The End Child Poverty Network Cymru is co-ordinated by
Consultation Response
Consultation on the Revised Child Poverty Strategy for Wales
The End Child Poverty Network Cymru (ECPN) is a coalition of concern focused on the eradication of child poverty in Wales, co-ordinated and managed on a day-to-day basis by Children in Wales. Its steering group include representation from across the voluntary and statutory sectors and the Network has an increasing supporting membership from a broad cross-section of agencies.
Steering Group members include Barnardo’s Cymru, Children in Wales, Save the Children Wales, NEA Wales, Action for Children, NSPCC Cymru, WLGA (observers), Citizens Advice, Oxfam Cymru, Public Health Wales, Shelter Cymru, the Buttle Trust, Princes Trust Wales, TUC Wales (observers), Welsh Women’s Aid, Wales Migration Partnership and the Office of the Children’s Commissioner for Wales (observers).
Operational since 2001, the ECPN Cymru is supporting the Governments vision that no child in Wales should be living in poverty by 2020, and is working to achieve this by
Increased public and professional understanding of child poverty in Wales
Public and professional support for measures to tackle child poverty
Ensure that policies are in place at all levels of Government (local, Assembly and Westminster), which contribute to eradicating child poverty in Wales.
The End Child Poverty Network Cymru supports the Welsh Governments started commitment to tackling child poverty and pledge to the legislative duty to eradicate child poverty by 2020. Child poverty damages children in the present and limits their opportunities in the future. It is imperative that the Welsh Government utilise the maximum extent of its available resources to enhance the quality of life and experience of children today and improve their outcome for the future.
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This response is submitted to both complement and reinforce the key messages shared during the consultation roundtable event between ECPN Cymru and Welsh Government officials in Cardiff on 21st January 2015 (ATTACHED with this paper). Children in Wales also undertook an e-consultation exercise amongst its membership through Survey Monkey
This response also compliments separate submissions from ECPN Cymru member organisations
Consultation Questions
Q1: Do you agree with our proposal to maintain our ambition to eradicate child poverty by 2020?
The ECPN supports the Welsh Governments repeated commitment to eradicate child poverty by 2020 and welcomes the reaffirmation of this commitment throughout the revised child poverty strategy. We continue to support and acknowledge the Welsh Government commitment to work with the UK Governments aim to eradicate child poverty by 2020, which in turn will contribute to the European wide target of reducing poverty by 20m through the Europe 2020 strategy.
The 2020 target, enshrined in legislation through the Child Poverty Act 2010, legally binds the UK Government to eradicate child poverty by 2020, a pledge reflected in the duties enshrined in the Children and Families (Wales) Measure. Part 1 of the Children and Families (Wales) Measure - ‘Eradication of Child Poverty’ - and the Explanatory Memorandum states that ‘the Welsh Assembly Government has made a commitment to work with the UK Government towards the eradicating of child poverty by 2020 and improving the life chances of disadvantaged children in Wales’. A target which maintains cross party support.
We recognise that the Welsh Government has made significant progress in adopting legislation, policy and developing programmes with the aim of meeting this target in so far as this is possible given the powers at its disposal. It is essential that the Welsh Government does not erode its message and retains its commitment to end child poverty by 2020. It must not rescind the promise it has made to all children and young people in Wales.
We accept that the forecast is bleak and remain deeply concerned that levels of child poverty are sharply increasing in Wales, with more and more children, young people and their families struggling to meet basic everyday costs and needs. Further, the Welsh Governments commissioned reports and recent publications by the Institute for Fiscal Studies predict a sharp growth in child poverty levels by 2020 on the relative and absolute measures. We are also aware that the cumulative consequences from changes being implemented through the UK Government’s welfare reform programme are beginning to take effect for many households with children in Wales, and young people without recourse to parental financial support.
Yet none of this is justification for abandoning the target. On the contrary, we would expect all Ministers and levels of Government to escalate action and ensure that every effort is made to meet this statutory target, whilst ensuring that there are a robust engagement mechanism in place between Ministers and officials in London around external and non-devolved matters.
The 2020 target allows for the focus and priority to remain, publically declaring that child poverty is not acceptable and prevents children from having the start they need in life. As well as demonstrating political will, the target can and should act as the catalyst for better forward planning, further investment, the removal of barriers which prevent or frustrate change and the distribution of resources appropriately towards solutions which achieve results within a clear cross government framework. What message would eroding our long held commitment send to the public, local delivery providers, public bodies and political leaders in other UK and European countries if we moved away from the target now? This is not the time for abandonment. This is the time to reaffirm the commitment, alongside an opportunity to reflect on what further progress can be made so that we are in a better position in 5 years’ time.
Q2: Do you agree with our proposal to continue with our existing three strategic objectives for tackling child poverty?
Whilst we generally welcome the proposal to retain the strategic objectives set out in the 2011 strategy and support the need to identify overarching aims and objectives to provide a framework for the strategy, there are a number of comments we would like to make in respect of each Objective
Strategic Objective 1
The health and social benefits of parents being in employment have been well documented and there is a plethora of evidence to support the notion that addressing worklessness should always be a key priority in all attempts to tackle child poverty. However, in-work poverty levels have proved that simply getting people into work does not always provide an adequate solution. There must also be economic benefits to accessing paid work. A labour market remedy alone continuously fails to lift families out of poverty as official figures show. Recent figures continue to show that the majority of the poor live in working households.
There is a need to consider the income entering the household as appose to whether or not there is a worker in the home. Getting people into work - where work currently exists - is not a solution to tackling child poverty alone and we would wish to avoid locking families into poverty permanently in poor quality and poorly paid jobs. Consideration needs to be given to household expenditure and the need to tackle the poverty premium low income households experience. The complexity and multi-dimensional nature of child poverty in wales requires a recognition of the struggles families face, including debt and access to affordable credit, high housing and childcare costs, as well as access to goods and services. Consideration of the ‘best interest of the child’ is also fundamental in the context of enabling parents to access employment.
We therefore suggest that this objective is supported by complimentary text which acknowledges the broader challenges families face in respect of household expenditure, in-work poverty and the best interest of the child, and makes clear that this objective is not simply about recording how many families are in workless households.
Strategic Objective 2
Whilst we support the need to improve the skill levels of parents, carers and young people in low-income families, there is a need to clarify what precisely is a ‘well paid’ job if the delivery of this objective is to be measured. This is clearly a complex area yet research has been undertaken around a ‘living wage’ and the adequacy of minimum wage levels and the challenges presented to employees working zero hour contracts. Whilst we agree that long-term and secure employment can be the most sustainable route out of poverty, wage levels in many parts of Wales and especially rural areas are inadequate with more and more families and individuals finding it increasingly difficult to live adequately on them. Equally, particular vulnerable groups, notably disabled people, care leavers and former young offenders face additional barrier to accessing employment.
The definition of skills should be broader to include life skills such as money management and parenting skills. Inequalities and issues around mental health, domestic violence and substance misuse are escalating because of the impact of poverty on parents’ ability to parent and this affects outcomes for children. This would reflect and compliment the priorities identified in the Early Years Outcomes Framework.
We therefore again suggest that this objective is supported by complimentary text which puts the objective into context.
Strategic objective No 3
We suggest that housing, community and environmental inequalities be included alongside health, education and economic outcomes as the key pillars of inequalities impacting on children and families. The inclusion of these would better reflect the detrimental impact poor housing, homelessness, excessive housing costs and the immediate environment has on disadvantaged families, and the interface between these factors with health outcomes, educational attainment levels and fuel poverty. Welsh Government have the necessary policy levers at their disposal in all three areas.
Q3 - Are the policies and programmes underpinning our strategic objectives the right ones?
ECPN welcomes the narrative which makes a valiant attempt to explain the relationship between the statutory Child Poverty Strategy and the Tackling Poverty Action Plan. This has been an area of some confusion locally, and we hope that the revised strategy will provide the necessary clarity. We would hope that the 2015 annual report of the TPAP provides a further opportunity to reiterate the interface between both documents and reinforces the prioritisation of efforts to tackle poverty as it impacts on children, young people and their families. The Welsh Government may wish to consider revising Figure 1 (pp. 6) however by placing the Strategy at the top of the diagram with the TPAP below. This would better reflect the role of the TPAP being the delivery agent for the Strategy in respect of the children/family outcome focused indicators and actions.
Commentary in relation to the Rights of Children and Young Persons (Wales) Measure requiring Ministers to ensure that ‘due regard’ is given to the UNCRC when policies and legislation are being developed or amended is also welcome. How this will be robustly put into practice other than carrying out the Six Steps to Due Regard process requires further consideration. It is difficult to ascertain at this stage how robustly a child rights approach will be taken to tackling child poverty, which is critical as a child right approach should help further differentiate this strategy from the non-rights based TPAP.
We welcome the continued emphasis on the three principle poverty programmes – Flying Start, Families First and Communities First – and the on-going work to develop a common outcome framework which should also help demonstrate how these programmes relate to one another, how joint working and shared priorities can be formed, and how there is cross fertilisation of information, ideas and learning. Area based programmes targeting populations with the highest levels of need have a key role to play and we would continue to support some degree of spatial prioritisation to tackle deep rooted deprivation and persistent poverty. Although there is the real risk that some householders will be excluded by virtue of not living in a pre-defined zone, it at least ensures that those householders in the poorest areas will receive much needed advice and support.
However we continue to believe that further discussions are required in respect of how services and funding can be ‘biased’ towards vulnerable individuals and groups in a non-stigmatized way, irrespective of their geographical location with particular consideration given to those in rural communities and less densely populated areas. Aside from reference to proposed future actions listed in the TPAP (Annex 1), there is surprisingly no commentary in respect of the additional and/or particular challenges experienced by children growing up in rural communities, and the need for local delivery partners to identify and prioritise solutions to address social exclusion and poverty. We would welcome this gap being addressed in the final strategy.
We have also previously questioned whether existing programmes are of sufficient scale to make a real dent and have the impact as is intended, sentiments which have been echoed in the 2014 independent evaluation of the current Child Poverty Strategy. Consideration should be given to scaling up those programmes where there is evidence that they are achieving positive outcomes, to aid more children and families to access much needed support across Wales.
Despite the challenging economic climate, universal services should be recognised as the foundation for achieving our shared objectives of tackling child poverty and enhancing children and young people’s health and emotional wellbeing. Universal services by their very nature avoid stigma and segmentation, and can act to keep the nation mutually as one, particularly in difficult economic times. Greater emphasis should be placed on the role of policies which support universal services, particularly in respect of tackling health inequalities, early intervention and prevention, which complement the development and expansion of targeted programmes for our most vulnerable populations.
In terms of the strategies listed in Figure 1, we note that the Children and Families Measure 2010 is absent. This legislation not only reinforces the statutory nature of the Child Poverty Strategy and the duties placed on public and named bodies to tackle child poverty, but also Chapter 1 includes duties on Play opportunities. Also absent are high level strategies in respect of economic development, jobs and growth; programmes in respect of sport and recreation, and also levels to tackle Transport poverty. Given the breadth of the child poverty agenda and the challenge of making reference to every piece of legislation and policy which has an impact, the final strategy may wish to either address gaps through a robust reference with hyperlinks or emphasize that the Annex list and Figure 2 is not exhaustive.
Q4 - Are you content with the collaborative approach we set out for tackling child poverty in Wales?
We acknowledge that the Welsh Government cannot address child poverty alone and that a collaborative approach is essential if the objectives of the Strategy are to be achieved. Local authorities and other public bodies named in the Measure are key delivery agents who play a vital role in the attempt to tackle child poverty locally. We would expect there to be regular engagement with such partners and for this engagement to be focused on nationally agreed and shared overarching objectives to ensure there is a consistent approach at a strategic local level, whilst allowing for an element of local discretion as appropriate.
The creation of local authority anti-poverty champions has been a welcomed development alongside the regular regional events convened to support local partners as key delivery agents. It is essential that local authorities take a whole government approach to addressing child poverty across all portfolio levels; that implementation of local programmes are more consistent and that clear expectations are in place to ensure that locally developed milestones which contribute to national targets are being met. A transparent reporting mechanism needs to be in place whereby local partners can evidence their actions and progress made. This was previously much clearer when local authorities were required to develop a separate Children’s Plan, and there is a need for the current and future planning processes through wellbeing plans to clearly demonstrate what is being delivered and achieved in respect of tackling poverty as it impacts on children and families. This still remains unclear. The Welsh Government have to be confident that the duties outlined in the C&F Measure are being met. If not, appropriate action should be taken where legislation is not being implemented as intended. There is also a clear role for the Inspectorate to hold public bodies to account.
We will expect the ‘Champions’ to fight to safeguard vital community services and protect local amenities from the threat of cuts. We have previously publically called for local authorities to produce and publish Social Impact Assessments in advance of any budgetary cuts and remain concerned that many essential public services are being withdrawn or reduced without adequate alternatives being put in place. This alongside the need to ensure that the child poverty duty under the Children and Families (Wales) Measure is effectively and consistently implemented. However, we must guard against the risk of anti-poverty action and initiatives residing with one or two persons rather than being mainstreamed into universal services with shared ownership and becoming everyone’s responsibility.
The strategy makes reference to the vital role the private sector can make to reducing child poverty, yet this point is not sufficiently developed in the context of encouraging evidence from joint collaboration programmes such as LIFT, apprentice schemes, Jobs Growth Wales etc, in addition to local commitments to implement a living wage. These are just some of the ways in which the private sector can and do play a significant role in tackling poverty and social exclusion. Yet many low income households continue to be excluded from recreational and cultural activities due to access or cost, and there is a need to engage small and large business employers and develop sustainable job creation opportunities in areas of high deprivation. The UK Social Mobility & Child Poverty Commission’s work with the professions on how they recruit has led to engagement with accountants in Wales. The strategy could therefore be enhanced with some narrative and reference to the collaborative opportunities being taken by Welsh Government and the private sector, and plans for the future to enhance this further.