Risk Management Log RESTRICTED TO BOARD MEMBERS AND NOT FOR ONWARD CIRCULATION. Timing Risk Owner Mitigating Actions

Transcription

1 Impact <programme/project name> Management Log OFFICIAL - SENSITIVE Version Control Scoring Timing 5 Overall Rating A A/R R R R Version v.0.2 Author Martin Caunt 16/03/2015 Imminent = within 3 months [Yellow] 1 = Rare 2 = Unlikely <10% 10% -33% Medium Term = within 6 Long Term = 6 months + months [Beige] [Light Blue] hood 3 = Possible 4 = Likely 5 = Almost Certain 34% - 67% 68% - 89% >90% Impact A A A/R R R A/G A A A/R A/R G A/G A/G A A G G G G G RESTRICTED TO BOARD MEMBERS AND NOT FOR ONWARD CIRCULATION 1 = Very Low 2 = Low 3 = Medium 4 = High 5 = Very High hood PREVIOUS PERIOD THIS PERIOD TARGET RESIDUAL ref. Raised Raised by Area Description hood Impact Score hood Impact Score TREND Timing Owner Mitigating Actions Action Owner Due for Actions Action updates hood Impact Score Target Reviewed Next Review R001 28/11/2013 Martin Caunt Programme There is a risk that implementation of the Care Act fails to deliver the desired outcomes from the reforms and realise the benefits for individuals and the system 1. Lack of alignment between Care Act implementation and the integration and other related programmes 2. Insufficient understanding by LAs of the changes represented by the Care Act and the shift needed to realise the vision 3. Pressure on resources available to local government to fund new responsibilities and duties 1. Unable to drive the intended shift in investment away from crisis management to interventions that promote wellbeing and independence, choice and control, and integrated care 2. Increased pressures on LA resources from failure to do things differently to respond to the challenges to LA funding A/R A i L 1. Develop and agree Summary Case for Change to bring together strategic 1. Martin Caunt case for the reforms into one place 2. Martin Caunt 2. Define indicators and methods of measurement to baseline and monitor 3. Andrew Hughes achievement of outcomes and realisation of financial benefits 4. Andrew Hughes 3. Develop and improve effectiveness of implementation communications and 5. Steven Pollock engagement with key stakeholders to support local delivery of the Care Act 6. Steven Pollock 4. Agree and commission package of implementation support products to 7. Andrew Hughes support LAs to deliver desired outcomes in 2014/15 5. Develop and use an overarching narrative to help tell a coherent story about integration and care and support reform 6. Communication of the reforms and the benefits of them to the public and other stakeholders 7. Agree and commission package of implementation support to help LAs deliver the desired outcomes in 2015/16 1. November March March September Autumn Autumn May 2015 has been reduced to Amber to reflect progress on benefits strategy and realisation plans, delivery of implementation support and mitigation of affordability risk for new burdens for 15/16 duties. 1. Summary case for change updated to reflect changes in the IA for regulations in 2015/16 package. Agreed with MPA that this form basis for tracking costs and benefits of the programme over time. 2. Scoping of independent research package on the evaluation of the Care Act and Care and Support White Paper ongoing with view to commission before end of financial year. Mapping of metrics to 'I' statements and identification of gaps to inform action to update data collection activity to address them completed. A benefits realisation strategy has been developed and will be presented to the March CSRP Board meeting. 3. Stakeholder analysis completed in September informed engagement in public awareness campaign and draft Implementation communications strategy 4. Majority of implementation support products for 2014/15 delivered with a few remaining 5. COMPLETE 6.Significant progress made on the development and delivery of the Public Awareness campaign of 15/16 reforms. Plans communicated to stakeholders through FTP site, implementation communications channels and regional network leads. Focus will now begin to shift to Phase 1B and 2 of the campaign 7. Action being taken to identify priorities in 15/16 to support embedding of change as well as Phase 2 implementation. A /03/ /03/ /03/2015 R002 28/11/2013 Programme There is a risk that LA's are unable to make sufficient preparations to ensure implementation of Care & Support reforms in time for its introduction in 2015 & Enabling activities (regulations, guidance etc) are not available in sufficient time / quality to make adequate plans 2. Insufficient programme management / change management capacity & capability 3. Failure to start planning early enough to deliver the scale of change 4. Pace of implementation, or LA discretion in approach to delivery of key elements of the Care Act 5. Implementation partners, such as the NHS, are not sufficiently aware or do not understand the scale, or detail of the reforms 6. Implementation support not targeted to the right areas and / or not available in adequate time / quality 7. A major LA failure impacts on the system 8. Insufficient funds to implement the Act as envisaged Impacts(s) 1. Insufficient time for LA's to plan for implementation leading to failure to achieve consistent, coherent implementation by all LA's in April 2015 & Clients (& their carers) do not receive care, or the level of care they need 3. The Care Act's benefits are not realised in the system or a locality 4. Local delivery implications from a judicial review on one or more areas of the reforms 5. Reputational risk for DH, the Government and Local Government from failure to deliver A A g 1. Agree Care Bill Implementation Assurance Strategy & Implementation Support 1. Andrew Hughes Vision 2. Andrew Hughes 2. Facilitate a further 3 LA readiness stocktakes to assess likelihood and 3. Andrew Hughes / Martin progress of Care Act implementation in 2015/16 Caunt 3. Identify implementation support products to aid LA's in planning, and 4. Simon Medcalf implementation of Care Act reforms 5. Andrew Hughes / Martin 4. Engage key stakeholders in development of draft guidance and regulations Caunt 5. Engage key stakeholders and delivery partners to ensure they understand the 6. scale and timetable for implementation 7. / Sally 6. Agree Board assessment of readiness in lead up to implementation taking Burlington evidence from LAs on readiness, on Finance and other sources as appropriate 8. Simon Medcalf 7. Engagement with LGA Community and Wellbeing Board (CWB) to discuss 9. concerns and action being take to address them 8. Publication of Care Act regulations and guidance for 2016/17with sufficient clarity, quality and timeliness to facilitate good planning by local authorities 9. Suitable and sufficient capacity available to support local authorities with L Andrew Webster specified and identified issues as appropriate 1. September February January October Ongoing 6. March Ongoing 8. October Ongoing 2015/16 reduced to Amber / Green due to progress made as evidenced in January 2015 stocktake of LA readiness. Proposed that risk is closed and the remaining risk on preparedness for 16/17 reforms be captured as an update to R COMPLETE 2. Board agreed in December to a further three stocktakes during 2015/16 3. Discussion regarding priorities for package of support in 2015/16 agreed Programme Board on 25 February. Further discussion of plans at 27 March Board. 4. Following the public consultation statutory guidance was published and negative regulations for the 2015/16 reforms were laid before Parliament in October /17 package engagement ongoing through public consultation following substantive discussion in the paying for Care Transformation Group. Further engagement through plans on financial modelling with a sample of LAs on the 16/17 changes. 5. Implementation communications resource raising awareness of support available and timetable for delivery. Development of integrated plan with sector input for programme. Agreement by Board to publish plan to aid local implementation. 6. Final stocktake of readiness report before 1 April 15 discussed at Programme Board on 25 February, demonstrating confidence and general readiness whilst some residual risks remain. Further quarterly stocktakes planned throughout 15/16 to support assurance of 16/17 delivery and embedding of 15/16 reforms. 7. MSCS attended meeting in Sept and discussed October regulations and guidance package ahead of publication. 8. The consultation on draft regulations and guidance for the cap on care costs and policy proposals for appeals was published on 4 February with consultation running unto 30 March. 9. Package of support delivered at national and regional level in addition to contribution to all LAs to provide programme management capacity to support implementation of the first phase of the Care Act reforms coming into effect from 1 April Local Authority Circular published to advise LAs on preparations for 16/17 and use of funds provided to support preparations. A /03/ /03/ /03/2015 PROPOSE CLOSE 27/03/15 WITH 2016/17 ELEMENT CAPTURED IN RISK 9 R003 28/11/2013 Programme Undesirable changes to the Care Market from the combined effects of the reforms; in particular "s18(3) 'right' of self-funders to access local authority rates" 1. Several key policies may lead to a change in consumer behaviour; for example increased transparency in LA vs. self-funder prices, brokerage service and cap 2. Sustainability of Care Providers and pressures to deliver efficiencies from LAs 3. Market distortions arising from price differentials between self-funder and LA-funded prices for residential care 1. Increased pressure on provider's returns leading to increased risk of provider failure, or insufficient and inadequate choice of quality suppliers if providers exit or reduce the market for state funded people 2. Increased pressure on local authority commissioning and prices A/R A/R g M Simon Medcalf 1. Integrate work with the development of DH market stewardship role Stephen Airey 1. February Develop work plan to: 2. April 2015 Establish projects to understand the current market & assess the possible impact Analyse evidence of differential pricing in the market and the potential behavioural impacts on self-funders Analyse the current financial health of care providers and scenario analysis to better understand the potential costs Work with the Paying for Care Transformation Group to ensure stakeholder buy in to policy development Consider how the forthcoming statutory guidance can be used to minimise the risk of adverse impacts Consider guidance for LAs on commissioning standards and market management to promote fair pricing Consider outputs of the care market simulation event which took place on the 12th November. Test model of local authority offer based on current domiciliary care arrangements with stakeholders and disseminate strategy to LAs through guidance Commission further exploration from external academics. Consider market behaviour testing via consultancy 3. Update statutory guidance to reflect research findings. 1. Market impact work moved to fall under Care Markets work stream. Proposals on programme governance strengthens oversight of this area. 2. Paper to March 2015 Programme Board sets out plans in 15/16. PSRRU research and OPM scenario report being considered. Research projects commissioned to understand the current market & assess the possible impact: (a) PRSSU - typology of LAs & differential effects of 18(3) (b) OPM market scenario workshop based on (a) (c) Commissioned - understanding pricing & extent of x-subsidy. Interim findings by June. (d) Qualitative assessment of what people are likely to prioritise in selecting services (care residents survey possible. Expensive and time consuming but most rigorous test of current problem. Possibility of pooling funding? Considering consultancy work as alternative) (e) With RDD for consideration: typology of demand & supply and barriers to them matching Further research and projects to help define local authority offer to self-funders being considered. 3. Focus group with LA reps and stakeholders to develop LA offer model and build strategic advice for LA implementation of 18(3). A /10/ /03/ /03/2015 R004 28/11/2013 Paying for the Reforms Failure to understand and estimate the additional costs of the reforms in 2015/16 and 2016/17 or allocations do not sufficiently match individual LA demands 1. Estimates of new burdens from the Care Act change over time as new information emerges. This could be due to lack of sufficient / robust information on demands resulting from the reforms, in particular, but not only, demands from carers and self-funders 2. Failure to implement reforms efficiently, for example, in responding to additional demand for assessments and in supporting carers, leading to underestimated unit costs 3. LAs unable to access sufficient income from the Better Care Fund to protect access to social care and meet the cost of new burdens arising from the Care Act 4. LA spending settlement is proven to be insufficient to meet cost of new burdens arising from the Care Act despite robust understanding of costs, additional income from the Better Care Fund and assurances that LAs would be able to implement efficient practices 1. Local Authorities unable to meet their legal duties 2. Overspend on LA budgets 3. Negative media attention locally and nationally 4. Unsustainable cost pressures on providers leading to a significant business failure 1. Establish a cross-cutting Finance workstream to co-ordinate activity relating to Tom Skrinar / Richard funding and costs of the reforms bringing together the following existing strands Campbell / Stephen Airey of activity: DH-led activity to model the costs of the Care Act at a local level; Review of costs by policy leads during the passage of the Act and development of secondary legislation; Relative Needs Formula research programme to provide recommendations on changes to the formulae used for funding reforms 2. Continue to revise risk assessments when new information is available 3. Working in partnership with SCIE and ADASS develop guidance on efficient A/R A i L practice in assessments and supporting carers Sebastian Habibi 4. LAs need to ensure they have an assurance processes in place to protect adult social care funding. Support to be provided to assist LAs in planning and budgeting. BCF plan approval is dependent on meeting the condition to protect social care services. 5. Ensure robust mechanisms in place to monitor the financial sustainability of major providers during implementation of the new duties and during transition to CQC taking on the function. 6. Sustainability of ASC funding to be investigated and addressed as part of the 2015 SR process within DH. 1. November Ongoing 3. March Ongoing 5. Ongoing 6. July 2015 Recommended for closure with two new separate risks for 15/16 and 16/17 reforms. 1. COMPLETE 2. COMPLETE FOR 2015/16. Work has begun on finance modelling work with councils on the 2016/17 financial reforms. An update will be provided to the March Board meeting 3. COMPLETE. SCIE have now published guidance on assessments including an online guide to appropriate and proportionate assessments and guide to supported self assessment in January. Guidance on carers planned for completion by end of March. 4. Monitoring of key activity data to be led by ADASS / LGA in early 15/16. Evidence to inform submission to Spending Review (that will likely be running through summer 2015). 5. DH to continue to monitor the financial sustainability of major providers pending full transfer of function to CQC and ensure. 6. Preparations for SR ongoing. A/G /03/ /03/ /03/2015 PROPOSE CLOSE & SPLIT INTO 2015/16 & 2016/17 RISKS 27/03/15 R005 28/11/2013 Communications Failure to raise public awareness of the reforms 1. Low awareness of care & support & how it is funded & delivered 2. Complexity of the current system & challenge in communicating some of the reforms, in particular the cap on care costs 3. Negative reporting of elements of the reforms in the media 4. Resource shortfall to deliver the communications strategy 5. Campaign is delayed by Ministerial decision making following election period in Reputational risk to DH in failing to deliver improved outcomes & deliver the benefits for people & Government 2. Increase in the number of complaints and disputes 3. Individuals do not know when the changes take effect, what support they can get, and how they can access it A A g M Stephen Pollock 1. Develop a resource proposal to support implementation & strategic Fraser Clubbe 1. November 2014 communications 2. January Deliver the communications strategy agreed by the Board to ensure 3. October 2014 communications play a role in supporting the implementation programme, so 4. September 2014 that the public understand what is changing, why and what action needs to be 5. October 2014 taken, by when, to benefit from the reformed system. 6. March Delivered a targeted series of media briefings to set stories straight and a myth busting product for the media so that lines are consistent and accurate 4. Engaged marketing experts via PHE to develop the public awareness campaigns for people with an existing care need and the general public audience groups 5. Promote strong lines on care and support reforms through our proactive/reactive media approach 6. Engage main political parties on the campaign strategy in line with DH s overall approach to pre-election planning so they are aware of and understand the campaign plans, proposed timings and risks to implementation. 1. The resource position has now been agreed between PMO, DH Comms and the LGA. Sufficient resource with the right skills is in place and responsibility for implementation comms will pass to PMO for future reporting. 2. The national campaign is now live and all materials are available for Local Authorities and stakeholders to use as appropriate. DH comms have set the evaluation baseline and will have evaluation data from the campaign by the end of March. 3. Media activity delivered in support of the publication of regulations and guidance for 2015/16 changes and for the consultation on 2016/17 regulations and guidance. Worked with the BBC to develop and promote their cost of care calculator which aims to promote public awareness and understanding of reforms. 4. Memorandum of Understanding agreed with PHE and schedule of payments relating to delivery in place. Outstanding issue to resolve budget request of 80k to secure PHE cover between April and Sept 2015 for Phase 1 a campaign maintenance - being taken forward in line with DH approval process. 5. Media lines in place and regularly reviewed and updated alongside policy team and programme. 6. To be planned out as part of post election preparations. ERG development for phases 1b and 2 of the campaign will support this process. This activity will be informed by phase 1a campaign evaluation and approvals sought at the Programme Board. A/G /03/ /03/ /05/ CSRP s Issues Assumptions Register Page 1 of 7

2 <programme/project name> Management Log OFFICIAL - SENSITIVE PREVIOUS PERIOD THIS PERIOD TARGET RESIDUAL ref. Raised Raised by Area Description hood Impact Score hood Impact Score TREND Timing Owner Mitigating Actions Action Owner Due for Actions Action updates hood Impact Score Target Reviewed Next Review R006 28/11/2013 Workforce Local Authorities have insufficient workforce capacity and capability to meet the new demands from the introduction of the Care Act in 2015 or LAs do not take sufficient steps to examine the workforce and ensure they meet requirements of the Care Act in time for introduction 2. Lack of reconfiguration and skilling up of the workforce to meet the Acts requirements in time for introduction 3. LAs are unable to make sufficient funding available for training because of lack of resources 4. LAs do not make sufficient steps to ensure workforce trained to the required standard fulfil the requirements of the Care Act in time for introduction 5. Late delivery or insufficient quality of nationally produced workforce implementation support products 6. Insufficient quality or supply of learning providers / trainers 7. Insufficient supply or significant staff turnover A/R A/R g M Glen Mason 1. Provision of local on site support to support use of capacity planning tool and identify model changes. 2. Monitor and maintain learning and development resources for 15/16 reforms and capacity planning tool. 3. Develop e-learning solution for 15/16 reforms. 4. Development of quality assurance processes, including a system for accrediting potential learning providers / trainers 5. Identify learning and development and other workforce support requirements for 16/17 reforms. 1. Graham Earnshaw 2. Graham Earnshaw 3. Liam Paul 4. Graham Earnshaw 5. John Woods 1. July July June April July SfC have briefed regional partners through their area networks and have regular meetings with the ADASS regional workforce leads. Local support started in April. Case studies made available to help local organisations. Model being evolved to accommodate feedback from LAs and partners. Regional events held in partnership with ADASS. 2. SfC business plan includes funds to support maintenance and update of existing workforce materials developed for 15/16 reforms. Evaluation of capacity planning tool and learning and development materials in progress. 3. Some regions invested element of additional 4m to procure e-learning materials. National long term offer to support embedding of skills within employers being developed for early 15/16 4. SfC in the process of rolling out the QA process for learning and development providers. 5. Planning workshops with representatives from local government identifying timing for provision of 16/17 workforce support. Implementation support lead for 16/17 reforms secured to help identify requirements. A /07/ /03/ /03/ Failure to achieve consistent, coherent implementation by all 152 LAs in April 2015 and Significant delays to LA delivery of services (e.g. assessments) undermining confidence and impacting on people's wellbeing 3. Local delivery implications from a judicial review on one or more areas of the reforms R007 28/11/2013 Informatics Local Authorities do not have the necessary upgrades to information systems in place in time for Care Act introduction in 2015 and Lack of capacity, resources & capability of LA's as a whole to deliver upgrades to their systems 2. Lack of supplier capacity to deliver all the upgrades in time 3. Lack of time to train staff on new systems 4. Timescale for IT implementation too short and delays in other aspects of policy work delay IT development & implementation 5. of delivery if LA's having to go through a reprocurement exercise or significant wider IT change or on lower versions of supplier software adding cost or risking delivery upgrades 6. Lack of resource within DH & sector to support implementation and organise effective engagement with suppliers 7. Wider inherent risks within the IT market - e.g. existing suppliers leave or have to exit the market. Note: s to delivery of the Care Act are linked to wider systemic risks across the sector in respect of IT. These systemic risks may impact on delivery of the Care Act in certain localities, but will not be caused directly by the Care Act itself 1. Failure to achieve consistent, coherent implementation by all 152 LA's in April 2015 (& again in 2016) 2. Costs of IT upgrades are unaffordable for some 3. Resources diverted to this area meaning other elements of implementation are impacted A/R A i L Glen Mason 1. Working closely with policy officials - provide guidance to the sector & Charlotte Buckley suppliers on required changes as soon as it is available for both 2015 and Continued engagement with suppliers to tackle key issues and gauge 'stretch' of the ask 3. Strong engagement and collaborative approach with sector, including ADASS Information Management Group, regional ADASS IMG groups, local CIO council, SOCITM and LGA 4. Bespoke support to any councils at risk of not being, using assurance process to monitor this and more effectively evaluate level of risk 5. Definition of a realistic and flexible roadmap of wider informatics changes (e.g. increasing use of digital) to account for priorities around care bill. Adopt agile approach and ensure that there is no scope creep to add risk to Care Act programme 6. Ensure strategic links with wider government health and care informatics are strong and key interdependencies and opportunities are identified. 7. Soft monitoring of market using local networks and experts 1. Ongoing 2. First round completed August. Will repeat engagement exercise for consultation on 2016 changes alongside update specification 3. Ongoing and on track 4. Ongoing, with bespoke support being led by LGA/ ADASS 5. Ongoing 6. Ongoing and on track 7. Ongoing 15/16 implementation risk assessed at Amber / Green. This reflects evidence on preparedness for 15/16 and that delay to upgrades can be mitigated locally. Proposed that this risk is closed to focus on the significant risks to upgrades for the 16/17 reforms following go live on 1 April Guidance to sector and suppliers published in January and July 2015 providing latest information to suppliers and LAs; updates provided via new LGA webpage. Further guidance to follow on 2016 changes in line with consultation. ADASS IMG produced report on latest state of readiness 2. Information sharing sessions arranged, with follow up with individual suppliers and lead customers (including DH, ADASS IMG and LGA), strong relationships have been established and should continue into 2015 to prepare for 2016 changes 3. Considering longer-term strategies for supporting better IT across LAs outside of the Care Act programme 4. DH sit on key strategic national informatics boards, including National Information Board (NIB) and NHS Choices and are working closely with Health & Social Care Information Centre to take forward a coherent strategy and plan for Adult Social Care Informatics. A/G /03/ /03/ /03/2015 PROPOSE CLOSE 2015/16 ELEMENT & CREATE NEW ONE FOR 2016/17 RESIDUAL RISK 27/03/15 R008 28/11/2013 There is a lack of consistency in the application of national eligibility criteria across the 152 LAs, leading to unplanned additional costs if eligibility is extended beyond the current approach 1. Difficulty in describing the national eligibility criteria in regulations that replicates the effect of existing guidance. Assessment & 2. Professional judgement applied to interpret how regulations are applied locally may create inconsistency in Eligibility inc Carers approach. 1. Unintended additional costs to LAs increases pressure on resources 2. Increase in number of complaints and disputes A A g L Simon Medcalf 1. Engaged SfC and SCIE to produce training materials and practice materials to Paul Woods 1. September 14 support implementation. 2. May London School of Economics to evaluate final version of eligibility regulations 3. Ongoing in Continue to work closely with the DH Finance workstream to ensure DH Impact Assessments include all relevant cost estimates 1. COMPLETE. The final version of the eligibility regulations and statutory guidance published in October This takes account of comments from the consultation and findings from the LSE evaluation. SfC published training materials on assessment and eligibility in October. SCIE has published the majority of the products they have been commissioned to develop on assessment and eligibility on its website. ADASS Carers Network preparing practice materials to support implementation of the carers requirements. 2. The London School of Economics has been commissioned to evaluate the final version of the eligibility regulations from May 2015, when practitioners will have had their training and will use the eligibility criteria in the new care and support system. Preparation has already started for the research. 3. DH IA includes cost estimations of training and additional assessment, clarifying what the requirement for additional resources could be. Monitoring by LGA / ADASS includes eligibility. A/G /06/ /03/ /03/2015 R009 28/11/2013 Charging for Care Local authorities fail to implement the cap on care costs and new appeals system in time for introduction in April 2016, & make insufficient preparations to allow smooth transition to new system 1. Delay in communicating cap regulations or details of implementation requirement. 2. Lack of understanding of the cap & its interactions with the charging framework & other aspects of the system. 3. Belief by LAs that the upcoming general election & SR mean that the cap will either not happen or will be delayed. 1. Failure to achieve consistent, coherent implementation by all 152 LAs in April 2016, & realise the desired outcomes from care and support reforms A A/R h M Sebastian Habibi 1. Work with stakeholders to produce draft guidance and regulations for consultation 2. Keep stakeholders fully engaged to ensure support for the cap, and encourage partners to promote 3. Produce implementation toolkit to aid LA implementation of the cap & other changes 4. Work closely with informatics team to ensure details of changes can be communicated asap 5. Work with x-govt colleagues to gain support for consultation, and follow up post consultation and post election to support publication of regulations and guidance. 6. Develop and test integrated programme plan for 15/16 and 16/17 implementation. Sara Mason 1. Nov 14 & ongoing increased to Amber Red to reflect increased understanding of risk to critical 2. March 2015 path for 16/17 reform delivery. 3. Jun COMPLETE. Transitional section within the statutory guidance for 2015 includes 4. Ongoing information on preparing for 2016 reforms. The consultation on the cap setting out draft 5. January 2015 regulations and guidance was published on 4 February and will run until 30 March. 6. March A series of 10 regional stakeholder events have been set up to support the 2015 cap consultation. Commitment for DH to continue engagement following election to communicate plans. PMO implementation communications to continue through election period. 3. Resource has been brought in to increase capacity to deliver implementation support. LA circular is being prepared to provide further information on planning and preparing for the introduction of the cap and how the funding can be used. 4. Working closely with the informatics team to ensure that details of the new system can be shared with IT suppliers at the earliest opportunity 5. Engaged with key OGDs in advance of HA and during HA clearance process to secure support for consultation. 6. Integrated plan for delivery of 16/17 reforms agreed by Programme Board on 25 February. This form baseline for monitoring and supporting progress. Plan to be shared via PMO implementation comms. Plan being tested and developed with LA implementation leads and through scenario planning. A /06/ /03/ /03/2015 R012 02/06/2014 Martin Caunt Programme There is a risk that a insufficient number of providers will adapt and change to meet demand, are and not at the required level of provider readiness in time for "go live" There is insufficient or appropriate support for providers to implement the Act 2. The programme does not effectively engage with providers and their representative groups 3. There is insufficient funding available to meet provider implementation support needs 4. Lack of awareness of the changes represented by the Care Act 5. Some LAs engage insufficiently with providers in development of implementation plans 6. LAs new market shaping responsibilities are slow to be implemented 7. Limited appropriate skilled resource available at affordable price to support providers 1. Providers are not able to provide sufficient services in a locality 2. Services users find that services are disjointed as providers do not understand how the new system works 3. Provider service provision does not comply with the new duties in the Care Act 4. Negative impact on quality and choice of care provision 5. Care needs not appropriately met 6. New services are not developed to meet people s needs A A g M 1. Ensure that the PMO has the capacity and capability to understand provider issues 2. Establish and maintain regular dialogue with provider representative organisations in order to understand concerns and share information 3. Provide sufficient and appropriate training tools and material for use by providers to support LAs in development of their market shaping strategies 4. Provide support to local authorities to help them effectively discharge their market shaping duty Ian Turner / PMO / Stephen 1. Jun-14 Airey 2. Jul From Sep From Oct Provider expert appointed to PMO and resource planned to allow continuation of role into 2015/ Regular meetings with major provider representative organisations established. Revised governance structures for the Programme Board include proposals to strengthen provider representation. 3. Implementation support products developed for providers made available from January PMO Provider representative Ian turner leading series of engagement events with providers over February and March. This builds on engagement by PHE as part of the public awareness campaign and communication materials for use by provider being developed as part of this campaign. 4. Guidance encourages LAs to develop a Market Position Statement. DH commissioned support material developed by IPC available to all LAs to use signposted in workforce L&D modules. Commissioning for Better outcomes guidance published at NCASC and 3 pilots of peer challenge using the framework planned before end of March. Further projects to help local authorities meet their key duties have been commissioned, including understanding the sustainability of their local markets, understanding and encouraging provider diversity, and support for co-production of commissioning. A/G /03/ /03/ /05/2015 R013 12/09/2014 Appeals There is a risk that implementation of Part 1 of the Care Act 2014 from 1 April 2015 leads to a significant increase in Judicial Reviews and challenge of Local Authority practice 1. More informed audience could result in an associated increased risk of JR 2. Care Act consolidates and replaces existing legal framework and case law 3. Regulation or guidance allows interpretation and variation in implementation 4. Pressures on funding in the system, local budget decisions may increase risks of incomplete or inconsistent delivery 5. Some LAs unable to make sufficient preparations to be fully compliant from 1 April Legal costs and resources to contest JRs undermine ability to implement reforms 2. Reputational risks of negative press following successful JRs. 3. Care Act loses buy in from the public to deliver on the promised reforms A A g M Simon Medcalf 1. Appeals workstream established to develop and design an appeals framework 1. Lawrence Erikson / system for implementation from 2016/17 2. Andrew Hughes 2. Implementation support package to support LAs in implementation and 3. Joanna David provide practice advice in key areas on how to deliver legal requirements 4. Sara Mason 3. Additional workforce L&D to support LA lawyers to provide advice locally 4. Engage key stakeholders in development of draft guidance and regulations for 16/17 reforms and throughout the consultation. 1. From 2016/17 2. January March January Consultation on policy proposals for new appeals system published alongside the consultation on the draft regulations and guidance for the cap on care costs. In parallel working with partners and stakeholders to understand the challenges to implementation and what support may be required to assist delivery of these changes. 2. As per risk 2 above. Package of implementation support products agreed and DH policy leads working with sector and delivery partners to deliver. Some key products already delivered - including L&D products which are ley to supporting workforce understanding of new duties - and others planned by January 2015 and March Continued scanning of LA support needs through intelligence networks. 3. Legal literacy training being developed by selected supplier under the oversight of a steering group of LG lawyers and PMO. 10 regional events planned for February and March. Materials to be updated and made available following events. 4. Consultation was launched on 4 February and will run until 30 March. It includes draft regulations and guidance that will underpin the cap system. A/G /10/ /03/ /03/ CSRP s Issues Assumptions Register Page 2 of 7

3 <programme/project name> Management Log OFFICIAL - SENSITIVE PREVIOUS PERIOD THIS PERIOD TARGET RESIDUAL ref. Raised Raised by Area Description hood Impact Score hood Impact Score TREND Timing Owner Mitigating Actions Action Owner Due for Actions Action updates hood Impact Score Target Reviewed Next Review R014 25/11/2014 Martin Caunt Programme There is a risk that the programme has insufficient capacity and capability to deliver legislation for 16/17 duties in October 2015, associated implementation support, assurance activity and communications 1. Loss of key skills from the programme team after completion of main activity supporting Phase 1 delivery. 2. Wider demands on DH resources to support preparations for the election and SR and to respond to new government. 3. Delay in confirming funding and securing agreement of business plans / support programmes with key delivery partners. 1. Providers are not able to provide sufficient services in a locality 2. Services users find that services are disjointed as providers do not understand how the new system works 3. Provider service provision does not comply with the new duties in the Care Act 4. Negative impact on quality and choice of care provision 5. Care needs not appropriately met 6. New services are not developed to meet people s needs A A/R h M 1. Review programme structure and resources for next phase of implementation 1. Martin Caunt to identify and secure what needed to reduce risks to delivery 2. Simon Medcalf 2. Monitoring and reporting of progress and risk to delivery of regulations and 3. Martin Caunt / Andrew guidance package for 2016/17 reforms by Programme Director Hughes 3. Identify and agree priorities for implementation support and ensure timely 4. Martin Caunt approvals to allow commissioning and delivery 5. Martin Caunt 4. Ensure accountability and reporting of programme workstreams includes delivery implementation support to LAs 5. Ensure coherence and pace of development of implementation support products developed by our delivery partners through commercial and / or accountability arrangements 1. March May March March March 15 increased to Amber Red to reflect increased understanding of risk to critical path for 16/17 reform delivery. 1. Seeking Board approval for restructuring of programme at March 2015 Board. Proposals aim to streamline and reduce programme management burdens whilst strengthening programme oversight and assurance. Business planning identified available resources to support programme and implementation. Secured additional resource to support phase 2 implementation and programme management. 2. February 2015 Programme Board approval for integrated plan for delivery of 16/17 reforms supported by scenario analysis informing contingency planning and risk mitigation. MPA PAR scheduled for April 15 to examine risks to phase 2 delivery supported by a challenge workshop with senior stakeholders across government and the system will stress test plans. 3. Implementation support priority themes to be discussed at February Board. Further detail to be presented to the March Board. 4. Following approval of integrated plan and implementation support priorities workstream plans will be updated to include additional implementation support products. 5. Building on progress on accountability and sign off process for implementation support products in 14/15 and apply with commissioning and requirements placed on suppliers and delivery partners in 15/16. Reviewing role of the Care Act Implementation Support Delivery Board as part of wider programme structure review. A /10/ /03/ /04/2015 NEW 27/03/2015 Martin Caunt Failure to understand and estimate the additional costs of the reforms in 2016/17 or allocations do not sufficiently match individual LA demands 1. Estimates of new burdens from the Care Act change over time as new information emerges. This could be due to lack of sufficient / robust information on demands resulting from the reforms, in particular, but not only, demands from carers and self-funders 2. Failure to implement reforms efficiently, for example, in responding to additional demand for assessments and in supporting carers, leading to underestimated unit costs 3. LAs unable to access sufficient income from the Better Care Fund to protect access to social care and meet the cost of new burdens arising from the Care Act 4. LA spending settlement is proven to be insufficient to meet cost of new burdens arising from the Care Act despite robust understanding of costs, additional income from the Better Care Fund and assurances that LAs would be able to implement efficient practices A/R L 1. Model the costs of the Care Act at a local level and review by policy leads 1. Sara Mason during the passage of secondary legislation and continue to revise risk 2. Paul Sherrell assessments when new information is available 3. Paul Sherrell 2. Relative Needs Formula research programme to provide recommendations on 4. Tom Skrinar changes to the formulae used for funding reforms. 3. Support to be provided to assist LAs in planning and budgeting. 4. Sustainability of ASC funding to be investigated and addressed as part of the 2015 SR process within DH. 1. October October July October Costs updated for draft regulations and guidance for cap on care costs and policy proposals on the new appeals system. Consultation to provide evidence to inform further updates alongside financial modelling for 2016/17 reforms being rolled out over March and April Consultation on allocations for funding reforms planned for October Financial modelling over March and April to develop model that may be of wider support to all LAs. Advice provided in Local Authority Circular published in February 2015 on understanding data driving costs. 4. Preparations for SR ongoing. A /10/ /03/2015 NA 1. Local Authorities unable to meet their legal duties 2. Overspend on LA budgets 3. Negative media attention locally and nationally 4. Unsustainable cost pressures on providers leading to a significant business failure Failure to understand and estimate the additional costs of the reforms in 2015/16 or allocations do not sufficiently match individual LA demands 1. Continue to review risk assessments when new information is available from data monitoring and other intelligence. 2. Sustainability of ASC funding to be investigated and addressed as part of the 2015 SR process within DH. 1. Simon Medcalf 2. Tom Skrinar 1. October October Monitoring of activity data to be led by ADASS / LGA in early 15/16. Evidence to inform submission to Spending Review (that will likely be running through summer 2015). 2. Preparations for SR ongoing. NEW 28/11/2013 Martin Caunt 1. Estimates of new burdens from the Care Act change over time as new information emerges. This could be due to lack of sufficient / robust information on demands resulting from the reforms, in particular, but not only, demands from carers and self-funders 2. Failure to implement reforms efficiently, for example, in responding to additional demand for assessments and in supporting carers, leading to underestimated unit costs 3. LAs unable to access sufficient income from the Better Care Fund to protect access to social care and meet the cost of new burdens arising from the Care Act 4. LA spending settlement is proven to be insufficient to meet cost of new burdens arising from the Care Act despite robust understanding of costs, additional income from the Better Care Fund and assurances that LAs would be able to implement efficient practices A M Sebastian Habibi A/G /10/ /03/ /03/ Local Authorities unable to meet their legal duties 2. Overspend on LA budgets 3. Negative media attention locally and nationally 4. Unsustainable cost pressures on providers leading to a significant business failure CSRP s Issues Assumptions Register Page 3 of 7

4 <programme/project name> Issue Management Log OFFICIAL - SENSITIVE Impact 1 = Very Low 2 = Low 3 = Medium 4 = High 5 = Very High Issue Ref. raised Raised By Area Description of Issue Impact Issue Owner Action Action Owner Due By Action Updates I002 11/07/2014 Martin Caunt Programme There is limited understanding of LA workforce capacity and capability to respond to the demands from the introduction of the Care Act at a national level 2 Glen Mason 1. Stocktake surveys in September and January to provide more detailed picture of LA workforce readiness 2. Review support provided on supporting LAs preparing the workforce 1. Tom Shakespeare 2. Glen Mason / Martin Caunt 30/09/ rd stocktake in January 2015 shows an improving picture on workforce preparations with 99% saying their own workforce will be prepared, 96% of councils responded that they are confident that changes made by the council will be adequate to manage the statutory duties in Councils are less confident about changes to the workforce within external providers with 17% not confident that the provider workforce will be sufficiently prepared for April Additional support provided in terms of 4m regional funds which include element for L&D rollout and project for specialist L&D for LA lawyers being delivered with regional events through February and March. L&D prospectus to pulls together L&D materials on offer. Discussions with regional care act leads around priority investment in e-learning materials to support L&D offer. Reviewed Next Review date Target Resolution X Ref: Number 16/03/ /03/ /04/2015 R006 I003 11/07/2014 Martin Caunt Programme There is currently limited understanding of provider capacity to deliver the changes needed to respond to the Care Act and risks to implementation 3 Andrew Hughes 1. Engagement programme with providers and their representative groups to raise awareness of changes and understand implementation support needs 2. Implementation support products for providers agreed by September Board nearing completion for publication 1. Ian Turner by end of year 2. Ian Turner 3. Reconsider provider representation on CSRP Board 3. Simon Medcalf 02/12/ Major provider organisations have been engaged with and discussions held on their implementation support needs 2. Products under development for publication by end March Public Awareness Campaign including substantial engagement with providers. CQC delivering own stakeholder engagement plans around market oversight duties from Care Act. 3. Under consideration as part of wider consideration of programme structure to meet challenges of the new phase of the programme. 11/03/ /03/ /04/2015 R012 I005 11/07/2014 Martin Caunt Programme Lack of understanding and public awareness of current system and financing of social care and the changes represented by the Care Act 3 Steven Pollock 1. Public awareness campaign to current and future carers and those cared for on the changes o social care and what this will mean for them 1. Fraser Clubbe 31/10/ Public awareness campaign plan fully developed and agreed 2. Campaign toolkit with communications materials for local authorities and partners in place for Jan National radio, digital, door drops and media activity began Feb Evaluation of the campaign against agreed metrics to determine the impact will take place during March, with a full report available in April 12/03/ /03/ /04/2016 R005 I006 11/07/2014 Martin Caunt Programme CQC market oversight function not fully operational from 1 April Simon Medcalf 1. DH to extend existing BDO contract beyond April 2015 to ensure there is not a gap in financial oversight of providers. Legal powers cannot be commenced before April 2015 and CQC will require some time to build capabilities and conduct assessments of providers within the regime over Q1 and Q2. 2. CQC finalising operating model following targeted consultation with stakeholders. 3. CQC recruiting the specialist expertise it needs. 4. CQC to issue guidance of how they will undertake the function in January Richard Campbell / Sally Warren (CQC) 01/04/ Approval obtained. Contracts extension being agreed. 2. CQC continue to make progress in implementing their new function, including continued testing of their operational procedures with stakeholders. Guidance on the scheme is on track for publication around 18 March. 3. Recruitment under way. DH approval obtained for an interim resource to fill gap in capability until the full team is in place. Interim systems will be in place for April to allow secure exchange of information whilst permanent system is developed. Staff training planned for delivery from March to May. 4. Draft provider guidance published on 29 January for consultation until 20 February with a view to publication by 30 March. Engagement plan underway culminating in "Getting ready for April 2015" comms plans. 11/03/ /03/ /06/2015 I011 22/08/2014 Sebastian Habibi Financial Some LAs will face significant additional volumes of assessments from self-funders from 2015/16 due to increased incentives arising from the funding reforms, and will need to identify and realise opportunities to increase efficiency in the assessment and review processes Develop and publish practical guidance to support LAs to understand flexibility within the Act and develop efficient practices for managing demand, including triage, self-assessment, online approaches. 2. Data monitoring of demands from assessments Simon Medcalf including those for self funders. 1. Simon Medcalf 31/10/ Implementation support materials published by SCIE in Further material on practice guidance and strength based approaches to follow. Engagement on implementation support needs for 15/16 identified further need for consultancy / advice on use of guidance in practice. Response being developed as part of programme implementation support plans. 2. ADASS Executive agreed in general areas for data monitoring of 15/16 implementation which includes early assessment of self funders. Data monitoring proposals to be put to March 2015 Board. 11/03/ /03/2015 R004 I012 22/08/2014 Sebastian Habibi Financial Some LAs may face significant increases in demand and cost for supporting carers arising from new rights in the Act, leading to increased volume of assessments. 3 Simon Medcalf 1. Develop and publish practical guidance for LAs in projecting demand and modelling costs for carers. 2. Develop practice guidance to describe application of the Act for carers, and support LAs to develop efficient operating models for assessment, support plans etc. 3. Data monitoring of demands and costs from supporting carers. 1. Simon Medcalf 31/10/ Cost modelling/assumptions provided to all LAs as part of broader modelling exercise over summer Revised IA published. Follow up work with ADASS carers network to look at unit cost underway. 2. Implementation support materials commissioned from ADASS Carers Network and under development for publication in November. Publication slipped to March ADASS carers network agreeing data monitoring needs as part of wider Care Act implementation data monitoring agree with ADASS Executive. Data monitoring proposals to be put to March 2015 Board. 11/03/ /03/ /06/2015 R CSRP s Issues Assumptions Register Page 4 of 7

5 <programme/project name> Issue Management Log OFFICIAL - SENSITIVE Issue Ref. raised Raised By Area Description of Issue Impact Issue Owner Action Action Owner Due By Action Updates I013 02/09/2014 Andrew Hughes Programme Implementation of the Care Act is being impacted by the need to implement other major changes such as the Better Care Fund, and Health and Care Integration in the same time period 3 Jon Rouse 1. Review Care Act and Better Care Fund major milestones in order to minimise conflicting deadlines, requirements and expectations 2. Capture milestones and dependencies as part of development of an integrated plan for 15/16 and 16/17 implementation that co-ordinates activity and requirements across Care Act and Better Care Fund programmes 3. Deliver communications to NHS partners to improve understanding of the Care Act and their role in working with councils to support implementation 4. Support LAs with the capacity to deliver multiple change agendas 1. Martin Caunt 2. Martin Caunt 3. Stephen Pollock 4. Jon Rouse 01/01/ Links made between Care Act implementation PMO and BCF task Force. Proposals for single quarterly data collections across all programmes and more co-ordinated support offers being explored as part of the programme planning. 2. Development of the integrated plan for the programme includes major milestones from related programmes. Testing with Local government implementation leads. Subject to Board approval plan will be published on Care act implementation web site and communicated at forthcoming consultation events on 16/17 reforms. Scenario analysis of 16/17 implementation plans include consideration of wider pressures on system 3. Public awareness campaign engagement with stakeholders includes key players in NHS. This includes waiting room information service, target alerts and bulletins, and national engagement with key representative groups. 4. Funding for preparation of 16/17 reforms includes 30m provision to support LAs capacity and capability to deliver. LA circular published in February 2015 to advise LAs on use of funds. Reviewed Next Review date Target Resolution X Ref: Number 11/03/ /03/ /06/2015 R002 NEW 16/03/2015 Programme Limited understanding by NHS partners of the change in requirements, and improvements / health benefits of the Care Act 3 1. Engagement with NHS partners as part of public awareness campaign 2. Direct communication to acute sector on new duties around delayed discharges 3. Direct communication to commissioners of providers and primary care on opportunities presented by the Care 1. Fraser Clubbe Act 2. Charlotte Buckley 3. Simon Medcalf 01/06/ The public awareness campaign team has briefed a range of NHS partners, many of whom have already shared information about the campaign and free resources with their networks. This has included: NHS Confederation, Royal College of GPs, Queen s Nursing Institute, NHS England who have shared campaign information with the National Clinical Directors and Chief Professional Officers. Further meetings are being scheduled with the Royal Pharmaceutical Society and Royal College of Nursing. 2. Letter from DH and NHS E planned before end of March to Acute sector Chief Executives. NA 27/03/ /06/2015 R CSRP s Issues Assumptions Register Page 5 of 7

6 ID Area Assumption Responsibility Comments / Verification A001 Finance Costs of early assessments of self-funders in 2015/16 have been based on the assumption of 80% take up Assumptions were revised to 80% following evidence from take up of other government policies where the benefits are more immediate. The impact assessment was revised and published in February Data monitoring of assessments will provide evidence of actual take up. Verification Actions - where assumption proved false 31/12/2015 OPEN A002 Planning After the General Election, there is no delay/ barrier to submission seeking confirmation of new Ministers intent on timing / delivery of these reforms i.e. no submission embargo covering this policy Advice to officials pre-election likely to set out potential restrictions. This could be updated once election outcome is known. 08/05/2015 OPEN A003 Planning New Ministers provide timely feedback on submission/s and wish to proceed with the programme to planned timing 31/06/2015 OPEN A004 Budget There is a Spending Review in summer 2015, and its outcome is known during October 2015 Government intent likely to be confirmed shortly after formation of new government. 30/05/2015 OPEN A005 Workstream - Appeals / Charging for Care / Informatics The consultation response and final published regulations and guidance do not differ significantly from that published in February and do not necessitate significant changes to the IT system specification or impact significantly on other implementation plans Consultation will provide indication of potential changes to regulations and guidance. New ministers decisions will however be the critical factor in determining the scale of change. 31/10/2015 OPEN A006 Local Government Implementation All local authorities develop and implement plans for delivery of 2016/17 reforms in a timely manner, based on assumptions for later ratification when necessary i.e. no loss of momentum during period up to feedback from new Ministers Andrew Hughes 3rd local authority stocktake of readiness in February 2015 will provide a baseline of action being taken to implement 2016/17 reforms. 4th stocktake planned for June 2015 will provide evidence of progress. This will be support by soft intelligence from Adult Improvement Advisers and Regional Care Act implementation networks. 31/07/2015 OPEN A007 Local Government Implementation All priority national implementation support products are available to local authorities covering 15/16 and 16/17 reforms Martin Caunt / Andrew Hughes 31/10/2015 OPEN A008 Budget Sufficient funding is available at national and local levels to cover additional costs of new burdens from 16/17 reforms. Furthermore, stakeholders (esp. LGA, ADASS, DCLG) accept funding risk is manageable Cost modelling with local authorities on 2016/17 reforms planned over March and April will provide additional evidence. Consultation on cap on care costs and new appeals system will provide some evidence of affordability. Local authority stocktake will provide qualitative evidence of local authority perception of funding risk for 2016/17 implementation. 31/06/2015 OPEN A009 Resources Sufficient Local Authority resources are available to work on implementing the 16/17 reforms i.e. staff are not diverted to embed 15/16 reforms or to work on other areas e.g. BCF Andrew Hughes 3rd local authority stocktake of readiness in February 2015 will provide a baseline of action being taken to implement 2016/17 reforms. 4th stocktake planned for June 2015 will provide evidence of progress. This will be support by soft intelligence from Adult Improvement Advisers and Regional Care Act implementation networks. 31/06/2015 OPEN

7 A010 Resources Sufficient national people resources are available to work on programme management, enabler and policy workstream teams, and to provide legal and other specialist advice and input at a national level when required Simon Medcalf OPEN A011 Workstream - Charging for Care Financial services industry will develop products in response to the cap on care costs and in accordance with the [concordat agreement] between DH and industry Sara Mason 31/12/2015 OPEN A012 Workstream - Appeals Costs from implementation of the administrative appeals system will be borne by local authorities and there is no centrally resourced provision of a pool of independent experts Laurence Erikson Consultation will provide indication of potential national role and potential costs. New ministers decisions will however be the critical factor in determining policy. 30//06/2015 OPEN A013 Workstream - Communications Phase 2 of Public Awareness Campaign investment sufficient to begin culture change required to encourage greater planning and preparation for the costs of care Fraser Clubbe / Phase 2 preparatory work will provide advice on likely impact of campaign. 30/05/2015 DRAFT Care Markets Informatics Eligibility & Assessment Scale of potential provider failure during set up of CQC oversight is manageable within interim arrangements between April and September Informatics systems not completely ready from 1 April 2015 this will not undermine implementation Estimate that circa 270,000 additional carers will come forward for an assessment in 2015/16, increasing to circa 360,000 per annum in steady-state. (The demand 2015/16 represents 75% of the steady-state estimate.) Richard Campbell / Sally Warren Charlotte Buckley Amy Baldwin Evidence from engagement with LAs and providers in Autumn 2014 suggests risk of systems not being ready is low and that workarounds can be used that will not have major impact on implementation In year data monitoring will include collection on numbers of carers assessments in 2015/16 31/09/2015 DRAFT 01/07/2015 DRAFT 01/10/2015 DRAFT Eligibility & Assessment Paying for Care NEW Workstream _ Legal Reform Regulations on eligibility describe level that allow LAs on average to maintain current access Uptake of DPAs will reach no more than the average of well-established local schemes (14% of self-funders or 31% of those eligible) in 2015/6 No savings realised in 1st year of implementation of the Care Act Paul Woods Edmund Hair Simon Medcalf In year data monitoring will include collection on numbers of eligibility determinations in 2015/16 In year data monitoring will include collection on numbers of DPAs in 2015/16 Assumptions revised in October 2014 impact assessment in light of evidence suggesting legal savings unlikely within 1st year of implementation. 01/10/2015 DRAFT 01/10/2015 DRAFT 31/03/2015 DRAFT