BEST VALUE PERFORMANCE INDICATORS 2002/2003
Department for Transport, Local Government and the Regions
Comments from the Association of Chartered Certified Accountants
December 2001
Executive Summary
The Association of Chartered Certified Accountants (ACCA) is pleased to have this opportunity to comment on Best Value Performance Indicators 2002/2003. These comments have been prepared in consultation with members of ACCA's Public Sector Technical Issues Committee, a group of experienced accountants working in the public sector.ACCA supports the reduction in the number of Best Value Performance Indicators (BVPIs), but we are concerned that the Government has yet to develop a stable suite of BVPIs which can be used to assess the relative performance of local authorities and measure improvements in the quality of their services from year to year. This failure is despite:
- the assertion that the proposals in the consultation
document were developed following the principle that BVPIs should be specified
'for sufficient time to generate a pattern of year-on-year data'
and - the statement last year that BVPIs would not be changed this year.
- the consultation paper proposes to reduce the number of BVPIs by around a quarter
- nearly a third of the BVPIs proposed for 2002/2003 are new or have been amended
and - last year 19 BVPIs were introduced, of which 6 are proposed to be deleted this year.
We believe that the reasons for many of the proposed changes have not been adequately explained and in several cases the definitions for the amended BVPIs are not complete.
ACCA believes that this consultation exercise has not followed the Government's own good practice on written consultation. A consultation period of only four weeks was adopted rather than the generally recommended period of 12 weeks. We believe that the adoption of longer consultation periods and adequate piloting of new or amended BVPIs should reduce the level of year-on-year changes. General Matters
Support for the reduction in the number of performance indicators
1. We support the reduction in the number of BVPIs which are to be specified by the Government. We consider, in general, that BVPIs should be developed locally to reflect the local environment and the specific priorities of the local authority concerned.
Extent of change of performance indicators
2. We are concerned that the Government has yet to develop a stable suite of BVPIs which can be used to assess the relative performance of local authorities and measure improvements in the quality of their services from year to year. This is despite the stated intention last year that:
'indicators prescribed for 2001/2002, should also be prescribed for 2002/2003. We believe this continuity will be welcomed by all who have an interest in improving the quality of local services'.
3. The consultation paper proposes to reduce the number of BVPIs for principal local authorities by around a quarter compared to last year and by half since the introduction of Best Value the previous year. In addition, nearly a third of the BVPIs proposed for 2002/2003 are new or have been amended. Last year 19 BVPIs were introduced, of which 6 are proposed to be deleted this year.
4. This degree of change means that:
- the information provided by many performance indicators is not comparable from one year to the next
and - an onerous administrative burden is placed on local authorities as they have to develop new or amended systems to provide the required data.
- that BVPIs should in normal circumstances be specified for sufficient time to generate a pattern of year-on-year data
and - that the Government should seek to reduce the overall burden of bureaucracy placed on local government, particularly by the ever increasing central demands for information and data.
6. We consider that, in several cases, the reasons for the proposed amendments or deletions of BVPIs have not been adequately explained in the consultation document. In a number of cases, the proposed BVPIs have yet to be comprehensively defined.
7. We believe that, in future, careful thought and consultation should be undertaken before new BVPIs are introduced or existing ones are amended. We also believe that new or significantly amended BVPIs should be adequately piloted before being introduced. These measures should help to ensure that sufficiently robust definitions of BVPIs are developed and that the extent to which BVPIs are changed from year to year is kept to a minimum.
Measuring cost effectiveness
8. We welcome the suggested development of a methodology for measuring cost effectiveness which could be used to assess the extent to which local authorities are achieving the required 2% annual efficiency gains. We believe, however, that to be successful this initiative needs to be carefully thought through and, as far as is possible, to gain the support of local authorities and other stakeholders. For this reason, we do not think there is adequate time for the Government to specify such a national performance indicator in advance of next year.
9. We believe that the proposed consultation on the results of research into developing such a methodology should ensure that all parties are provided with adequate time carefully to formulate their responses. This exercise should then be followed with a pilot study to explore the robustness of the methodology which has been developed.
Length of the consultation period
10. ACCA believes that it is unfortunate that this consultation exercise has not followed the Cabinet Office Code of Practice on Written Consultation. A consultation period of only four weeks has been adopted rather than the generally recommended period of 12 weeks.
11. The relatively short consultation period has made it difficult for us to consult our members working in local government to discuss the important issues raised by the consultation paper and to prepare a fully considered response. Comments on Specific Best Value Performance Indicators
12. In this section we provide comments on some specific BVPIs in the format requested by the consultation document. We have only provided comments on a limited number of the BVPIs where we have specific points to raise.
13. We have provided comments on the following proposed new BVPIs:
- BV(X7) - Roads not needing major repair (Transport)
and - BV(X8) - Delegation to officers (Environment/Planning).
- BV6 - Percentage turnout for local elections (Corporate)
- BV84 - Number of kilograms of household waste collected per head
- BV159 - Alternative tuition (Education)
and - BV160 - Percentage of primary classes with more than 30 pupils in years 3 to 6 (Education).
15. We welcome the move from the input-based indicator (BV93) that this BVPI aims to replace. We believe, however, that further thought needs to be given to the development of a suitable BVPI.
16. We are concerned that further guidance has yet to be developed on the definition for this proposed BVPI. We are also concerned that future changes are planned for this BVPI which will change the focus from 'road condition' to 'change in road condition' without specifying at this stage what these changes will be. We note that BV96 and BV97 are also to be retained to monitor the condition of roads.
Definition
17. We are concerned that the definition for this BVPI will not be easily understandable by the lay reader. In addition, the proposed definition is a mixture of outputs and inputs.
BV(X8) - Delegation to officers (Environment/Planning)
18. We agree that, in many cases, delegation of planning decisions to officers is an effective means of speeding up the handling of planning applications. We believe, however, that it is fundamental for planning decisions to be taken in an open and accountable manner, which means that the role of elected members in the process is key. We do not consider it appropriate to suggest that in all cases it is preferable to delegate planning determinations to officers.
19. In addition, two other existing BVPIs relate to the speed with which planning applications are determined (BV109 and BV110), although we recognise that it is proposed to delete BV110.
BV6 - Percentage turnout for local elections (Corporate)
20. We believe that this BVPI is an important indicator of the health of the local democratic process. As the statistical information from this BVPI is collected through other sources, its deletion will not significantly reduce the administrative burden on local authorities.
21. The turnout for local elections has declined in recent years. We consider that the deletion of this performance indicator could be interpreted as an attempt to reduce further reporting of this fact. Each of the three reasons given for deleting this BVPI were in existence when this BVPI was first proposed and therefore do not provide an adequate reason for the proposal to now delete this performance indicator.
BV84 - Number of kilograms of household waste collected per head
22. We believe that this BVPI should be retained. The main argument suggested for its deletion is that it is not outcome focused. In contrast, BV86, relating to the cost of waste collection per household, which is input focused, is to be retained.
BV159 - Alternative tuition (Education)
23. This BVPI was amended last year and no reasons are given for the further proposed changes. Two amendments are being proposed:
- further analysis of the hours of alternative education which are provided to permanently excluded pupils
and - excluding pupils for the first 15 days for which they are excluded from school.
25. We believe that this BVPI should not be amended without adequate justification of the proposed changes in terms of significant improvements to the quality and understandability of the information provided.
BV160 - Percentage of primary classes with more than 30 pupils in years 3 to 6 (Education)
26. We believe that this BVPI should be retained. There is a Government target of 30 pupils per class for years 1 and 2 of primary school. Individual schools are provided with additional resources to ensure that this target is achieved. Once the relevant cohort of pupils moves into years 3 to 6, these additional resources are no longer generally available to primary schools. As a result, class sizes in years 3 to 6 may inevitably increase. This BVPI was subject to amendment last year.