Future Arrangements for the Welsh Government’s Equality, Inclusion and Human Rights Grants Programme for 2013-2016
A response from WCVA
15 January 2013
WCVA
Baltic House
Mount Stuart Square
Cardiff
CF10 5FH
A response to the consultation Future Arrangements for the Welsh Government’s Equality, Inclusion and Human Rights Grants Programme for 2013-2016
Introduction to WCVA
Wales Council for Voluntary Action represents, campaigns for, supports and develops voluntary organisations, community action and volunteering in Wales. It represents the sector at UK and national level; and together with a range of national specialist agencies, County Voluntary Councils, Volunteer Centres and other development agencies, it provides a support structure for the third sector in Wales. It has over 3,000 members, and is in touch with many more organisations through a wide range of national and local networks.
WCVA’s mission is to provide excellent support, leadership and an influential voice for the third sector and volunteering in Wales.
WCVA chairs and provides the secretariat for the Equalities and Human Rights Coalition. This is a network of over 100 third sector organisations working on equality in Wales. For several years now the Coalition has been interested in and given consideration to the Welsh Government's equality funding. This includes a submission to the review of the Promoting Equality Fund a number of years ago, a complaint to the Funding and Compliance Committee about the administration of the fund and concerns raised at our Ministerial Meetings. WCVA's response is based on these discussions and issues brought to our attention from the third sector.
We commend the Welsh Government on this consultation in which a number of important questions have been highlighted. Underlying these questions is the wider issue of what we mean by equalities representation and how this it is best achieved. We do not feel that this wider issue has been given enough consideration or space within this consultation. We therefore think that this consultation should be part of a much wider engagement exercise and discussion on equalities representation. In a time of increasing financial difficulty for the third sector many organisation will be interested in this funding and demand is bound to outstrip supply. It is therefore essential that Welsh Government use this consultation to develop a clear, transparent and rational approach to this funding to ensure that lessons are learned and difficulties associated with this funding in the past are not repeated.
Question 1: The Welsh Government has made a case for change to the current grants structure. Do you agree that present arrangements should change?
Alignment to Welsh Government Strategic Equality Objectives
WCVA agrees that a more joined up approach to tackling inequality and exclusion which aligns the efforts of the third sector and the Welsh Government (via the equality objectives) could produce clearer outcomes and greater impact.
We believe this approach could provide a platform to adopt a co-production approach to the design and delivery of public services. Co-production can benefit both those receiving services and the third sector through building its capacity and ability to sustain itself.
Whilst welcoming this strategic alignment there area number of issues which we believe the Welsh Government needs to be mindful of:
•This could lead to less opportunity for the third sector to respond in a demand-led way to its beneficiaries’ needs, which the previous open grant provided. One of the strengths of the third sector is its flexibility to respond to these needs as they arise.
•There could be less opportunity for innovation and testing out new approaches to service delivery.
•This approach assumes that the equality objectives are the most important areas. WCVA welcomes the engagement on these objectives but there still remain priority areas of inequality which these objectives do not tackle, such as transport. In a time of significant welfare reform and financial difficulty for many people, along with increasing cuts to public services, there may be changes in other areas which need new interventions.
The very nature of the equalities agenda is about responding to changing needs and being able to support those who face discrimination and barriers to inclusion. Even with the setting of robust objectives this will mean that there is some need for flexibility in the use of equalities funding and the Welsh Government should enable protected groups to identify for themselves what their needs are and how best to meet them. Part of core funding for groups should be to enable them to work with people whose needs may be less well identified, and to respond to emerging agendas. In order to be able to provide support for groups to effectively meet the needs of individuals and communities who face disadvantage it is important to acknowledge that who those people are and what services they need will change as a result of both Welsh Government and UK Government policy decisions; there is a need for flexibility in order to respond accordingly.
Target Funding for Areas Requiring Capacity Building
WCVA welcomes government support for third sector capacity building. However, the interpretation of capacity building can vary, therefore a clearer sense of what the Welsh Government means by capacity building within the grant is needed. We would suggest it means developing the capacity and skills of organisations in such a way that they are better able to manage and finance third sector services to ensure their future sustainability.
Without details of the identified need for capacity building within the sector, that Welsh Government suggests is needed, it is difficult for us to comment on this in detail. We would like to highlight that there are already a number of programmes and organisations which provide capacity building support for the third sector including WCVA and the County Voluntary Councils. These provide support to the full range of third sector organisations, across the range of areas in which third sector operates, including equality organisations. It would be useful for Welsh Government to factor existing support into their considerations and liaise with the organisations that provide this support to identify gaps. In the current financial climate with limited resources, it is vital that duplication of support is avoided. A transparent process of needs analysis and mapping of existing services is recommended before proceeding with this aspect of the grant.
This identification of need for capacity building due to gaps in organisations supporting and/or representing protected characteristics should be based on a comprehensive consultation and engagement with the third sector, in an open and transparent way. Capacity building of protected characteristic organisations is something we support in principle but there are risks to this which need to be considered if this is pursued. Historic examples of Welsh Government interventions in this area have led to provision of funds in areas which were not found to benefit the third sector and its beneficiaries as expected. It has also led to other organisations in the field who may have been doing this work already being negatively impacted. It is therefore good practice to engage with the third sector before proceeding.
For a number of years, the third sector, supported by WCVA, has requested that a mapping of the equalities third sector organisations funded by Welsh Government is undertaken and shared with the third sector. This has been raised consistently through the Ministerial meetings. This mapping of existing organisations should be used to provide an open and progressive approach to working together to identify where there needs to be development within the equalities third sector.
WCVA agrees that smaller organisations need to be able to access grants and compete in an open grants application, however this needs to be done in a way which does not unfairly penalise larger organisations who may be best placed to deliver against the equality objectives and develop the projects and programmes needed. If the recommended needs assessment against existing provision identifies that additional capacity funding is needed, then we recommend that an additional fund or ring fenced fund for capacity building is provided. This should be separate to funding to support delivery of the strategic equality objectives as it is likely the capacity building requirements will be different. The current proposals of mixing delivery with capacity funding do not help to develop understandable and transparent criteria.
The ‘Case for Change’ makes mixed statements on core funding and capacity building, using them interchangeably. Capacity building refers to the process of enhancing an organisation's abilities to develop skills and resources that enable them to operate more effectively. Core funding has a different role. Often when core funding is provided to national or umbrella organisations it is to provide voice for its members at a strategic policy making level. These organisations are essential to provide strategic policy input into Welsh Government’s programmes to ensure they are designed to deliver outcomes for the people the organisations represent. If this funding is to be removed, there is a serious risk to the provision of the voice at the national, regional and often local level as smaller organisations often use the larger network or umbrella organisation to act as a policy lead as well as for development support.
We recommend the application of the principles of core funding outlined in the Welsh Government’s Code of practice for funding the third sector. We would suggest instead of ‘self sustaining organisations’ the aim should be for organisations to become financially sustainable, and we must bear in mind that not all organisations will become financially sustainable because of the nature of the work they do. This is particularly the case for the core funding of equalities organisations funded to provide strategic policy input to Welsh Government. If core funding was taken away there would be a serious risk of these organisations not being able to get funding from anywhere else to provide this important input consistently and comprehensively.
Question 2: Should the new grants structure more closely align with the Government’s Programme for Government, Strategic Equality Plan and equality objectives in order to strengthen outcomes?
See response to Q1.
.
Question 3: Are there opportunities to encourage greater partnership working under the new grants structure? If so, do you have any ideas for how this might be achieved?
We encourage and support partnership working where it is in the best interests of the organisations and improves efficiency and delivery of services. It is however important not force partnerships. A partnership approach should be relevant and proportionate to the situation with flexibility built in.
Question 4: Should human rights be more explicitly addressed as part of the new grants structure? If so, how can this best be achieved?
WCVA recognises, and wants to promote, human rights within the Welsh Government and the third sector.However the inclusion of human rights in this grant scheme feels like an add-on rather than central to the purpose of this grant. Most references within the grants scheme are to the strategic equalities objectives and new equalities duties. These, whilst of course related, are currently a separate policy framework to human rights. Human rights were barely mentioned in the strategic equalities objectives, therefore to include it in these grants does not seem consistent. To help make this grant transparent and increase understanding it is better to keep it simple and have its outcomes based on one policy framework rather than attempting to use it as a catch all.
Question 5: Is there a need for both core and project funding? If not, why not?
As outlined above in the Welsh Government statement there is a strong argument and need for both core and project funding.
Question 6: If you consider that there should be core funding:
•Should it be targeted at sectors where there is a clear need for capacity building?
•Should it be time-limited?
•If so, how long should targeted core funding last?
WCVA does not think core funding should be targeted solely at sectors where there is a need for capacity building.Core funding is currently provided for all-Wales bodies to assist with representing the views of particular equality strands or taking forward a Programme for Government commitment. If their funding was removed there would be a very serious risk that their capacity to do this, which is a vital part of Welsh policy making, would be reduced. There is a need to distinguish between core funding and capacity building funding. The Welsh Government’s definition, ‘Organisational development grants/capacity building grants’, suggests that this is start up/capacity building funding rather than core funding. It is not helpful to confuse the two and further clarity on this would be helpful.
Welsh Government questions over effectiveness of core funding could be dealt with via effective management and monitoring by grant managers e.g. annual performance/contract management with measurable milestones/targets.
Question 7: Which of the two models we have suggested do you prefer and why?
Model 2 is our preferred option.
Previous difficulties with management of some grants by EDID has led to issues with this fund as highlighted by the AWEMA case. The Equalities and Human Rights Coalition has raised concerns over effective management of this grant for a number of years, including a complaint to the Funding and Compliance Committee. We welcome the improvements made since that time and feel improved monitoring of these grants means that core funding can be an effective and valuable way to support the sector to deliver equalities outcomes.
As outlined above, the removal of core funding from national umbrella organisation would risk the loss of strategic equalities input into national policy making. Also it is these organisations that have expertise and capacity to be able to deliver larger scale projects which drive the public service improvement agenda forward. Start up and capacity building funding to smaller organisations or areas where there are gaps in representation should be done through a separate fund or ring fenced section of the equalities fund.
Whilst there is a need for development of the evidence base, in particular the type of evidence that third sector can offer, the inclusion of this in a funding stream would provide too wide a remit for this funding. There are other research grants provided by the Welsh Government which equalities organisations can apply for. Research could fall into project funding in Model 2.
Question 8: Do you have alternative models for funding and what are your reasons for this?
See our suggestions made above in relation to capacity funding.
Question 9: How do you think the allocation of funding for different protected characteristics (including groups within these such as asylum seekers and refugees, migrants and Gypsies and Travellers) should be achieved within the grants structure?
The approach to the allocation of funding to organisations supporting and/or representing protected characteristics should be based on a comprehensive consultation and engagement with the equalities third sector, in an open and transparent way. We have consistently suggested that a mapping of equalities organisations across Wales is needed and should be the basis for the start of an open and brave discussion about the future structuring of equalities in Wales. This includes not just representation of protected characteristics e.g. do we need single strand or all stand organisations, but also geographical spread e.g. are national organisations the right representative models? These are difficult questions which need to be explored in an open forum if we are to move together to develop a fair, transparent and effective structure. We suggest that this consultation is the start of this process. Following the analysis of the consultations responses an event which explores the findings and tackles the keys areas of disagreement straight on would enable this process.
Question 10: Should geographical spread across Wales be factored into the grants structure and, if so, how can this be achieved? Should it form part of criteria for funding?
WCVA supports representation across Wales but this should be considered alongside need. The proposed mapping of need with engagement of the third sector would help with this.
JMc
WCVA
15 January 2013
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