Achieving consistent and high quality Debt Advice An approach to Standards and Quality Assurance for the debt advice sector: Consultation response
2 Section Money Advice Service moneyadviceservice.org.uk
Contents Executive summary 4 Accreditation of Organisational Standards and Codes for Debt Advice Services 6 Summary of general points raised through the consultation 8 Summary of consultation questions and responses 10 Implementation plan 14 Revised Money Advice Service Quality Framework for Organisations 15 List of respondents 24 Acknowledgements The Money Advice Service is grateful to both the individuals and organisations that attended the consultation events held across the UK during February 2013, and to those that submitted written responses to the consultation. The Money Advice Service values the input from stakeholders into this process and welcomes the opportunity to work in collaboration to improve the quality and consistency of debt advice across the UK.
4 Executive summary Money Advice Service Executive summary 1. We believe that given the importance of debt advice interventions in people s lives, it is crucial that the advice given to clients is of the highest quality. Our paper Achieving Consistent and High Quality Debt Advice on which we consulted between December 2012 and March 2013, set out our proposed approach for achieving a consistent, high quality delivery of debt advice across the sector. Our decision to create a new framework against which existing standards that are currently in use across the advice sector could be measured and assessed is one that has received high levels of support. 2. The framework incorporates both organisational and individual elements of quality. It provides a single mechanism against which quality standards, membership codes, qualifications and vocational training currently used in the advice sector can be assessed; this will ensure that both an organisation and its individual advisers are delivering consistent and high quality debt advice. 3. We have developed our framework in light of the responses received through the consultation process. We have now incorporated the detailed list of internal processes and systems that will need to be evidenced by organisations to show that they meet a standard that fits within the framework. 4. The revised framework embodies excellence in debt advice delivery and it incorporates two elements, individual competencies and skills and organisational systems and processes, and outcomes. The framework provides for the first time a single, transparent and consistent mechanism against which both the free-to-client and fee-charging sectors can be assessed. 5. We will form and maintain strong on-going working relationships with each of the standard and membership code owners that meet the framework and implement the appropriate processes. This facilitate the sharing of information on whether debt advice organisations pass or fail audits. Standard owners will have to ensure that the compliance checks they carry out meet our minimum criteria, including on site audit and the assessment of advice. 6. We will investigate the development of an appropriate independent peer review process to provide additional reassurance of suitable and relevant advice to clients. 7. The organisational element of the framework is now complete. We will now appoint an independent organisation to map organisational standards and membership codes against this part of the framework. This will identify those that meet it in full, in part or not at all. Responses to the consultation on the individual element of the framework suggested that whilst the individual tasks identified in our proposal were accurate, the suggested role profiles were not necessarily reflective of the diversity of the sector.
Achieving consistent and high quality Debt Advice Executive summary 5 8. A small working group will meet over the summer of 2013 to put together a set of specific tasks, debt advisers need to perform and identify the skills and competencies required to perform those tasks. A set of National Occupational Standards (NOS) considering the inclusion of the Qualifications and Credit Framework (QCF) units, where relevant, that underpin these tasks will then be defined in order to assess the content of debt advice qualifications and training against them. These will then be mapped against the framework by an independent organisation to identify those that meet that part of the framework. 9. A standard, or membership code that is externally assessed as meeting the framework will be accredited and we will publish a list of those standards, and the organisations that comply with both parts of our framework, on our website. We will work with standard owners to keep this up to date, and this will enable over-indebted people to make more informed choices when accessing debt advice services. 10. The assurance provided by the framework will be evident to both creditors and funders of advice services. In this way the framework will act as an incentive for debt advice organisations to adopt and work to an accredited standard and this will impact on raising quality across the whole sector far beyond the services we fund. 11. For the projects we fund we will introduce a requirement to comply with a standard or code that meets our framework. From April 2014 we will only fund providers that hold an approved standard or code. Where an organisation fails to maintain an accredited standard then it will no longer be eligible to receive funding. 12. We have considered the value to the public of a Money Advice Service endorsement or logo displayed alongside the quality standard logo and concluded that this is not the appropriate time to do that. However, we will review the benefits of a public facing logo after a period of 12 months.
6 Accreditation of Organisational Standards and Codes for Debt Advice Services Money Advice Service Accreditation of Organisational Standards and Codes for Debt Advice Services 1. Our framework has been designed to enable the wide range of existing and new quality standards, membership codes, qualifications and training in use across the debt advice sector to be independently mapped and, where they meet the requirements of the framework, they will be accredited by the Money Advice Service. 2. The framework provides the foundation for raising quality and consistency in the delivery of debt advice and it covers organisational systems, governance, adviser skills and competence and outcomes for clients. 3. Throughout the consultation process we have taken into account the wide range of detailed views and suggested amendments and we have responded to these within the revised framework. The organisational element of the framework covering standards and codes has now been finalised and this can be found at page 15. The framework takes each of the three high level quality areas: focussed on client need, well governed and a learning organisation. It provides the details of organisational systems and processes that must be evidenced to standards and membership code owners. 4. All accredited standards and codes will need to show that they assess compliance through appropriate and rigorous processes that will include on-site audit, the assessment of advice and a three year audit cycle. 5. Accreditation will be open to standards, codes, training and qualifications covering both free to client and fee charging debt services. The accreditation process will begin by inviting all standard and membership code owners currently in use for debt advice, to submit evidence of their scheme requirements to enable a mapping of their respective quality standards and membership codes against the requirements of our framework. The mapping for training and qualifications will take place in the autumn so that the framework for individuals can be finalised in line with the responses to the consultation. 6. Once the mapping is complete and an assessment has been made, the results will be communicated to each standard and membership code owner. Recommendations to accredit will be made where a standard or code fully meets the framework. Where further development or modifications are required, a period of two months will be provided for this to take place prior to a formal reassessment. We will then work closely with the accredited standard and code owners to ensure that they share information on their audits of debt advice organisations so that we know which organisations comply with their standard.
Achieving consistent and high quality Debt Advice Accreditation of Organisational Standards and Codes for Debt Advice Services 7 7. To take this mapping work forward we will appoint an independent external assessment organisation early in the summer of 2013 to complete the assessment and accreditation process. All advice organisations and individuals who hold the appropriate accredited standard, or code, qualification or training will then be judged to meet the requirements of the framework and this will be disclosed on our website. 8. Our framework will require that standard owners audit organisations on a three-year cycle. Additional risk based triggers will need to be put in place e.g. through annual self-assessment or through a peer-review process which would alert standard and code owners to the need for an interim assessment. We will work with the owners of accredited standards, and codes, to encourage them to implement a more consistent and standardised approach to the process of assessing compliance. 9. We will develop a full, partnership working process with standards and membership codes owners to develop a mechanism to maintain a list of accredited advice organisations on the Money Advice Service website. 10. Our framework will be reviewed every five years, with the exception of where there are changes in legislation or regulations that occur. At this point we will also reassess all accredited standards, membership codes, training and qualifications against the revised framework and renew accreditation where it is appropriate. 11. Any new standards, membership codes, training or qualifications covering debt advice can be submitted for assessment on an on-going basis.
8 Summary of general points raised through the consultation Money Advice Service Summary of general points raised through the consultation In addition to the specific consultation questions, respondents had raised a number of more general points in their individual responses. These comments together with our responses are shown below: 1. Respondents felt it was important that there should be a strong alignment between the Money Advice Service Quality Framework and the Financial Conduct Authority (FCA) requirements for the regulation of debt advice. Response: We are committed to working with the FCA to embed adherence to our Quality Framework into the regulatory architecture through their authorisation, supervision and enforcement work. We have responded to the FCA consultation on the consumer credit transfer and recommended that adherence to the Money Advice Service Framework should be a condition of granting authorisation to organisations delivering debt advice. We further advised that the FCA should gather data on adherence to the framework from all debt advice organisations entering the new regime, including those that will be operating under interim permissions. Our response to the consultation can be found here: www.moneyadviceservice.org.uk/files/fcacc-response-20130501.pdf 2. Respondents wanted clarity on the implications for debt advice organisations where they did not meet one of the accredited standards or codes. Response: We will require all organisations that we fund from April 2014 to hold a standard or membership code that has been accredited against the quality framework. Any services that lose an accredited standard whilst funded will not have funding withdrawn immediately but will first exhaust all due process set out in the relevant standard or code that they hold including any subsequent appeal. Only after that process is complete would we withdraw funding. We will also work with, and encourage other funders, of debt advice to require adherence to the framework in their funding decisions for debt advice. 3. Respondents felt that the framework did not sufficiently reflect or focus on client outcomes and it was proposed that this was strengthened in a revised framework. Response: The framework specifically requires organisations to demonstrate that they capture evidence and record client outcomes and that they analyse and review those outcomes to improve their services. To facilitate this process the Money Advice Service is developing a common evaluation framework that will enable the measurement of client outcomes across all channels of advice. This framework will be published with a toolkit that will be made available to all debt advice providers.
Achieving consistent and high quality Debt Advice Summary of general points raised through the consultation 9 4. Respondents wanted full transparency on whether organisations that held accredited standards or codes were offering free or fee charging services to the public. Response: It is important that the framework remains a single mechanism that measures quality consistently across the whole sector. The list of organisations that hold accredited codes and standards will be published on our website and this will distinguish both free and fee charging advice providers. 5. Some respondents expressed concern that the Money Advice Service framework would not raise quality across the sector but would just set a minimum benchmark. It was suggested that there was a potential for inconsistent and variable levels of quality because of the differences in each of the standards and codes. Response: The framework was constructed by first identifying the critical elements of quality that a debt advice organisation must exhibit, and then looking at the best practice measures that exist in the sector. This will ensure that accredited standards and codes would require evidence of the highest levels of quality in any organisation that they award with their accreditation. The framework raises quality by linking individual skills and competences and organisational processes and systems into a single framework providing a comprehensive measure of quality that will serve to raise standards in the sector. The framework sets out a list of detailed evidence that any accredited standard or code owner will be required to assess in an organisation, providing consistency in quality measures across the range of standards and codes. 6. Some respondents expressed a view that the framework should support, strengthen and evidence effective relationships between debt advice providers and creditors, thereby enabling and maintaining a smooth and timely journey for the client. Response: The framework includes a requirement for debt advice organisations to be able to demonstrate that they have clear and effective processes and policies in place for engaging with and maintaining effective relationships with creditors, including providing appropriate feedback to them. Our Business Plan 2013/14 outlines work we are doing on creditor referral, common data and triage, all of which once developed and implemented will facilitate and strengthen the links between debt advice providers and creditors, enabling a better client journey. 7. Respondents wanted to understand the details of the capacity building support that Money Advice Service would provide and the scope and criteria for such funding. Response: Our 2013/14 business plan identified funding to support our accreditation work and the capacity building, for the work on Quality and Standards. This will provide some initial funding in the short term to help free to client advice organisations bridge gaps and work towards meeting an accredited standard or membership code. The funding will be available to non-profit making debt advice organisations, both those that we fund and others. We will publish a full set of criteria and the timescales for applications for funding in the autumn. We will explore what capacity building requirements are necessary across the free debt advice sector and we will seek funding to address those requirements.
10 Summary of consultation questions and responses Money Advice Service Summary of consultation questions and responses Question 1 Is there any additional value in using a Money Advice Service logo linked to the relevant Quality Standard badge that is customer facing so that it is widely recognisable to the public? 1. There was a mix of responses to this question and a number of concerns were identified. These included a view that there would be a dilution of existing brands and the potential for clients to be confused by too many brands. It was suggested that perhaps a more simplified endorsement would be more appropriate. A view was also expressed that the use of any Money Advice Service brand should be optional for organisations so where it may prove confusing or misrepresent the entirety of the service available it would not be used. Respondents also felt that any public facing Money Advice Service branding would need to be heavily promoted and publicised to make it meaningful. Response: We will not be seeking to implement a public facing Money Advice Service logo or endorsement at this time but we will review this after a period of 12 months. A list of all debt advice organisations that hold an accredited standard or code will be published on the Money Advice Service website and categorised as appropriate. It is important that creditors, the public and advice providers are aware which debt advice services hold an accredited standard or code. We will encourage the public to use accredited debt advice services listed on the Money Advice Service website which will also clearly identify those that are free and those that charge a fee to the client. Question 2 Which standards or membership codes do you consider to fully meet our framework? 2. A range of standards and codes were highlighted through a number of sources as potentially meeting the Money Advice Service framework. Those referred to included; the Citizens Advice Membership Code; Citizens Advice Scotland Membership Code, Scottish National Standards; Advice Quality Standard (AQS); PQASSO; DRF Code and the LSC Specialist Quality Mark. Response: The Money Advice Service has been meeting with standard and membership code owners throughout the consultation period to discuss working with Money Advice Service on accreditation. Now that the organisational element of the framework has been finalised these and other standards and membership code owners will be invited to be independently assessed to identify whether their standard or code meets the requirements of the framework. Question 3 Are there any requirements that should be included or excluded from the framework? 3. There were a number of proposed amendments and suggestions submitted by respondents. Some respondents felt that there should be a greater focus on evidencing the quality of advice within the framework; strengthening evidence that demonstrated debt management protocols are being followed; and ensuring there are requirements which align and provide coordination with the requirements of the FCA.
Achieving consistent and high quality Debt Advice Summary of consultation questions and responses 11 Response The proposed framework for organisations has been revised taking into account many of the amendments proposed. On the point of assessing quality of advice given to clients we have incorporated further measures to specifically review the quality of advice being delivered, and we will work with standard and code owners to ensure that part of their compliance checking includes on-site audit and the assessment of advice. We will investigate the development of an appropriate independent peer review process to provide an additional independent assessment of the quality of advice. We are pleased to note that the Debt Management Protocol now includes a requirement for fee charging debt advice organisations to work with the requirements of the framework. We have also set out our position in working with the FCA to embed the framework into their procedures for the regulation of debt advice. Question 4 Are the role profiles identified correct and reflective of best practice across the sector? 4. The feedback from the advice sector was that the role profiles proposed were not broad enough to reflect the diversity of practice across the sector. The prescriptive nature of the role profiles did not allow for sufficient flexibility to incorporate different business models and organisation types and sizes. It was suggested that a taskbased approach should be used to identify the appropriate set of National Occupational Standards (NOS) and that this would better reflect the variable job roles that exist. Response: We accept that the proposed role profiles are not flexible enough to allow for the diversity of job roles across the debt advice sector. We will set up a small working group of stakeholders led by a subject matter expert to meet over the summer to redefine a set of National Occupational Standards (considering the inclusion of QCF Units where relevant) against which training and qualifications can be mapped. Where these meet the requirements, through independent assessment, they will then be accredited where appropriate. The individual element of the framework will be finalised and published in the autumn. Question 5 Have the appropriate NOS been used within the role profiles? 5. Very little specific feedback was received. Some respondents said that they were unfamiliar with the detail of NOS; some provided overarching statements of support, and others expressed the view that the number of individual NOS allocated to each role profile were too many and may be impractical. Response: As outlined in the response in Question 4 above. Question 6 Which debt qualifications and training courses have been developed using NOS? 6. A range of debt qualifications and training were identified that had used NOS in their development including; the ICM accredited qualification used by Stepchange; IMA qualification; Debt Resolution Forum - Edexcel Certificate in Debt Resolution Advanced BTEC; Citizens Advice training; Advice UK training; Wiser Adviser; Advice NI training and Skills for Justice Framework Legal Advice 4. Response: As outlined in the response in Question 4 above.
12 Summary of consultation questions and responses Money Advice Service Question 7 - Are there other requirements that a sole debt adviser should evidence? 7. A number of suggested additional requirements were identified and referenced across the responses, these included a requirement for on-going Continuous Professional Development (CPD), and ensuring that lone advisers must demonstrate how they keep up-to-date with legislative changes. It was suggested that they must have access to a specialist unit, they must hold the relevant license and have suitable insurances in place such as professional indemnity; they must be part of a system that enables them to receive support/supervision relating to their area of law on a regular basis, including independent file/peer review; and they need to be a member of a professional body. Response: The Money Advice Service recognises that in order to meet the requirements of the framework sole advisers will need to have access to additional support. The individual element of the framework will include additional overarching requirements for sole advisers due to the higher risk posed by advisers operating in isolation from support. Question 8 Do you agree that this is the appropriate approach to evidencing the quality of individuals delivering debt advice? 8. Very few responses were received on this question. There was some concern that just undertaking training and getting a qualification was not a sufficient guarantee of on going assurance for high quality advice. Qualification, training, standards and code owners should be required to assess random samples of individual adviser casework to ensure that quality was looked at across both debt advice and administration. This reinforced the general feedback that highlighted the importance of including independent case review (peer review) as a mechanism for assuring quality. Response: The proposed framework for individuals will be revised based on a new set of NOS/QCF Units identified over the summer by our working group. On the point of assessing quality of advice given to clients we will investigate the development of an appropriate independent peer review process to provide an additional independent assessment of the quality of advice. The individual component of the framework when published will include a requirement to be qualified to a recognised level to receive Money Advice Service accreditation. Sole advisers will also be required to be part of a membership body with access to updates, CPD, peer support and a range of technical support. In addition they will need to demonstrate that they hold all of the relevant insurances and licence requirements. Sole advisers will also be subject to any independent peer review as previously outlined.
Achieving consistent and high quality Debt Advice Summary of consultation questions and responses 13 Question 9 Currently different standards owners use a variety of accreditation processes. How often is it appropriate for standards owners to monitor and review compliance? 9. Views ranged considerably with approximately a third of respondents considering a three year assessment of compliance to be appropriate, another third felt that an annual review with varying intensity and a different focus each year was more suitable. Another group of respondents suggested that following an initial assessment a purely risk-based approach should be adopted. Response: Our view is that a default position for the frequency of assessment should be every three years. We will also work with standard and membership code owners to develop an annual checklist for organisations to complete and submit, to identify levels of risk and to flag up where an additional audit may be required. Question 10 How often should the Money Advice Service review standards and codes against our Quality Framework? 10. Responses were mixed. Some respondents felt that every five years was the appropriate time period, with the requirement to review specifically when there were any legal or regulatory changes. Others felt there should be a minimum of an annual review, and some responses suggested that a review was not necessary unless there were regulatory or legal changes. Other suggestions included that they should be reviewed against the framework every three years with the option for annual self-assessment unless standards themselves changed. Response: Our view is that it is important to achieve a stable established framework and that it is not desirable to make regular or unnecessary changes. Whilst there will be a need to make changes periodically where there are any major regulatory or legislative changes, our default position is that we will review standards against our framework every five years. Question 11 - Should the Money Advice Service appoint an independent third party to conduct a verification audit of organisations working to the standards that meet the Quality Framework? 11. Responses to this question were mixed with some expressing support for an independent third party suggesting that this would offer transparency and independence in the process. Other respondents felt that it would be a better use of resources and a more proportionate approach to ensure that standards owners were more transparent in their own audit processes and more effective in ensuring compliance. Response: We do not believe that it is necessary or desirable to conduct any verification audit through a third party organisation. However, we will continue to work alongside standards and membership code owners to understand the processes and safeguards they have in place in determining how organisations demonstrate compliance.
14 Implementation plan Money Advice Service Implementation plan Money Advice Service Quality Framework for Debt Advice Activity Completion date Publication of the Money Advice Service Organisational Component of Quality Framework. Summer 2013 Establish a working group of stakeholders to undertake further developmental work on the individual component of framework. Working group to meet on three or four occasions. To develop and agree a set of specific tasks, skills and competencies that debt advisers need to perform (Debt advice related tasks only). To identify the appropriate National Occupational Standards/QCF units that underpin these tasks. Issue tender and appoint a third party organisation to conduct mapping of quality standards and membership codes. Third party review of standards and membership codes, including development discussions with owners. Publication of Money Advice Service Individual Component of Quality Framework (including plans for accreditation of sole advisers). Third party review of training and qualifications, including development discussions with owners. Summer 2013 Summer/Autumn 2013 Summer 2013 Summer/Autumn 2013 Autumn 2013 Autumn 2013 Scope, eligibility criteria for capacity building fund to be published. Autumn 2013 Investigate the development of an independent peer review process. Autumn 2013 Accreditation award and continued development work with standards, code membership, training and qualification owners. Winter 2013 Assessment of Money Advice Service funded debt advice organisations. Winter 2013 Develop and maintain within the Money Advice Service website an online list of accredited standards, membership codes and organisations holding Money Advice Service accreditation. January 2014 onwards
Achieving consistent and high quality Debt Advice Revised Money Advice Service Quality Framework for Organisations 15 Money Advice Service Quality Framework for Organisations Section 1: Meeting Clients' Needs A debt advice service that is driven by client need first and foremost, focused on access to advice and timely outcomes Theme Purpose Quality Measure Measurements/illustrations Accessible 1.1 To maximise reach of service Accessible 1.2 To build awareness of the service and encourage usage Service is easily accessible to the community Effectively communicate and promote services to potential clients Up-to-date community and client profiles maintained. In addition, services could produce an annual statement identifying any specific advice needs anticipated for these communities. This could be incorporated into a Service Plan Evidence of regularly reviewing and adapting the service based on client need. Access should be assessed as a minimum against: nhours of service noutreach (geographic accessibility) including virtual access. nmethods of delivery (channels) nrange of formats, languages and abilities Evidence of a client-focused communication strategy and action plan compliant with statutory rules. Other organisations engaged regarding changes to services or practice Evidence that clients, potential clients and external organisations are clear about the level and type of service available, and there is a clear and defined process for referral
16 Revised Money Advice Service Quality Framework for Organisations Money Advice Service Section 1: Meeting Clients' Needs A debt advice service that is driven by client need first and foremost, focused on access to advice and timely outcomes Theme Purpose Quality Measure Measurements/illustrations Accessible 1.3 To facilitate effective and timely referrals Responsive 1.4 To ensure clients needs are met with the right tools and resources Responsive 1.5 To facilitate client outcomes. Builds and maintains strong formal networks that cater for current and potential client need Provides appropriate information and support Delivers appropriate client outcomes through effective advice Proactive in seeking, building, using and keeping up to date referral routes Evidenced use of an effective process for engagement with and feedback to creditors Maintain records of referrals, including referrals in and out of the service Referral routes identified for the delivery of all advice channels Referral routes identified for all potential advice solutions needed e.g DRO/DMP/IVA A series of provisions should be in place throughout the client journey including: Referral processes for specialist debt and nondebt related services embedded with clear information to clients at the outset Self-help and assisted self-help resources are accessible and provided where appropriate Processes in place for clients to be kept informed of their case through whole journey and the process communicated by which clients can access personal information held about them Client journey can be articulated by all levels of staff Clients outcomes are measured and captured frequently, even when referred Client outcomes have been used to improve future client experience through service changes
Achieving consistent and high quality Debt Advice Revised Money Advice Service Quality Framework for Organisations 17 Section 1: Meeting Clients' Needs A debt advice service that is driven by client need first and foremost, focused on access to advice and timely outcomes Theme Purpose Quality Measure Measurements/illustrations Responsive 1.6 To ensure services are targeted, designed and promoted appropriately Trusted 1.7 Building and maintaining clients, confidence in the objectivity and impartiality of advice Define and understand clients needs Act and be seen to act with impartiality and integrity at all times Systems in place for recording client information and any specific needs Client input into the design and development of services Client feedback systems in place with evidence of adapting services in relation to needs Records identify clients needs, any advice given and the actions to be taken and by whom Records accessible to all advisers Effective and appropriate policies and practice on: nconfidentiality and access to information nsafe maintenance and destruction of case files nmanagement of case files nforms of authority enabling the provider to speak or act on behalf of the client nthe protection of client data nconflict of interest, including the management of conflict of interest in staff and remedy decision Evidence of a published clear client charter that has a commitment to treat service users with respect and sets out any expectations of behaviour they have of clients
18 Revised Money Advice Service Quality Framework for Organisations Money Advice Service Section 2: Well governed Theme Purpose Quality Measure Measurements/illustrations Compliance 2.1 To deliver a quality service to meet clients needs free from legal challenge Compliant with appropriate legislation Health & Safety, Charity, Equality & Diversity, Company, Regulatory, Employment, DPA, Consumer Credit (including standards set out by the regulator in rules/ guidance) Insurances held are appropriate to the service provided Evidence of organisation and staff awareness of legislative and / or regulatory requirements Staff are aware of routes for reporting breaches in requirements e.g whistleblowing Transparency and longevity 2.2 To provide a consistent and sustainable service to clients Financially viable An annual budget Annual profit and loss account or income and expenditure account Annual balance sheet Quarterly variance of income and expenditure against budget Accounts are monitored at least quarterly by management committee / board Forecasting model meaningfully assesses financial strength Evidence of financial review by an independent source Transparency and longevity 2.3 To ensure a sustainable organisation Identifies and seeks to mitigate risks Up to date risk log with mitigation plan for organisation and individual projects and services (including HR needs)
Achieving consistent and high quality Debt Advice Revised Money Advice Service Quality Framework for Organisations 19 Section 2: Well governed Theme Purpose Quality Measure Measurements/illustrations Leadership 2.4 To provide vision and clarity of purpose Effectiveness 2.5 To enable the assessment of performance against service aims and objectives and to drive and enable continuous improvement of the service Effectiveness 2.6 To deliver high quality and appropriate services across the organisation Well led Gathers, challenges and scrutinises monitoring data Staffed by competent people who are appropriately trained Strategic aims and operational objectives for the service are clearly set out All staff and volunteers have access to policies and procedures and they are embedded into induction Supervision process is adhered to for all staff involved in the advice process Clear outcomes for the service are defined and success measured against them Collects and collates a consistent set of client data and evidenced use of management data Evidence of CPD activity for Trustees/ Management Board/staff Staff are aware of service changes Evidence of improvements following service, client or environmental reviews where relevant All staff involved in delivering the service have achieved identified core competencies before they advise the public Staff are aware of their tasks and responsibilities and where to turn for help if faced with a problem beyond their own abilities Staff feedback systems in place and used by management Supervision is delivered by appropriately trained staff within or outside the organisation Evidence that all cases are dealt with by an adviser trained/qualified to the appropriate level of debt advice as detailed in the individual components of the Money Advice Service Quality Framework
20 Revised Money Advice Service Quality Framework for Organisations Money Advice Service Section 2: Well governed Theme Purpose Quality Measure Measurements/illustrations Effectiveness 2.7 To maximise the efficiency and effectiveness of its service Effectiveness 2.8 To maintain and improve quality of advice Effectiveness 2.9 To provide transparency, accountability and longevity of the service Manages resources well Demonstrable internal quality assurance process including appropriate/ effective centralised systems and controls Sets out clear plans and timescales Attendance records are recorded Processes in place to reduce any potential nonattendance of clients Record of client access routes and consistent use of assessment mechanisms to inform client journey Evidence that financial prudence is observed with the organisation management eg. procurement procedures Use channel shift where appropriate Evidence of internal quality assessment and responsibility for maintaining quality made clear in the management structure Quality is maintained where part of the service is delivered by a third party Evidence that systems and processes are reviewed regularly eg. operation and advice processes Plans outline service delivery aims, timelines for service developments and finances
Achieving consistent and high quality Debt Advice Revised Money Advice Service Quality Framework for Organisations 21 Section 3: A learning organisation Theme Purpose Quality Measure Measurements/illustrations Reflecting 3.1 To identify the opportunities to develop the organisation and the service Reflecting 3.2 To improve the quality of advice and delivery across the sector Reflecting 3.3 To improve the quality of advice and skills levels of advisers Conducts selfevaluation when appropriate Shares evidence based good practice with peers Reaches out to other debt providers and other sectors to learn Facilitates learning and development Completion of self-assessment audit of service Use of client and community profiles to identify new and future trends Service strategies are updated and reviewed against the aims and objectives of the organisation Services are subject to regular independent review and/or evaluation of advice outcomes Systems in place for staff learning/training Internal communications documentation covering good practice and success Engagement in external forums/workshops/ meetings where best practice is shared Evidence of involvement in peer-to-peer support and learning Staff appraisals, supervision and training needs analysis are completed for staff and the organisation, including evidence of active performance management Advisers have access to a suitably experienced person internally or externally, who can provide guidance
22 Revised Money Advice Service Quality Framework for Organisations Money Advice Service Section 3: A learning organisation Theme Purpose Quality Measure Measurements/illustrations Reflecting 3.3 To improve the quality of advice and skills levels of advisers Actioning 3.4 Responsive and adaptable Facilitates learning and development To innovate and improve service delivery internally Training plan and continuous professional development plan in place for all staff and volunteers Process that uses evidence from client cases for staff development Arrangements are in place to ensure that the service and staff have access to up-to-date reference materials and appropriate journals Services to evidence that the casework files of individual advisers are subject to suitably qualified, independent review Evidence of observed client interaction eg. call listening, shadowing Supervisors/trainers to retain one-to-one client advice skills to a proportionate level Evidence based changes designed into service plans Review of client journeys
Achieving consistent and high quality Debt Advice Revised Money Advice Service Quality Framework for Organisations 23 Section 3: A learning organisation Theme Purpose Quality Measure Measurements/illustrations Actioning 3.5 To improve service delivery and improve client focus Actioning 3.6 To maintain appropriate service delivery and staff skills Gathers and responds to client feedback Identify environmental changes and responds effectively Evidence of actively gathering client feedback and responding to clients Client complaints procedure exists, is clear in client journey and is complied with Channel shift is clear within process and procedures to support more efficient and appropriate support for clients Evidence of process in place for clients and advisers to make an accurate assessment of need and service varied accordingly Evidence of external engagement eg. participation in local advice networks Subscribes to industry publications Evidence of environmental and service review shaping training and development of staff
24 List of respondents Money Advice Service List of respondents Advice NI Advice Services Alliance (ASA) Advice UK Age Concern Torfaen Age UK British Bankers' Association (BBA) Charities Evaluation Services (CES) Cheshire East Citizens Advice Bureau Citizens Advice Citizens Advice Northern Ireland Citizens Advice Scotland Community Housing Cymru Group Community Money Advice Council of Mortgage Lenders (CML) Credit Services Association (CSA) Debt Managers Standards Association (DEMSA) Finance & Leasing Association (FLA) Financial Services Consumer Panel Gateshead Citizens Advice Bureau HSBC Institute of Money Advisers (IMA) Leeds Metropolitan University Leicestershire Citizens Advice Bureau Lloyds Banking Group Money Advice Scotland Money Advice Trust (MAT) National Association of Student Money Advisers (NASMA) Nick Lord Office of Fair Trading (OFT) Peaks & Plains Housing Trust R3 Association of Business Recovery Professionals Smaller Businesses Practitioner Panel StepChange Debt Charity Stockport Council The Debt Resolution Forum (DRF) The Highland Council The Hyde Group The Institute of Credit Management (ICM) The Legal Aid Agency Welsh Government Zero-Credit Ltd
Achieving consistent and high quality Debt Advice Section 25 Money Advice Service Holborn Centre 120 Holborn London EC1N 2TD Annex 3 moneyadviceservice.org.uk
Money Advice Service June 2013