E3 Napo Response 2

A RESPONSE FROM Napo TO THE E3 Blueprint

Napo the Trade Union for Probation and Family Court Workers, welcome the efforts made by the NPS to receive feedback from staff on the Blueprint. The initial analysis by NOMS of this feedback is helpful, but we are unable to share the expressed view (Chapter 10 – Conclusion) that “no major design issues have emerged”. This statement is not really supported by many of the comments made by staff – many of which echo what Napo has been saying for some time, notably around court work and report writing. Nor do we think the statement is supported in the following bullet points summarising the review of design work.

In his foreword, Colin Allars states that what is needed for the NPS to progress within the E3 format is an “evidence based model of practice….backed by a fair distribution of resource”. In the overview it is quite clearly stated that “…..we have worked with and involved experienced probation professionals in the development of all of these proposals” although the document itself is then lacking in terms of the source material provided by the authors through which anyone reading the document can refer to the necessary research which would support these claims.

Our views on the Blueprint are outlined below, with headings relating to those shown in the original Blueprint. These reflect the considerable efforts of members of Napo’s Professional Committee, and many members engaged in ‘front facing’ work with service users who have attended the E3 engagement events, supplemented by contributions from a number of our practitioner Officers. Appreciation is due to them all for their work. 

Chapter 2 - Courts

The clearly stated aim is to streamline the process to the extent that 90% of PSRs are completed on the same day, in a short format. In our view, the emphasis is clearly on maximizing the efficiency of the Court rather than on the effectiveness and accuracy of the assessment. In order to simplify matters it appears that RSR/CAS processes will be streamlined and a proposal framework developed taking much of the considerative work out of the process. Consequently, most Court staff will be PSO’s under this model. The paper mentions that PSO’s undertaking PSR’s will allow PO’s to focus on more complex work. We must question who has decided that initial assessments are not complex pieces of work? The PSR is not only a crucial stage for an individual case but for decisions about risk, allocation (CRC or NPS) and the future work required. An organisation which does not see its intake point to require the exercising of careful professional judgement rather than a quick fix, is storing up future problems for itself. 

The E3 scheme also admits that it relies upon physical space being found in the court buildings which has historically been a difficulty. The emphasis is on the quantity and speed of reports rather than quality. The E3 document informs us that the report writing hubs will enable the development of “improved report writing” – we fail to see how this can work.

This section cites Wales as providing evidence of ‘excellent performance’ using this model but does not elaborate other than to say it has provided same day reports ‘nearing 90%’, largely written by PSO’s suggesting excellent value for money (nothing on quality or knock-on effects elsewhere, however). How well would this model translate to a system suitable for the entirety of the NPS including large urban conurbations with large numbers of courts? What is the “PO back-up” system in Wales?

It also cites London as developing an ‘enforcement hub’ that leads to consistency that it would like to see rolled out (although it accepts that this might not work in all locations). 

2.3.1 Advocates dedicated court teams under separate management. This is already happening in some parts of England and Wales, but the proposals here look more like a complete separation to focus on a largely administrative function. The implications of this are obvious, in that it could lead to a rapid deskilling of staff and a lack of development opportunities. Now not only the PO’s in CRCs will be unable to prepare PSR’s on new or existing cases but it seems that PO’s in the NPS will also be redundant in this sphere. The submission of “progress reports” at the point of reoffending is yet another example of duplication of work, inefficiency and lack of continuity. The latter, re the individual casework model, flies directly in the face of a quote in the E3 document at 3.4 -“ HMIP reviews (Hanson and White2006 Rice 2006) record the potentially serious risks of ‘building in discontinuities’”

2.3.2 Expectation that 90% reports will be done on the day, 70% oral, 20% written using a short format. Again the implications of this are obvious, in that very few if any safeguarding checks will be completed pre-sentence, resulting in possible misallocation and creating opportunities for risks to be missed. This is particularly the case in domestic abuse cases. The lack of quality and thoroughness of short format and oral reports is such that CRC’s are finding a dramatic dip in their work - proposals are insufficient in terms of generating community orders in particular. Effective assessment of risk relies on accurate and timely information sharing. It is currently not possible in most areas to get information from Police Safeguarding units or Children’s Social Care on the same day, never mind within an hour. We are aware of examples of Police information taking up to 4 weeks to arrive (which is out of time for even an adjourned report). We are clear that this information is crucial to safe assessments and we are suggesting that an hour is the maximum that staff should have to wait for information. Until these arrangements are in place everywhere the proposals should not be rolled out. This is a major concern bearing directly, as it does, on funding and ultimately staffing. We would like to see further analytical work done on sentencing patterns before and since TR, with an open discussion on the implications of the findings. 

2.3.3 Advocates a move to almost exclusively PSO teams for reports except where dangerousness is involved. They will not be expected to write reports on sex offenders but there is a strong suggestion that DA, high risk and complex cases could all be done by PSO’s with appropriate training. This is a dangerous precedent in our view; PSO’s may well be able to develop the knowledge and skills base but this should be reflected in both their job title and remuneration – i.e. they should be trained and qualified as probation officers. 

SFO'S and risk assessments. One of the first questions asked when completing an SFO review is about the quality of the initial risk assessment. Our understanding is that reports have already shown a decline in quality in some areas, which is of concern. We have further concerns that if the standard practice is to remove the pre-sentence assessment period and further have it completed by lesser qualified staff, that this result is likely to show a further decline. It should be noted that even if a case is reassessed very quickly post sentence, this question will still focus on the initial assessment at point of sentence.'

2.3.4 Looks at admin hubs, but suggests this idea is put on hold while other developments around digital Courts are discussed elsewhere (which seems sensible) 

2.3.5 RSR/CAS are described as complex and in need of further development to streamline them, (whereas clinical assessment by qualified probation staff barely gets a mention!). We are extremely sceptical of both the RSR and CAS tools particularly when considering their cost effectiveness and their impact on workload. 

2.3.6 Proposal framework – no detail here but we suggest this is likely to be a tick-box menu of proposals to make it easy for unqualified staff to choose. Such a development is unlikely to enhance the quality of reports presented to the courts, is unlikely to enhance the standing of probation in the courts and is very unlikely to reverse the decline in appropriate community sentencing. 

2.3.7 Enforcement hubs – some advantages in terms of consistency but as with admin hubs we await more evidence of what’s happening with digital Courts. The E3 board are also looking at pilots running in NW and NE divisions before making any decisions, but the clear implication is that enforcement officers should be banded at 3 

2.3.8 Separate management of Courts outside LDU cluster. Has some advantages in terms of efficiency of resource allocation but is likely to lead to further fragmentation of the service and deskilling of the workforce.

2.4 In our view this section contains a truly staggering comment which recognises that while safeguarding information is difficult to obtain on the day, ‘it is rarely crucial to the sentencing decision’. It is certainly crucial to the management of cases. How, for example, does that work when curfews may be imposed without knowing who else is living in the premises? Here there could be “looked after children”, vulnerable adults etc. etc. These are concerns long voiced by Napo and re-iterated by staff in the feedback on the Blueprint.

2.5 Recognises the impact on PSO’s beyond their current VQ3 qualification and suggests some modules from the Community Justice Learning Programme could be utilised to meet this need. No further detail is currently available on this proposal and it looks like more of an aspiration than a properly thought out proposal. This also talks about excellent administration being in place to underpin successful delivery, yet we have numerous reports of IT systems and facilities which are clearly not fit for this purpose. For example, lack of interview and work space, and IT systems not working. Electronic (paperfree) courts mean that Probation is way behind and lacking in the proper tools to do the job. Many Courts simply don't have space required for NPS staff to conduct private interviews and write up reports. One example is of 15 staff in one Court queueing up to use one interview space! IT is a massive issue, paperwork can be emailed to NPS staff but there is a bureaucracy around this and emails can take hours to arrive due to our outmoded IT systems. Added to this is the fact that there aren't usually enough computers for staff to use; an example was given of Bradford Court where several staff were told they needed to share only 2 laptops which had been delivered but don't work as yet! In North Yorkshire, court staff have taken delivery of a batch of new laptops, none of which can be used wirelessly. They are in their 8th week of reporting this and still they do not have access to get the job done. We need to be clear that these proposals can only work once the infrastructure is in place and as this relies on other agencies (i.e. HMCTS) NPS should wait until they have everything in place before rolling it out.

Chapter 3 - Community Supervision

The goal here is to have a standard operating model across the NPS, however many of the variations in operations across the country have developed in response to local situations or to work with local partnerships or specialist projects. Losing the ability to do this would disadvantage clients who have benefited from such arrangements.

3.3.1/2 Introduces the new tiering model. Little detail is given and more will be needed to analyse the effectiveness of this model. We would also need to see the link between the tiering model and workload management timings to ensure that appropriate resource is being allocated.

3.3.3 Suggests that PSO colleagues will work with cases up to category C2 in the new tiering model. C2 includes low and medium risk cases where additional factors (MAPPA level 1, child protection plan, IOM, vulnerability) are not present. For some PSO’s this will not be new but in some areas of the country PSOs have not worked with medium risk cases in the past. These colleagues will require support and training and development opportunities to ensure they are properly equipped to carry out the work. Currently there is little or no training and development available for NPS staff outside of the PQF arrangements and significant additional resources will be required for this. Consideration will need to be given to offering alternative roles to PSO’s who do not wish to do this work. 

There is no indication of the number of cases to be managed by PSO colleagues but we are aware of significant recruitment of PSO’s in some NPS divisions which raises concerns about future staffing levels. The logic of this model is also that PSO’s in the NPS will be holding apparently higher risk cases than the PO’s in the CRCs – which is illogical.

3.3.4 Discusses "case management support" and lists types of tasks that may be completed by someone other than the OM. It does not detail who would undertake these tasks but appears to suggest Case Admin or PSO colleagues. While some purely administrative tasks are currently performed by Case Admin colleagues some of the tasks on this list raise concerns. For example information sharing is included as something that could be done by others. While purely administrative queries can be dealt with in this way’ proper information sharing is a 2-way process that supports the development of risk assessment and risk management plans by all agencies involved. If this is not done by the person responsible for the risk assessment and risk management there is the potential for vital risk indicators to be missed. This is all detailed in the research that the Blueprint uses to "evidence" the proposals, so it seems bizarre to suggest removing continuity in response to evidence that clearly states continuity as a key factor in risk management. Section 3.3.2 introduces the concept of individual case management which is not unfamiliar to Probation staff but some of the proposals in this section undermine that principle.

3.3.5 Introduces the idea of using volunteers to support the work of the NPS. Prior to TR many Probation Trusts were developing volunteer schemes but most of the staff involved in these schemes were transferred to CRC’s as their work was deemed to belong to those organisations. Some of the feedback from those schemes was that the process of properly developing and supporting volunteers is very resource intensive. There is no "quick fix" and volunteers can never be used as a way to save money. We would support well-funded/properly organised volunteer schemes but the proposal to use external agencies is concerning. Maintaining safety and quality requires staff with a good understanding of the work of the NPS alongside staff with skills in working with volunteers.

3.3.6 Discusses the possibility of group interventions. This section will astound NPS staff who previously worked very effectively with their colleagues who delivered group-based interventions, most of which are now working in CRCs. The idea that the NPS will now develop group based interventions where those that the CRC offer are perceived as too expensive, is bizarre and undermines the case for TR itself. In some cases group based intervention can be very effective but not always. Any group based interventions will require careful development and properly trained staff. Whilst we acknowledge that the NPS have retained a number of staff with these skills, the resource exists in the CRC’s and it should be the role of the contract managers to ensure that it is affordable for the NPS. It is not the role of NPS staff to take on additional work to fill in the gaps. Any decision to move towards this model will have clear resourcing implications and hence a need to recruit widely to facilitate the freeing up of time.

Chapter 4 - Custody.

It is noted in the document that the details of the Offender Management in Custody review, conducted separately, has not yet published its recommendations and this may have a significant impact on the NPS work with those serving custodial sentences. This is likely to affect both Probation Staff in the community and those working in custodial establishments, and has the potential to bring about significant changes. We would like to know when this will appear. 

4.1 What does the model look like now?

There is comment made in relation to Parole Reports as a generic term, however there appears to be some confusion over the type of work being undertaken. NPS colleagues prepare reports on a number of different types of prisoners and the format for those reports are different, as can be the decision making when the case is reviewed by the Parole Board.  For example the reports prepared for Indeterminate Sentenced prisoners (IPP prisoners and Life Sentenced prisoners etc.) are different to those prepared on a Licence Recall prisoner.

Comment is made that those offenders recalled to custody have their cases reviewed routinely by the Parole Board at set intervals. Whilst there is usually an initial review, it’s the experience of our members that there can be problems with subsequent reviews due to backlogs at the Parole Board. This can be problematic to the prisoner however also has an impact for the sequencing of work and resources for staff, both in custody and in the community.

4.2 What do we want the future model to look like?

There is little recognition about the limited resources available within a number of custodial establishments including resettlement prisons, nor of the significant changes that the prison estate and many of its providers have gone through. This could have a significant impact on the suggestion that “those eligible will be able to access interventions early in their sentence”. In addition, motivational work may need to be done with individuals to ensure that they will be as receptive as possible for any planned intervention.

We would be interested in your proposals of the timing of the MAPPA process and how it could be used to inform target sentence planning.

Whilst we would welcome any improvement in the quality of reports to the Parole Board, Napo would be like to know what is meant by the front loading of quality assurance into the parole process, especially how this will happen, who will do it and where are the resources coming from.

Comment is made in this section about increasing the release of suitable prisoners at the first parole hearing. It would be helpful if these were more explicit and there is an acknowledgement of the different types of case heard by the Parole Board. For example this is more likely to happen if it was a review of a licence recall case rather than an indeterminate prisoner given the first review will be pre-tariff in those cases.

The proposal to work with colleagues at PPCS and presumably also at the Parole Board to make greater use of telephone and video conferencing for reviews is welcome as it would be a much more effective use of the Offender Manager time. Consideration also will need to be given to the physical resourcing of this for both probation offices and prisons, given that there is a limited amount of equipment available. It would also be helpful if discussion occurred about the timing of Oral Hearings. For example we are aware of one proposed Oral Hearing which was scheduled to start at 16.45. This is a potential hearing of 1.5-2 hours and the prison cannot accommodate it due to regime and staffing levels at that time of day.

4.3 End state proposals

4.3.1 Parole

We would appreciate more details and input from a professional association perspective into a review of when the MAPPA process should commence and how it could link to sentence planning at an early stage.

We note the question on EPIC “how will the programme deal with the issue of parole reports asking for addendums 6 months after the report was commissioned” The response makes reference to a meeting between the Director of Probation and the Parole Board Chief Executives to discuss inefficiencies in the system. Again comment is made about improved quality of reports supporting more offenders on the day of scheduled hearings, driving down the backlogs of hearings and reducing the need for addendum reports. Whilst a reduction of the backlog at the Parole Board would be helpful to NPS staff, It is our experience that many of the addendum reports being requested are for indeterminate prisoners and they arise from the whole structure and time-tabling of the Generic Parole Process and on occasions two or three addendum reports are being requested.

It is welcome that there is a proposal for training for Offender Managers for parole and Oral hearings. It would be useful if that is also made available to NPS staff in custody and if an arrangement can be made with HMPS colleagues.

It would be our view that such training would not be suitable for e-learning.

In terms of the long term proposal for the removal of SPO signatures, it is not clear if this links to re-call reports which also require an ACO signature at some stages, or Indeterminate Sentence Prisoners, or both.

In terms of the proposal for the wider use of ROTL for attendance on accredited programmes where these are not available in prisons, we believe that there will need to be liaison with the Prison Service in relation to this, and a review of the relevant Prison Service Instructions; especially given there are restrictions on MAPPA eligible prisoners going on ROTL and access to periods of ROTL have been reduced significantly in a number of establishments.

4.3.2 Recall

The greater use of executive re-release could be beneficial if all parties take the view that risk can be safely managed within the community.

In terms of improving the timeliness and quality of recall reports, and as a result reducing the number of oral hearings; whilst improvements in quality would always be welcomed, it is not evident how this would reduce the number of oral hearings especially in light of Osborn and Booth 2013.

4.4 Impact on Service Delivery

We would welcome consultation on the Quality Assurance Framework given that we have members working both in the community and custody who have significant experience of preparing reports for the Parole Board and giving evidence at Oral Hearings.

More details of the plan for an “earlier and more comprehensive risk assessment including access to interventions and intelligence sharing” would be helpful.

4.5 Impact on Staff

As previously stated we welcome the encouragement to make greater use of video links etc. However in terms of service delivery, there is the potential for staff never to have met the client prior to giving evidence at an Oral hearing. Therefore a balanced approach is needed.

A widening of the use of PPUD could be beneficial although our understanding is that it is limited at this stage to a small number of case administrators and we would be interested in your proposals to make improvements in the use of it.

Chapter 5 - Victims

5.2 States that the VLO role is a band 3 role but that this is subject to a review of the job description and job evaluation. It is strange that this pronouncement is made in advance of the job evaluation process and this suggests that the job evaluation will be manipulated to come to the answer required by NOMS as opposed to being a fair and transparent process. In those areas where VLOs are paid at band 4 this is as a result of a previous job evaluation process. It is vital that NOMS commits to a fair and transparent job evaluation process and also to positively supporting any staff who may be affected by re-banding following such activities.

5.3.1 Introduces the idea of admin hubs for victim work. While this may provide more administrative support for some VLOs who currently have none it will reduce administrative support to those VLO teams who currently have an on-site administrator. There are issues about case records and how they will be managed as well as concerns about the new IT model. There is a poor track record with regards to the introduction of new IT systems. They are regularly introduced before they have been properly tested and it is rare for practitioners to be properly involved in their development. It should also be noted that systems introduced recently were not properly tested for AT compliance and it is hoped that lessons will be learned in the development of any new victim systems. 

5.3.2 Appears to introduce a kind of tiering model to measure the complexity of the VLO cases. It is silent on how cases will be placed into each of the groups and doesn't indicate how this information will be used to manage workloads in practice. Without more information it is difficult to comment on the use of these bands. The bands are however very task based and make no mention of the actual complexities of working with vulnerable individuals. There is no mention of the additional complexities of working with victims who are also serving a sentence, or working with complex cases involving multiple co-defendants or offending families with victims and offenders.

Chapter 6 – Approved Premises

6.3.1 Introduces the proposal that all AP’s will become enabling environments or ‘PIPE’ establishments over the next 3 years. This will undoubtedly have an impact on the need for further staff training with most establishments being staffed almost exclusively by PSO’s. We would be interested to see what training is proposed and how this will be rolled out. Another concern around these changes is the increasing difficulty for OMs to access beds for those high risk cases who do not meet the criteria for a psychologically informed environment. Our members are already starting to feel the impact out in the field and the availability of a suitable bedspace, or not, can impact hugely on whether or not the practitioner is able to support release. 

6.3.2 Sadly, we will always be sceptical with regard to proposed new ICT systems. “The ICT requirement for this is likely to be met quickly” The description of how this will be achieved and the resulting benefits is a little glib, but we agree that we should seek to reduce the time commitment of AP managers to this process.

3.3.3 Whilst on paper this seems to be a sensible proposal, saving time on duplication of work, we are unsure how effective this may be in practice. As you have highlighted this system is already in place in some areas, either formally or informally, but staff have not indicated much being seen in the way of improvements. We acknowledge that this could have been contributed to by other changes in progress, and would be interested in any data you have evidencing that this is an improved state.

6.3.4 In relation to the concept of ‘standard’ and ‘complex’ APs, we would need to know more about this and how it is to be calculated before commenting.

6.3.5 Napo welcomes the commitment to double waking night cover at all times, and a Band 5 AP manager for each establishment. However moving to such an arrangement will require careful negotiation bearing in mind current staffing structures. Concerns have been expressed both in workshops and feedback regarding day/night staffing, standard payments for sessional staff, rostering and out of hours payments. We acknowledge that there are many current anomalies which we would have liked to have seen sorted out before now. Again, rationalization here will need to involve careful negotiation and attention to detail. We are unclear as regards how the administrative support staff arrangements that are proposed will work.

We would seek confirmation that work on the Health and Safety aspects of these new proposals has involved union Health & Safety representatives.

6.5 We would seek further clarification regarding the role of key workers and most notably how they will be rostered. What is also less than clear is what type of regime will be operated during daylight hours at weekends.

Napo would wish to express its serious concern regarding the use of security staff at any time of day or night, particularly when they are employed on sub-contracts to the private sector. They must have the requisite interpersonal skills and training and need to be able to work readily and collaboratively in the AP environment which must involve a degree of regularity in their use at any one establishment. Lack of familiarity with systems, staff and indeed residents will be unhelpful. This will be true also of sessional staff.

The interchange of staff as between the AP estate and other areas of NPS work such as offender management has yet to be explored properly. In principle, Napo favours the development of a workforce with the ability to move across all aspects of NPS work and thus with a greater breadth of experience. This will however necessitate attention to training/re-training as well as a better commitment to mobility policies. Quite how this might be effected for bands (1), 2 & 3 remains for discussion. Linked to this, particularly in the event of an initial significant reorganization of staffing structures, is the need for careful planning and incremental introduction with sufficient time for support, training and taster sessions in other environments where appropriate.

Chapter 7 – Youth Offending Services

7.1 Harmonisation of staffing and working models is long overdue. Since the YOS was created in 1998, no real thought has been given to the relationship between the YOS and the Probation Service. This has been particularly true of the use of and impact on probation staff. Sadly the benefits of multi-agency working have not been sufficiently realised through cross-fertilisation with staff moving in and out of the YOS under mobility policies.

7.3.1 A commitment to a national framework is welcome and long overdue.

7.3.2 The commiment to standardising band 4 secondments is welcome, though we are not sure that the use of band 3 staff should be ruled out altogether.

7.3.3 Caseloads - Where has the caseload figure of 25 young people been derived from? The statement is made with no supporting references as to what research was undertaken to come up with this figure. Our understanding is that maximum caseloads within YOT’s, for very good reasons, are around 15. Is it not somewhat insulting to suggest that seconded Probation Officers could manage this much higher caseload where qualified social workers who work as Case Managers within YOTs are unable to do so? Presumably, to manage this higher caseload, corners would necessarily need to be cut to achieve this in terms of the work that seconded Probation Officers undertake. Have YOT’s been consulted about how they would feel about some of their young people being treated differently in terms of receiving a lesser service and the inevitability of seconded probation staff missing some of the YOT’s National Standards owing to such a high caseload? It seems utterly bizarre to suggest that case managers managing high risk cases can cover 25 cases when the average for low/medium risk cases is no more than 15 in YOTs

Have YOTs been consulted about seconded probation staff working exclusively with older, higher risk young people? How do YOT’s feel about how this may de-skill their own staff in this area of work? 

7.4 Impact on service delivery – There is no mention in the Blueprint about the role of CRCs and CRC staff. Whilst acknowledging the statutory restrictions, it seems illogical that all young people passing the age of 18 should move into the NPS, if still subject to supervision. They should move directly to a CRC or the NPS depending on risk assessment. Where the NPS is becoming overloaded with work and some CRCs are not receiving sufficient work, this would seem doubly sensible.

7.5 Impact on staff – We would not disagree with the sentiments expressed here though, as already highlighted, secondments, protocols, training etc., have never really been methodically addressed. Equally, we would pose the question as to the potential role of CRC staff in YOT‘s or working with them.

Chapter 8 - Management Structures

8.1 We acknowledge that these need rationalising but this will require commitment to proper negotiation recognising existing structures and staff gradings – This is covered to an extent in 8.5.

8.3 The big failing is the ludicrous extent of HR work currently vested in middle managers (Bands 5 to ACO) since the demise of Trusts and the disappearance of local HR support. Complex clusters will require additional support in our view, in that often LDU clusters are hopelessly overloaded and proper resolution of this issue is critical.

There is very little in this chapter about the role of SPOs and this is a failing. The main concern is where will POs and PSOs, to say nothing of trainees, within teams, get the professional supervision which they need? Group supervision is mentioned somewhere but it still needs to run alongside some individual supervision. It is not entirely clear what grade the QDOs mentioned might be and whether their role will be as supporters of good practice or overseers and checkers. This is very vague. Also, the place of clinical supervision of staff dealing with high risk work all of the time is not addressed anywhere.

Again with reference to attendance at multi agency meetings, it is stated that, (as pre TR) MASH and MARAC will “sit at PO level” – with these meetings, liaison which was already convoluted pre-TR is made more complicated by the need to have adequate communication channels between CRC and NPS especially as the CRC has a high number of the DV and CP cases.

8.4 We are interested to explore how the tool works

We agree that more work is required on this chapter of work.

Chapter 9 – Other Supported Activity

Reference has been made in our response to Chapter 2 to the historic and ongoing issues of sufficient and appropriate accommodation within Courts. This, linked to continuing ICT issues, will remain a critical stumbling block to service provision within Courts for the foreseeable future. It hampers all models of service provision, existing and proposed. It can only be adequately addressed by first addressing the underlying power imbalance that exists between HMCS and the probation service (NPS), with the latter historically existing as a poor relation – founded no doubt in the original master/servant relationship. 

The re-ordering of the NPS estate as CRC’s increasingly move out, will be critical to the success or failure of any future operating models, and Napo would expect to have full consultation over this going forwards, as a key stakeholder.

Proposals for administrative ‘hubs’ have yet to be discussed at all and are far from agreed. There would be significant issues both around service provision as well as working arrangements for staff.

Linked to comments at 3.3.6 above, we question the proposals for the further expansion of group and programme work. We understood this to be primarily the province of CRC’s (apart from sex offender work) and would wish to know more about what is being proposed.

Facilities Management – Similarly, here we would expect full consultation over the future re-letting of these contracts. Napo has long been in favour of returning AP catering to an in-house provision as it has a special role involving not only feeding residents but also the development of essential life-skills.

Learning and Development – Whilst the new probation qualification scheme (CJL) is something that Napo has long supported, this is not really the vehicle for the support and development of existing staff, notably PSOs. This requires a specific and separate initiative – and one which will need to be in place and activated before any of the prosed changes are made.

Chapter 10 – implementation Approach

A realistic timeframe with appropriate milestones needs to be proposed and discussed.

Chapter 11 – Conclusion/Engagement

Napo acknowledges the efforts made to include staff in the planning stage of the E3 blueprint document. This has been done via a number of methods; electronically, face to face consultation meetings and consultation with the unions. However, we would like to remind you of the limitations of this, with a relatively small number of people actually getting involved in the process and thus a limited view of the wider workforce. 

We note that NOMS intend to widen the requests for feedback by use of an online survey and general E3 facility to mail in questions, which is already in place. Again we would like to note that the likelihood of widespread response is limited given the pressures of workload and limited understanding of the changes. These points have been raised before but are worthy of note here.

In respect of the future operating model for the NPS, it is crucial that NOMS get the communications right, in terms of timeliness, style and method. These need to be succinct, and especially cover: ‘the how will it affect me’ aspects and be easy to digest. We feel that this is essential if the intention is to take the relevant staff group with you, and that these communications must include appropriate feedback on the critical issues raised by NPS staff through their trade union. 

Napo welcomes the opportunity to continue our current dialogue with you on the E3 project.

Ian Lawrence                      Yvonne Pattison     Chris Winters
Napo General Secretary     National Co-Chair   National Co-Chair

27th January 2016