€¦  · Web viewThe Common Advice Performance Management Framework (CAPMF) seeks to capture key...

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Common Advice Performance Management Framework (CAPMF) Indicator Guide v5 Contents Introduction.......................................................2 Scope and aim......................................................4 Future Developments................................................5 Consultation.......................................................6 Data returns submitted by each Council.............................7 Indicators included within the framework...........................8 Supporting information.............................................9 Appendix:.........................................................10 Definition of money and welfare rights advice...................10 Overarching key outcomes for money and welfare rights advice....10 CAPMF indicators and definitions................................11 1

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Common Advice Performance Management Framework (CAPMF)

Indicator Guide v5

Contents

Introduction...........................................................................................................................................2

Scope and aim.......................................................................................................................................4

Future Developments............................................................................................................................5

Consultation..........................................................................................................................................6

Data returns submitted by each Council................................................................................................7

Indicators included within the framework............................................................................................8

Supporting information.........................................................................................................................9

Appendix:............................................................................................................................................10

Definition of money and welfare rights advice................................................................................10

Overarching key outcomes for money and welfare rights advice....................................................10

CAPMF indicators and definitions....................................................................................................11

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Introduction

The Common Advice Performance Management Framework (CAPMF) seeks to capture key performance data for money and welfare rights advice services funded by local authorities on both an in-house and commissioned basis. By collecting this information, it is intended to achieve a consistent approach to reporting and measuring the performance of these services. The framework is co-ordinated by the Improvement Service (IS) but relies on the support and commitment of councils.

This is the fifth iteration of the Indicator Guide, and the second in which the framework has been known as the ‘Common Advice Performance Management Framework (CAPMF)’. The name change resulted from the inclusion of indicators relating to welfare rights advice and was formerly known as the ‘Money Advice Performance Management Framework (MAPMF)’.

The CAPMF sets out the measures used to demonstrate the nature and extent of money and welfare rights advice activities. These measures also form the basis for assessing performance. This Guide provides a definition and, where appropriate, simple guidance concerning how the data for each indicator should be recorded and reported. The framework has been revised following workshops, consultations and discussions with local authorities and other strategic partners.

A detailed rationale for the guide and the approach it takes can be found in the original version1.

Considerable support and commitment has been demonstrated by local authorities throughout the various iterations of the Framework. This has resulted in marked annual improvements in the consistency and accuracy of reporting.

1 http://www.improvementservice.org.uk/documents/money_advice/MAPMF/MAPMF-Indicator-Guide.pdf

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Scope and aim

The aim of the CAPMF is to support local authorities to measure and report on the contribution they make to money and welfare rights advice services in Scotland. Ultimately, the focus of the framework is on the identification of the benefits the services deliver for their users. In the current context of financial constraint, the framework can play a key role in assisting local authorities to assess and evidence the contribution their investment makes at both local and national levels. Ownership of the framework rests with local authorities, and the role of the IS is to facilitate and enable its use.

The IS recognise the importance of co-ordinating the CAPMF in line with the reporting requirements of other national funders of money and welfare rights advice, as well as key stakeholders, to ensure the widest possible consensus in relation to its key indicators. By adopting this approach, it is hoped to encourage consistency and establish common reporting requirements from funders. In the long run, this should reduce the overall data collection workload for local authorities.

It is essential to note, from the outset, that there are considerable variations as to how money and welfare rights advice services are delivered by local authorities. It is important to account for local needs, geography, and differing priorities. Consequentially, direct comparisons between one area and another are not always possible or sensible, due to the different contexts in which the services operate.

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Future Developments

This is the fifth version of the Indicator Guide for the performance framework. It will continue to be reviewed on an annual basis to ensure that it reflects continuous improvement, and that the indicators remain robust and relevant. A balance has to be struck between stability and certainty in relation to data collection, and the need to reflect changes in policy and practice. At the request of local authorities last year saw significant changes with the inclusion of indicators in relation to welfare advice and the inclusion of softer outcomes. As a result, identifying trends in the overview report, except in relation to those indicators for money advice, was limited. This year the changes are minor in nature and have been agreed following feedback from two workshops.

The changes (which are highlighted in yellow in the accompanying guide) are as follows:

Demographic data: Household Composition- the inclusion of additional categories to assist with

local child poverty reports. Household Status- the inclusion of additional categories to better reflect the

housing status of individuals seeking advice. The option to use either not recorded or not reported for occasions when data

is not returned.

Financial Gain: Separate reporting of financial gain from both welfare rights advice and

money advice.

Softer outcomes: Clarification on distinction between outcomes and indicators.

As the CAPMF develops through an iterative process, it relies on ongoing commitment and support from all local authorities. The extent to which this exists has been evidenced by the fact that all local authorities who provide or support money and welfare rights advice services have submitted information for the past three years. There is an acceptance and acknowledgement that the ultimate goal should be consistent reporting on all the agreed indicators. The IS will continue to work closely with key stakeholders to achieve this. Significant progress has already been made to date.

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Over the next year, consultation will take place in relation to testing the use of Office 365 to enable councils to self-populate data templates and to facilitate easier access to national information/data sets.

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Consultation

Following their involvement in its initial development, local authorities, their partners, and other stakeholders are regularly invited to contribute to the revision and improvement of the CAPMF. Each iteration of the framework is subject to in-depth discussion on identified areas via workshops, to which all local authorities and key stakeholders are invited. Whilst frequent opportunities are offered for feedback, the workshops provide the main platform via which any difficulties regarding the current framework can be expressed and possible solutions explored. Additional feedback is then sought prior to the implementation of any changes. All comments and contributions are considered and, where consensus is not possible, the majority view prevails.

The draft annual overview report is circulated among local authorities and key stakeholders prior to publication, providing a further opportunity for comment. All comments and contributions are considered and, where consensus is not possible, the majority view prevails.

In addition to a national overview report, individual councils are provided with area reports which set out the position at a local level. Councils are given the opportunity to review and highlight key information in their individual area reports. In many instances case studies which provide additional information are also included

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Data returns submitted by each Council

Each Council will be asked to submit one data return detailing the performance information of all money and welfare rights advice services that are funded and/or provided by the local authority.

The period covered by the current return is 1st April 2018 – 31st March 2019. Data returns should be submitted to the Improvement Service no later than 24th May 2019 using the CAPMF Data Return Excel Spreadsheet - issued with the Guide and also available to download from the IS website. Returns should be submitted to: [email protected].

Any queries relating to the data returns can be sent to the same e-mail address or can be discussed further with:

Karen [email protected] 283566

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Indicators included within the framework

There are five types of indicator included within the CAPMF: Context Input Activity Output Outcome

While not measuring performance directly, the context indicators are required to collect essential information on the composition of services and types of clients within each local authority area. In simple terms, local authorities rely on inputs (e.g. staff and budgets) to deliver money and welfare rights advice services. These inputs allow a range of activities to take place (e.g. meetings with clients). In turn, these activities will deliver a range of outputs (e.g. the debt strategy agreed with a client, benefit checks). These outputs may result in a range of outcomes for individuals, communities and the economy (e.g. client financial gain, improved health and wellbeing).

The Appendix of this Indicator Guide defines and summarises each indicator in the CAPMF.

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Supporting information

In addition to the data provided by local authorities, the IS will consult national datasets and other sources of information. The inclusion of this additional data, where appropriate, will strengthen the report analysis and contextualise the findings.

For example, areas the IS will include supporting data from the Scottish Legal Aid Board (SLAB) in relation to funding, and household financial behaviours relating to savings and bank accounts.

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Appendix:

Definition of money and welfare rights advice

Money and welfare rights advice, in the context of this framework, refers to free-to-client advice. Most free-to-client money advice providers describe the service they offer as money or debt advice with some elements of budgeting support, income maximisation, financial inclusion and financial education. Most free-to-client welfare rights advice providers offer assistance with questions regarding entitlement to benefits, benefit checks, help completing application forms, and advice on challenging unfair decisions.

It is recognised that service delivery models vary across local authorities in Scotland and therefore the interpretation of what constitutes money and welfare rights advice varies. This framework aims to record the performance of all the main services provided and funded by local authorities under the umbrella of money and welfare rights advice.

Overarching key outcomes for money and welfare rights advice

Effectiveness and client outcomes:The client’s situation has improved as a direct or indirect result of the money and/or welfare rights advice service’s intervention.

Operational and service delivery outcomes:All citizens requiring it can access good quality money and/or welfare rights advice via the channel that best meets their needs and preferences. Those who require face-to-face advice have access to it.

Efficiency outcomes:The money and/or welfare rights advice service delivers good value for the resources invested in it.

Strategic outcomes: The money and/or welfare rights advice service contributes to relevant local and national strategic outcomes.

Community and economic outcomes:The money and/or welfare rights advice service contributes to outcomes which benefit the community and local economy.

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CAPMF indicators and definitions

Indicator list

The indicators are categorised following a logic chain model of INPUT (I), ACTIVITY (A), OUTPUT (OP) and OUTCOME (OC) indicators. We have also included some CONTEXT (C) indicators. Local authorities are asked to provide only one data return. If a Council funds and/or provides more than one money and/or welfare rights advice service, the information should be aggregated locally before submission.

Context indicators

The context indicators are used to understand the make-up of money and welfare rights advice services and the people who access them within each local authority area. These indicators do not provide performance information, but will help to explain the complexities surrounding money and welfare rights advice service delivery across local authorities in Scotland.

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REF INDICATOR DEFINITION NOTESC1 Money and

welfare rights advice services and case management system(s) in the local authority area

Local authorities should provide the total number and individual names of:

In-house ExternalNo. money advice only No. money advice onlyNo. welfare rights advice only

No. welfare rights advice only

No. both money and welfare rights advice

No. both money and welfare rights advice

They should also list the case management systems used by money and/or welfare rights advice services in their area (e.g. AdvicePro, PG Debt).

Where a local authority funds a consortium containing several providers, each provider should be counted individually.

Outreach locations should not be counted as separate services.

C2 Number of clients per demographic measure

Local authorities are required to provide the total number of clients dealt with per financial year, broken down into the following categories:

Sex MaleFemaleNot recordedPrefer not to answer

Year of Birth 1937 and earlierList of all years in between2001 and laterNot recorded

Optional: Age 0-1516-2425-3435-4445-5960-6465-7071+

An adult is anyone over the age of 16.

The definition of a ‘pensioner’ is a person for whom the majority of their income is derived from pension payments.

Reporting by year of birth was introduced as it was suggested that was offered the easiest and most consistent way of recording age. However, concerns have been expressed that providing data in this way would be challenging. As a result, an option to report by the existing age bandings has been included. The age

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Not recordedPrefer not to say

Ethnicity WhiteMixed or Multiple Ethnic GroupsAsian, Asian Scottish or Asian BritishAfricanCaribbean or BlackOther Ethnic GroupNot recordedPrefer not to say

Household Composition

A single adult household contains one adult (non-pensioner) and no children

A single pensioner household contains one pensioner and no children

A small single parent household contains one adult and one or two dependent children

A large single parent household contains one adult and three or more dependent children

A young single parent household contains one adult (under 25) and one or more dependent children

A family household contains two adults (non-pensioner) and one or two dependent children

A large family household contains two adults (non-pensioner) and three or more dependent children

An adult family household contains two or more adults (non-pensioner) and no dependant children

An older adult family

banding 60-74 has been refined. Please use either category but not both.

An option to use ‘Not recorded’ or ‘Prefer not to say’ is offered. ‘Not recorded’ refers to data that is not collected , whilst ‘Prefer not to say’ means that the individual does not wish to disclose this information.

This includes additional categories which align with those set out in the Child Poverty (Scotland) 2017 Act.

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household contains at least one pensioner

Not Recorded Prefer not to answer

Disability or long-term condition

YesNoNot disclosed

Household Income

Note: income may be from a variety of sources-employment, welfare benefits, etc.

Net annual household income (after taxation and other deductions):£6,000 or less£6,001-£10,000£10,001-£15,000£15,001-£20,000£20,001-£25,000£25,001-£30,000£30,001-£40,000Over £40,000Not recordedPrefer not to answer

Economic status Self-employed

Employed full-time

Employed part-time

Looking after the home or family

Permanently retired from work

Unemployed and seeking work

At school

In further/higher education

Government work or training scheme

Permanently sick or disabled

Unable to work because of short-term illness or injury

Other

Not recorded

If it is not possible to distinguish between ‘at school’ and ‘in further /higher education please include under other and describe as student.

If recording in the other category please provide descriptions and numbers for each in the additional information box. For example, 11 students and 15 not seeking work.

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Prefer not to say

Housing status Owner occupier, which includes households who are buying their home with a mortgage or loan

Tenant (Social Landlord), which includes tenants of local authorities and Housing Associations or Co-operatives

Tenant (Private Landlord) which includes all types of tenancy for which a contractual arrangement between an individual and another individual/ company exists

Temporary accommodation, provided through the council in exercise of its statutory duties

Homeless ,an individual who lacks housing (without regard to whether the individual is a member of a family) as defined in the Housing (Scotland) Act 1987

Other tenure, which includes any other category of tenure such as living rent free

Not recordedPrefer not to say

Aditional categories to better reflect the housing status of individuals seeking advice have been included.

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If recording in the other category please provide descriptions and numbers for each in the additional information box.

C3 Amount, number, and type of debts owed by client

Local authorities are required to provide the total amount of debt, associated with each category listed. The figures provided for this measure should relate to all clients when they make initial contact with the service (before receiving debt advice). It is accepted that, in the course of receiving advice, further debts may be identified:

Benefit OverpaymentCouncil Tax arrearsUtility arrearsCredit, Store and Charge card debtsRent-to-Own debtsCatalogue debtsUnsecured personal loan (except payday loans)Payday loan / High cost credit arrearsBank and Building society overdraftsMortgage arrearsRent arrearsOther (please specify)

The figures provided for this measure should include the debts of all clients who made initial contact in the current year. This should include clients whose cases have been closed within the financial year.

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Input Indicators

The input indicators are used to measure the level of investment, via the funding and staff numbers attributed, that local authorities make into money and welfare rights advice services.

REF INDICATOR DEFINITION NOTESI1 Number of FTE

staff Local authorities are required to provide the total number of full-time equivalent (FTE) staff involved in the delivery of money and welfare rights advice per financial year, including administrative duties, for:

In-house ExternalPaid FTE Paid FTEVolunteer FTE Volunteer FTE

Figures should be reported dependent on how much staff time is spent providing money and welfare rights advice e.g. if money and welfare rights advice makes up 80% of staff business then 1 FTE should be recorded as 0.8 FTE. Part-time and temporary staff members should also be recorded proportionately.

I2 Funding Local authorities are required to provide the total annual sum of funding they provide in their area for money and welfare rights advice services:

Figures should include overhead costs (gross salary costs, i.e. including employer’s costs).

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In-houseExternally-funded

They are also required to provide the annual sums of funding that money and welfare rights advice services in the local authority area receive from other sources:

Scottish GovernmentBig Lottery FundEuropean Social FundOther*

Do not include Scottish Legal Aid Board funding as these figures will be provided by the funder directly

If funding for money and welfare rights advice is included as part of the total funding for the provision of general advice, this should be apportioned to give an estimation e.g. if the provision of money and welfare rights advice takes up 70% of service activity, then 70% of total funding should be cited.

Activity indicators

The activity indicators give an overview of the volume of clients and cases each money and/or welfare rights advice service has dealt with over the financial year. It is recognised that these measures do not reflect the overall activity of a service, but do provide valuable insight.

REF INDICATOR DEFINITION NOTESA1 Volume Local authorities are asked to provide the total number

of:

Any contact, in relation to money or welfare rights advice, made to the service over the last financial year ending

A money or welfare rights advice contact can be defined as an enquiry from a person seeking information on a money or welfare rights advice matter. The contact turns into a new client if the service has to take some form of action (e.g. signposting, referral, casework), to support the

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31.03.2019Clients supported by the service in the 12 months to 31.03.2019, including those whose access has continued from the previous financial yearNew clients accessing the service in the 12 months to 31.03.2019, who have not previously contacted the serviceContacts by channel: Face-to-face

TelephoneEmailWebWebchat

Number of benefit health checks carried out

Number of benefit health checks carried out

Referrals: Self-referralLocal Authority: Housing Social Services Revenues EmployabilityPrimary Health CareThird SectorOther

Reason for initially contacting the service (should not include

Benefit OverpaymentCouncil Tax arrearsCredit, store and charge

person and/or resolve the issue.

The framework takes a client-focused, rather than case-based approach to the measurement of volume. As such, each client supported by the service should be counted only once, regardless of the number of different issues they present with, or the number of times they present.

A ‘referral’ is where contact with the money and/or welfare rights advice service is initially established by another organisation on behalf of a client.

For the number of contacts by channel, only include the channel through which the individual first contacted the service. If repeated contact is made by the same individual, do not count the additional contacts separately.

Contact established with the service via the completion of online forms should be included under the ‘Email’ channel category.

The ‘Web’ channel category should be

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subsequent issues dealt with in the case)

card debtsCatalogue and Mail order debtsPPIPayday loanUnsecured personal loan from other provider (except payday loans)Bank and Building Society overdraftsMortgage arrearsRent arrearsHelp with appealing welfare benefit decisionSanctionedAssistance with making initial application for benefitsBenefits entitlement checkSeeking to access other funds (i.e. grants)Other (please specify)

Number of open cases at the end of the financial year

SNSIAP Type I casesSNSIAP Type II casesSNSIAP Type III cases

Number of cases closed during the financial year

SNSIAP Type I casesSNSIAP Type II casesSNSIAP Type III cases

measured via the number of unique page views of the service’s website.

The number of benefit health checks carried out should be recorded.

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Output indicators

The output indicators show whether a result has been achieved with each client.

REF INDICATOR DEFINITION NOTESOP1 Breakdown of

debt strategy agreed with client

Local authorities are asked to provide the total number of clients who agreed each debt strategy in the financial year:

SequestrationDebt Arrangement SchemeTrust DeedAwaiting sequestrationToken paymentsPro rata offersMoratoriumDebt written offRepayment planNil Payments/OffersConsolidation Loan

If a client has moved from one debt strategy to another, only report on the new strategy agreed. However, if they are using multiple strategies simultaneously, record all of them.

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Mortgage to rent/shared equityDid not agree a debt strategyAwaiting OutcomeOther

If recording in the other category please provide descriptions and numbers for each in the additional information box

OP2 Number of claims submitted and awards made/maintained for each type of welfare/social security benefit

Local authorities are asked to provide the total number of claims submitted and the number of awards made/or continued to be paid after review for each type of welfare benefit in the financial year:

Ill Health and Disability Benefits: Disability Living Allowance

Personal Independence Payment Attendance AllowanceIndustrial Injuries Disablement BenefitCarers AllowanceSure Start Maternity Grant (replaced by the Best Start Grant)Funeral ExpensesScottish Welfare FundCold Weather Payments and Winter Fuel PaymentsDiscretionary Housing PaymentsUniversal Credit*Contributory BenefitsChild BenefitChild Tax CreditMaternity AllowanceState PensionPension Credit

The intention is to identify the number of claims for welfare/social security benefits that are supported by advice agencies and which subsequently result in the benefit being awarded (or continuing to be paid) for the main types of welfare benefits.

It is noted that the list will be subject to review, and that it includes social security benefits that are being devolved to Scotland.

*This area is still under development and it is acknowledged that the complexity of UC may make reporting challenging.

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Bereavement BenefitsOther

OP3 Number of welfare/social security benefit claims that result in Mandatory Reconsiderations and Appeals, and their outcome

Local authorities are asked to provide the total number and outcome (won or lost) of benefit claims that result in Mandatory Reconsiderations or Appeals for the following benefits:

Ill Health and Disability Benefits: Disability Living Allowance

Personal Independence Payment Attendance AllowanceIndustrial Injuries Disablement BenefitCarers AllowanceSure Start Maternity Grant (replaced by the Best Start Grant)Funeral ExpensesScottish Welfare FundCold Weather Payments and Winter Fuel PaymentsDiscretionary Housing PaymentsUniversal Credit*Contributory BenefitsChild BenefitChild Tax CreditMaternity AllowanceState PensionPension CreditBereavement BenefitsOther

The intention is to identify the support provided by advice agencies to service users to challenge decisions about the award of welfare/social security benefits and the result.

*This area is still under development and it is acknowledged that the complexity of UC may make reporting challenging.

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Outcome indicators

The outcome indicators describe the benefits of interacting with the money and/or welfare rights advice service for the client. In the short term, this benefit comes in the form of financial gain. However, there are also longer-term positive outcomes relating to financial inclusion and financial wellbeing.

REF INDICATOR DEFINITION NOTESOC1 Verified and

unverified financial gain

Financial gain is the total amount of income generated for clients per financial year as a result of the intervention of the money and/or welfare rights advice service.

Financial gain is considered to be verified if the money and/or welfare rights advice service has independent evidence of the level of financial gain. This may be achieved via confirmation of receipt of the gain by the client, or by accessing a client’s records with another organisation. Other verification methods may also be possible.

Local authorities should provide the total sum of verified and unverified financial gain for the following:

Ill Health and Disability Benefits: Disability Living Allowance

Personal Independence Payment Attendance AllowanceIndustrial Injuries Disablement Benefit

Verified financial gain should be reported wherever possible.

This includes any income to which clients were entitled but would not have received without the intervention of the money and/or welfare rights advice service. This should include benefit/tax credits, refunds, debt written off, and grants accessed. In case of benefit/tax credits the award should be assumed for 12 months.

If the gain results from a change in benefits, only submit any additional payments gained (e.g. if a client was in receipt of benefits totalling £55.10 a week, and this increased to £82.30 a week following intervention, the

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Carers AllowanceSure Start Maternity Grant (replaced by the Best Start Grant)Funeral ExpensesScottish Welfare FundCold Weather Payments and Winter Fuel PaymentsDiscretionary Housing PaymentsUniversal Credit*Contributory BenefitsChild BenefitChild Tax CreditMaternity AllowanceState PensionPension CreditBereavement BenefitsOtherMoney Advice

figure submitted would be the new payment minus the old payment, and then calculated for the year. In this instance 82.30 – 55.10 = 27.20, multiplied by 52 = £1,414.40).

However, if the gain comes as the result of an appeal or mandatory reconsideration, include the full amount as this may have been lost without the service’s intervention.

The thinking behind it is that the role advice services play in ensuring service users continue to receive existing benefits should be reflected.

Do not include the following as financial gain:

Referrals to foodbanks Charitable donations Successful Blue Badge

applications

‘Other’ should include any welfare benefit gains not already covered.

Please note there is a separate for recording financial gain from money advice. This should Include financial

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gains resulting from increased resources i.e. money that is no longer payable, due to a debt being written off, DAS etc.

OC2 Improved health and wellbeing

Percentage (or number, in relation to sample size) of service users self-reporting improved health and wellbeing as a direct result of getting advice/support from the service. This will be evidenced by the numbers recorded agreeing with each indicator statement which relates to the defined outcome.

Agree/Disagree - as a result of the advice/support given:

I’ve been feeling relaxed I’ve been feeling physically better I’ve been feeling good about myself I ’ve been feeling optimistic about the future I’ve been getting on better with others

Please note – the wording of these can be amended slightly. If organisations wish to do this then please submit the statements that will be used so that we can ensure a consistent approach is adopted.

The intention is to identify what has changed for the service user as a result of the advice/support that has been provided.

This will be done by asking set questions at the final advice session (or as near to it as possible) of all clients who have received type II or III advice on an annual basis.

Baseline data will not be required. At this stage, we will not be measuring the extent to which change has occurred. However, this will be considered in future iterations.

To ensure consistent reporting, the indicators identified must be used. However, the data collection method applied is entirely up to individual organisations.

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OC3 Improved capacity and ability to cope

Percentage (or number, in relation to sample size) of service users self-reporting improved capacity and ability to cope as a direct result of getting advice/support from the service. This will be evidenced by the numbers recorded agreeing with each indicator statement which relates to the defined outcome.

Agree/Disagree - as a result of the advice/support given: I am thinking more clearly I feel more in control of my life I am able to make decisions I can cope with day to day issues/problems I know when to seek support and where to get it

Please note – the wording of these can be amended slightly. If organisations wish to do this then please submit the statements that will be used so that we can ensure a consistent approach is adopted

Guidance outlined in the ‘Notes’ section for OC2 applies.

OC4 Increased financial stability and resilience

Percentage (or number, in relation to sample size) of service users self-reporting increased financial stability and resilience as a direct result of getting advice/ support from the service. This will be evidenced by the numbers agreeing with each indicator statement which relates to the defined outcome.

Agree/Disagree - as a result of the advice/support given:

I recognise that I need help to sort out my money I am confident that I am getting all the benefits/help

to which I am entitled

Guidance outlined in the ‘Notes’ section for OC2 applies.

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I know how much money I have to spend I can manage my money I would be able to cope if I had an unexpected

expense

Please note – the wording of these can be amended slightly. If organisations wish to do this then please submit the statements that will be used so that we can ensure a consistent approach is adopted

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