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Money Advice Service

Debt Advice Peer Assessment Scheme (DAPA) for Webchat Advice

Pre-Assessment Questionnaire and Supporting Guidance for Participating Organisations

Administered by Recognising Excellence

September 2018

Your Organisation has been scheduled to participate with the Money Advice Service Debt Advice Peer Assessment process. This Pre-Assessment Questionnaire is the first stage of the assessment and will enable Recognising Excellence (RE) to select a sample of case files to be considered by the Peer Assessor. The questionnaire should be completed and returned directly to RE within the next 10 working days along with the supporting documentation that has been requested.

To support participating organisations with the assessment approach and provide additional insight into the different stages of the process, this document also identifies key guidance.

Money Advice Service Debt Advice Peer Assessment (DAPA)

Pre-Assessment Questionnaire for Webchat Advice

Organisation Contact Details:

Name of Organisation:

Name of MAS Funded Partnership (where relevant):

Capitalise / MASDAP/ EMMA/ GMMAP/ Money Advice West/ Other

If MASDAP, please confirm the sub region within which you operate:

Principal Office Address:

Postcode:

Primary Contact (Person responsible for Peer Assessment):

Position:

Telephone Number:

Email Address:

Secondary Contact Name:

Position:

Email Address:

2Debt Advice Peer Assessment (DAPA) for Webchat Advice

Pre-Assessment Questionnaire and Supporting Guidance for Participating Organisations Final www.recognisingexcellence.co.uk

Service Delivery Overview:

Service delivery data is now collected within the Case Sampling Tool workbook which accompanies this questionnaire and has been provided separately in the covering email. Case information will only be accepted if submitted within this workbook.

Please confirm the volume of MAS funded debt related webchat sessions completed over the preceding 6-month period to receipt of this notice: _________________

Organisational and Advice Service Delivery Overview:

Please use the following sections to provide additional insight for your Peer Assessor on the way your service is structured and delivered, including the approach taken to quality assurance.

Standard Information Accessible to Clients: - Please provide an overview of any standard information which is made available to clients accessing the service along with an overview of any channel engagement considerations e.g. Timeout arrangements, Nature and Role of Service, Complaints Procedure, Confidentiality and Data Protection including how the client needs to acknowledge these prior to moving into the chat. (Where appropriate, please provide screen shots/ pre-loaded system messages to the webchat entry platform.)



Standard Advice Fact Sheets / Templates – Please provide an overview of any standard advice routinely used which may not be included within the case file record, including how and when used i.e. Standard Fact Sheets where applicable. (Where hyperlinks form part of the case transcript, no further information will be required).

Approach to Case Recording: - An assumption has been made that the case submission will reflect the full chat transcript. If this is not the case, please provide an overview of how cases are managed and how the cases will be presented for assessment.

Can Case Records be exported out of your CRM system into a word document to support the case submission process? (If no, what format can this be provided in?)

YES / NO



Standards of a good webchat – Please provide an overview of the organisational standards expected from a webchat and your approach to quality monitoring/internal case review.

Vulnerability – Do you have a policy for dealing with vulnerable clients?

Yes / No

If yes, please provide a copy to RE.

Safeguarding – Do you have a Safeguarding policy in place?

Yes / No

If yes, please provide a copy to RE.

Changes to operational delivery: Please provide an overview of any changes made to the way advice is delivered in the webchat setting and how cases are managed as a result of the findings of the previous peer assessment (where applicable).



Personnel Changes: Please identify if there have been any personnel changes over recent months that we should consider when determining the sample of cases to be considered at assessment.

Additional Comments: Please use this opportunity to share any additional information you would like the assessment process to consider e.g. internal checklists or prompts utilised by the Advisers.

Staffing and Personnel

Employee and volunteer resource data is now collected within the Case Sampling Tool workbook which accompanies this questionnaire and has been provided separately.

Protected Characteristics – Do you have any individuals within your team who are covered by one or more of the Protected Characteristics identified within the Equality Act? Yes / No

If yes, please provide an overview of any adaptations/reasonable allowances made for staff and the employer support that is available to them. E.g. if an Adviser has been diagnosed as dyslexic, what arrangements/allowance/support are available to them to enable an accurate and comprehensive record of the advice given to a client to be maintained.



Disclaimer:

I can confirm the information provided is accurate and reflects our current delivery model. I can confirm the primary contact for the Peer Assessment process is someone with authority to act upon the findings of the process, implementing any changes required as appropriate. I can confirm we have provided RE with all standard information that is routinely used, which may not be contained within the case file record itself.

Signed: Date: …......./….........../…..........

Name: …........................................................................................ Position: …..................................

Documentation to be returned to RE to enable the assessment to commence:1. Completed Pre-Assessment Questionnaire Yes / No2. Completed Case Sampling Tool containing A) Service delivery overview B) Staff List C) Case activity report for previous 6 months (or 3 if not the first assessment rotation) for each Adviser identified within the Staff List

Yes / NoYes / NoYes / No

3. Copies of any standard / routine advice templates that may not be incorporated within the case file (where appropriate)

Yes / No / Na

4. Copies of any Screen Shots applicable to chat entry platform Yes / No / Na5. Copy of Vulnerability Policy Yes / No / Na6. Copy of Safeguarding Policy Yes / No / Na7. Copy of any quality monitoring/ internal case review criteria as appropriate Yes / No/ Na8. Any other relevant supporting documentation you would like us to consider Yes / No / Na

Please submit your completed questionnaire and all relevant documentation to:

[email protected]



Debt Advice Peer Assessment Guidance for Webchat Advice



Contents

Page No.

1.0 Glossary of Terms 132.0 Summary of key changes to the Peer Assessment process 133.0 Engagement with the Debt Advice Peer Assessment process 144.0 Appointed Administrator 145.0 Peer Assessment Panel 156.0 Data Protection and GDPR Compliance 16

6.1 Data Protection 166.2 IT Security 176.3 Hard Copy/Document Security 176.4 Peer Assessor Confidentiality 18

7.0 Debt Advice Peer Assessment Cycle 208.0 Pre-assessment Guidance 21

8.1 Assessment Cycle 218.2 Notice of a scheduled Peer Assessment 218.3 Pre-assessment Questionnaire, Staff List and Closed File List

Requested21

8.3.1 Pre-assessment Questionnaire 218.3.2 Case Sampling Tool 22

8.3.2.1 Staff List and Volunteers 228.3.2.2 Completed Cases 228.3.2.3 Client Consent 22

8.4 Case Selection Process 238.5 Case Sampling 238.6 Case Sample Essentials 248.7 Submitting Cases for Assessment 24

8.7.1 Acceptance of the Case Sample and Evidence of Client Consent 248.7.2 Case Submission Content 248.7.3 Unique Reference Numbers 248.7.4 Case Submission Declaration 25

8.8 Storage of Cases During Assessment Process 258.9 Allocation of a Peer Assessor 25

8.9.1 Conflict of Interest 258.10 Assessment Commencement 278.11 Service Level Agreement 27

9.0 Assessment 309.1 Approach and Objectivity of the Peer Assessment Panel 309.2 Void Peer Assessment 309.3 Assessment of the Case 319.4 Case File Preliminaries 31



9.5 File Scoring Process 319.5.1 Stage One – Score the Case File 329.5.2 Scoring Definitions 339.5.3 Stage Two – Organisational Score 339.5.4 Assessment Report 34

10.0

Post Assessment 34

10.1 Quality Control and Moderation 3410.2 Assessment Findings Shared with Participating Organisation 34

10.2.1 Urgent Remedial Action 3510.2.2 Other Remedial Actions 35

10.3 Assessment Findings share with MAS and Lead Organisation 3510.4 Post Assessment Discussions with Scheme Representatives 35

10.4.1 Technical Clarifications 3610.4.2 Participating Organisation’s Representatives 3610.4.3 Post Assessment Discussions Outline Agenda 36

10.5 Representations Process 3710.6 Assessment Cycle 38

11.0

Thematic Insight Analysis and Sharing of Good Practice 38

Appendix One Debt Advice Peer Assessment Criteria – Webchat 39Appendix Two Debt Advice Peer Assessment Case File Submission Declaration 47Appendix Three RE Key Personnel and Contact Details 49Appendix Four Peer Assessment Panel Biographies 51Appendix Five Debt Advice Peer Assessment – Conflict of Interest Policy 58Appendix Six Debt Advice Peer Assessor Code of Conduct 60



1.0 Glossary of Terms

Administrator Recognising ExcellenceAssessment Peer assessment on a sample of webchat casesAssessor Peer AssessorLead Organisation The organisation contracted directly with MAS

MAS The Money Advice ServiceOrganisation An organisation to be assessed Peer Assessment Panel Team of RE appointed individuals to undertake Peer Assessment

activityPeer Assessment The Money Advice Service Debt Advice Peer Assessment ProcessRE Recognising Excellence

2.0 Summary of Key Changes to the Peer Assessment Process

From April 2018, MAS has incorporated the findings of the Peer Assessment process into its performance management framework. The peer assessment findings form one of a series of metrics within the performance management framework. This will mean that peer assessment results, including summary reports will be shared with both MAS and the lead organisation (where relevant).

Key changes that have been made to the assessment process and which took effect from April 2018 are summarised as follows:

Previously called the Peer Review Scheme, the name has been changed to Debt Advice Peer Assessment;

Assessment findings will now be shared with both MAS and the lead organisation (where relevant); The criteria which form the basis of the assessment has been refined to clearly identify those

requirements that are considered essential to provide high quality debt advice, and those that are examples of good practice.

The DAPA Face to Face Scheme launched in April 2018 and the Scheme was adapted during the Summer of 2018 to reflect delivery of advice via the channel of webchat.

A mandatory Case Sampling Tool workbook has been created to support the Pre-Assessment Questionnaire. Completion of the workbook with both staffing and completed case information is an essential element of the pre-assessment and case selection process;

Cases to be considered by the assessment process will now be drawn from the preceding 6- month period rather than the previous 12;

Cases will be drawn from the pool of MAS funded debt advice only;



The Pre-Assessment Questionnaire has been revised and now requests additional insight into the delivery models and approach to quality assurance within which participating organisations operate;

The Service Level Agreement has been restructured and will now run the maximum timeframes determined within each stage. Participant performance against SLA will be reported through to MAS.

A declaration has been introduced at case submission stage for participating organisations to confirm the submission reflects the complete record of the cases to be considered;

The post assessment feedback discussion with both RE and the Assessor has been re-structured. A revised process for Representations is now in place; The reporting structure for case file findings and the assessment summary report has been revised.

The assessment summary report will now make recommendations on areas for improvement, which will be managed post assessment by both MAS and the lead organisation (where relevant).

Remedial Action phase post assessment – the peer assessment process will now only identify actions that are considered urgent. These will relate to the findings of the case files themselves and typically to those files that score either a 0 or a 1. It is recognised that due to the nature of the advice channel, it will not be possible for an urgent action to require re-engagement with the client. Any urgent actions that arise from the assessment are likely therefore to be limited to adviser technical knowledge and supervisory points only. Non-urgent recommendations may be made as part of the process and recorded in the assessment report.

3.0 Engagement with the Debt Advice Peer Assessment

Participation with the assessment process is a mandatory requirement for those organisations who are in receipt of funding from MAS.

From April 2018, RE will directly share the findings of the assessment process with both MAS and lead organisations (where relevant).

4.0 Appointed Administrator

Recognising Excellence (RE) was appointed by MAS as the Administrator in 2015. For any queries in relation to the Peer Assessment and delivery approach, in the first instance, please contact:

Recognising ExcellenceUnit 3, Twigworth Court Business Centre

Tewkesbury RoadTwigworth

Gloucester, GL2 9PGHelpline: 07934 299 667



Email: [email protected]

Key RE personnel involved in delivering the assessment process are identified within Appendix Four, which also includes appropriate contact information.

5.0 Peer Assessment Panel

The Peer Assessment Panel represents a broad range of debt advice organisations from both independent advice organisations, Citizens Advice members and national telephone providers. The panel includes a mix of both MAS funded and non-funded agencies. Appendix Five contains a brief biography of each team member.



mailto:[email protected]

6.0 Data Protection and GDPR Compliance

6.1 Data Protection

Recognising Excellence is complying with current data protection legislation, the Data Protection Act 1998 and the General Data Protection Regulation 2016/679 (GDPR) or any codes of practices issued by the Information Commissioner from time to time.

For the purposes of this guidance to carry peer assessments the Money Advice Service is the ‘Data Controller’, Recognising Excellence the ‘Data Processor’ and the Peer Assessor acts as the ‘data sub-processor’.

The legal basis for Recognising Excellence for processing data is that of “contractual obligation” as set out in Article 6 (1) (b) of the GDPR.

The organisation being assessed will be made fully aware of its rights under GDPR by reference to the Money Advice Service’s Privacy Policy https://www.moneyadviceservice.org.uk/en/corporate/privacy and the Recognising Excellence’s Privacy Policy www.recognisingexcellence.co.uk/Privacy. Most commonly these are:

All information gathered during the assessment shall be held as absolutely confidential however obtained or learned from the organisation in pursuant to or in preparation of, or obtained or learned during the term of this activity, whether relating to the organisation or to any of its officers, servants, agents, clients, suppliers, or subsidiaries or to the business of any of the foregoing persons or otherwise, and whether or not expressly designated confidential.;

Recognising Excellence shall not without the organisation’s prior written consent use or permit or cause the same to be used, save for the direct purpose of this assessment.;

Recognising Excellence shall not without the organisation’s prior written consent, disclose or permit or cause the same to be disclosed to any person other than to those of its full-time employees and/or its Peer Assessors and/or Moderators who need to be informed thereof to enable Recognising Excellence to perform its obligations.

No case files or employee records will leave the organisation’s premises, except by GDPR compliant couriers (see below) and Recognising Excellence’s Peer Assessor will destroy all notes/records on completion of the assessment process.;

Recognising Excellence, on behalf of the Money Advice Service, will securely retain any peer assessment related information for 6 years from the date of creation, for the period it holds the MAS contract. At the end of the contract, all data will be transferred to MAS.



http://www.recognisingexcellence.co.uk/Privacy

https://www.moneyadviceservice.org.uk/en/corporate/privacy

6.2 IT Security RE’s IT system, a generic Microsoft Office 365 system, Client Relationship Management (CRM) system and Sage accounting system is operated through an individualised password protected web based terminal server programme. Staff and contractors are allocated access levels to the systems dependant on roles and responsibilities. This is set by a member of the Senior Management team with counter signatory from IT support.

Staff and contractors’ passwords are changed through automated prompting on a 40-day basis to the individual member of staff and known only to them. These passwords are subject to complexity requirements around previous passwords, length, alphanumeric, case etc. All personal data transferred by email between RE personnel is password protected.

All PCs and laptops are further encrypted using Becrypt software which meets the FIPS 140-2 Standard. All databases and CRMs with client data and contracts are also encrypted with further passwording, which is only viewable to those with the password. For example, details of the Microsoft encryption are available via the link

https://support.office.com/en-us/article/data-encryption-in-onedrive-for-business-and-sharepoint-online-6501b5ef-6bf7-43df-b60d-f65781847d6c

RE does not use any USBs which are not password protected or suitably encrypted.

Systems are securely backed up each evening with the latest back up taken off site to a secure storage facility in the local area. All personal data is stored in secure UK based data centres. No personal data will be transferred or processed beyond the EEA unless adequately protected, as required by the GDPR.

Our systems suppliers provide automatic updates and patches as required by our SLA. Our anti-virus protection is supplied by ESET which provides anti-virus definition updates (patches) automatically via the internet to protect us against viruses, malware, malicious websites, etc.

Redundant media such as hard discs and USBs when no longer required are picked up and shredded by a local organisation fully certified to WEE Regulations to destroy media.

Users are subject to random internet monitoring and all activities are monitored.

All systems holding client data are secure. Server rooms, offices and filing systems have secure entry systems and staff are unable to enter without appropriate credentials.

6.3 Hard Copy/Document Security

RE uses DHL International, who are GDPR compliant, for the transfer of any hard copy data. The fully tracked transfer collects from a nominated person and can only be signed for by the authorised recipient.





All hard copy data is stored within locked filing cabinets which are situated in non-public, locked and alarmed offices.

We employ secure recycling paperwork services; our supplier collects on a weekly basis all information for secure destruction. The organisation we employ has gained the new standard in paper shredding: BS EN 15713:2009.

6.4 Peer Assessor Confidentiality

Peer Assessors are bound by RE’s Confidentiality policy.

Confidentiality RequirementsTo protect all confidential information to which you have access, or otherwise acquire, from loss, misuse, alteration or unauthorized disclosure, modification or access by:

making sure paper records are not left unattended in areas where unauthorised people may view them;

using password protection, screensavers, automatic time-outs or other appropriate security measures to ensure no unauthorised person may access confidential information from your workstation or other device;

appropriately disposing of confidential information in a manner that will prevent a breach of confidentiality and never discarding paper documents or other materials containing confidential information in the bin unless they have been shredded;

safeguarding and protecting portable electronic devices containing confidential information including but not limited to computers, smartphones, PDAs, CDs, and USB drives;

disclosing confidential information only to those individuals at RE who have a need to know in order to fulfil their job responsibilities and contract obligations.

Data Protection RequirementsAssessors must ensure they work in a secure and authorised manner as set out in the key principles below: Peer assessment activity should not take place in an open plan office environment. An

appropriate personal space should be provided to ensure you are able to concentrate on the assessment methodology whilst ensuring confidentiality is observed at all times;

IT equipment should not be used where it can be overlooked by unauthorised persons;

Under no circumstances should a Peer assessment take place in an open public place;



Computers should not be left unattended whilst still logged in. Assessors must shut down their PC if they leave the room/office, or lock the screen if they are only away from the computer for a short period of time;

When not in use, files should be stored in lockable filing cabinets or a suitably secure equivalent location;

If assessments are being undertaken from home, care should be taken to ensure that data is kept secure from unexpected visitors and protected from accidental damage.



7.0 Debt Advice Peer Assessment Cycle

The following diagram identifies the key stages of the Peer Assessment process:



8.0 Pre-Assessment Guidance

8.1 Assessment Cycle:

Assessment activity for MAS funded debt advice delivered through webchat will be delivered as a rolling programme of activity, working on a 6-monthly rotation. The full complement of individual Advisers involved in delivering MAS funded advice, including any volunteer resource, will be included within the assessment in each rotation.

8.2 Notice of a scheduled Peer Assessment

RE will provide a minimum notice period of 3 calendar months prior to commencing with the first assessment rotation. The 3-month notice stage will confirm the intended timing of the peer assessment activity and share a copy of the Pre-Assessment Questionnaire and Guidance. At this first stage, the questionnaire and guidance are for information purposes only and intended to support organisations through the Peer Assessment process. An invitation will also be extended to schedule a call with Senior RE personnel to discuss the approach and methodology of the assessment process to ensure that expectations are clearly managed.

The second stage notice will be issued 8 weeks prior to the scheduled peer assessment. At this 8-week stage, the Pre-Assessment Questionnaire and guidance will be re issued, along with a request to complete and return the questionnaire within a period of 10 working days. This will ensure that the Peer Assessment takes place within the allocated schedule.

8.3 Pre-Assessment Questionnaire, Staff List and Closed File List Requested

8.3.1 Pre-Assessment Questionnaire

The Pre-Assessment Questionnaire will provide RE with all the data required to understand the service provision of the participating organisation and will enable the selection of a sample of cases to be considered during the assessment process.

The questionnaire provides the opportunity for participating organisations to provide RE with insight into the way the webchat service is structured. It prompts for information which includes the delivery model in place, approach to quality, and any changes that have been introduced as a result of previous peer assessment findings (where applicable). When completing the questionnaire, participating organisations should consider that the Peer Assessment panel will have no knowledge of the delivery arrangements and the questionnaire therefore provides an opportunity to share this insight.

The questionnaire should be completed and returned along with all the supporting documentation that organisations would like the assessment process to consider and the Case Sampling Tool.



Upon return of the questionnaire, the organisation will be allocated a Peer Assessor. Allocation of a Peer Assessor will reflect the protocols of the RE Conflict of Interest Policy, (Appendix Six) ensuring no obvious conflict of interest exists.

8.3.2 Case Sampling Tool

RE will provide a Case Sampling Tool in the form of an Excel workbook template at the 8-week notice stage which participating organisations will be required to populate. The workbook will facilitate an automated approach to case sampling, and therefore RE will only be able to accept case information on this template.

8.3.2.1 Staff List and Volunteers

The Case Sampling Tool workbook will request information about the resourcing of the webchat service and specifically, it will require confirmation of the individual Advisers that deliver the advice function. Participants will need to ensure that they have appropriate authorisations in place with both employees and volunteer resources, to enable their details to be shared with the Scheme.

The Peer Assessment will consider a sample of cases that have been completed within the preceding 6-month period by both current and previous employees. Where there has been a high turnover of staff within the period, please highlight this information within the Pre-Assessment Questionnaire. Volunteer resources that deliver advice through the chat facilities will also be included within the scope of the assessment.

8.3.2.2 Completed Cases

Completed webchat sessions should be captured within the Case Sampling Tool workbook within the appropriate section. The workbook requests specific information on all MAS funded webchat sessions completed within the proceeding 6-month period and each record should identify the name of the Adviser, and the date of transcript. Information only cases and out of scope cases should be removed from the list prior to submission to RE. RE will only be able to accept completed webchat sessions recorded using this template.

8.3.2.3 Client Consent

The Scheme has considered it’s lawful basis for processing data under GDPR requirements and has determined that as from 25th May 2018, there is no longer a reliance on explicit client consent to enable you to share client data. Where the processing is for something that The Money Advice Service (MAS) is required to do by government, this is what will provide the authority to process data, rather than the consent of individuals or other lawful bases. The organisations functions are described in the following:

Financial Services and Markets Act 2000 20

Debt Advice Peer Assessment (DAPA) for Webchat Advice Pre-Assessment Questionnaire and Supporting Guidance for Participating Organisations Final

www.recognisingexcellence.co.uk

http://www.legislation.gov.uk/ukpga/2000/8/contents

Schedule One and (Section 26) of the Financial Services Act 2010 Schedule 15 of the Financial Services Act 2012

Due to the varying approaches taken in capturing and recording client consent across the MAS funded advice network, the Scheme has taken the following position:

1) All files opened and closed from 25th May to 30th September 2018 will only be included in the sample for DAPA where client consent for special category data to be shared is obtained. Where this poses a problem in obtaining a suitable sample size, organisations will be required to recontact clients to obtain consent to share for quality checking purposes. Assessments will not be postponed.

2) All files opened and closed prior to 25th May 2018 will require consent as required under the Data Protection Act.

3) All files opened prior to 25th May 2018 and closed after this date will require consent (as above)

For all cases prior to 25th May 2018, the Scheme will only assess transcripts where there is an appropriate level of client consent in place. All clients accessing debt advice, should be informed at the outset of receiving advice, that their records may be used for the monitoring of quality, including Peer Assessment and external quality assurance audits e.g. when the organisation providing advice is renewing or applying for quality standards. If a client informs the organisation they do not wish their information to be shared, a record should be kept, and their case will be excluded from the peer assessment process.

For organisations who do not currently have a process in place to capture client consent, the following is a suggested form of words which could be included in an information leaflet or client care letter:

As an organisation, we are committed to achieving the best possible outcome for all individuals who seek our assistance. We strive to maintain the highest possible levels of quality across our service delivery and as such, may seek external endorsement on the quality of our work through the achievement of publicly recognisable quality standards. As part of this external assessment, we are required to make a sample of client files available to an independent Assessor for them to verify the quality of our advice and file management. External Assessors are required to maintain confidentiality in relation to your file and it is important to note that they are assessing us as an organisation and not you as an Individual. If you would prefer that your file did not form part of this independent assessment, please notify your Adviser of your preference in writing.

8.4 Case Selection Process

Case selection is a randomised, automated process which is managed by RE. Cases will be drawn from the pool of MAS funded advice only.



http://www.legislation.gov.uk/ukpga/2012/21/schedule/15

http://www.legislation.gov.uk/ukpga/2010/28/schedule/1

Once the sample has been drawn, RE will provide notification of the cases selected to the participating organisation and seek confirmation of the appropriateness to proceed with the sample. Participating organisations will be required to agree the sample is a true reflection of the service delivered. Any queries with the sample should be raised directly with RE.

Examples of cases not appropriate to proceed with will include:

When the case selected is not a debt case Where the case has resulted in incomplete advice being given to the client i.e. the chat was

disconnected part way through or the client had to leave Where the case records do not indicate appropriate client authorisation to enable the file to be

submitted for assessment (this will apply to only those cases that were opened prior to 25th May 2018 – See section 8.3.2.3)

Where the case is considered to be out of scope of the assessment i.e. information rather than advice

8.5 Case Sampling

A list of completed chat cases per adviser will be requested each rotation period.

RE will take the following approach to the volume of cases to be assessed:

The standard sample drawn will be 3 cases per Adviser. Of the 3 cases identified, 2 will be assessed. All 3 cases selected should be prepared and submitted for peer assessment.

For the first assessment, cases will be drawn from the preceding 6-month period. For the second assessment rotation and onwards, cases will be drawn from the previous 3-month period and outside of any action plan implementation period that may follow the previous assessment.

In the event that a case is considered not to be appropriate to submit for assessment the Organisation should contact RE to discuss the concerns. Where considered appropriate by RE, a new sample will be drawn.

8.6 Case Sample Essentials

To be eligible for consideration as part of the Peer Assessment, the following mandatory criteria will apply:

Cases must:

Relate to a debt issue Have resulted in complete advice being given to the client Must have taken place within the last 6 months*



Have the appropriate client authorisation in place to proceed with the peer review assessment (this will apply to only those cases that were opened prior to 25th May 2018 – (See section 8.3.2.3)

8.7 Submitting Cases for assessment

Once the sample of cases has been agreed, organisations will have a period of 20 working days to prepare and submit the selected case records to enable the assessment process to begin. For this Scheme, case transcripts should be submitted in electronic format with an appropriate password encryption as an additional security measure.

8.7.1 Acceptance of the File Sample and Evidence of Client Consent

Organisations will be asked to verify and accept the sample of cases selected for assessment within 5 working days of receiving the notification of the file sample. At this stage, RE will also request evidence of client consent for each file selected for assessment that was opened prior to 25th May 2018 to ensure that the Scheme is able to assess these. (See section 8.3.2.3)

8.7.2 Case Submission Content:

Please note that Peer Assessors will not have direct access to any internal case management system that you may use. It is anticipated that the full transcript of the webchat will be exported out of the case management system into a Word document.

8.7.3 Unique Reference Numbers

It is important that all cases submitted for peer assessment identify a unique reference number. This will enable Peer Assessors to ensure that the assessment report references the unique identifier as opposed to a client name, ensuring confidentiality is maintained and that assessment reports are able to be shared electronically. NB, this does not mean RE require client information to be redacted, only that there is a clear reference which does not refer to the client name.

8.7.4 Case Submission Declaration

Organisations participating with the Peer Assessment will be required to sign and return a declaration at the point when cases are submitted for assessment. The declaration will seek confirmation that the submission is complete and reflects the full and complete record of advice for each case provided for assessment. The assessment process will not be able to commence until RE has received a signed declaration and evidence of consent (as appropriate). An example of the declaration template can be found at Appendix Three.



8.8 Storage of cases during the assessment process

Whilst in their care, Peer Assessors will be responsible for ensuring the safeguarding and confidentiality of all data relating to the Organisation they are assessing, any Individual Adviser employed by the Organisation, and the contents and detail of the client record. Case records will be stored in a secure area within the Assessor’s IT system and all assessment data, including the case records submitted for assessment and the assessment reports will be secured with an appropriate password encryption.

8.9 Allocation of a Peer Assessor

Upon receipt of the completed Pre-Assessment Questionnaire, a Peer Assessor will be allocated. To assure the impartiality of the assessment process several factors will be considered prior to a Peer Assessor being appointed to undertake the assessment. Consideration will extend to both the Organisation to be assessed and to the Peer Assessor as an individual. Although RE will work to a stringent protocol when pairing an organisation with a Peer Assessor, the Peer Assessor themselves will also have a responsibility to identify any apparent or perceived conflict of interest. Similarly, organisations will have the opportunity to self-identify any apparent or perceived conflict of interest. Any concern with the allocated Peer Assessor can be raised directly to the Debt Advice Peer Assessment Administrator’s Contact Manager via e mail: [email protected] A brief biography for each member of the Peer Assessor Panel is included within Appendix Five.

8.9.1 Conflict of Interest

Within the Debt Advice Peer Assessment, a Conflict of Interest is determined as a conflict between a person’s duties and responsibilities with regards to the assessment process, and the person’s private, professional, business or public interests. In general terms, there may be a conflict of interest (or the perception of a conflict of interest) where the Peer Assessor has had an opportunity to form a view about the level of competence of the Organisation to be assessed and/or of advisers who work in it or to have their view of an Organisation and/or its advisers biased or affected in some way.

There may be a real, perceived or potential conflict of interest when the peer assessor:

would receive professional or personal benefit resulting from the organisation being reviewed; has a professional or personal relationship with an organisation; or has a direct or indirect financial interest in a funding opportunity or organisation being reviewed

For the purposes of the Debt Advice Peer Assessment, RE has determined the following examples would result in an Individual being ‘conflicted’ and unable to undertake an assessment:




Organisational Conflict:

If the individual works for the Organisation to be assessed If the Organisation is part of the same MAS funded partnership or sub partnership If informal partnership arrangements exist between the individual’s Employer Organisation and the

Organisation to be assessed If the Organisation is located within the same local authority area as the Individual’s employer

organisation

Individual Conflict:

If the Individual has previously worked for or had substantive dealings with the Organisation to be assessed

If a spouse, partner, close friend or family member works for the Organisation to be assessed If the Individual (or a colleague in the Individual’s Organisation) has previously advised or had

substantive dealings with the client file to be assessed including where the Individual (or colleague) has advised the other party in a conflict of interest situation

If the Individual has any knowledge which could affect their ability to remain impartial

RE will consider any apparent or perceived conflict of interest prior to allocating a Peer Assessor to complete the assessment. Peer Assessors will have a duty to notify RE from the outset if there is any conflict or potential conflict of interest from their perspective. If they discover a conflict of interest during the conduct of an assessment which was not apparent at the outset, they are required to immediately speak to the RE Contract Manager who will provide further guidance.

If a Peer Assessor is employed by a Citizens Advice partner, under the terms of managing conflict of interest, they will able to assess another Citizens Advice partner only if they do not work within the same sub partnership (relevant for some MAS funded advice services)

8.10 Assessment Commencement

Once we have received and acknowledged safe receipt of the cases, the allocated Peer Assessor will be instructed to commence the assessment activity. The assessment itself will consider the webchat transcript against the Scheme’s criteria. A summary report will be prepared for each case assessed.

The table below highlights the Service Level Agreement in place with MAS for each stage of the assessment process:

8.11 Service Level Agreement25

Debt Advice Peer Assessment (DAPA) for Webchat Advice Pre-Assessment Questionnaire and Supporting Guidance for Participating Organisations Final

www.recognisingexcellence.co.uk

The table below is designed to help Organisations understand the different stages of the Peer Assessment process, and specifically those which require their direct input. The service level agreement for turnaround is identified at each step.

The Service Level Agreement described is non-flexible in that Recognising Excellence will not move assessments on to the next stage of the process until the last day of the SLA for that stage. In doing, so the complete cycle time for each assessment will remain constant, enabling Organisations to plan their participation with surety. Organisations themselves do not have to wait until the end of the relevant Service Level Agreement to complete the action, and, where they are able to complete actions ahead of the determined deadline, are encouraged to do so as long as any return is full and accurate.

Please note, Organisations’ engagement with the Scheme within the parameters of the Service Level Agreement is a core requirement of the agreement in place with MAS. Recognising Excellence is under obligation to immediately report any breach of service level directly to both MAS and the Lead Organisation (where relevant), as the breach occurs.

Debt Advice Peer Assessment Scheme Service Level Agreement

Activity By Whom SLA Lead Time(Working Days)

Pre- assessment(There is a 30 -day notification window of assessment, prior to any participant engagement required)

1. Peer assessment notice (including process and guidance) shared with Participant scheduled for assessment

RE Three months prior to assessment date

1a. Opportunity for Q and A Session to ensure process, assessment methodology and approach is understood

(optional engagement, strongly recommended)

REWithin three-month notice

window

Participant Engagement with Pre-Assessment Process Starts

2. Pre-assessment questionnaire and Case Sampling Tool released to Participant for completion

RE 8 weeks prior to assessment date

2a. Participant completes Pre-assessment questionnaire and Case Sampling Tool and returns to RE

Participant 10 days

3. Peer Assessor allocated, and conflict check completed RE 1 days4. Case selection RE 5 days

4a. Participant confirms case sample is suitable for peer assessment and provides RE with evidence of client

consent for each case (as appropriate)NB. SLA forms part of time allocation for Step 5.

Participant 5 days

5. Case transcripts prepared for submissionSubmission declaration signed and returned to RE along

with case transcripts

Participant 20 days



6. Peer Assessment ActivityDraft findings and individual case summaries submitted to

RE for Moderation

Peer Assessor 15 days

7. Moderation Activitya) Technical findings and scores

b) Summary report findings

ModeratorRE

10 days

8. Assessment findings finalised based upon Moderation feedback. Urgent actions identified as appropriate. Recommendations made for improvement areas as

appropriate.

Peer Assessor 5 days

Post Assessment

9. Peer Assessment findings shared with Participating Organisation, Lead Organisation and MAS

RE 5 days

10. Post-assessment discussion (optional) REParticipant

Peer Assessor

10 days

11. Peer Assessment report signed and returned to RESigned report shared with MAS Commissioning Manager

ParticipantRE

10 days

12. Participant to report Urgent Remedial Actions to RE (Steps 10 and 11 combined)

Participant 20 days

13. Arrangements for next scheduled Peer Assessment confirmed to Organisations

Case transcripts destroyed by RE

RE 3 days

14. Action plan and response to recommendations (Non-Urgent Action) reported directly to MAS/Lead Organisation

Participant/Lead Organisation

65 days

10 (a)

Written representations submitted (where applicable) Participant 20 days

10 (b)

Peer Assessor, Moderator, Lead Organisation and MAS notified of intention to appeal

RE 1 day

10 (c)

Representations considered by Peer Assessor and Moderator

Formal written response prepared

Peer AssessorModerator

Technical Expert

10 days

10 (d)

Moderation of Representations response

Final report and assessment findings (amended as

RE 5 days



appropriate) shared with Organisation, MAS and Lead Organisation

Steps 11-14 then apply

In the event that Representations are made, the SLA for steps 11, 13 and 14 will pause for the duration of the Representations process. The SLA will recommence after this time.

9.0 Assessment

9.1 Approach and Objectivity of the Peer Assessment Panel

The Peer Assessment process can be described as follows:

To examine the quality of the work carried out on behalf of the client, based on the evidence contained within the case record. The case is assessed against the Debt Advice Peer Assessment criteria. Not all criteria are relevant to every case, but every relevant criterion will be assessed for applicability. Appendix One identifies the assessment criteria for webchat cases.

‘Evidence’ = something within the case transcript which points to whether the criterion has been fulfilled or not. There are many areas where advice is given as a matter of routine; in these cases, the Peer Assessor will need to see within the case record that this routine advice has been given, to be sure the case has been handled correctly.

‘Accurate’ and ‘appropriate’ are commonly used in the criteria. ‘Accurate’ = factually and legally acceptable. ‘Appropriate’ = having regard to (i) the circumstances of the case; (ii) the level of information available (which in turn relies on sufficient information having been obtained from the client and recorded and (iii) the ethical, practical, tactical and legal considerations.

In conjunction with quality of advice, the Debt Advice Peer Assessment also considers process and Peer Assessors will therefore assess Case Recording and Case Management issues in addition to the quality and accuracy of advice. Therefore, to ensure the consistency and success of a Debt Advice Peer Assessment, a Peer Assessor must:

• Consider the evidence presented in an impartial and objective way

• Only consider the evidence contained within the case record/chat transcript

• Not assume anything. If the Peer Assessor is not able to evidence what they are looking for from the case transcript, the score will be reflective of this.

• Focus on whether the outcome and the solution were the most appropriate option for the client’s individual circumstances.



9.2 Void Peer Assessment

Assessments may become void in the following circumstances:

Incomplete case sample e.g. cases submitted for assessment which do not relate to a debt matter, have resulted in no advice given to the client, appear to be an incomplete advice session.

In the event that the assessment sample falls below 2 eligible cases per Adviser, the assessment will be void. MAS will charge an administration fee to the Organisation and a further assessment will be scheduled to take place 6-months later.

9.3 Assessment of the Case

The Peer Assessment process will consider, from the evidence contained within the transcript, whether the Adviser has demonstrated they have dealt with the case effectively.

The fundamental nature of Peer Assessment is it involves the judgement of an experienced practitioner. The Peer Assessment Panel may use personal experiences of running their own cases and supervising the cases of others to assess a case, but in the context of keeping an open mind and considering the varying approaches to debt advice. Peer Assessors will recognise their way of dealing with a case is not necessarily the only way and that alternative approaches may be just as valid. Ultimately it may well be that the client’s journey will vary and therefore the peer assessment will focus on assessing whether the correct advice coupled with the appropriate solution(s) was presented to the client.

9.4 Case File Preliminaries

Preliminary processes when advising a new or returning client are considered within the assessment criteria. These include Client Identity Checking, Equal Opportunities Monitoring and obtaining appropriate Client Authorities and Consents. Some of these criteria are areas of Organisational Policy and failure to meet these criteria will not affect the score applied to the case in situations where cases do not provide appropriate evidence of these requirements. Instead, any examples of omission will be highlighted as part of the assessment summary and recommended as a consideration of improvement.

9.5 File Scoring Process

The Debt Advice Peer Assessment uses a staged scoring system. Peer Assessors will consider each case against the Scheme’s webchat criteria and using their professional judgement and associated guidance available to them, will award each case a score. All relevant criteria are considered during the assessment, but this does not involve a mathematical process. The criteria in the various sections are divided into:



Organisational Policy; and Criteria relevant to the quality of the advice: these are further sub-divided into:

o Essential criteria;o Issues to consider; and

Good practice.

No sections are weighted: it is the case as a complete record which is scored. The scoring takes account of missed issues and actual or potential client detriment. It is possible to give legally accurate and comprehensive advice which is neither timely nor appropriate to the client and will therefore not be positively scored. The sample of 2 files per organisation will then be totalled to provide the organisation’s overall score and percentage.

In the context of this assessment process, detriment is defined as:

Damage, loss or harm to the client

On this basis, a failure to improve the circumstances of a client is not treated as detriment, but may affect the score awarded to the case on other grounds, and may be evidence of a missed issue.

The principles adopted for the assessment process and scoring system are that they should:

be transparent; be uncomplicated; be straightforward; be easy for the Peer Assessor Panel to use and organisations to understand; represent a fair reflection of the quality of advice displayed for each case; produce results which can be objectively justified; contain clear dividing lines between good, adequate and poor quality of advice.

9.5.1 Stage One – Scoring the Case

The first stage of scoring each case will involve the Peer Assessor making an assessment against the individual criteria in the various sections of the Peer Assessment case form and making a decision as to whether the criteria have been: Met, Not Met or Not Applicable. Any examples of partially met criteria will be classed as Not Met.

In instances where a ‘Not Met’ score has been applied, a full explanation will be detailed in the comments section of the report alongside each of the criteria. One example of this could be where there was no information recorded within the case and therefore the criteria could not be assessed.

The second stage involves the Assessor considering the case as a whole. Their expertise will be used to consider the impact of the advice on the client, taking particular account of whether or not the advice has gone beyond the issue the client presents with, and based on information that the client has disclosed.



In determining which score to apply, the Assessor will consider the impact of any ‘missed issues’ on the client’s situation. Where a client fails to take the appropriate steps, potentially leading to a detrimental outcome, this will not have an impact on the score for the file.

The objective of the Debt Advice Peer Assessment process is to assess the quality of advice. In examples where the client fails to fully engage with the Advisor and act upon the advice given, potentially leading to a detrimental outcome, this will not have an impact on the score for the file.

9.5.2 Scoring Definitions

The scoring categories for the overall assessment (stage 1 and stage 2 combined) are as follows:

Score Awarded Categorisation

0 The advice given has not progressed the client’s situation and/or there has been actual or potential detriment to the client’s situation. Detriment in this context means ‘damage, loss or harm’.

1 Adequate advice has been given and has progressed the client’s situation, but either that advice did not go beyond the presenting issue(s) and/or there has been a missed issue(s). A ‘missed issue’ means something which should have been advised on* Where this has had an actual, or potentially detrimental impact on the client’s situation, the file will be scored as zero.’

2 - Competent The client has been advised fully and correctly and the client’s situation has been progressed significantly, but more could have been done.

3 The client has been advised comprehensively and correctly and the client’s situation has been progressed appropriately and in a timely manner. (For ‘advice only’ scoring: provided that the action plan/next steps in these cases are appropriate, the file will be marked at a 3).

*webchats will generally not go beyond the presenting issue. However, where based upon the information provided by the client, other issues presented themselves, the Scheme will expect these to be explored and advised on appropriately. Where the client presents with only one issue e.g. a parking fine, it would be considered appropriate for the Adviser to actively question if there are other debts that the client would like advice about.

The Debt Advice Peer Assessment aspires for each case file assessed to achieve the benchmark level of 2 – Competent.

9.5.3 Stage Two – Organisational Score

The organisational score is calculated by adding together the individual scores from the cases reviewed to produce an overall organisation mark out of the maximum possible. (i.e. 4 Advisers x 2 cases x maximum



score of 3 = maximum possible score of 24). The score will be shown as a percentage for the assessed organisation.

9.5.4 Assessment Report

Following completion of the peer assessment, the Peer Assessor will compile a report summarising their assessment of the organisation based on the case sample. The report will identify the scores for each case assessed, as well as the overall organisational score. Relevant examples of organisational and individual adviser good practice will be documented as well as those areas, where in the Peer Assessor’s opinion, it is felt there is an opportunity to improve.

The report will contain the appropriate level of explanation to justify the Peer Assessor’s assessment of the quality of the organisation’s work. In addition to the assessment summary report, organisations will receive copies of each of the case review forms to inform feedback to, and the development of, individual advisers.

10.0 Post Assessment

10.1 Quality Control and Moderation

The first draft of the assessment findings will be subject to stringent quality control and moderation checks to ensure consistency of approach across the Peer Assessor Panel. Moderation activities will involve both Senior Moderators, Moderators and senior personnel within RE. The moderation process will be two staged, focusing on both the technical findings and scores, as well as the overall summary and recommendations. To support the process of moderation, RE will move cases between the Peer Assessor and Moderator to enable the Moderator access to the case record contents to verify the peer assessment findings. Moderation activities may result in amendments being made to the assessment findings, and therefore neither the assessment findings nor the reports will be shared with organisations until the moderation process has concluded.

10.2 Assessment Findings Shared with Participating Organisations

Following the moderation process, the assessment findings will be finalised; at which stage the assessment summary report, supported by individual case summaries will be shared with the organisation. There will be an opportunity to discuss the findings of the assessment process with Scheme representatives.



Organisations will be requested to sign and return a copy of the Peer Assessment summary report within a period of 10 working days of receipt.

Organisations have the right to make representations where case files have scored a 0 or 1. See section 10.5 for full details of the Representations process. Where representations are not made within 20 working days receipt of the assessment summary report, the peer assessment findings will be deemed as accepted.

10.2.1 Urgent Remedial Actions

Urgent remedial actions may arise out of the areas of concern identified within the Peer Assessment Report. I.e. the main issues which caused the file to score 0 or 1. Urgent remedial actions are likely to arise due to the perceived risk of detriment/potential detriment to a client.

It is recognised that due to the nature of the advice channel, it will not be possible for an urgent action to require re-engagement with the client. Any urgent actions that arise from the assessment are likely therefore to be limited to adviser technical knowledge and supervisory points only. The Scheme requests that urgent action is completed within a period of 20 working days following receipt of the assessment report.

10.2.2 Other Remedial Actions

Through the assessment summary report, the Peer Assessment Panel will make recommendations as appropriate, on those areas where it is felt that there is room for improvement. These recommendations are likely to relate to service delivery issues and the way case files are managed. The assessment process provides a period of 65 working days for the participating organisation to consider and implement any process changes as appropriate. Examples of such recommendations may include:

Suggested changes to improve the client’s engagement with the channel Implementation of a training plan following urgent remedial action (identified above)

The Scheme does not longer require organisations to report directly back to RE on these recommendations. This process will be managed directly via MAS and the Lead Organisation (where applicable).

10.3 Assessment Findings Shared with MAS and Lead Organisation

Assessment summary reports confirming the findings of the Debt Advice Peer Assessment will be shared directly with MAS and the Lead Organisation (where applicable) at the same time as being released to the organisation. This will enable the Commissioning Manager/Project Lead to provide additional support and



guidance as appropriate whilst organisations consider the Peer Assessment Panel’s recommendations for improvement.

10.4 Post Assessment Discussion with Scheme Representatives

Organisations will have an opportunity to discuss assessment findings with both senior personnel at RE and the Peer Assessor. This element of the assessment process is optional, and organisations can choose to either engage with this element or opt out of it. A conference call or Skype meeting will be scheduled at a mutually convenient date and time, which must take place within 10 working days of the assessment findings being shared. The call will be limited to approximately one hour in duration. Organisations will also have the opportunity to invite a representative from their Lead Organisation (where relevant) to participate with the call if they wish to do so.

10.4.1 Technical Clarifications

Where there are queries relating to the technical findings of the assessment for individual cases, Organisations will be required to submit their queries directly to RE in advance of the scheduled call. Any case specific queries must be received at least 3-working days prior to the call taking place to provide the Peer Assessor with an opportunity to consider ahead of the call. Assessment scores will not be changed as a result of this clarification process. The meeting will not enable a change in score but will provide insight for organisations on specific queries. A stand-alone representations process is available to any organisation wanting to challenge the case scores following the meeting.

10.4.2 Organisation Representatives

It will be for the Organisation to decide who should participate in the post assessment discussion. Participation will be limited to two individuals from the organisation, one of whom should be the person responsible for Peer Assessment and quality.

10.4.3 Post Assessment Discussion Outline Agenda

Below is an outline agenda to structure the post-assessment discussion:

1. Introductions and Overview of process to date - RE2. Recap of approach to Peer Assessment and scoring categories - RE3. Summary and review of assessment outcome – RE4. Reflection of Assessment Findings – Organisation5. Summary of Good Practice – Peer Assessor6. Technical discussion relating to findings of individual cases – Peer Assessor and Organisation7. Overview of Recommendations made – Peer Assessor and RE8. Urgent Remedial Action requested - RE9. Next steps - RE

a. Representations Processb. Documentation to be returned



c. Reporting on Urgent Remedial Actionsd. Timeframes e. Arrangements for future assessmentf. Support available to Organisation

10. Any other business

10.5 Representations Process

The Debt Advice Peer Assessment Scheme provides an opportunity for organisations to make formal representations to challenge the findings of the peer assessment report. This process is open for those case that score 0 and 1 only. Representations may be made on the following ground:

The organisation disputes a score awarded to one or more cases within the sample.

Organisations should confirm their intention to dispute the findings within a maximum period of 10 working days of receiving the Peer Assessment Findings Report. This communication should be sent to [email protected] . Formal written representations against the peer assessment findings should then be received by RE within a maximum period of 20 working days of report receipt.

RE will secure the availability of the Peer Assessor involved in the original assessment and a Moderator. The Moderator’s participation in the representations process is intended to ensure all the representations are fully considered. The original case file(s) submission will be shared with both individuals.

Please note, no additional documentation can be accepted as part of the Representations process. Participating organisations should therefore identify where there is a perceived error in the assessment findings from documentation within the original case submission only.

Both the Peer Assessor and Moderator will consider the written representations in conjunction with the original case record to determine if the assessment findings are to be upheld or if, considering the representations received, an adjustment should be made.

The Peer Assessor and Moderator will prepare a final report, which will include any amendments to the Peer Assessment Findings report and their response to the representations, with one of two possible outcomes:

The original score(s) are upheld The original score (s) are revised

If the Peer Assessor and Moderator cannot reach an agreement, the Debt Advice Peer Assessment Technical Expert will consider both the original case and the representations made and make the final decision. In situations where the Peer Assessor and Moderator determine the original score(s) are to be upheld, the Technical Expert will undertake a second review of the case record to verify this decision.




The final report and response to the representations will be considered by senior RE personnel to ensure the correct process has been followed and the Peer Assessor and Moderator and Technical Expert (where applicable) have fully considered and addressed the representations made. A full response will be shared with the organisation within a maximum period of 15 working days from receipt of the written representations. The findings of the representations process will be considered final, and there will be no further recourse available to the organisation.

MAS will be notified of any intention to dispute the assessment findings along with confirmation of the outcome of the representations process. The final version of the assessment summary report will be shared with both MAS and the Lead Organisation.

10.6 Assessment Cycle

Assessment activity for MAS funded debt advice delivered through webchat will be delivered as a rolling programme of activity, working on a 6-monthly rotation. The full complement of individual Advisers involved in delivering advice, including any volunteer resource, will be included within the assessment in each rotation.

11.0 Thematic Insight Analysis and Sharing of Good Practice

On a minimum of an annual basis, RE will undertake thematic analysis of insight and knowledge gained from the peer assessment process to identify common challenges and learning/solutions and will share this with MAS. RE will continue to collaborate with MAS to create/refine examples of considered good practice observed across the Debt Advice Peer Assessment.



Appendix One

Debt Advice Peer Assessment Scheme Webchat Criteria and Assessment of Findings Summary:

The following criteria will be considered when reviewing debt advice Webchat transcripts that are submitted for Peer Assessment. The criteria have been grouped into three headings:

Organisational Policy – These criteria are likely to be evidenced through the Organisation’s approach to client engagement and may or may not be in evidence on an individual case record. Where not met, these criteria will not impact upon the score awarded to the case.

Essential Criteria - These criteria are considered essential to the delivery of good quality debt advice. Good Practice - Each criterion is an example of good practice. The case cannot be scored 3 unless these

criteria are met (where relevant) but might still be scored 2, the ‘benchmark’ score.

The Peer Assessment will consider the criteria that are relevant to the case and will determine a score for each file. Not all criteria will be relevant to all cases.

Case File Information:

Peer Assessor:

Case File Reference:

Adviser:

Organisation:

Date of Webchat: Linked Webchats: (where applicable)

File Score and Reason:

General Summary of the Case:



1. Webchat Preliminaries

Organisational Policy: Met, Not Met, NA

Peer Assessor Comments:

1.1 Where client is returning client, progress/developments since last contact are reviewed (as appropriate). (May be evidenced through multiple case records)

1.2 Client consent to share the file and webchat records with a third party e.g. Peer Assessment, is in place and evidenced

1.3 Complaints procedure made available to the client

1.4 Nature of the service and the assistance available, explained to the client

1.5 Confidentiality and data protection arrangements made available by the client

Outcome of this Stage: Met / Not Met / NA

2. Explore the debt ProblemEssential Criteria: Met, Not Met,

NAPeer Assessor Comments:

2.1 All relevant aspects of the case fully explored and key information gathered including personal and background details i.e.

immigration status housing tenure employment/self-employment status dependants and non-dependants health or disability issues



2.2 Presenting issue identified and clarified

2.3 Any secondary issues included e.g. issues recognised by the Adviser which the client did not ask for advice about (where applicable)

2.4 Enquiry made into client’s full indebtedness – what other debts does the client have?

2.5 Key dates and time limits identified (where applicable)

2.6 Action taken so far by either client or creditor, identified

2.7 Possible assets explored

2.8 When presented, the clients capacity, capability, disability, vulnerability or mental health problems recognised, and appropriate action taken

2.9 Any known or foreseeable changes to the client’s circumstances identified

2.10 Explored and identified whether client facing an emergency and advised as appropriate

2.11 Debt(s) correctly identified as priority debts taking account of client’s personal circumstances when assessing what goods and services are essential

2.12 Where presented, possible unenforceable debts, other possible defences or other possible challenges to creditor action for all or part of debt, identified


3 Explore OptionsEssential Criteria: Met, Not Met, Peer Assessor Comments:



NA

3.1 Where insufficient information provided to enable diagnosis of the problem, the further information required identified and client advised to obtain

3.2 Where appropriate, sources given to maximise income

Issues to consider include:

a) Benefits/tax credits/tax codes - client sign-posted

b) Deficit budgets and appropriate signposting

3.3 Where appropriate, Deficit budget investigated, and reasons addressed

3.4 Where appropriate, advice given in relation to opening new bank account

3.5 Where appropriate, relevant information is obtained about the client’s financial position to enable the client’s situation to be assessed

3.6 Where appropriate, client recommended to complete budget sheet/financial statement and signposted to an appropriate source

3.7 Where appropriate, status of priority and non- priority debts established and discussed including:

a) any enforcement actions

b) offers to priority creditors are realistic and sustainable

c) adequate provision made for on-going essential expenditure, unless justified otherwise

d)available income for paying non-priority creditors discussed, taking account of payments



to priority creditors

3.8 Value and treatment of any client assets considered, where relevant e.g. insolvency options

3.9 Advice given is:

a) accurate and legally correct

b) appropriate to the client’s individual situation

c) appropriate to the level of the problem

3.10 Relevant options considered and explained clearly to enable client to make an informed choice

Areas to be considered includes:

a) advantages/disadvantages

b) actual or potential consequences and implications and obligations including the impact of debt remedies on credit reference files and banking

c) any eligibility criteria

d) debts covered by that option

e) any costs involved

f) likelihood of acceptance

g) any risks associated with that option, including adverse costs orders in relation to court costs being made

3.11 Utility Trust Funds and schemes for dealing with arrears identified (where appropriate).




Good Practice Criteria:

3.12 Possible charity payments, grant, occupational charity grants, appropriate utility trust funds and other one-off payments, utility schemes for reducing on-going bills identified (as appropriate) and client signposted

3.13 If appropriate financial capability interventions identified, particularly around budgeting, cash flow, shopping around, comparison sites, essential and non-essential expenditure and money management and client signposted

4 Implement Action Plan (incl. signposting, referral and self-help) Essential Criteria: Met, Not Met,

NAPeer Assessor Comments:

4.1 Sufficient information provided to client on next steps

4.2 Client signposted to written information sources where appropriate. Written information should be written in a language the client can understand, avoiding jargon and technical terms. Relevant and key information was brought to the client’s attention

Evidence to be considered includes fact sheets shared

4.3 In an emergency and where the Adviser/Organisation was unable to assist, the client was signposted/referred appropriately, including where client needs advice on non-debt matters



4.4 Where client lives in a different nation within the UK (i.e. England, Wales, Scotland or Northern Ireland), the client was sign-posted/referred for information on the range of debt solutions in that nation


5 Case Recording and Case Management (The following represent the records that are expected to be evident in each case record)

Essential Criteria: Met, Not Met, NA

Peer Assessor Comments:

5.1. Client provided with opportunity to ask follow- up questions

5.2 Confirmation of client’s understanding of the advice given, sought

5.3 Appropriateness of channel considered in conjunction with needs of client. Client signposted to an alternative channel (where appropriate)

5.4 Webchat interaction was managed by Adviser and client’s enquiry responded to without unnecessary delay

Peer Assessor Findings of the Case File:

Positive Findings:

Organisational Good Practice:



Individual Adviser Good Practice:

Areas of Concern:

Areas for Improvement:

Areas for Development:

General Comments:



Appendix Two - Debt Advice Peer Assessment Scheme- Organisation Case File Submission Declaration

To enable your Peer Assessor to fully consider the sample of cases as a complete record, it is important to ensure case contents provide a true representation of the client interaction, showing the entirety of the approach taken and advice given. The assessment process will not provide for multiple submissions of documentation and therefore once submitted, your assessment will be made only based upon the content provided.

Participants of the Money Advice Service Debt Advice Peer Assessment are required to sign and return this declaration as part of the case submission process. The completed declaration should be accompanied with evidence of client consent for each of the cases within the agreed sample (appropriate for all cases prior to 25th May 2018). Please ensure the signatory has the authority to complete this declaration.

I confirm my acknowledgement that:

The Debt Advice Peer Assessment will consider a sample of completed cases which have been randomly selected for assessment through a remote, desk-top based assessment process

An assumption has been made that the case submission made for this channel will reflect the full chat transcript. However, where this is not the case, information additional to the case record may include:

Preliminary Client Profile, including Data Protection, Authorisation to Act, Consent for Third Party Review, Conflict of Interest Check, Equal Opportunities Monitoring

Full set of Case Notes in a logical order and the supporting Information Sheet Creditor correspondence – incoming and outgoing correspondence (if applicable) Financial Statement (where applicable) Proof of Income / Income and Expenditure Review / Common Initial Assessment Confirmation of Advice (where applicable), including any advice that was given, any agreed

action plan/next steps and/or any other confirmation of advice such as a factsheet (either a copy or link if it is available online)

Details of any local practices which impact on the advice given to clients and which might, therefore, affect the assessment of the file

Copies of any standard letters used but not routinely copied on the files together with an explanation of when and how they are used

Information Sources used (as appropriate) particularly in relation to ‘specialist level’ advice Case notes from any appropriate Linked File (where applicable)

The case files provided are duplicate copies. No original documentation has been provided. 3 cases per Adviser have been provided for assessment. I acknowledge that of these , 2 will be

assessed. I confirm each of the cases provided for assessment:

Relate to a debt issue



Have resulted in complete advice being given to the client Reflect advice given within the last 6/3 months Have the appropriate client authorisation in place to proceed with the peer assessment

(applicable only to the cases prior to 25th May 2018) I understand if the assessment sample falls below 2 eligible files per Adviser, the assessment will be

void and an administration fee charged. A further assessment will be scheduled for 6-months later. A report detailing the findings of the assessment process will be shared with my organisation once

the Peer Assessment and Moderation process has completed. I understand I will have the opportunity to participate in a post assessment discussion involving

Senior RE Personnel and my Peer Assessor. I agree to submit any technical queries arising from the assessment findings, at least 3 working days in advance of the discussion.

Having considered the case content requirements identified above, I confirm that the cases submitted for Peer Assessment are deemed to be a complete record of the case and contain everything to be considered as part of the Peer Assessment.

I confirm that appropriate evidence of client consent to share their details with the Scheme is attached to this declaration, for each of the cases submitted for assessment.

Signed: ........................................................................................................................................

On behalf of Organisation:........................................................................................

Name:.........................................................................................................................................

Position:......................................................................................................................................

Date:...........................................................................................................................................



Appendix Three – RE Personnel

The Peer Assessment process is delivered by a team with a wide range of expertise and knowledge, including technical debt advice, contract management and quality assurance.

Amanda Jordan, Contract Manager [email protected]

It has been managed by Amanda since 2015 who has worked closely with both the organisations and the team of appointed Peer Assessors to ensure impartially and integrity of the process.

From April 2018, Amanda primarily focuses on the relationships with all organisations, facilitating both pre-and post assessment discussions. Amanda will continue to provide on-going support and guidance to the team of Peer Assessors through moderation and training activities to ensure the quality and consistency of peer assessment outcomes. In addition, Amanda will continue to work closely with MAS and other key stakeholders to ensure the process drives continuous improvement and the adoption of good practice across the debt advice sector.

Philip Monk, Operations Manager [email protected]

As a qualified Solicitor, Philip has worked in the field of Money Advice for 18 years, 14 of which have been in the role as Debt Supervisor. In addition to acting as an Authorised Intermediary for Debt Relief Orders, Philip has experience in dealing with various County Court proceedings including Charging Orders, Time Orders and challenging liability for consumer debts. He has also represented clients in council tax committal hearings and possession hearings was the instructing adviser in the Court of Appeal Case R (Steele) v Birmingham City Council and Secretary of State for Work and Pensions [2005] EWCA Civ 1824, [2006] 1 WLR 238. This was a case which determined whether overpayments of welfare benefits could be included in an individual’s personal bankruptcy.

Philip is passionate about improving the standard of advice across the sector and has been a Peer Assessor and Moderator since 2015. In April 2018, Philip joined RE in the role of Operations Manager, taking the lead on day to day activities. Philip manages the team of Peer Assessors to ensure the quality and consistency of the assessment outputs are achieved.

Peter Madge, Technical Expert [email protected]

Peter has worked in the debt advice sector for over 30 years. Prior to his involvement with RE, he provided second tier specialist support to debt advisers through Citizens Advice for a period of 15 years.




Peter was instrumental in supporting MAS in the design of the original Scheme back in 2014 and continues to support the process and team of Peer Assessors in the role of Technical Expert. He works closely with the appointed team to ensure quality and consistency of approach, with a specific focus on assessment methodology, and the representations process. In addition, Peter continues to collate and develop all good practice observed and shares this insight with MAS.

Marina Gallagher, Senior Moderator [email protected]

Marina has been working in free debt advice for the past 25 years in various roles including debt caseworker, and until 2015, worked for Citizens Advice for 13 years as a Debt Advice Specialist Support Officer. Marina is a volunteer caseworker for a local citizens advice organisation, and has been a Peer Assessor and Moderator since September 2015. Marina leads the Peer Assessment Moderation team, ensuring the consistency of all assessment findings and in addition, leads on the delivery of the assessment process within Northern Ireland.

Lucie Rainford, Senior Project Co-ordinator [email protected]

Georgina Milsom, Project Co-ordinator [email protected]

Lucie and Georgina support the operational delivery of the Scheme and will be the first port of call in relation to assessment scheduling, file selection, file movement and finance related matters. Together they ensure peer assessments take place according to the planned schedule, and files are selected and available for assessment within the appropriate timescales.




Appendix Four – Peer Assessor Biographies

Nick Ansell

Senior Peer Assessor and Moderator

Nick works for Blackpool Citizen Advice Bureau in the role of Casework Supervisor which involves the mentoring and training of caseworkers and volunteers in debt advice. Originally working as a volunteer in 2003, Nick was employed as a generalist caseworker on the GP outreach team in 2005. Nick’s experience includes working as the Deputy Supervisor and playing an integral role in developing the bureau’s integrated debt advice process. As a result, the bureau achieved the Best New Initiative award at the IMA conference in 2011. Whilst working on a legal aid contract, Nick spent many years manning the court desk on repossession days and has represented clients at debt related hearings.Nick was shortlisted as a finalist at the 2016 IMA awards for Money Adviser of the Year, and for Best Partnership for Money AdviceNick’s current role involves peer review and providing feedback to colleagues, identifying training needs and mentoring where required. Nick has been working with the Scheme since 2015.

Jill Appleton

Peer Assessor

Jill is the Money Advice Supervisor, responsible for performance and quality of the Debt Advisers within the newly merged Citizens Advice Liverpool. Jill has a good all round knowledge of debt work across all types of debt, court processes and insolvency, advising clients by telephone as well as face to face. Jill has been a Debt Adviser for Citizens Advice for 9 years, 7 of which she has been a Money Advice Supervisor, originally under the LSC contract and now under the MASDAP GMMAP contract. Prior to this, Jill worked in FCA regulated roles in financial services and banking for 14 years. Jill has been a DRO intermediary for 8 years and an accredited IMA member for 5 years. Jill joined the team of Peer Assessors in December 2017.

Aruna Bucktuar

Peer Assessor

Aruna has been employed within the Citizens Advice service for 19 years and has worked for Citizens Advice Derbyshire Districts for 9 years in the role as Money Advice caseworker. Prior to this role Aruna was a Money Advice/Welfare Rights Supervisor at Wolverhampton Citizens Advice, working under the Legal Services Commission contract. As part of her role within Citizens Advice Aruna has represented clients at the County Court and Social Security Tribunals (Tribunal Service). Aruna has been a Debt Relief Intermediary since 2009 and enjoys giving financial capability advice to clients and undertaking social policy work.



Aruna has recently, successfully completed the (MAS) Giving Good Debt Advice assessments in Advice, Casework Specialist and Court Representation. Aruna is an advocate of sharing best practice and is looking forward to her continuing involvement in the Peer Review Scheme.

Catherine Cunliffe

Peer Assessor

Catherine has worked in the debt advice sector for over 15 years and holds a Certificate in Money Advice Practice. Catherine has worked in a variety of agencies including Citizens Advice, Solicitors and Social Housing Providers and has considerable experience in court representation. Catherine is currently an Income Manager in charge of a team of Income Management Officers providing help, advice and support to council tenants who are struggling to pay their rent and other essential household bills and to help prevent arrears, maximise their income and deal with the challenges faced by tenants in a full service Universal Credit area.

Kirsty Edwards

Peer Assessor

Kirsty has been employed by the Citizens Advice Portsmouth as a Specialist Money Adviser for the past 5 years. Kirsty is currently the Service Manager and is overseeing a team of 5 specialist money advisers.

Prior to becoming a Service Manager, Kirsty was a money adviser for 4 years, Kirsty dealt with all aspects of money advice, including Financial Capability and is a DRO Intermediary. Kirsty also attends the County Court to assist clients with Housing Repossessions. Kirsty has successfully achieved the Certificate in Money Advice Practice and is a member of the Institute of Money Advisers. Kirsty also holds vast knowledge in Welfare Rights as she was a Specialist in Welfare Rights for 4 years at Citizens Advice Shropshire. Kirsty joined the Peer Assessor team in 2016.

Andy FisherPeer Assessor

Andy currently works for Citizens Advice in a supervisory role, supporting MASDAP participants. Previously, Andy worked for Sheffield Citizens Advice as a Service Supervisor, following a period working for Calderdale Citizens Advice as the MAS DAP Supervisor. Andy has been working the Debt Advice sector since March 2007, when he worked for Howells Solicitors, which comprised of the delivery and supervision of Legal Advice and Casework under the Community/Civil Legal Advice Contract. Andy has a wide experience of Court Representation, both written and face to face on behalf of clients, in particular



Possession Hearings for rent arrears. In addition, Andy has been a Debt Relief Order Intermediary since April 2009 and was part of the first intake to successfully complete the Certificate of Money Advice in Practice in October 2010. Andy has been part of the Peer Assessment Schemed since 2016.

Marina Gallagher

Senior Moderator

Marina has been working in the area of free debt advice for the past 25 years. She has spent 12 years as a debt caseworker and is currently a volunteer adviser at Citizens Advice Gloucester. Marina worked for 13 years as a Debt Advice Specialist Support Officer at Citizens Advice, supporting debt advisers with their casework. During her time as a caseworker she has represented clients in court at administration order, time order, charging order, possession order and bankruptcy order hearings and helped to run a mortgage possession advice desk at Gloucester County Court. As part of her role at Citizens Advice, she peer reviewed her Specialist Support colleague’s cases. Marina joined the Peer Assessment Scheme in 2015 and her role with the Scheme has evolved from assessment activity to moderation and mentoring of the current team.

Peter Grant

Peer Assessor

Peter joined Citizens Advice in 2002 as a volunteer and became a paid generalist adviser in early 2003. In 2004, Peter became a specialist debt adviser under the Legal Help Scheme, latterly supervising the scheme until it’s end in 2014. He represented extensively, both in the County Court (Possession Claims) and at Tribunal (Welfare Benefits appeals) throughout this period. Since then Peter has managed the Debt Team at Citizens Advice and worked with Pensionwise. He currently volunteers for Citizens Advice Derbyshire District and joined the Peer Assessor team in 2016.

Louise Hall

Peer Assessor

Louise is the Quality Assurance Officer for the Money Advice Trust. The Trust is a national charity helping people across the UK to tackle their debts and runs National Debtline and Business Debtline.Louise’s career in debt advice began 12 years ago when she was employed as a specialist money adviser for National Debtline, providing advice to clients through multiple channels including telephone, emails and letters. Louise moved on to join the Quality Team where her responsibilities included quality monitoring advice sessions, providing specialist support, coaching and training, as well as continuing to deliver specialist



advice to clients. Louise also became a Bank Team Manager which involved her managing and supporting advice teams. Louise moved to her current role as Quality Assurance Officer in 2016. She carries out peer assessments to help her fulfil her responsibilities. These include monitoring and interpreting the implications of FCA regulation in relation to advice delivery across all channels, developing and maintaining the Trust’s internal quality assurance processes and assessing the approach and effectiveness of the Trust’s quality monitoring.Louise joined the Scheme in December 2017.

Piers Heneker

Senior Peer Assessorand Moderator

Piers has worked at Citizens Advice Ceredigion for the last 11 years as a debt adviser Debt Supervisor, Session Supervisor and now Project Manager. Piers has been delivering debt advice since 2007 and has been a member of the Institute of Money Advisers for the same length of time. Pier has been a DRO intermediary since 2009 and holds a Certificate in Money Advice Practise. As part of his role, Piers undertakes monthly peer reviews across the debt team. Piers has worked with the Scheme since September 2015 and still delivers frontline debt advice daily.

Gemma Jones

Peer Assessor

Gemma is a ‘Debt Senior’ in the Benefit, Debt and Money Advice Team for Connect Assist and has been working for this current employer since April 2017. Connect Assist is contracted to The Royal British Legion, providing specialist benefit, debt and money advice to veterans. This work is with a particular client group and deals with people in particularly vulnerable positions: homelessness, mental health and substance mis-use. Gemma’s role includes carrying out Quality Assurance work including: checking advice documents for new starters and closed/open case reviews. Prior to this, Gemma worked for Rhondda Cynon Taff Citizens Advice as a specialist debt adviser for 7 years, working under projects including: FIF, MAS and Frontline. This included delivering advice based in the office, outreach and Bridgend Citizens Advice. Gemma joined the Scheme in December 2017.

Hristina Jones

Peer Assessor

Hristina joined Citizens Advice Solihull Borough in 2009 as a volunteer and became actively involved in providing money advice in 2012 initially on a part time basis. Since 2013 Hristina has been in full time employment as Money Advice Caseworker dealing with all aspects of money advice. Hristina is a DRO Intermediary and has experience preparing court documents for



court. Hristina additional responsibilities include supervision, advice and assistance to other staff and volunteers across the whole range of debt issues within her organisation. Hristina has worked with the Scheme since 2016.

Peter Madge

Technical Expert

Peter has worked in the debt advice sector for nearly 30 years. From 1991 - 2015 he provided second tier specialist support to debt advisers through Citizens Advice. In addition, Peter updates the CPAG Debt Advice Handbook, is a member of the Adviser Editorial Board and was Editor of the Adviser magazine between1992 - 2006. Furthermore, Peter has been an Honorary Fellow of the Institute of Money Advisers since 2010.

Peter has been closely involved with the Scheme since the concept was first designed in 2014. Peter’s role with the Scheme has evolved over the last three years, and with his role as Technical Expert, Peter takes a lead role in the dispute resolution process and leads on the recruitment and training of the Assessor team and develop of good practice observed from assessment findings.

Christina Metibemu

Peer Assessor

Christina is the Head of Prevention Services has worked in Advising Communities since September 2002. She is presently responsible for all early intervention and prevention programmes across the organisation, building relationships with other local service providers to achieve community development and leads on debt services within the organisation. She possesses a wealth of experience in advice service planning, development and delivery. She has 15 years’ legal advice experience and is a debt specialist, a DRO Intermediary and generalist legal advisor. She is a member of the Institute of Money Advisers and holds the MIMA Cert qualification. Christina joined the team of Peer Assessors in December 2017.

Katherine Parker

Senior Peer Assessorand Moderator

Katherine is currently employed as a Senior Debt Advice Worker for an independent Advice Agency in the North East of England. She has over 12 years’ experience in the Debt Advice Sector and is both a qualified Debt Relief Order Intermediary and holds the Certificate in Money Advice Practice. Katherine has been involved with the Debt Advice Peer Assessment scheme since 2016, initially as a peer assessor and more recently as a Senior Peer Assessor. Katherine is passionate about ensuring the quality of debt advice in the sector remains high to all who access it and believes this scheme is key to achieving this.



Lindon Parr

Peer Assessor

Lindon has worked in the debt advice sector for 9 years. All this time has been spent working for a small rural LCA in the Staffordshire Moorlands. Lindon is now the Advice Services Manager and is responsible for quality of advice issues in addition to his other managerial duties. Lindon has completed several legal and money-advice based qualifications over recent years and considers himself to be a skilled Money Advice Worker with specialisms in Mortgage/Rent Arrears, Possession Action, Magistrates Courts Fines Insolvency and HP debts and Time Order applications. Lindon joined the team of Peer Assessors in 2017.

Sarah Sauvat

Peer Assessor

Sarah is a debt Caseworker and Supervisor for Island Advice Centre, an independent advice agency in Tower Hamlets London, which offers specialist advice and casework in Debt, Welfare Rights and Housing advice as well as volunteer training. Originally working as a volunteer, Sarah has over 12 years’ experience of debt advice working under different funding streams, including the Legal Aid Agency and MAS. Sarah is an approved intermediary and have helped clients with DRO applications as well setting aside CCJ, mortgage arrears repossession, write of fifa, suspending warrant, and avoiding order for sale. Sarah has undertaken peer reviews across several independent advice agencies within the London region and across different funding streams for the past 10 years and has been a part of the MAS Scheme since 2015.

Shabnam SharminPeer Assessor

Shabnam has been working as a debt adviser for over 9 years and has been employed by Advising London for over 5 years. Shabnam’s previous experience includes working for East End Citizens Advice Bureaux, Tower Hamlets Law Centre and Island Advice Centre. She is a DRO approved intermediary. Shabnam has experience preparing court forms but not in representation. She provides debt advice at specialist level. She is part of the debt advisers’ team who provide face to face, email and outreach services for debt advice. One of her current responsibilities is to provide Financial Capability workshops to the residents and front-line staff employed by service providers throughout the borough. Shabnam joined the Peer Assessment Scheme in 2016.

Karen Watson

Peer Assessor

Karen began her debt advice journey as a volunteer and subsequently gained employment with the Citizens Advice Bureau in 2004. She is now employed as a Money Advice



Supervisor and is responsible for a team of four money advice workers and supervises the delivery of two contracts.Karen has successfully achieved the Certificate in Money Advice Practice and became a DRO intermediary in April 2009. Her considerable experience includes dealing with council tax arrears, rent arrears, local authority procedures, bailiff action and other more complex money advice issues such as challenging/disputing debts and court action.Karen’s responsibilities also include internal peer review within the bureau and ensuring compliance with CITA and SQM.Karen is passionate about the delivery of quality debt advice across the sector. Karen has worked as a Peer Assessor since 2016.



Appendix Five – Debt Advice Peer Assessment Conflict of Interest Policy

A Conflict of Interest is a conflict between a person’s duties and responsibilities with regard to the Peer Assessment process, and the person’s private, professional, business or public interests. In general terms, there may be a conflict of interest (or the perception of a conflict of interest) where the Peer Assessor has had an opportunity to form a view about the level of competence of the Organisation to be assessed and/or of advisers who work in it or to have their view of an Organisation and/or its advisers biased or affected in some way.

There may be a real, perceived or potential conflict of interest when the Peer Assessor:

would receive professional or personal benefit resulting from the organisation being reviewed; has a professional or personal relationship with an organisation; or has a direct or indirect financial interest in a funding opportunity or organisation being reviewed

For the purposes of the Debt Advice Peer Assessment, RE has determined the following examples would result in an Individual being ‘conflicted out’ from undertaking an assessment:

Organisational Conflict:

If the individual works for the Organisation to be assessed If the Organisation is part of the same MAS funded partnership or sub partnership If informal partnership arrangements exist between the individuals Employer Organisation and the

Organisation to be assessed If the Organisation is located within the same local authority area as the Individuals employer

organisation

Individual Conflict:

If the Individual has previously worked for or had substantive dealings with the Organisation to be assessed

If a spouse, partner, close friend or family member works for the Organisation to be assessed If the Individual (or a colleague in the Individual’s Organisation) has previously advised or had

substantive dealings with the client file to be assessed including where the Individual (or colleague) has advised the other party in a conflict of interest situation

If the Individual has any knowledge that could affect their ability to remain impartial



RE will consider any apparent or perceived conflict of interest prior to allocating a Peer Assessor to complete the assessment. Peer Assessors will have a duty to notify RE from the outset if there is any conflict or potential conflict of interest from their perspective. If they discover a conflict of interest during the conduct of an assessment that was not apparent at the outset, they are required to immediately speak to the RE Contract Manager who will provide further guidance.

If a Peer Assessor is employed by a Citizens Advice partner, under the terms of managing conflict of interest, they will able to assess another Citizens Advice partner only if they do not work within the same sub region.



Appendix Six – Debt Advice Peer Assessment – Peer Assessor Code of Conduct

Individuals who undertake Peer Assessment activity on behalf of RE should always adhere to the specific guidance, criteria and processes which underpin our delivery of the assessment process. In addition, the following good practice should be applied to all assessments:

Objectivity, Impartiality and Integrity: this should be maintained throughout the assessment process, irrespective of the personal or professional experience of the Peer Assessor. Assessors should not accept any gifts or inducement which could influence, compromise or threaten their ability to act and to be seen as acting independently. Competence: Peer Assessors have a responsibility to inform RE in cases where they consider themselves to be insufficiently expert in the area for review i.e. where a case file involves Court Representation. If necessary, Peer Assessors should decline the assessment and return the material to RE.Professionalism: Peer Assessors must commit to being honest, thorough and providing straightforward communication in the performance of peer assessment activities. Assessors should be consistent and accurate in their evaluations of information received during the peer assessment process and strive to be complete in the assessment activity, avoiding any omissions. Facts should be separated from opinion and clearly and concisely conveyed within assessment reports. Fundamentally, all peer assessment activity should be undertaken in a conscientious, diligent, respectful and efficient manner. Constructive critique: while Peer Assessors are required to critically evaluate case files, they should aim to do so in a balanced way, wherever possible identifying strengths and phrasing criticisms in a constructive way. Personal attacks or criticisms are unacceptable. The review and resulting report should provide guidance on how the advice, approach and case file management processes might be improved, providing supporting evidence drawn from the case files reviewed to substantiate the feedback.Organisational sensitivity: Peer Assessors should keep under consideration the sensitive nature of the work they are reviewing and should structure the assessment report summary and recommendations for improvement as appropriate. By the very nature of the assessment process, trends may emerge relating to either organisational practice, individual performance or both, and assessment findings should clearly differentiate between the two. Timeliness and responsiveness: every effort should be made to complete the review within the specified time period and Peer Assessors should notify RE in cases where this is not possible. Full details are identified within the Service Level Agreement. Disclosure of Conflicts of Interest: Peer Assessors should identify and declare in advance of the assessment, any potential conflicting interests that could impinge on the effectiveness or objectivity of the assessment process. This could include, but is not limited to, any organisational, legal, ethical, financial, moral or personal conflict of interest. This should be assessed in conjunction with RE’s guidance on conflict of interests. Where applicable, assessments should be declined.Confidentiality: All information made available as part of the assessment process should be treated in the strictest confidence. Peer Assessors should maintain confidentiality and protect the identity of any



Organisation, individual Adviser or client identified within a case file, by not disclosing, retaining or copying any information and by not discussing any aspect of the assessment process with colleagues. Peer Assessors must not take advantage of any information obtained as a result of their role and must adhere to the Confidentiality and Data Security/Data Protection policies of RE. This relates to all information received during the peer assessment and the peer assessment results. Data Protection: Peer Assessors must store and dispose of documents in compliance with the Data Protection Act, by storing documents in a secure place, not sharing or making copies of documents and returning or destroying documents in accordance with the guidance provided by RE. When sharing data electronically, extra care and caution should be taken to ensure data is shared only to the intended recipients authorised by the Debt Advice Peer Assessment Scheme.Misconduct: Peer Assessors should inform RE (in confidence) when they become aware of practice which is considered to fall below good conduct e.g. practice which raises ethical concerns or identifies misconduct on the part of an Adviser or Organisation including plagiarism, fabrication or falsification.Engagement: To ensure the success of the Debt Advice Peer Assessment, Peer Assessors should be engaged with the approach and assessment process throughout their involvement. This will involve, but is not limited to, participation in ongoing CPD, individual and group moderation and evaluation activities. Suggestions for ways in which the Debt Advice Peer Assessment approach could be simplified/improved are encouraged, particularly during the transition period post April 2018.



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