Police authority inspection – responding to consultation

Report: 17
Date: 8 June 2009
By: Chief Executive

Summary

This report summarises the key issues arising in relation to the recently announced HMIC/Audit Commission consultation on police authority inspection. The consultation period finishes on 10 June 2009. The report outlines the proposed MPA consultation response. It also considers some of the issues, for which the MPA will need to prepare, in advance of our inspection in the autumn.

A. Recommendation

That members comment on the draft MPA response to the consultation on police authority inspections and endorse it on behalf of the MPA.

B. Supporting information

Introduction

The Audit Commission and HMIC announced a consultation exercise on 29 April on the police authority inspection process. The closing date is 10 June 2009. There have been some significant changes in methodology since the beginning of the pilot period for example more focus on community engagement and ensuring outcomes that meet community needs. The inspection process is based on a “no surprises” approach. Police authorities were assured by the AC/HMIC at their consultation event on the 28 April that the consultation is a genuine exercise, as there are a number of differing opinions in key areas.

Consultation

The consultation document asks for feedback in five key areas. The questions are outlined below, as well as suggested responses. The Authority is invited to endorse the suggestions outlined – which will be reformatted into a letter to the Audit Commission/HMIC.

The consultation questions are as follows:

1. Do you agree with our proposed assessment themes, key questions and assessment criteria? If not, what do you think is missing?
   • The assessment themes, key questions and assessment criteria are laid out at appendix 1. On balance they appear to capture the core responsibilities of a police authority and, should enable the inspectors to understand how a police authority adds value to policing although we won’t be sure until we see the key lines of enquiry (kloes) due to be published in July. The MPA has been involved in the AC/HMIC reference group and has therefore been consulted on the development of the key themes. It is therefore suggested that MPA feedback is supportive of the proposals. The challenge in respect of the MPA will be ensuring that the inspectors understand the complexity of the London landscape.
   • There are two issues that could be developed further. Firstly there is no explicit mention of equality and diversity. Secondly, the MPA agrees with the concerns raised by the Police Authority Treasurers Group about the plethora of work around value for money. We are pleased that the Audit Commission has acknowledged the need to provide proper narrative around the overall framework. We also look forward to seeing more detailed ‘key lines of enquiry’ that will enable us to understand how inspectors are going to assess the less tangible aspects of the added value provided by police authorities.
2. Do the proposals provide a clear focus on how police authorities make a difference to securing improved policing outcomes for local people? If not, please suggest how we could make this focus clearer.
   • The proposals are fairly high level so it is difficult at this stage to know whether they are sufficiently focused or not, although as per comments above, they do capture the key areas of business for police authorities. The difficulty here will be demonstrating and more importantly, evidencing the influence of the police authority over service delivery.
3. Do you agree with our proposals for scoring?
   • Each is theme to be scored 1-4. Combined score will be delivered. There will be clear guidance about rounding up and down, aim to be as transparent as possible although there will be inevitably some instances where judgment has to be used. It is suggested that the MPA accepts the proposals, but urges transparency/dialogue if the scores have to be rounded up or down.
   • Of more concern is the absence of an agreed understanding of what constitutes a “good” police authority. This is of particular concern for the MPA. Although the MPA has much in common with police authorities across the country, there are key differences in terms of constitution, size and complexity. We would therefore seek more detailed guidance on how the scoring framework would take account of these key differences.
   • Members should note that the consultation event, there was some concern that providing combined scores would lead to police authorities being ranked, and that this was why combined scores were not applied to police forces during the baseline process. It should be noted that inspections in all other spheres in the public sector include combined scoring. In light of the comments above about the difficulty in comparing police authorities. Does the MPA want to comment on this?
4. Which of the options for peer involvement do you think we should adopt and why?
   • This is the one area of genuine concern for police authorities. Two options have been put forward in the consultation document - one with just a peer member, the other with either a peer member or chief executive. There was a very clear feeling at a recent consultation event for police authorities, that it should be a member and a chief officer although it is not clear if there is consensus in the APA about this. The MPA will need to come to a decision about this. There are two key issues. Firstly whether it is appropriate for officers/members to be assessing each other. There is also a concern about the capacity of the team, given that the HMIC and AC team members are going to have very limited knowledge of police authorities. Members are asked to provide a view on which model of peer involvement they support.
   • HMIC/AC/APA are developing specific PA focused accreditation with IDEA. Even if Members are accredited by IDEA, they will need to attend this training. It is not clear yet how may peer accredited members and chief executives are going to be required. This could place a significant burden on police authority chief executives.
5. Do you agree with our proposals for the police authority inspection framework?
   • This is a general question allowing police authorities to raise any concerns they have with any of the issues raised in the consultation document around methodology, timing etc. Other than the issues raised above, until we see the key lines of inquiry, it is difficult to know if the framework is robust. That said, there are some issues the MPA many like to include in its response:
   • The inspections are being undertaken in blocks of 10 and the MPA is in the first tranche which begins in Sept 09. Given the size of the authority, the complexity of London, the high profile issues we have on our agenda at the moment which place demands on member time (G20, ACPO recruitment, Olympics etc.), Business Management Group is clear that we should be arguing to be assessed later. The Chief Executive has been asked to write to the Chief HMIC and to make the case on their behalf.
   • Self assessment isn’t currently a requirement. Whist it isn’t wise to advocate undertaking a mandatory self assessment, the MPA may want to consider developing a narrative to help inspectors when they are on site. This will enable the MPA to consider its strengths and weaknesses (being self aware is likely to sit well with the inspectors, particularly if we can demonstrate that we have plans in place to address the weaknesses), and allow it to better showcase its achievements
   • If the MPA is unsuccessful in its bid to delay its inspection, the first tranche onsite activity between Sept and November 2009. Inspectors will spend a max 4 days on-site and the whole process will take 17 weeks from start to finish. Authority reports to be delivered within 8 weeks of onsite visit (draft within 3-4 weeks), with a national interim findings report published in Feb 2010. There was some disquiet at the consultation event, that this would not provide a comprehensive view of police authorities. Does the MPA have views on the publication of an interim report of findings based on 10 inspections?

C. Race and equality impact

As noted above, the extent to which equality and diversity is embedded within the framework is unclear, and the MPA will highlight the need to strengthen this element.

D. Financial implications

The inspection of police authorities is being undertaken with no additional direct cost to the authority, although clearly the opportunity costs of preparing for the inspection could be substantial. Officers will be looking to keep this to a minimum, without jeopardising the quality of evidence we put forward during the inspection. A further opportunity cost would be the participation of members or chief officers as peer inspectors.

E. Background papers

• Audit Commission/HMIC Consultation – Police Authority Inspection (published 29 April 2009)
• SOP report Police Authority Inspection, February 2009

F. Contact details

Report author: Siobhan Coldwell, Head of Oversight and Review, MPA

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

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