The UNISON Scotland Submission
To Scottish Executive Scrutiny Review Secretariat
UNISON Scotland welcomes the opportunity to respond
to the Independent Review of Regulation Audit Inspection and Complaints
Handling of Public Services in Scotland. UNISON is Scotland's
largest public sector trade union representing 160,000 members
delivering and scrutinising public services. UNISON represents
the majority of employees in the National Health Service and local
government in Scotland, and large numbers of employees working
in the voluntary and community sector, police staff and scrutiny
and review bodies for example the Care Commission. UNISON Scotland
welcomes the opportunity to comment on this review.
Independent Review of Regulation, Audit, Inspection
and Complaints Handling in Scotland
UNISON Scotland's experience of scrutiny regimes
supports the interim conclusions in the review paper:
- The burden of external scrutiny has grown significantly
- The costs of scrutiny have increased significantly
- The external scrutiny system is unnecessarily complex, lacks
coherence and there is lack of evidence on impact
- There is duplication and overlap between scrutiny bodies
causing unnecessary burdens on providers
- The public voice is not sufficiently represented in external
- The complaints system is unnecessarily complex and not fit
The defining difference between public and private
services is democracy. It is democracy that makes public services
responsive to the needs of those who pay for and use them. UNISON
believes that democracy is about more than elections and a Scottish
Parliament; it is about ensuring that the public can meaningfully
participate in the decision-making processes about public services.
Democracy requires government at all levels to ensure
adequate opportunities for the general public to participate in
and influence the policy making process. This should be more than
being asked to comment on plans that have been made in private.
It should mean involvement in developing desired outcomes and
the methods to achieve them. To facilitate this, organisational
structures need to be decentralised to the appropriate level for
Democratic structures create public bodies which
are open and transparent in their dealings with the public. Government
at all levels must explain and accept responsibility for its actions.
However, weak mechanisms and the rise of the quango state have
devalued many of our democratic structures. We currently have
144 quangos in Scotland spending nearly £10billion.
UNISON believes that public bodies should as far
as possible be directly elected, for example, direct elections
to health boards. While for some quangos direct elections may
not be practicable, an amalgam of elected representatives, appointed
laypersons and professionals with a statutory duty to engage with
service users and the public would provide an accountable alternative.
Others could be incorporated into existing democratic structures.
Expanding the number of scrutiny bodies and increasing
their power will not provide the services people need nor improve
their confidence in delivery. Only involving users as partners,
not customers, in a meaningful decision making process will achieve
this. Public service organisations (PSOs) should have a statutory
duty to do so. This must involve a high degree of transparency
and the provision of capacity for users to fully participate.
Genuine involvement is more than just consultation. It means involving
users and staff in defining the problems as well as the solutions.
The best public service organisations are developing
a range of such mechanisms and there should be a forum to provide
guidance and disseminate best practice. UNISON is supportive of
an increased role for voluntary and community organisations, and
staff representative bodies in working with elected representatives
to influence planning and delivery of local services. This cannot
be achieved without appropriate resources. These are not just
financial, although that is clearly crucial, it also means politicians
and public service workers developing listening skills, the skills
to get people together to discuss issues, and to ensure that all
voices are heard, not just the best educated, wealthiest or the
loudest. All PSOs should be required to produce a corporate strategy
on participation and involvement which demonstrates how users,
community organisations, staff and their trade unions can be involved
in the planning, design, monitoring and review of services.
Complex services, "fair to all" and "personal
to each of us" cannot be delivered by central mandate. There
must be space for local innovation with broad standards set to
disseminate best practice. Users of public services are not homogeneous.
The needs and wants of differing groups need to be taken into
account when evaluating service delivery.
Appropriate performance measures are essential.
Traditional methods of measuring the performance of organisations
have concentrated on cost accounting methods that are not be entirely
suitable to public services. There is also a concern that a costly,
bureaucratic, scrutiny industry is developing to examine public
services. The measurements used to assess performance are often
subjective and fairly crude and do not take into account all the
factors involved in providing a service. They are also often based
on what data is already being collected or from the private sector.
This can lead to pressure on PSOs to concentrate on such indicators
to the detriment of the services they provide: the furore about
GPs appointment waiting time guarantees in England illustrates
Targets should be based on inputs, outputs and outcomes
together with process measures. Financial systems will also need
to be reviewed to be consistent with this approach. It should
also be recognised that assessing outcomes is fraught with the
difficulties of identifying cause and effect and the influence
of other policies and organisations. There is also a concern about
how open, transparent and useful reports are to the public.
Revitalising public services requires innovation
so new ideas and improvements to the way services meet the needs
of people are developed. PSOs must also have the capacity to allow
innovation to occur; otherwise no amount of innovative thought
will actually translate into better services at the frontline.
Innovation requires challenging the assumption that public services
are based on a "one size fits all" approach. This process
requires transparency and an element of risk taking, so it is
necessary to end the blame culture to enable innovation to take
place without recrimination. Giving staff the resources and freedom
to develop networks to learn from best practice is the most effective
route to improvement.
Efficiency and effectiveness in the public services
are about more than price. The public has a right to expect high
performance from public services. That performance should be rooted
in a culture of citizenship not consumerism. The quality of services
offered - not just the lowest cost - must be a crucial factor.
Any analysis of the performance of public services needs to take
into account the often-variable funding levels that public services
receive as well as their interaction with other public service
organisations and the possible impact on their service provision.
UNISON recognises that all public sector organisations should
be aware of opportunities to work more efficiently and effectively.
Genuine scrutiny should provide an opportunity for best practice
The current amalgam of scrutiny bodies leads to
a time consuming set of visits and reports which divert time and
resources away from service delivery. There is little or no coordination
between audit and regulatory bodies so a review can start a few
days after the previous review finishes. Scrutinisers are also
often looking for similar information but in very different formats.
This means the same data cannot just be passed on but has to be
re-collated and reports have to be rewritten within weeks of each
other. This complex duplication of data gathering is particularly
frustrating for staff. It also leaves organisation with large
periods of time where key members of staff are fully involved
in reviews rather than delivery of services.
In conclusion UNISON believes that the burden of
external scrutiny needs to be significantly reduced. Any new process
needs to be greatly simplified and should bring to an end the
duplication and overlap that causes significant difficulties for
the delivery of services.