Directorate of Adult, Community and Housing Services
Ednam House, St James’s Road, Dudley, West Midlands, DY1 3JJ
Tel: (01384) 815822 Fax: (01384) 815865
MV/SK 01384 815806
10th October 2012
Elias Koufou
ILF Consultation Team
Ground floor
Caxton House
Tothill Street
London
SW1A 9NA
Date 9th October 2012
Dear Elias,
Please find below the response from Dudley Metropolitan Borough Council to the Independent Living Fund Consultation.
Question 1
Do you agree with the Government’s proposal that the care and support needs of current ILF users should be met within the mainstream care and support system, with funding devolved to local government in England and the devolved administrations in Scotland and Wales?
This would mean the closure of the ILF in 2015.
We would generally be in favour of the proposals to close the ILF and transfer the responsibilities to local authorities.
With the implementation of personalisation in social care the ILF has become an anomaly, and since the closure of the ILF to new applicants in March 2010, a '2 tier' system has developed with young people moving through transition getting a poorer deal than those on ILF.
However, as with these things the devil will be in the detail, and unfortunately there is little detail in the proposals at the moment for us to make a more considered judgement.
Question 2
What are the key challenges that ILF users would face in moving from joint ILF/Local Authority to sole Local Authority funding of their care and support needs? How can any impacts be mitigated?
We refer here to the response given to question 4 relating to localised FACS criteria and the difficulties around managing any required reduction in funding once responsibility is transferred to Local Authorities.
Question 3
What impact would the closure of the ILF have on Local Authorities and the provision of care and support services more widely? How could any impacts be mitigated?
Currently the ILF has a group of staff who visit to complete annual reviews supported by an administration team. One of the issues for us as a Local Authority is whether funding for this activity at a local level would be included in the money transferred to LA also whether the money transferred will sufficient to cope with the current levels of demand.
However much the final transfer to Local Authorities is to be we would ask that consideration is given by DWP colleagues into the ring fencing of ILF monies.
Question 4
What are the specific challenges in relation to Group 1 users? How can the Government ensure this group are able to access the full range of Local Authority care and support services for which they are eligible?
There are indeed 2 distinct groups receiving ILF. The first group to receive this payment in its beginnings are not likely to be known to LA/they will be receiving services funded by ILF which are not at the FACS level of substantial or critical.
We would suggest that this group be allowed to have" protected rights" and not to introduce changes for this group as they will be clearly expecting that the current level of support will continue as originally promised by ILF
The second group they are more likely to have complex needs and the total care package has been joint funded from ILF and Local Authorities. Once again the elements funded by ILF could be below FACS eligible criteria.
Reviews will be needed for this group and to enable us to do this in a timely manner the programme should begin as soon as possible. However this may place Local Authorities in a difficult position as people were told that all money has been devolved and they will retain current level of service. If a review takes place and a persons allocation needs to change then perception could be that it is the Local Authorities are responsible for reducing benefits to individuals
Question 5
How can DWP, the ILF and Local Authorities best continue to work with ILF users between now and 2015? How can the ILF best work with individual Local Authorities if the decision to close the ILF is taken?
The distribution formula developed between local authorities needs to based on current ILF usage, not on population. Different Local Authorities use the ILF in differing amounts.
To distribute ILF spend using the normal population formulae would discriminate against areas that use the ILF more than others.
The 'taper' that no doubt will be applied to any transfer needs to be a very long one. We have 21 year olds with normal life expectancy in receipt of ILF funding.
Dudley will have to do more assessments before the ILF closes. These assessments and the subsequent support planning will be complex. Therefore the current care management and admin costs of the ILF should also be overtly transferred to LA's.
That completes the consultation response from Dudley MBC if you have any further questions please do not hesitate to contact me or one of my team.
Yours sincerely,
Maggie Venables
Assistant Director Adult Social Care
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