Achieving consistent
and high quality
Debt Advice
An approach to Standards and Quality Assurance
for the debt advice sector: Consultation response
2
Section
moneyadviceservice.org.uk
Money Advice Service
Contents
Executive summary
4
Accreditation of Organisational Standards and Codes for Debt Advice Services
6
Summary of general points raised through the consultation
8
Summary of consultation questions and responses
10
Implementation plan 14
Revised Money Advice Service Quality Framework for Organisations
15
List of respondents 24
Acknowledgements
The Money Advice Service is grateful to both
the individuals and organisations that attended
the consultation events held across the UK
during February 2013, and to those that
submitted written responses to the
consultation. The Money Advice Service values
the input from stakeholders into this process
and welcomes the opportunity to work in
collaboration to improve the quality and
consistency of debt advice across the UK.
4
Executive summary
Executive
summary
1. W
e believe that given the importance of
debt advice interventions in people’s lives,
it is crucial that the advice given to clients is
of the highest quality. Our paper “Achieving
Consistent and High Quality Debt Advice”
on which we consulted between December
2012 and March 2013, set out our proposed
approach for achieving a consistent, high
quality delivery of debt advice across
the sector. Our decision to create a new
framework against which existing standards
that are currently in use across the advice
sector could be measured and assessed is
one that has received high levels of support.
2. T
he framework incorporates both
organisational and individual elements of
quality. It provides a single mechanism
against which quality standards,
membership codes, qualifications and
vocational training currently used in the
advice sector can be assessed; this will
ensure that both an organisation and its
individual advisers are delivering consistent
and high quality debt advice.
3. W
e have developed our framework in
light of the responses received through
the consultation process. We have now
incorporated the detailed list of internal
processes and systems that will need to be
evidenced by organisations to show that
they meet a standard that fits within the framework.
4. The revised framework embodies excellence
in debt advice delivery and it incorporates
two elements, individual competencies
and skills and organisational systems and
processes, and outcomes. The framework
provides for the first time a single,
transparent and consistent mechanism
against which both the free-to-client and
fee-charging sectors can be assessed.
5. We will form and maintain strong on-going
working relationships with each of the
standard and membership code owners
that meet the framework and implement
the appropriate processes. This facilitate
the sharing of information on whether debt
advice organisations pass or fail audits.
Standard owners will have to ensure that the
compliance checks they carry out meet our
minimum criteria, including on site audit and
the assessment of advice.
6. We will investigate the development of
an appropriate independent peer review
process to provide additional reassurance of
suitable and relevant advice to clients.
7. The organisational element of the framework
is now complete. We will now appoint
an independent organisation to map
organisational standards and membership
codes against this part of the framework.
This will identify those that meet it in full,
in part or not at all. Responses to the
consultation on the individual element of
the framework suggested that whilst the
individual tasks identified in our proposal
were accurate, the suggested role profiles
were not necessarily reflective of the
diversity of the sector.
Money Advice Service
Achieving consistent and
high quality Debt Advice
Executive summary
8. A small working group will meet over
the summer of 2013 to put together a
set of specific tasks, debt advisers need
to perform and identify the skills and
competencies required to perform those
tasks. A set of National Occupational
Standards (NOS) considering the inclusion
of the Qualifications and Credit Framework
(QCF) units, where relevant, that underpin
these tasks will then be defined in order
to assess the content of debt advice
qualifications and training against them.
These will then be mapped against the
framework by an independent organisation
to identify those that meet that part of
the framework.
11. For the projects we fund we will introduce
a requirement to comply with a standard or
code that meets our framework. From April
2014 we will only fund providers that hold
an approved standard or code. Where an
organisation fails to maintain an accredited
standard then it will no longer be eligible to
receive funding.
9. A standard, or membership code that
is externally assessed as meeting the
framework will be “accredited” and we will
publish a list of those standards, and the
organisations that comply with both parts
of our framework, on our website. We will
work with standard owners to keep this up
to date, and this will enable over-indebted
people to make more informed choices
when accessing debt advice services.
10. The assurance provided by the framework
will be evident to both creditors and
funders of advice services. In this way the
framework will act as an incentive for debt
advice organisations to adopt and work to
an accredited standard and this will impact
on raising quality across the whole sector
far beyond the services we fund.
12. We have considered the value to the public
of a Money Advice Service endorsement
or logo displayed alongside the quality
standard logo and concluded that this
is not the appropriate time to do that.
However, we will review the benefits of a
public facing logo after a period of 12 months.
5
6
Accreditation of Organisational Standards
and Codes for Debt Advice Services
Accreditation of Organisational
Standards and Codes for Debt
Advice Services
1. O
ur framework has been designed to
enable the wide range of existing and new
quality standards, membership codes,
qualifications and training in use across
the debt advice sector to be independently
mapped and, where they meet the
requirements of the framework, they will be
accredited by the Money Advice Service.
2. T
he framework provides the foundation
for raising quality and consistency in
the delivery of debt advice and it covers
organisational systems, governance,
adviser skills and competence and
outcomes for clients.
3. Throughout
the consultation process we
have taken into account the wide range of
detailed views and suggested amendments
and we have responded to these within
the revised framework. The organisational
element of the framework covering
standards and codes has now been
finalised and this can be found at page 15.
The framework takes each of the three high
level quality areas: focussed on client need,
well governed and a learning organisation.
It provides the details of organisational
systems and processes that must be
evidenced to standards and membership
code owners.
4. A
ll accredited standards and codes will
need to show that they assess compliance
through appropriate and rigorous
processes that will include on-site audit,
the assessment of advice and a three year
audit cycle.
5. Accreditation
will be open to standards,
codes, training and qualifications covering
both free to client and fee charging debt
services. The accreditation process
will begin by inviting all standard and
membership code owners currently in
use for debt advice, to submit evidence
of their scheme requirements to enable
a mapping of their respective quality
standards and membership codes against
the requirements of our framework. The
mapping for training and qualifications
will take place in the autumn so that the
framework for individuals can be finalised in
line with the responses to the consultation.
6. Once the mapping is complete and
an assessment has been made, the
results will be communicated to each
standard and membership code owner.
Recommendations to accredit will be made
where a standard or code fully meets the
framework. Where further development
or modifications are required, a period of
two months will be provided for this to take
place prior to a formal reassessment. We
will then work closely with the accredited
standard and code owners to ensure that
they share information on their audits of
debt advice organisations so that we know
which organisations comply with their standard.
Money Advice Service
Achieving consistent and
high quality Debt Advice
Accreditation of Organisational Standards
and Codes for Debt Advice Services
7. T
o take this mapping work forward we
will appoint an independent external
assessment organisation early in
the summer of 2013 to complete the
assessment and accreditation process. All advice organisations and individuals who hold the appropriate accredited
standard, or code, qualification or
training will then be judged to meet the
requirements of the framework and this will be disclosed on our website.
10. Our framework will be reviewed every five
years, with the exception of where there are
changes in legislation or regulations that
occur. At this point we will also reassess all
accredited standards, membership codes,
training and qualifications against the
revised framework and renew accreditation
where it is appropriate.
8. O
ur framework will require that standard
owners audit organisations on a three-year
cycle. Additional risk based triggers will
need to be put in place e.g. through annual
self-assessment or through a peer-review
process which would alert standard and
code owners to the need for an interim
assessment. We will work with the owners
of accredited standards, and codes, to
encourage them to implement a more
consistent and standardised approach to
the process of assessing compliance.
9. W
e will develop a full, partnership working
process with standards and membership
codes owners to develop a mechanism
to maintain a list of accredited advice
organisations on the Money Advice Service website.
11. Any new standards, membership codes,
training or qualifications covering debt
advice can be submitted for assessment
on an on-going basis.
7
8
Summary of general points raised
through the consultation
Summary of general
points raised through
the consultation
In addition to the specific consultation
questions, respondents had raised a number
of more general points in their individual
responses. These comments together with our
responses are shown below:
1. R
espondents felt it was important that
there should be a strong alignment
between the Money Advice Service
Quality Framework and the Financial
Conduct Authority (FCA) requirements
for the regulation of debt advice.
R
esponse: We are committed to working
with the FCA to embed adherence to our
Quality Framework into the regulatory
architecture through their authorisation,
supervision and enforcement work. We
have responded to the FCA consultation
on the consumer credit transfer and
recommended that adherence to the
Money Advice Service Framework should
be a condition of granting authorisation to
organisations delivering debt advice. We
further advised that the FCA should gather
data on adherence to the framework from
all debt advice organisations entering the
new regime, including those that will be
operating under interim permissions.
Our response to the consultation can be
found here:
ww.moneyadviceservice.org.uk/files/fcaw
cc-response-20130501.pdf
2. R
espondents wanted clarity on
the implications for debt advice
organisations where they did not meet
one of the accredited standards or codes.
esponse: We will require all organisations
R
that we fund from April 2014 to hold
a standard or membership code that
has been accredited against the quality
framework. Any services that lose an
accredited standard whilst funded will not
have funding withdrawn immediately but
will first exhaust all due process set out
in the relevant standard or code that they
hold including any subsequent appeal.
Only after that process is complete would
we withdraw funding. We will also work
with, and encourage other funders, of
debt advice to require adherence to the
framework in their funding decisions for
debt advice.
3. R
espondents felt that the framework
did not sufficiently reflect or focus on
client outcomes and it was proposed
that this was strengthened in a revised
framework.
esponse: The framework specifically
R
requires organisations to demonstrate that
they capture evidence and record client
outcomes and that they analyse and review
those outcomes to improve their services.
To facilitate this process the Money
Advice Service is developing a common
evaluation framework that will enable the
measurement of client outcomes across all
channels of advice. This framework will be
published with a toolkit that will be made
available to all debt advice providers.
Money Advice Service
Achieving consistent and
high quality Debt Advice
Summary of general points raised
through the consultation
4. R
espondents wanted full transparency
on whether organisations that held
accredited standards or codes were
offering free or fee charging services to
the public.
6. Some respondents expressed a view
that the framework should support,
strengthen and evidence effective
relationships between debt advice
providers and creditors, thereby
enabling and maintaining a smooth and
timely journey for the client.
Response: It is important that the
framework remains a single mechanism
that measures quality consistently across
the whole sector. The list of organisations
that hold accredited codes and standards
will be published on our website and this
will distinguish both free and fee charging
advice providers.
5. S
ome respondents expressed concern
that the Money Advice Service
framework would not raise quality
across the sector but would just
set a minimum benchmark. It was
suggested that there was a potential
for inconsistent and variable levels of
quality because of the differences in
each of the standards and codes.
Response: The framework was constructed
by first identifying the critical elements of
quality that a debt advice organisation
must exhibit, and then looking at the best
practice measures that exist in the sector.
This will ensure that accredited standards
and codes would require evidence of the
highest levels of quality in any organisation
that they award with their accreditation. The
framework raises quality by linking individual
skills and competences and organisational
processes and systems into a single
framework providing a comprehensive
measure of quality that will serve to raise
standards in the sector. The framework
sets out a list of detailed evidence that any
accredited standard or code owner will
be required to assess in an organisation,
providing consistency in quality measures
across the range of standards and codes.
Response: The framework includes a
requirement for debt advice organisations
to be able to demonstrate that they have
clear and effective processes and policies
in place for engaging with and maintaining
effective relationships with creditors,
including providing appropriate feedback to
them. Our Business Plan 2013/14 outlines
work we are doing on ‘creditor referral,
common data and triage’, all of which once
developed and implemented will facilitate
and strengthen the links between debt
advice providers and creditors, enabling a
better client journey.
7. Respondents wanted to understand the
details of the capacity building support
that Money Advice Service would
provide and the scope and criteria for
such funding.
Response: Our 2013/14 business
plan identified funding to support our
accreditation work and the capacity
building, for the work on Quality and
Standards. This will provide some initial
funding in the short term to help free to
client advice organisations bridge gaps
and work towards meeting an accredited
standard or membership code. The funding
will be available to non-profit making debt
advice organisations, both those that we
fund and others. We will publish a full set of
criteria and the timescales for applications
for funding in the autumn. We will explore
what capacity building requirements are
necessary across the free debt advice
sector and we will seek funding to address
those requirements.
9
10
Summary of consultation
questions and responses
Summary of consultation
questions and responses
Question 1 – Is there any additional value in
using a Money Advice Service logo linked
to the relevant Quality Standard badge
that is customer facing so that it is widely
recognisable to the public?
1. T
here was a mix of responses to this
question and a number of concerns were
identified. These included a view that there
would be a dilution of existing brands and
the potential for clients to be confused by
too many brands. It was suggested that
perhaps a more simplified endorsement
would be more appropriate. A view was
also expressed that the use of any Money
Advice Service brand should be optional
for organisations so where it may prove
confusing or misrepresent the entirety of
the service available it would not be used.
Respondents also felt that any public facing
Money Advice Service branding would need
to be heavily promoted and publicised to
make it meaningful.
esponse: We will not be seeking to
R
implement a public facing Money Advice
Service logo or endorsement at this
time but we will review this after a period
of 12 months. A list of all debt advice
organisations that hold an accredited
standard or code will be published on
the Money Advice Service website and
categorised as appropriate. It is important
that creditors, the public and advice
providers are aware which debt advice
services hold an accredited standard or
code. We will encourage the public to use
accredited debt advice services listed on
the Money Advice Service website which
will also clearly identify those that are free
and those that charge a fee to the client.
Question 2 – Which standards or
membership codes do you consider to fully
meet our framework?
2. A
range of standards and codes were
highlighted through a number of sources
as potentially meeting the Money Advice
Service framework. Those referred to
included; the Citizens Advice Membership
Code; Citizens Advice Scotland
Membership Code, Scottish National
Standards; Advice Quality Standard
(AQS); PQASSO; DRF Code and the LSC
Specialist Quality Mark.
esponse: The Money Advice Service
R
has been meeting with standard and
membership code owners throughout the
consultation period to discuss working with
Money Advice Service on accreditation.
Now that the organisational element of the
framework has been finalised these and
other standards and membership code
owners will be invited to be independently
assessed to identify whether their standard
or code meets the requirements of the framework.
Question 3 – Are there any requirements
that should be included or excluded from
the framework?
3. T
here were a number of proposed
amendments and suggestions submitted
by respondents. Some respondents felt
that there should be a greater focus on
evidencing the quality of advice within the
framework; strengthening evidence that
demonstrated debt management protocols
are being followed; and ensuring there are
requirements which align and provide coordination with the requirements of the FCA.
Money Advice Service
Achieving consistent and
high quality Debt Advice
Response – The proposed framework
for organisations has been revised taking
into account many of the amendments
proposed. On the point of assessing
quality of advice given to clients we
have incorporated further measures to
specifically review the quality of advice
being delivered, and we will work with
standard and code owners to ensure that
part of their compliance checking includes
on-site audit and the assessment of
advice. We will investigate the development
of an appropriate independent peer
review process to provide an additional
independent assessment of the quality of
advice. We are pleased to note that the
Debt Management Protocol now includes
a requirement for fee charging debt advice
organisations to work with the requirements
of the framework. We have also set out our
position in working with the FCA to embed
the framework into their procedures for the
regulation of debt advice.
Question 4 – Are the role profiles identified
correct and reflective of best practice
across the sector?
4. T
he feedback from the advice sector was
that the role profiles proposed were not
broad enough to reflect the diversity of
practice across the sector. The prescriptive
nature of the role profiles did not allow for
sufficient flexibility to incorporate different
business models and organisation types
and sizes. It was suggested that a taskbased approach should be used to
identify the appropriate set of National
Occupational Standards (NOS) and that this
would better reflect the variable job roles
that exist.
esponse: We accept that the proposed
R
role profiles are not flexible enough to
allow for the diversity of job roles across
the debt advice sector. We will set up a
small working group of stakeholders led
Summary of consultation
questions and responses
by a subject matter expert to meet over
the summer to redefine a set of National
Occupational Standards (considering the
inclusion of QCF Units where relevant)
against which training and qualifications
can be mapped. Where these meet
the requirements, through independent
assessment, they will then be accredited
where appropriate. The individual element
of the framework will be finalised and
published in the autumn.
Question 5 – Have the appropriate NOS
been used within the role profiles?
5. Very little specific feedback was received.
Some respondents said that they were
unfamiliar with the detail of NOS; some
provided overarching statements of
support, and others expressed the view
that the number of individual NOS allocated
to each role profile were too many and may
be impractical.
Response: As outlined in the response in
Question 4 above.
Question 6 – Which debt qualifications
and training courses have been developed
using NOS?
6. A range of debt qualifications and training
were identified that had used NOS in their
development including; the ICM accredited
qualification used by Stepchange; IMA
qualification; Debt Resolution Forum Edexcel Certificate in Debt Resolution
Advanced BTEC; Citizens Advice training;
Advice UK training; Wiser Adviser; Advice
NI training and Skills for Justice Framework
Legal Advice 4.
Response: As outlined in the response in
Question 4 above.
11
12
Summary of consultation
questions and responses
Question 7 - Are there other requirements
that a sole debt adviser should evidence?
Question 8 – Do you agree that this is
the appropriate approach to evidencing
the quality of individuals delivering debt
advice?
7. A
number of suggested additional
requirements were identified and referenced
across the responses, these included
a requirement for on-going Continuous
Professional Development (CPD),
and ensuring that lone advisers must
demonstrate how they keep up-to-date
with legislative changes. It was suggested
that they must have access to a specialist
unit, they must hold the relevant license
and have suitable insurances in place
such as professional indemnity; they must
be part of a system that enables them to
receive support/supervision relating to their
area of law on a regular basis, including
independent file/peer review; and they need
to be a member of a professional body.
esponse: The Money Advice Service
R
recognises that in order to meet the
requirements of the framework sole
advisers will need to have access to
additional support. The individual element
of the framework will include additional
overarching requirements for sole advisers
due to the higher risk posed by advisers
operating in isolation from support.
he individual component of the
T
framework when published will include a
requirement to be qualified to a recognised
level to receive Money Advice Service
accreditation. Sole advisers will also be
required to be part of a membership body
with access to updates, CPD, peer support
and a range of technical support. In
addition they will need to demonstrate that
they hold all of the relevant insurances and
licence requirements. Sole advisers will also
be subject to any independent peer review
as previously outlined.
8. V
ery few responses were received on this
question. There was some concern that
just undertaking training and getting a
qualification was not a sufficient guarantee
of on going assurance for high quality
advice. Qualification, training, standards
and code owners should be required
to assess random samples of individual
adviser casework to ensure that quality
was looked at across both debt advice and
administration. This reinforced the general
feedback that highlighted the importance
of including independent case review (peer
review) as a mechanism for assuring quality.
esponse: The proposed framework for
R
individuals will be revised based on a new
set of NOS/QCF Units identified over the
summer by our working group. On the
point of assessing quality of advice given to
clients we will investigate the development
of an appropriate independent peer
review process to provide an additional
independent assessment of the quality of advice.
Money Advice Service
Achieving consistent and
high quality Debt Advice
Question 9 – Currently different standards
owners use a variety of accreditation
processes. How often is it appropriate for
standards owners to monitor and review
compliance?
9. V
iews ranged considerably with
approximately a third of respondents
considering a three year assessment of
compliance to be appropriate, another
third felt that an annual review with varying
intensity and a different focus each year
was more suitable. Another group of
respondents suggested that following
an initial assessment a purely risk-based
approach should be adopted.
esponse: Our view is that a default
R
position for the frequency of assessment
should be every three years. We will also
work with standard and membership code
owners to develop an annual checklist for
organisations to complete and submit, to
identify levels of risk and to flag up where
an additional audit may be required.
Question 10 – How often should the Money
Advice Service review standards and
codes against our Quality Framework?
10. Responses were mixed. Some
respondents felt that every five years
was the appropriate time period, with
the requirement to review specifically
when there were any legal or regulatory
changes. Others felt there should be a
minimum of an annual review, and some
responses suggested that a review was not
necessary unless there were regulatory or
legal changes. Other suggestions included
that they should be reviewed against the
framework every three years with the
option for annual self-assessment unless
standards themselves changed.
Summary of consultation
questions and responses
Response: Our view is that it is important to
achieve a stable established framework and
that it is not desirable to make regular or
unnecessary changes. Whilst there will be
a need to make changes periodically where
there are any major regulatory or legislative
changes, our default position is that we will
review standards against our framework
every five years.
Question 11 - Should the Money Advice
Service appoint an independent third
party to conduct a verification audit of
organisations working to the standards that
meet the Quality Framework?
11. Responses to this question were mixed
with some expressing support for an
independent third party suggesting
that this would offer transparency and
independence in the process. Other
respondents felt that it would be a better
use of resources and a more proportionate
approach to ensure that standards owners
were more transparent in their own audit
processes and more effective in ensuring
compliance.
R
esponse: We do not believe that it is
necessary or desirable to conduct any
verification audit through a third party
organisation. However, we will continue
to work alongside standards and
membership code owners to understand
the processes and safeguards they have
in place in determining how organisations
demonstrate compliance.
13
14
Implementation plan
Money Advice Service
Implementation plan
Money Advice Service Quality Framework for Debt Advice
Activity
Completion date
Publication of the Money Advice Service Organisational Component of Quality Framework.
Summer 2013
Establish a working group of stakeholders to undertake further developmental work on the
individual component of framework.
Summer 2013
Working group to meet on three or four occasions.
Summer/Autumn
2013
To develop and agree a set of specific tasks, skills and competencies that debt advisers
need to perform (Debt advice related tasks only).
To identify the appropriate National Occupational Standards/QCF units that underpin these
tasks.
Issue tender and appoint a third party organisation to conduct mapping of quality standards
and membership codes.
Summer 2013
Third party review of standards and membership codes, including development discussions
with owners.
Summer/Autumn
2013
Publication of Money Advice Service Individual Component of Quality Framework (including
plans for accreditation of sole advisers).
Autumn 2013
Third party review of training and qualifications, including development discussions
with owners.
Autumn 2013
Scope, eligibility criteria for capacity building fund to be published.
Autumn 2013
Investigate the development of an independent peer review process.
Autumn 2013
Accreditation award and continued development work with standards, code membership,
training and qualification owners.
Winter 2013
Assessment of Money Advice Service funded debt advice organisations.
Winter 2013
Develop and maintain within the Money Advice Service website an online list of
accredited standards, membership codes and organisations holding Money
Advice Service accreditation.
January 2014
onwards
Revised Money Advice Service Quality
Framework for Organisations
Achieving consistent and
high quality Debt Advice
15
Money Advice Service Quality
Framework for Organisations
Section 1:
Meeting Clients' Needs
A debt advice service that is driven by
client need first and foremost, focused
on access to advice and
timely outcomes
Theme
Purpose
Quality Measure
Measurements/illustrations
Accessible
1.1
Service is easily
accessible to the
community
Up-to-date community and client profiles
maintained. In addition, services could produce an
annual statement identifying any specific advice
needs anticipated for these communities. This
could be incorporated into a Service Plan
To maximise
reach of service
Evidence of regularly reviewing and adapting the
service based on client need. Access should be
assessed as a minimum against:
nn
hours of service
nn
outreach (geographic accessibility) including
virtual access.
nn
methods of delivery (channels)
nn
range of formats, languages and abilities
Accessible
1.2
To build
awareness of
the service
and encourage
usage
Effectively
communicate and
promote services to
potential clients
Evidence of a client-focused communication
strategy and action plan compliant with statutory
rules.
Other organisations engaged regarding changes
to services or practice
Evidence that clients, potential clients and external
organisations are clear about the level and type of
service available, and there is a clear and defined
process for referral
16
Section 1:
Revised Money Advice Service Quality
Framework for Organisations
Meeting Clients' Needs
Money Advice Service
A debt advice service that is driven by
client need first and foremost, focused
on access to advice and
timely outcomes
Theme
Purpose
Quality Measure
Measurements/illustrations
Accessible
1.3
Builds and maintains
strong formal
networks that cater
for current and
potential client need
Proactive in seeking, building, using and keeping
up to date referral routes
To facilitate
effective and
timely referrals
Evidenced use of an effective process for
engagement with and feedback to creditors
Maintain records of referrals, including referrals in
and out of the service
Referral routes identified for the delivery of all
advice channels
Referral routes identified for all potential advice
solutions needed e.g DRO/DMP/IVA
Responsive
1.4
To ensure
clients’ needs
are met with
the right tools
and resources
Provides appropriate
information and
support
A series of provisions should be in place
throughout the client journey including:
Referral processes for specialist debt and nondebt related services embedded with clear
information to clients at the outset
Self-help and assisted self-help resources are
accessible and provided where appropriate
Processes in place for clients to be kept informed of
their case through whole journey and the process
communicated by which clients can access
personal information held about them
Responsive
1.5
To facilitate
client
outcomes.
Delivers appropriate
client outcomes
through effective
advice
Client journey can be articulated by all levels
of staff
Clients outcomes are measured and captured
frequently, even when referred
Client outcomes have been used to improve future
client experience through service changes
Revised Money Advice Service Quality
Framework for Organisations
Achieving consistent and
high quality Debt Advice
Section 1:
Meeting Clients' Needs
A debt advice service that is driven by
client need first and foremost, focused
on access to advice and
timely outcomes
Theme
Purpose
Quality Measure
Measurements/illustrations
Responsive
1.6
Define and
understand clients’
needs
Systems in place for recording client information
and any specific needs
To ensure
services are
targeted,
designed and
promoted
appropriately
Client input into the design and development of
services
Client feedback systems in place with evidence of
adapting services in relation to needs
Records identify clients’ needs, any advice
given and the actions to be taken and by whom
Records accessible to all advisers
Trusted
1.7
Building and
maintaining
clients,
confidence in
the objectivity
and impartiality
of advice
Act and be seen
to act with
impartiality and
integrity at all times
Effective and appropriate policies and practice on:
nn
confidentiality and access to information
nn
safe maintenance and destruction of case files
nn
management of case files
nn
forms of authority enabling the provider to speak
or act on behalf of the client
nn
the protection of client data
nn
conflict of interest, including the management of
conflict of interest in staff and remedy decision
Evidence of a published clear client charter
that has a commitment to treat service users
with respect and sets out any expectations of
behaviour they have of clients
17
18
Revised Money Advice Service Quality
Framework for Organisations
Money Advice Service
Section 2: Well governed
Theme
Purpose
Quality Measure
Measurements/illustrations
Compliance
2.1
To deliver a
quality service
to meet clients’
needs free
from legal
challenge
Compliant with
appropriate
legislation –
Health & Safety,
Charity, Equality &
Diversity, Company,
Regulatory,
Employment, DPA,
Consumer Credit
(including standards
set out by the
regulator in rules/
guidance)
Insurances held are appropriate to the
service provided
To provide a
consistent and
sustainable
service to
clients
Financially viable
An annual budget
Transparency
and longevity
2.2
Evidence of organisation and staff awareness of
legislative and / or regulatory requirements
Staff are aware of routes for reporting breaches in
requirements e.g whistleblowing
Annual profit and loss account or income and
expenditure account
Annual balance sheet
Quarterly variance of income and expenditure
against budget
Accounts are monitored at least quarterly by
management committee / board
Forecasting model meaningfully assesses financial
strength
Evidence of financial review by an independent
source
Transparency
and longevity
2.3
To ensure a
sustainable
organisation
Identifies and seeks
to mitigate risks
Up to date risk log with mitigation plan for
organisation and individual projects and services
(including HR needs)
Revised Money Advice Service Quality
Framework for Organisations
Achieving consistent and
high quality Debt Advice
19
Section 2: Well governed
Theme
Purpose
Quality Measure
Measurements/illustrations
Leadership
2.4
Well led
Strategic aims and operational objectives for the
service are clearly set out
To provide
vision and
clarity of
purpose
All staff and volunteers have access to policies
and procedures and they are embedded into
induction
Supervision process is adhered to for all staff
involved in the advice process
Effectiveness
Effectiveness
2.5
2.6
To enable the
assessment of
performance
against service
aims and
objectives
and to drive
and enable
continuous
improvement of
the service
Gathers, challenges
and scrutinises
monitoring data
To deliver high
quality and
appropriate
services
across the
organisation
Staffed by competent
people who are
appropriately trained
Clear outcomes for the service are defined and
success measured against them
Collects and collates a consistent set of client
data and evidenced use of management data
Evidence of CPD activity for Trustees/
Management Board/staff
Staff are aware of service changes
Evidence of improvements following service, client
or environmental reviews where relevant
All staff involved in delivering the service have
achieved identified core competencies before they
advise the public
Staff are aware of their tasks and responsibilities
and where to turn for help if faced with a problem
beyond their own abilities
Staff feedback systems in place and used by
management
Supervision is delivered by appropriately trained
staff within or outside the organisation
Evidence that all cases are dealt with by an
adviser trained/qualified to the appropriate
level of debt advice as detailed in the individual
components of the Money Advice Service Quality
Framework
20
Revised Money Advice Service Quality
Framework for Organisations
Money Advice Service
Section 2: Well governed
Theme
Purpose
Quality Measure
Measurements/illustrations
Effectiveness
2.7
Manages resources
well
Attendance records are recorded
To maximise
the efficiency
and
effectiveness of
its service
Processes in place to reduce any potential nonattendance of clients
Record of client access routes and consistent
use of assessment mechanisms to inform client
journey
Evidence that financial prudence is observed with
the organisation management eg. procurement
procedures
Use channel shift where appropriate
Effectiveness
2.8
To maintain
and improve
quality of
advice
Demonstrable
internal quality
assurance process
including appropriate/
effective centralised
systems and controls
Evidence of internal quality assessment and
responsibility for maintaining quality made clear in
the management structure
Quality is maintained where part of the service is
delivered by a third party
Evidence that systems and processes are
reviewed regularly eg. operation and advice
processes
Effectiveness
2.9
To provide
transparency,
accountability
and longevity
of the service
Sets out clear plans
and timescales
Plans outline service delivery aims, timelines for
service developments and finances
Revised Money Advice Service Quality
Framework for Organisations
Achieving consistent and
high quality Debt Advice
Section 3: A learning organisation
Theme
Purpose
Quality Measure
Measurements/illustrations
Reflecting
3.1
Conducts selfevaluation when
appropriate
Completion of self-assessment audit of service
To identify the
opportunities
to develop the
organisation
and the
service
Use of client and community profiles to identify
new and future trends
Service strategies are updated and reviewed
against the aims and objectives of the
organisation
Services are subject to regular independent
review and/or evaluation of advice outcomes
Reflecting
3.2
To improve
the quality
of advice
and delivery
across the
sector
Shares evidence
based good practice
with peers
Reaches out to other
debt providers and
other sectors to learn
Systems in place for staff learning/training
Internal communications documentation covering
good practice and success
Engagement in external forums/workshops/
meetings where best practice is shared
Evidence of involvement in peer-to-peer support
and learning
Reflecting
3.3
To improve
the quality of
advice and
skills levels of
advisers
Facilitates learning and
development
Staff appraisals, supervision and training
needs analysis are completed for staff and
the organisation, including evidence of active
performance management
Advisers have access to a suitably experienced
person internally or externally, who can provide
guidance
21
22
Revised Money Advice Service Quality
Framework for Organisations
Money Advice Service
Section 3: A learning organisation
Theme
Purpose
Quality Measure
Measurements/illustrations
Reflecting
3.3
Facilitates learning and
development
Training plan and continuous professional
development plan in place for all staff and
volunteers
To improve
the quality of
advice and
skills levels of
advisers
Process that uses evidence from client cases for
staff development
Arrangements are in place to ensure that the
service and staff have access to up-to-date
reference materials and appropriate journals
Services to evidence that the casework files of
individual advisers are subject to suitably qualified,
independent review
Evidence of observed client interaction eg. call
listening, shadowing
Supervisors/trainers to retain one-to-one client
advice skills to a proportionate level
Actioning
3.4
Responsive
and adaptable
To innovate and
improve service
delivery internally
Evidence based changes designed into
service plans
Review of client journeys
Revised Money Advice Service Quality
Framework for Organisations
Achieving consistent and
high quality Debt Advice
23
Section 3: A learning organisation
Theme
Purpose
Quality Measure
Measurements/illustrations
Actioning
3.5
Gathers and responds
to client feedback
Evidence of actively gathering client feedback and
responding to clients
To improve
service
delivery and
improve client
focus
Client complaints procedure exists, is clear in
client journey and is complied with
Channel shift is clear within process and
procedures to support more efficient and
appropriate support for clients
Evidence of process in place for clients and
advisers to make an accurate assessment of need
and service varied accordingly
Actioning
3.6
To maintain
appropriate
service
delivery and
staff skills
Identify environmental
changes and
responds effectively
Evidence of external engagement eg.
participation in local advice networks
Subscribes to industry publications
Evidence of environmental and service review
shaping training and development of staff
24
List of respondents
List of
respondents
Advice NI
Advice Services Alliance (ASA)
Advice UK
Age Concern Torfaen
Age UK
British Bankers' Association (BBA)
Charities Evaluation Services (CES)
Cheshire East Citizens Advice Bureau
Citizens Advice
Citizens Advice Northern Ireland
Citizens Advice Scotland
Community Housing Cymru Group
Community Money Advice
Council of Mortgage Lenders (CML)
Credit Services Association (CSA)
Debt Managers Standards Association
(DEMSA)
Finance & Leasing Association (FLA)
Financial Services Consumer Panel
Gateshead Citizens Advice Bureau
HSBC
Institute of Money Advisers (IMA)
Leeds Metropolitan University
Leicestershire Citizens Advice Bureau
Lloyds Banking Group
Money Advice Scotland
Money Advice Trust (MAT)
National Association of Student Money
Advisers (NASMA)
Nick Lord
Office of Fair Trading (OFT)
Peaks & Plains Housing Trust
R3 Association of Business Recovery
Professionals
Smaller Businesses Practitioner Panel
StepChange Debt Charity
Stockport Council
The Debt Resolution Forum (DRF)
The Highland Council
The Hyde Group
The Institute of Credit Management (ICM)
The Legal Aid Agency
Welsh Government
Zero-Credit Ltd
Money Advice Service
Achieving consistent and
high quality Debt Advice
Money Advice Service
Holborn Centre
120 Holborn
London EC1N 2TD
Section
25
moneyadviceservice.org.uk
Annex 3
© Money Advice Service June 2013