Inspections and reviews
In March 2023 our Children, Families and Safeguarding Service took part in a national review of care planning for children and young people subject to the Public Law Outline (PLO) pre-proceedings. When social services are concerned about the welfare of a child they may hold a PLO or a pre-proceedings meeting. If adequate change or improvements are not made following this meeting, then the Local Authority may need to make an application to the court and ask them to make orders to protect the child.
The purpose of CIW’s review was to provide external scrutiny, assurance and to promote improvement in relation to the care planning for children and young people subject to the PLO pre-proceedings.
The review highlighted that we benefit from an experienced and stable management team within children’s services, who effectively oversee PLO-related procedures. The review highlighted a consistent approach to best practice in relation to statutory guidance, and also evidence of a clear approach taken by managers and staff members at every stage of the process.
In terms of improvements, the review included recommendations for future practice to ensure:
- A timely assessment process which avoids delays
- Routine sharing of information with parents and children, and clear communication with parents as a priority
- Methods of gaining feedback from parents and families regarding our work
- The voice of the child is captured in the process
Following the review we have introduced an improved quality assurance system that tracks the PLO assessment process from day 1 to day 42. In addition to the information leaflets we provide to families, we also utilise Mind of My Own, which allows us to capture the voice of the child directly, via the app. You can view the findings and recommendations from this review on the CIW website.
Complaints and representations
Everyone who makes a complaint about Social Services in Wales has a right to be listened to. Their views, wishes and feelings must be heard, and their concerns should be resolved quickly and effectively. Complaints can highlight where services need changing, so it’s important that as a Local Authority, we learn from them in order to identify where we can make changes and improvements.
We believe that effective handling of complaints is a crucial part of our responsibilities, and a robust complaints handling process is vital to ensure that our citizens receive the services that they’re entitled to. It enables us to:
- Acknowledge quickly when mistakes have been made
- Put them right effectively and apologise where appropriate
- Ensure that we learn lessons from complaints
The most common reasons for people making a complaint include:
- Wanting to be heard
- Ensuring that concerns are recognised, acknowledged and taken seriously
- Ensuring that appropriate action is taken to remedy problems and avoid similar incidents in the future
- To receive an apology
The Legal Framework for Social Services complaints sits within the Social Services Complaints Procedure (Wales) Regulations 2014 and the Representations Procedure (Wales) Regulations 2014. There is also reference to Complaints and the important role of Advocacy in Part 10 of the Social Services and Well-Being (Wales) Act 2014.
In addition, A Guide to handling Complaints and Representations by Local Authority Social Services was issued to all Local Authorities in May 2014 to enable planning for full implementation from 1 August 2014.
These Regulations and guidance confirm the arrangements for the:
- Setting up a complaints procedure
- The designation of a Senior Complaints Officer, to be responsible for ensuring compliance with arrangements made by the Local Authority
- The appointment of a Complaints Officer to manage the procedure
- The training of staff
- The production of an Annual Report
If possible, the Local Authority will try to deal with any issue straight away rather than try to sort the problem out later. If a citizen has a concern regarding practice, we will try to resolve the issue immediately or within 24 hours of the issue being raised. If successful, these instances are not required to be logged as a ‘formal complaint’ and are recorded as a ‘concern’, on our client information system.
To understand the volume of complaints we received during 2022-23, they represented 0.38% of the number of adults receiving care and support, and 1% of children and young people receiving services. In total, we received 22 formal complaints during the year. The decline in complaints received over the last five years can be seen in the graph above.
The financial impact on Conwy as a Local Authority related to the costs of appointing Independent Investigators or Independent Persons to complete the Stage 2 Investigation process totalled £9,162.77. This was an increase in comparison to £5,426.00 in 2021/22.
Whilst there were only two Stage 2 Independent Investigations undertaken in 2022/23, this expenditure includes the cost of an Independent Investigation which was actually completed in 2021/22, however, wasn’t reconciled until the following financial year.
There is a dedicated budget of £20,000 to commission Stage 2 Independent Investigators; however it is an unpredictable area due to the fact that complainants have a right to request a Stage 2 Investigation under the Regulations.
Of the 22 complaints we received, 20 were resolved at a local level, without the need to commission an Independent Investigator. The two remaining complaints progressed directly to Stage 2 at the request of the complainants, as is their right.
The number of complaints received by service area is very much dependant on the types and nature of the services being provided. Areas such as Family Support and Intervention and Children Looked After are particularly emotive, and our involvement with the families are based on concerns for the well-being and welfare of Children and Young People.
Other areas, such as Business Support and Transformation and Quality Standards and Commissioning do not have as many public-facing functions and therefore you would expect fewer formal complaints in relation to these particular services.
Of the 20 Stage 1 complaints, 17 (85%) were acknowledged by letter within two working days and 16 (80%) were completed within the 15 working day timescale. In all four cases where the deadline was exceeded, the complainant was communicated with and agreed to receive a later but thorough response, rather than rushing to adhere to the prescribed timescales.
What did people complain about?
It is quite difficult to identify single themes in relation to Social Services complaints. Many are quite complex in nature and include more than one specific element. For the purposes of the report we have identified what we believe to be the ‘main’ theme in each separate complaint. The most common theme identified was some form of disagreement with the actions of Social Services. Examining this theme further revealed that people often complain about actions undertaken in the best interests of another family member; however, they are in opposition to the action taken. Further work will be undertaken in relation to classifying the themes, in order to analyse trends over time and examine any recurring themes, going forward.
How we can improve
- To prevent any delays in complaints reaching our dedicated team, we will run Complaints Awareness training sessions with staff to raise awareness.
- We will be providing more support to staff who deal with persistent and vexatious complaints with a new managing Customer Contact in Social Care policy.
- We have recognised the importance of following up on any agreed actions in health and safety and multi-disciplinary meetings, so we’ll ensure that review meetings are held until all agreed actions are complete and signed off.
- We’ll undertake learning and reflection events after complex Stage 2 Independent Investigations to give all staff who’ve been involved a chance to debrief and apply learning to improve practice for the future.
- We’ll ensure that our charging policy arrangements are shared as soon as possible with individuals so that any invoices received are expected and not challenged.
- We need to set up a clear process for dealing with Disability Living Allowance payments where the child or young person is in a residential placement.
- As it is such a complex topic, we need to create guidance for families and carers on secure accommodation for young people.
- Where safeguarding concerns are received as part of a larger complaint, we will separate them out to avoid confusion and duplication of process.
- We need to create separate appeals processes where the Social Services Complaints Procedure (Wales) Regulations 2014 are not applicable.
In addition, our main aims for 2023-24 are:
- Resolving complaints within 24 hours of receipt as a complaint concern rather than a formal complaint.
- Encouraging local resolution at Stage 1 to avoid time and costs associated with Stage 2 Independent Investigators.
- Continuing to promote effective communication between staff and citizens.
- Reiterating the importance of timescales via planned training sessions.
- Introducing new forms to log complaints data accurately on our client information system.
- Undertaking a recruitment drive to increase the number of Stage 2 Independent Investigators available to cope with demand across North Wales.
- Facilitating smoother remote Independent Investigations through more reliable information technology.
- Updating our Service Level Agreement with Independent Investigators, to reflect latest data protection legislation.
Partnership Support Work / Monitoring of Commissioned Services
The Quality Standards Team consists of four Partnership Support Officers, one Assistant Partnership Support Officer, a Team Manager and a Section Manager.
Since April 2023, the team has carried out 107 monitoring visits to Care Homes, 45 visits to community supported living schemes and 14 visits to domiciliary agencies in Conwy.
In 2023, the team has also supported the work of Deprivation of Liberty Safeguarding (DoLS) Practitioners by undertaking follow-up visits to settings to monitor and audit a sample of existing DoLS authorisations to ensure they remain lawful and meaningful and to help maintain quality in applying principles of the Mental Capacity Act.
Seven visits have been completed to Community Supported Living Schemes to monitor financial record keeping.
The North Wales Escalating Concerns Procedure exists to ensure quality services and respond to increasing and escalating risks or concerns in relation to providers of services. Last year, work was undertaken with five care homes in Conwy under the Escalating Concerns Procedure. Enhanced monitoring visits to the settings are carried out in order to support the home to manage the agreed action plan process. Follow-up visits at one month, three months and six months are completed after the EC process has ended. In the coming year we plan to introduce a feedback form for providers to comment on our monitoring visits. We will also develop our monitoring work further to be able to support the children’s residential facilities that are currently being created within Conwy.