Consultation Response
Wales and the EU: Partnership for Jobs and Growth Consultation
on European Structural Funds 2014–2020
Children in Wales is a membership organisation. It is the national umbrella
organisation in Wales, bringing organisations and individuals from all disciplines and
sectors together. Its role is to make the United Nations Convention on the Rights of
the Child a reality in Wales. Children in Wales also fights for sustainable quality
services for all children and young people, and special attention for children in need,
as well as ensuring children and young people have a voice in issues that affect
them.
Children in Wales has around 200 organisations in membership, including the major
voluntary children’s agencies, professional associations, local authorities and health
bodies, as well as many smaller community groups. Children in Wales facilitates as
variety of forums across Wales and works in partnership with the National Children’s
Bureau in England and Children in Scotland, and internationally is active in Eurochild
and the International Forum for Child welfare.
Children in Wales have been recipients of 2007-13 Structural Funds through the
European Social Fund programme and have led on the delivery of a number of the
previous ESF programmes priorities including work streams around the theme of
participation of young people and reducing the number of NEETs. Our projects in
particular involved working with and up-skilling disabled children and young people,
young carers and engaging with young people on fuel poverty matters. Children in
Wales, working with our member organisations and joint sponsors, have also
developed and managed the Participation Workers Network for Wales
1. Introduction
1.1
Children in Wales welcomes the opportunity to influence the planning towards
the next EU budgetary cycle and assist in helping to identify the priorities for
investment ahead of the Multiannual Financial Framework 2014-2020 taking effect.
Children in Wales broadly welcomes the commitments and proposals set out in the
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consultation documents and recognise the added value that European funding can
bring to the convergence areas of Wales.
1.2
We acknowledge that there will be a significant decrease in European funding
compared to the previous programme and it is for this reason that it is essential that
finite resources are both managed and distributed effectively, and deliver positive
outcomes for our poorest individuals and communities.
1.3
Amongst the priorities for the next European Structural Funds Programme
should be a specific focus on tackling child poverty, given that independent research
and analysis has clearly demonstrated the children are being disproportionately
affected by economic austerity and the projected negative impact of welfare reform.
1.4
With over 200,000 children living in poverty, Wales can ill afford to miss this
opportunity of ensuring that European Structural funds work to improve the
outcomes for those most at risk and those most vulnerable.
We do not
underestimate the scale of the challenge ahead but recognise the contribution
funding from Europe can make alongside other sources of funding from nonEuropean streams, if utilised efficiently.
2. Safeguarding the Tackling Poverty priority
2.1
A clear requirement of the European Commission’s Europe 2020 framework is
for a commitment to tackle poverty and address current levels of social exclusion
across all member states. The European Commission have set a target for 20
million fewer people to be in poverty by 2020. This supports the current UK and
Welsh Governments legislative targets to eradicate child poverty by 2020 through
the Child Poverty Act and Children and Families (Wales) Measure.
2.2
Effective lobbying and negotiation at a European level by Eurochild, of which
Children in Wales are an active member, and other umbrella networks has ensured
that there is now a requirement for a minimum of 20% of available ESF funds to be
ring fenced for action to tackle poverty and social exclusion. Children in Wales
welcomes the commitment from the European Commission for this to happen.
2.3
The intention is therefore clear; to ensure that at least a fifth of funding is
channelled towards activities which demonstrate and maximise the impact that can
be had in tackling poverty in member states.
2.4
The Welsh Government consultation document however has identified this
core priority as one of 3 cross-cutting themes (CCT) with no safeguards in place to
ensure that this 20% allocation is effectively protected.
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2.5
We are concerned that in the absence of robust guidance which commits to
protecting the 20% allocation in Wales, this requirement will be interpreted differently
and will lead to different approaches being adopted, not only across member states
(as some countries will protect the 20%) but within individual nations.
2.6
Tackling Poverty as a priority themes should therefore be more visible and be
one of the explicit themes in its own right.
2.7
The Welsh Government should, as a matter of urgency, issue clear guidance
which both reinforces the European Commissions’ expectations for 20% of ESF to
be earmarked for tackling poverty AND which set out the Welsh Government’s
expectations on how programmes can tackle poverty in line with existing priorities.
This should include Programme for Government priorities and the objectives of the
statutory Child Poverty Strategy and Tackling Poverty Action Plan, soon to be
refreshed.
2.8
Without robust guidance on how this requirement should be met, there is a
risk and a real danger of this simply being reduced to an add-on or tick box exercise
and any positive outcomes in respect of tackling poverty will not be sufficiently met.
We are concerned that solely as a cross cutting theme, that this risks the European
Commissions’ intention becoming diluted and could compromise the opportunity for
meeting agreed European targets
3. Framework for delivering the tackling poverty priority – focus on
children
“Member states could consider putting a particular focus on children as a
contribution to the proposed objective of ‘Promoting Social Inclusion and Combating
Poverty’ when elaborating their Partnership Agreement and subsequent Operational
programmes 2014-2020” (Social Protection Committee 2012)
3.1
Children in Wales, with our European partner networks, have also been
involved in lobbying for and informing the development of the European Commission
Recommendation on Child Poverty which, after much delay, was adopted on 20th
February 2013 as part of the Social Investment Package for Growth and Cohesion.
3.2
The intention behind the Recommendation “Investing in Children: Breaking
the Cycle of Disadvantage”1 is to recognise children as rights holders and to provide
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Investing in Children: Breaking the Cycle of Disadvantage”
http://ec.europa.eu/social/BlobServlet?docId=9762&langId=en
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all member states with helpful guidance on how to tackle child poverty and enhance
children’s well-being.
3.3
The Recommendation is structured under three pillars which recognise that
whilst jobs and growth are key to combating poverty, they are not the only means by
which to reduce child poverty levels (this approach is consistent with that of Welsh
Government)
The Three Pillar approach focused on

Access to adequate resources (including supporting parents participation in
the labour market)

Access to affordable quality services (including early years education and
care, improved health systems and safe/quality housing and environment)

Children’s right to participate (including play, recreation and cultural
activities, and opportunities to engage in the decision making process)
Children in Wales believe that the Welsh Government should

Fully adopt and implement the Recommendation

Make explicit reference to the Recommendation in the Structural Funds
Guidance issued in Wales

Ensure that projects and innovations applying to receive future structural
funds under the tackling poverty priority meet at least one of the 3 pillars of
child poverty outlined in the Recommendation. This should be made explicit.
3.4
Coherent outcome focused indicators should also be in place to measure
performance and progress. These should closely align with existing child and antipoverty indicators in the Programme of Government and Tackling Poverty Action
Plan, as well as programme level indicators, particularly those being developed for
Communities First and Families First (as two examples of many)
3.5
Programmes funded through the ESF programme should be required to
demonstrate in advance of funding being released



how they intend to meet the tackling poverty priority,
which of the three pillar themes they intend to prioritise and
how the funding will meet Welsh Government priority outcomes under the
policy documents listed above.
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4. National support to deliver national priorities
4.1
To enable organisations and civil society both to access structural funds and
to meet the above expectations during the duration of the funding, Children in Wales
believes there should be sufficient capacity within WEFO to support and advise
organisations in their role.
4.2
Within this team, there should be at least one person of sufficient seniority
and who has the necessary knowledge and expertise in which to be able to fully
support organisations to meet the poverty and social exclusion obligations. This
person should have strategic links with officials in the Welsh Government Tackling
Poverty Team and be a recognised member of the Welsh Government Tackling
Poverty Champions network.
4.3
They should also ensure links are made with external stakeholders, including
key leads within local authorities, regional partners and the third sector. This would
include Children in Wales, as the national children and young people’s umbrella
body, the Tackling Poverty External Advisory Group, the Local Authority Tackling
Poverty Champions Network, the End Child Poverty Network Cymru (facilitated and
managed by Children in Wales), the third sector Anti Poverty Task Force and other
alliance groups as appropriate, including member organisation of Children in Wales.
In summary, whilst we support tackling poverty being identified by Welsh
Government as a priority in line with Europe 2020, the framework for delivering
on this priority should be sufficiently explicit and robust to ensure that any
gap between rhetoric and reality is avoided. An enhanced framework with
aligned outcomes and indicators should be developed which has explicit
regard to the European Commission’s recommendation on Child Poverty and
interventions should be funded utilising the Recommendation’s Three Pillar
Approach, as outlined above. The 20% funding for tackling poverty activities
should be ring fenced and protected in line with the Europe 2020 directive and
there should be sufficient support and expertise in WEFO in respect of the
tackling poverty theme.
5. Learning the lessons from the previous ESF programme
5.1
It is essential we learn the lessons of what has worked well and where new
approaches should be adopted as we enter this transition period from the previous
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funding round into the next programme. This will include learning from the
administration process for the previous grant to maintaining a support for projects
and services which have achieved the required impact under the previous
programme.
5.2
Sustainability of funding is key in terms of ensuring long term success for
projects funded through structural funds. Unfortunately, sustainability is often difficult
to achieve in the present financial climate and we are aware that a number of
projects funded through the previous programme have had to close or significantly
down size as a result of the funding coming to a close.
5.3
There should be opportunities in the next ESF programme for Social
Innovation to compliment tried and tested good practice models which have been
robustly evaluated and proved to deliver positive outcomes for children, young
people and/or their families.
6. External engagement: including the Children and Young People’s Third
Sector
6.1
It is imperative that the children and young people’s third sector are effectively
engaged as key stakeholders and are recognised as a key strategic partner in the
design and delivery of future ESF proposed priorities and solutions. The children’s
third sector can once again play a pivotal role in shaping the programme and
delivering projects on the tackling child poverty and social exclusion theme and the
proposed priorities identified, including ‘Early Years’, ‘Youth Attainment and
Engagement’ and ‘Youth Employment’.
6.2
Children in Wales, as the national umbrella body for the children and young
people’s sector, has a significant membership base which includes all the large
children’s charities and a cross section of smaller national and local providers,
projects and community based services. The children and young people’s third
sector will be, once again, well placed to lead projects in respect of the ESF
programme priorities.
6.3
Engagement with the children and young people’s third sector should take
place alongside effective and strategic dialogue with statutory and public sector
partners. This is essential given the national drive towards collaboration and multisector partnership arrangements in the design and delivery of key services and
programmes. Children in Wales membership extends to working with local
authorities, local health boards, the education sector etc. and we would be well
positioned to engage with Welsh Government in this regard.
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6.4
Children in Wales is a member of the Third Sector Partnership Council
facilitated by WCVA and a detailed response in respect of the role of the Third
Sector more broadly, commissioning arrangements and funding procedures has
been submitted which should be recognised as supporting the points made under
this heading
7. Commissioning and Civil Society
7.1
We support calls for the funding structure to be sufficiently flexible and
accessible to enable all third sector organisations to engage, including those smaller
organisations with limited capacity and resources. The commissioning process
should also avoid any undue complexity and be simplified to enable civil society to
access funds. Civil society has faced difficulties in the past in accessing structural
funds and it is essential that concerted efforts are made to enable a broad range of
stakeholders to effectively engage.
8. National Monitoring and evaluation arrangements
8.1
Children in Wales, with our European partner networks, have called on the
European Commission to effectively monitor the delivery and administration of the
programme and to capture the achieved outcomes from across all member states.
This is to help ensure that finite resources are spent in line with the requirements of
the Europe 2020 framework and to help capture good practice across different
member states which could be shared more widely as the next Programme
progresses.
8.2
We also call on the Welsh Government to ensure that there are robust and
transparent monitoring arrangements in place here in Wales prior to funds being
released. Whilst there should be a requirement to monitor the administration of the
grant and how money is being spent, there should also be a process for monitoring
the impact of funding to ensure it meets national priorities and expected outcomes.
8.3
There should of course be an expectation placed on funded projects to
effectively evaluate their projects and ensure that they achieve the desired impact.
However, we also need to achieve a fair balance between ensuring projects evaluate
robustly and ensuring that we avoid a disproportional amount of time and resources
dedicated to this which could compromise delivery. We do not wish to discourage
organisations applying for funds due to burdensome evaluation requirements.
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8.4
We would also wish to see on-going support from WEFO throughout the
duration of the funding framework to ensure that evaluation requirements are
understood and met.
Sean O’Neill
Policy Director
Children in Wales
Sean.oneill@childreninwales.org.uk
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you would prefer your response to be kept confidential, please tick here:
YES
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