Best Value Performance Indicators 2003/2004
Comments from The Association of Chartered Certified Accountants
October 2002
The Association of Chartered Certified Accountants (ACCA) is pleased to have this opportunity to comment on Best Value Performance Indicators 2003/2004 (the consultation document). 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 is pleased to note the significant reduction in the number of proposed changes to the suite of proposed Best Value Performance Indicators (BVPIs) compared to previous years. We note, however, that the number of changes is still almost 30% of the number of Indicators used last year and the number of new BVPIs proposed this year is 12 (as two are multiple performance indicators) compared to only 9 last year. Thus the Government still has yet to achieve its professed aim of establishing and maintaining a consistent set of BVPIs to allow year on year performance comparisons.
As a result, the following comment, which we included in our response to last years consultation exercise on BVPIs, remains valid:
"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."
We are disappointed that little progress appears to have been made in using BVPIs to assist authorities to measure the extent to which they are achieving the 2% efficiency target included in the National Public Service Agreement for Local Government. The consultation document merely notes (on page 9) that "further work is planned" in this area. We are pleased, however, that the suggestion, made in our response last year, to undertake a pilot study to explore the robustness of the suggested methodology has been accepted.
We are also disappointed that further consistency and co-ordination has not been achieved in the various agreed priorities for local government, for example:
- seven agreed head-line priorities for local government have been agreed with the Local Government Association
- only 4 of the15 elements of the National Public Service Agreement for Local Government are to be monitored by BVPIs
- only 20 of the proposed 101 BVPIs are to be used to assess the 15 elements of the National Public Service Agreement for Local Government
and - a Comprehensive Performance Assessment process which the Government has instructed the Audit Commission to develop this year simultaneously with the current review of BVPIs.
The current BV30 on the number of three year olds who have access to good education appears clear and covers an important area of local government service provision. The suggestion that local authorities "will wish to consider continuing to monitor their performance against this as a local indicator" (page 25) appears to confirm this view. The deletion of this indicator will, however, make it more difficult to assess the national level of success in this area.
Whilst we accept that the quality of early years education is important, we believe that this aspect should be reported on in addition to the number of children benefiting from this type of education. In addition, we do not accept that the proposed BVPI, BV(X1), addresses this issue in a way that will be clearly understood by most people, for example one aspect is described as: "All settings that deliver the Foundation Stage to have access to a QTS teacher with a target ratio of 1 QTS teacher to every 10 non-maintained settings". This BVPI has three aspects and the consultation paper does not indicated how these will be integrated into one indicator.
We accept that the current BVPIs BV36a, BV36b and BV36c are measures of input, but it is proposed that they will be replaced by a more complex indicator which will also measure input. Again this indicator has more than one aspect and the consultation paper does not indicate how these two aspects will be integrated into one indicator.
ACCA believes that this consultation exercise has not followed the Government's own good practice on written consultation (included in the Cabinet Office Code). A consultation period of only six weeks was adopted rather than the generally recommended period of 12 weeks. This is acknowledged in the consultation paper, but, at page 10, the Central Local Partnership memorandum of understanding is referred to which permits a six-week period of consultation. We believe that it would be acceptable for a local agreement to specify a higher than normal standard, but not the lower standard included in the memorandum.
We believe that the adoption of longer consultation periods and adequate piloting of new or amended BVPIs should further reduce the level of year-on-year changes. We are also disappointed that although we submitted a formal response to last year's consultation exercise on BVPIs we were not directly invited to submit a response this year. As was the case last year, 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.