 money-related areas of law that can be accredited. Agencies are free to choose which areas they apply for - depending on the services that they offer - and the level that they wish to seek accreditation at. Accreditation of the Standards is awarded to services rather than individual advisers.
• In preparation for audit, organisations assess their compliance with the Standards against a self-assessment checklist. The audit process then involves a Quality of Advice Audit undertaken by peer auditors and a Process Audit undertaken by the contractor's own staff.
• Accredited agencies need to re-apply for accreditation after three years and they are required to undergo an interim validation after 18 months.
• HomePoint provides a range of direct support and resources for agencies that are aiming to implement the National Standards. A training programme for agencies seeking accreditation is delivered by a range of agencies including Shelter and MATRICS.
• Advice agencies have to contribute to the cost of the audit. This is based on a sliding scale, dependent on the number of areas of law being audited and the size of the organisation. Accredited agencies have to pay for interim validations and re-accreditation. Charging is a significant factor that is perceived as contributing to the relatively low take-up of accreditation at the outset.
• Subsequently, support towards the cost of audit has been provided from other agencies including CAS and some local authorities. All have found that the take up of funding has not been as great as anticipated.
• To date, a total of 29 agencies have been through the audit process. There are currently 15 agencies accredited to the National Standards.

Context

• The context in which the information and advice sector operates continues to change and there have been a number of drivers at a national level which will potentially influence the level of uptake of accreditation. These drivers include: the Housing Act (2001) which placed new duties on local authorities to provide sound housing advice; performance standards for social landlords and homelessness functions; the introduction of the Debt Arrangement Scheme; and the introduction of new powers to the Scottish Legal Aid Board ( SLAB) which allow the provision of legal advice by non-solicitors. In addition, the 2007 Crerar Review promotes a reduction in the burden of regulation through a greater emphasis on self-assessment rather than external scrutiny.
• The Scottish Government's move towards establishing a Single Outcome Agreement ( SOA) with every local authority will reduce the proportion of local authority funding that is ring-fenced. One consequence is uncertainty as to whether it is a Scottish Government or local authority responsibility to support organisations to meet some or all of the costs associated with National Standards accreditation.

Lessons from other accreditation schemes

• We looked at five quality assurance schemes operating in Scotland and England to establish any lessons. These included:

• Service provider involvement in governance structures gives those seeking accreditation a sense of ownership;
• Cost will impact on the ability and willingness of organisations to undergo the accreditation process unless there are other drivers;
• The extent to which accreditation bodies are able to offer flexibility in the audit process and take account of other quality management frameworks is relatively limited;
• There are positive aspects to accreditation of either an adviser or an agency. While the former may be better for consistency, the latter has advantages in terms of team-building and cultural change;
• Few schemes incorporate tools to measure quality of advice - this is a perceived strength of National Standards accreditation; and
• Some schemes are designed to act as a platform for continuous improvement whilst others are seen as an absolute.