Sustrans Cymru response to Welsh Government consultation: Continuity and change –
Refreshing the relationship between Welsh Government and the Third Sector
Overview
Sustrans Cymru welcomes the Welsh Government’s review of the relationship with the Third
Sector in Wales. While there are a number of positive aspects currently in the relationship,
there are a number of aspects which could be improved.
Notably the “one-size-fits-all” approach that the Welsh Government takes in communicating
and engaging with the sector fails to take into account the diversity within the sector,
particularly with relation to the different sizes of charities.
For example, the regular meetings organised with Ministers by the WCVA cover such a broad
subject range that the format is often not useful. However, for smaller charities with fewer
opportunities to engage, we can see that these meetings are a vital way of communicating
with Welsh Government. Welsh Government also relies too much on WCVA to
communicate on its behalf, and should communicate more directly with the sector on
occasion.
The range of funding opportunities for Third Sector organisations to directly engage with is
limited – and largely focussed on revenue over capital. Some schemes remain difficult for
the Sector to engage with, e.g. Communities First.
We broadly welcome the concept of an Innovations Fund for the Sector.
Question 1: Are there other key changes or developments in recent years that impact on
the relationship between Welsh Government and the Third Sector and should be taken
into account?
We broadly agree with the key changes and developments identified in the document.
However, with regards to funding, it is not just the pressures on public financing that are
important to the Sector, but also the ability to bid for and access funding directly.
We would welcome a review on payment to Third Sector bodies. The Agreement is
supposed to see the Third Sector paid in advance – to assist with cash flow issues – yet many
payments are still made by invoice in arrears.
We would also welcome a review of all projects that could offer opportunities to the Third
Sector either for accessing funding or delivering against Welsh Government priorities, to see
how effectively they are accessible to the Sector. For example, projects such as
Communities First appears to have unfulfilled potential for engaging with the Third Sector.
Also, while there are opportunities to deliver practical projects, it is not always possible for
the Sector to engage at the strategic level.
The Welsh Language (Wales) Measure 2011 will have a major impact on the Sector, and we
believe it’s vital the Welsh Government works positively with the Sector to ensure effective
compliance, but also to understand fully the challenges the Sector will face. We welcome
the Welsh Government’s reference to this in the consultation document.
Question 2: Do you agree that the analysis of the Third Sector and its qualities listed above
are still relevant?
Question 3: Do you consider that the give strategic themes in 2.17 are still useful as a basis
for ongoing dialogue?
Question 4: Are there other elements you would add or consider to be more useful?
While we agree with the premise that the Third Sector is complex and varied, the description
of the sector as listed in 2.11 fails to pay due regard to the professionalism that exists across
much of the Sector. We therefore feel it’s vital that the Welsh Government’s interaction
with the Sector reflects this diversity.
While the strategic themes listed in 2.17 are still useful for ongoing discussion, they are far
from exhaustive. A notable omission is the ability for the sector to provide policy expertise
and thinking at a strategic level. A number of Third Sector bodies have gained practical
experience in delivery that could be applied to policy formulation across a variety of
portfolios. Sustrans Cymru believes that a review of the strategic themes, potentially
involving the creation of sub-levels, is necessary. This will assist Third Sector organisations in
fully understanding where they sit within Wales.
The ability to innovate to achieve agreed outcomes is a key element of the way the Third
Sector operates – able to take a flexible approach and adapt to different situations. We feel
this flexibility and ability to innovate should be recognised as a strategic theme going
forward. We believe the relationship with the Sector would be strengthened by clear
required objectives and monitoring.
Question 5: The role of infrastructure is set out above. Please let us know if there is
something that you think has been overlooked.
We broadly support the role of the infrastructure as listed, however we would place a strong
importance on the role on the infrastructure to disseminate communication from Welsh
Government to its members, and also a more clear focus on the role of the infrastructure to
provide information on the wide range of funding opportunities.
While funding is covered by the stated aim of enabling Third Sector organisations to “grow
and develop”, that section is clearly a broad church. The infrastructure should have a vital
role to play in disseminating the variety of funding opportunities throughout the sector,
understanding the varied nature of the sector and the fact that different funding streams
will be suited to different organisations.
There could also be a role for the infrastructure in providing advice to the Sector in how to
apply to different funding streams.
However, it’s important to realise that the Third Sector is far wider than the infrastructure
and the Welsh Government should not solely rely on their relationship with the
infrastructure to be their relationship with the Sector as a whole. WCVA is good at
communication opportunities for consultation, but is regrettably poor at communicating
funding opportunities.
Question 6: How might we achieve the right balance of funding and delivery across the
Infrastructure nationally, regionally and locally?
Because of the varied nature of the sector, it’s vital that there are varied funding
opportunities, both in terms of size of grants and the type of funds on offer. For example
most funding available to the sector is revenue funding, despite the fact that many
organisations have very worthwhile capital projects.
As referenced earlier in our response, it is not just the direct funding provided that is
important, but the support available to help access funding not directly provided by the
Welsh Government.
It may be necessary to reform the Code of Practice for Funding the voluntary sector, as its
current application varies significantly across departments and levels of government.
Question 7: Do you support the proposal to develop a Third Sector Innovation Fund on the
basis outlined here?
Sustrans Cymru supports the introduction of a Third Sector Innovation Fund. The Sector has
a strong ability to come up with innovative and new ways of working to meet priorities, and
the Fund would support members of the Sector in fully developing those projects and
programmes, for the wider benefit of Wales.
Currently it is difficult for third sector organisations to access funding to come up with
innovative projects, and it is not always possible to justify spending core funding on
innovation. A Fund would provide greater opportunity to work on new ideas.
Question 8: We consider that the current infrastructure support for volunteering is strong
in many respects but could be simplified. Do you have any suggestions for how it could be
improved?
We agree with the view that the volunteering support is generally strong – although the
quality is varied across Wales. We welcome the moves underway to simplify the structure,
providing a single contact point for volunteering opportunities in Wales. For organisations
looking to recruit volunteers having to advertise in multiple areas can result in confusion or
ineffective advertising.
One area for improvement would be to ensure the suitability of volunteers for volunteering
opportunities in terms of a time commitment – of which the onus does also partly fall on the
Sector itself. For example, many of our volunteering opportunities are for a couple of days a
month, yet the majority of applicants are looking for opportunities to replace full time work.
Greater clarity on advertisement of posts on the time needed for the role is therefore key.
We also believe more should be done to provide support outside of the infrastructure, for
example in the private sector. The Platinum level of the Corporate Health Standard
encourages employee volunteering, but this is not effectively linked into the infrastructure
and opportunities.
Question 9: Do you agree the proposals for development of the TSPC and meeting
structure?
Question 10: The suggested framework for TSPC Workstream activity seeks to increase
the effectiveness of the contribution of the Workstreams. Do you have other suggestions
to add to/or improve the proposal?
Question 11: Do you agree that the existing biannual cross-portfolio Ministerial meetings
should be replaced be a more flexible pattern of meetings with Ministers which focus on
timely and specific issues of mutual interest/concern?
We fully support the reform and development of TSPC Workstream meetings and activities
to make them a more effective engagement tool. A Leadership group could help to provide
more focussed and topical meetings and to ensure strategic direction within the sector.
There is a clear need to reform feedback and communications as part of the set up.
We would support a more flexible approach to Ministerial Meetings to be able to respond to
key current events. At the moment, the meetings can fall out of sync with key
developments, reducing the opportunity for the sector to input into Government plans and
legislation.
This would also help in narrowing the agendas, which are also too broad to be useful. As a
larger organisation within the Sector in Wales, we think it would be worth looking at how
the meetings work for organisations of different sizes across the sector. Many larger
charities have greater options for direct engagement which are not always available to
smaller, community based organisations.
Question 12: What can be done to ensure that the Third Sector’s contribution to the
Programme for Government is recognised and maximised?
It’s vital that the Third Sector has a greater opportunity to engage at the strategic levels and
not just further down the line in project delivery. Early engagement with the sector and
more structured meetings with Ministers and key officials will be crucial in achieving this.
In particular, early engagement with the sector on new legislation will provide an
opportunity not only for stronger legislation, but also for input from those delivering related
projects in Wales.
In order to highlight how the sector (and indeed other sectors) are delivering against the
Programme for Government and recognised for their work, it’s important that delivery
organisations are recognised within all documentation.
Question 13: The proposal is for a greater Third Sector involvement in regional working.
How would you wish to see that achieved?
We support a greater opportunity for the Sector to engage at a regional level. However, the
varied and inconsistent nature of regional structures within Wales makes it difficult to
engage across departments and policy areas. Clarity over which level of government is
appropriate to engage with will make it more possible for the Sector to engage and work at
a regional level.
For regional working to be a success, more funding has to be available at that level of
government, both to innovate and deliver services.
Question 14: Do you agree that the model of commissioning set out in 5.17 should be
adopted within the Code of Practice?
We broadly support the proposals on commissioning contained within section 5.17. We
particularly welcome a focus on evaluation. It is vital projects are evaluated not just to
measure their outcomes against expectations and/or targets, but also to inform future
delivery.
This is especially important if a range of solutions to achieve desired outcomes is funded.
We will need to understand which solution is working best – and why – but also take into
account that different solutions could work best in different parts of Wales.
Question 15: Community development and community resilience is an important part of
the Welsh Government and the Third Sector relationship. How would you like to see our
proposals in this area taken forward?
We believe that some of the schemes that operate in more deprived communities are
difficult for the Sector to engage with, for example the Communities First programme could
have a far greater involvement from the sector, which could improve results.
In taking this work forward, it’s important that Welsh Government programmes in
communities are accessible for the sector to input into.
Question 18: Do you agree that the Voluntary Sector Scheme should be revised on the
suggested basis?
We agree that the Voluntary Sector Scheme will need to be updated following and changes
made as a result of this consultation process. We believe the sector should be involved in
reforming the new Scheme.
We particularly welcome an Annual Report laid before the National Assembly each year,
which will provide a continued opportunity to debate and discuss the Welsh Government’s
relationship with the sector.
Question 19: Do you agree that the Code of Practice for Funding the Third Sector should be
strengthened and updated? Are there particular issues you think should be addressed in
the revision?
We fully support an updating of the Code of Practice for Funding, especially in updating the
differences between grants and procured services and updated information on application
processes for funding.
It is our view that the Code is not always followed, and there is an inconsistent approach
between different Welsh Government departments. The code, therefore, needs to be
strengthened to ensure that in all but exceptional circumstances the funding code is
followed. A key issue is advance payment rather than invoice in arrears, and also certainty
over core funding. Cash flow issues are particularly important to the sector, and late
decisions over funding and annual grants can majorly impact on the sector’s delivery
capabilities.
Question 20: Do you agree that the existing Action Plan should be superseded by the
Integrated Delivery Plan, Annual Report and Work stream Framework?
We agree that the existing Action Plan will need to be updated to reflect changes within the
sector and following this consultation.
However, we have concerns over replacing one document with three documents. The
sector already faces challenges in dealing with vast quantities of government information
and Sustrans supports calls for simplicity and clarity. Those calls are as important in the plan
going forward as, for example, in the volunteering structure.
We would prefer to see a reformed Action Plan – a single document – which focussed on all
the key areas.
Sustrans Cymru
123 Bute Street
Cardiff
CF!0 5AE
sustranscymru@sustrans.org.uk
023 2065 0602