why bradford should continue to care

8/22/2019 Why Bradford Should Continue to Care

1/28

1

Why Bradford should continue to care:

A joint response to the consultation by Bradford Council on the proposedchanges to the Fair Access to Care Services Criteria

Submitted by

David Ward Member of Parliament for Bradford East

Liberal Democrat Group on Bradford Council


2/28

2

Contents Page

1. Introduction 3

2. What are moderate and substantial needs? 4

3. Demographic Pressures 5

4. Pressures on Local Government Funding 7

5. The Proposals 8

6. Who will be affected by the proposals 15

7. The financial benefits of intervention and early prevention 19

8. National changes to FACS and Social Care 23

9. Bradford Cares 26

10. Conclusion 28


3/28

3

1. Introduction

Unlike the NHS, social care is not free at the point of use and never has been. To receive

funding and support, a person must be deemed to have a high enough level of need to

warrant support.

In England, local authorities use a framework called Prioritising Need and the Fair Access to

Care Services (FACS)criteria to determine whether or not an individuals need is eligible for

support from a council. The FACS criteria are based on assessing the risk to the individual of

not receiving support and are defined across four bands of eligibility: low, moderate,

substantial and critical. The band at which a persons need is assessed determines

whether or not they will be entitled to paid care and support from the Council. At present,

Councils have discretion to set eligibility for care and support at any one of these different

FACS levels, taking account of their resources, local expectations and costs. The threshold

which is set by the Council is key because it is a statement of where the Council accepts a

legal duty to provide care and support services.

Recent research suggests that the funding pressures on councils coupled with the discretion

they have to set eligibility has led to councils using eligibility thresholds to try to manage

numbers coming into the care system, rather than focusing on determining levels of

support1.

This is exactly what Bradford Council is proposing to do. They are proposing to change the

Fair Access to Care Services (FACS) eligibility criteria from moderate to substantial

thereby reducing the number of people eligible to receive paid care and support from the

Council saving money in the process. Budgetary pressures are the sole rationale forintroducing these proposals. A consultation on these proposals opened in early May and will

finish on 4th

August. This paper is our submission to the consultation in which we urge the

Council to retain the existing criteria.

In response to a summer survey of 35,000 households in Bradford undertaken by David

Ward in 2012, responses showed that there was very strong support for keeping the level of

FACS at moderate in Bradford with 97% of respondents opposing any increase to

substantial.

This paper outlines why we believe Bradford Councils proposals are wrong; we do notbelieve the proposed change will save any money either in the short or long term but will

have devastating health and wellbeing implications for over 2,000 vulnerable people across

Bradford. We are not oblivious to the stringent financial circumstances faced by the Council

but our argument is that retaining the existing FACS criteria will, over-time, save millions of

pounds for the Council and the NHS. Bradford has so far resisted the national trend away

from using moderate needs and this is something we should be proud of as it sends out a

clear message about the way that we treat some of the most vulnerable people in our

communityin a phrase, it shows that Bradford Cares.

1Scope et al (2013) The other care crisis: Making social care funding work for disabled adults in England


4/28

4

2. What are moderate and substantial needs?

To understand the types of services that the Council are proposing to stop, it is really

important that we understand what these actually are.

Bradford Council currently provides paid care and support services to those people thathave been assessed as having moderate care and support needs. moderate needs are:

MODERATE

- There is, or will be, an inability to carry out several personal care or domestic routines

- Involvement in several aspects of work, education or learning cannot/will not be sustained

- Several social support systems and relationships cannot or will not be sustained

- Several family and other social roles and responsibilities cannot or will not be undertaken

- Engagement with formal support networks are at some risk of not being maintained

- Ability to access some community facilities is limited2.

Put simply, moderate care needs means that people need some help either on a daily or

regular basis, to get up, wash, get dressed, clean the house, help with work, education or

domestic paperwork and help to get out of the house and socialise with other people.

Bradford Council are proposing to stop giving paid care and support to people that need

such basic help to live healthy and independent lives. As part of their proposals, they will

increase eligibility to substantial which is when:

SUBSTANTIAL

- There is, or will be, only partial choice and control over the immediate environment- Abuse or neglect has occurred or will occur

- There is/will be, an inability to carry out the majority of personal care or domestic routines

- Involvement in many aspects of work, education or learning cannot/will not be sustained.

- The majority of social support systems and relationships cannot or will not be sustained

- The majority of family, social roles and responsibilities cannot or will not be undertaken

- Engagement with vital formal support systems are at risk of not being maintained

- Some risk of harm to self or others, or potential current risk exists

- Ability to access a range of essential community facilities is limited

- There is, or will be, an inability to carry out essential tasks of daily living3.

As this clearly demonstrates, the severity ofa persons condition needs to be far worse for a

person to be assessed as having substantial needs rather than at the current moderate

needs. This means that in an area which sets eligibility at substantiala persons disabilities

or conditions have to significantly deteriorate for people to be eligible for care.

The level a Council sets its eligibility criteria is so important because it is the gateway into

the adult social care system. Its the point at which a person is formally captured in the care

system and where they continue to receive the care and support essential to ensuring that

they are able to live fully independent lives.

2Social Care Institute for Excellencehttp://www.scie.org.uk/publications/guides/guide33/introduction/whatis.asp

3Ibid.
http://www.scie.org.uk/publications/guides/guide33/introduction/whatis.asphttp://www.scie.org.uk/publications/guides/guide33/introduction/whatis.asphttp://www.scie.org.uk/publications/guides/guide33/introduction/whatis.asphttp://www.scie.org.uk/publications/guides/guide33/introduction/whatis.asp


5/28

5

3. Demographic Pressures

Bradford Council asserts that the budgetary effects of future demographic pressures is one

of its key reasons for increasing the FACS eligibility threshold and reducing the availability of

care and support services for those that need it. In the budget 2013/14 the Council state

that the largest cost pressures on Adult Social Care comes from demographic growth andthey have therefore allocated 1.7m to Adult Social Care to deal with the increasing

demand.

Nationally, there are ten million people in the UK over 65 years old. The latest projections

state that there will be 5.5million more older people by 2030 and the number will nearly

double to around 19 million by 2050. Within this total, the number of very old people grows

even faster. There are currently 3 million people aged more than 80 years and this is

projected to almost double by 2030, and reach 8 million by 20504.

In 2011 through the National Census, The Office of National Statistics (ONS) estimated thatBradford District had a population of 522,452. By 2033, the population is forecast to reach

approximately 640,000, an increase of around 25%5. However, what is significant is that the

number of older people in Bradford is disproportionally increasing relative to the population

as a whole.

Bradfords Joint Strategic Needs Assessment states that by 2030, there will be an 83%

increase in those aged over 85. Thats 9,000 more old and frail people living in Bradford6.

People aged over 85 are the biggest consumers of care services and this increase is

therefore likely to lead to a significant rise in demand for care and support services.

The Office of National Statistics (ONS) states that there will be a 6.2% growth in the number

of older people within the Bradford district in the next three years alone including increased

numbers with higher needs related to dementia and other serious illness requiring care. In

addition the number of working age adults with severe learning disabilities, autistic

spectrum disorders and serious physical disabilities is expected to rise by around 5% by

2021.

Over the same time, the number of people aged under 65 with disabilities is expected to

grow by 32%. In addition, the Council also faces rising numbers of adults with dementia. In

Bradford there are currently estimated to be 5500 people living with dementia, however

only 52% of these are currently diagnosed.

It is fair to say that as peoples life expectancy is increasing, including for those with complex

needs, there will be more demand for care and support services which will act as an

inflationary pull and increase budgetary pressures on the Council. More people will be

requiring social care over a longer period. In Bradford the Council forecast is that there will

be an additional 1,000 service users by 2015.

As a result of demographic pressures Bradford Councils spending on care services has

increased in recent years from 94.8m in 09/10, 109.4m in 12/13, 111.3m in 13/14 and is

4Womens Royal Voluntary Service (2012) Loneliness amongst older people and the impact of family connections.

5Bradford Metropolitan District Council and Airedale, Bradford and Leeds NHS (2012) Joint Strategic Needs Assessment 2012

6Ibid.


6/28

6

projected to increase further to be 114.4m in 14/15, 126.7m in 2020 and 144.8m in

20307.

Due to future budgetary pressures, the Council states that this is a reason to change, but we

do not accept this view. If there are more people that need our help to live independent and

happy lives then the Council needs to prioritise Adult Social Care budgets more. Instead ofshowing that it cares about the welfare of its vulnerable residents, the Council is tackling the

issue of Adult Social Care from completely the wrong perspective and putting other

priorities before the care of disabled and elderly people. The Council should be putting its

vulnerable members first and coming up with new and innovative ways of delivering

services to the people that most need it.

The Council is correct in stating it will have to face further budgetary pressures, primarily

caused by demographic changes but a policy of reducing support to all but the most needy

is not only morally wrong it is a false economy and will only lead to higher costs in the

future.

7Bradford Council (2013) Report to January Executive Committee - Breakdown of clients with a community based service by FACS banding

2010-11


7/28

7

4. Pressures on Local Government Funding

The Local Government Financial Settlement published on the 10th December 2010 required

Bradford to make budget savings over 4 years of 28%. 30% of Council spending is on adult

social care. The Chancellors Autumn Statement in December 2012 required a further 2% cut

to council funding for 2014/15 and Junes Comprehensive Spending Review demanded a

further 10% cut in Local Government funding in 2015/2016.

Since the start of the austerity programme in 2010, 2.68 billion, thats 20% of net spending,

has been saved by local authorities on Adult Social Care8. A large proportion of this has

been achieved through efficiency savings, better procurement, better ways of working and

in a minority of cases increasing charging.

In Bradford, the Councils Adult and Community Services Department has reduced its

expenditure over the last two years by 23m or 15%. The Council has reduced the Adult and

Community Services budget by a further 7m this financial year in 2013/14. The Councilestimates that 71% of the Adult Social Care budget is spent on the delivery of FACS eligible

provision including assessment, planning support and reviewing.

As this demonstrates, there have been large cuts to Local Government funding which has

resulted in the need to cut Adult Social Care budgets. With the effect of future demographic

pressures, the Council state that current service provision is unsustainable and therefore

needs to change by managing demand for services by raising the FACS criteria.

However, whilst the Government has cut Local Government funding as a whole, they have

also provided huge sums of money to help protect Adult Social Care against the worsteffects of the austerity programme. In 2010, the Government committed an extra 2.1bn of

funding to local authorities to pay for Adult Social Care, 1bn of this will be a transfer from

the NHS capital budget to local authorities for them to spend on Adult Social Care. This

money was allocated so that Councils could protect services to vulnerable people.

Regretfully in our opinion, this funding was not ring-fenced and therefore Councils could

spend it on other priorities if it so wished.

As part of this extra funding, Bradford Council will receive almost 30m between 2011 and

2015. Broken down this equates to 6.0m in 11/12, 6m in 12/13, 8.2m in 13/14 and

8.6m in 14/15. If the Council has received an extra 30m in funding from the Governmentto protect social care, why does the Council need to cut any services to vulnerable adults?

According to the Association of Directors of Adult Social Services (ADASS) in their budget

surveys in 2011, 2012, 2013 much of this extra money has or is being used to prevent cuts to

services and to deal with demographic pressures9. Therefore, whilst there have been

significant cuts to Local Government budgets as a whole, Adult Social Care has fared slightly

better than most Council services.

8 Association of Directors of Adult Social Services (2013) ADASS Budget Survey 2013 , 6thMay 2013, Social care funding a bleak outlook isgetting bleaker. http://www.adass.org.uk/index.php?option=com_content&view=article&id=914:social-care-funding-bleak-outlook-

bleaker&catid=160:press-releases-2013&Itemid=4899

Association of Directors of Adult Social Services - www.adass.org.uk
http://www.adass.org.uk/index.php?option=com_content&view=article&id=914:social-care-funding-bleak-outlook-bleaker&catid=160:press-releases-2013&Itemid=489http://www.adass.org.uk/index.php?option=com_content&view=article&id=914:social-care-funding-bleak-outlook-bleaker&catid=160:press-releases-2013&Itemid=489http://www.adass.org.uk/index.php?option=com_content&view=article&id=914:social-care-funding-bleak-outlook-bleaker&catid=160:press-releases-2013&Itemid=489http://www.adass.org.uk/index.php?option=com_content&view=article&id=914:social-care-funding-bleak-outlook-bleaker&catid=160:press-releases-2013&Itemid=489http://www.adass.org.uk/http://www.adass.org.uk/http://www.adass.org.uk/http://www.adass.org.uk/http://www.adass.org.uk/index.php?option=com_content&view=article&id=914:social-care-funding-bleak-outlook-bleaker&catid=160:press-releases-2013&Itemid=489http://www.adass.org.uk/index.php?option=com_content&view=article&id=914:social-care-funding-bleak-outlook-bleaker&catid=160:press-releases-2013&Itemid=489


8/28

8

5. The Proposals

The Council is proposing to save money by raising the FACS threshold from moderate` to

substantial to help prioritise budgets for those with the worst conditions and to help

support further prevention and early intervention.

FACS Band 18-64 65+ Total

Critical 1014 34% 2031 35% 3045 35%

Substantial 1104 37% 2342 40% 3446 39%

Moderate 788 26% 1290 22% 2079 24%

Low 90 3% 119 2% 210 2%

Total 2996 5783 8779

Table 110

How many people will this effect in Bradford?

In a report to the Councils Executive Committee in January 2013 seeking approval tocommence a consultation on their proposals, the Council stated that in 2010/11, there were

2079 people assessed as having moderate needs. Thats over a quarte r (+25%) of service

users in Bradford that would lose any paid care and support services from the Council from

their figures in 2010/11.

However, when asked for an up to date figure of the number of people that would lose their

care packages, the Council stated that This information is not available because it has not

been recorded on our client database. What they did say is that during the last 12 months

out of the 3,400 assessments undertaken, approximately 300 (10%) were assessed at being

at moderate level with the other 3,100 being assessed at critica` or substantial.

The Council further confirmed that there are 8,500 people currently in receipt of services

from the Adult Social Care department. Given that there are 8,500 people receiving services

from the Council, and that 10% of people in the past year were assessed at moderate level,

the Council state that to get a number for the total number of people currently classified as

having moderate needs, then we can assume that approx 10% of these have moderate

needs. This equates to 850 people who are currently assessed as having moderate needs.

This is the most accurate picture that the Council has.

This is figure is extremely troubling for a number of reasons:

1. It is surprising that the Council do not have an accurate figure of the exact number of

people that are classified within all four FACS criteria levels.

2. The Council do not know how many people will be affected by the changes and

therefore it is impossible to determine how much money will be saved by changing

the criteria. Given that the proposals are prima facie about how much money will be

saved by the Council, if the Council do not have an accurate picture of how much

money they will save, which presumably justifies taking care away from thousands of

people, then this calls into question the fundamental justification of these proposals.

3. The Council confirmed that they aim to maximise the number of people in receipt

of a service whose needs are reassessed and reviewed annually and in 2012/13,

10Bradford Council (2013) Report to January Executive Committee - Breakdown of clients with a community based service by FACS

banding 2010-11.


9/28

9

65% of service users were reassessed and reviewed. However, the Council stated

that in the past year 12/13 they assessed 3,400 people. 3,400 is not 65% of 8,500

people and therefore the Councils data is wrong and cannot be relied upon.

4. Assuming that the 850 current moderate users figure from the Council is accurate

which represents 10% of all people with care needs, this is a dramatic change from

the figures in 2010/11 where there were 2079 people with moderate needs whichrepresents 25% of total users. If the total number of those with moderate needs

has reduced, surely this calls into question the Councils predictions that there will

be future demographic pressures on the Councils budget, which according to them

is making them have no choice but to make these difficult cuts to Adult Social Care in

Bradford.

5. North Yorkshire County Council is also currently consulting on changing its FACS

criteria but it had no problem in identifying the number of people that will be

affected by the proposal. At present North Yorkshire County Council provides

services to 10,000 people assessed as being at FACS moderate and above. Of the

10,000 approximately 2,600 were last assessed at the moderate level 11- thatsabout 25% of service users classified at moderate needs in a neighbouring County

Council. This is similar to Bradford Councils original 2011 figure of 2079 with

moderate needs rather than the current 850 that they are stating.

Due to the large number of inaccuracies and anomalies outlined above, we cannot have any

confidence in the data provided by Bradford Council. They are either not being forthcoming

with the real impact of their proposals or they do not actually know the full impact of their

proposals. Either way is extremely troubling and calls into real question the fundamental

rationale and justification for these proposals.

How much money will the Council save?

In the Councils Executive report of January 2013, its states that although approximately

25% of service users have moderate needs, this does not represent 25% of Adult and

Community Services budget spend, with the type of services utilised being less intensive and

therefore not as costly as those required to meet the needs of critical or substantial service

users. Sampling of individual package costs of people identified with moderate needs

suggests the total cost of their care is approximately 7.8million per annum, or

approximately 10%12

. Therefore, the Council is proposing to remove relatively low cost

services from people that represent good value for money in terms of their preventativenature.

What is significant however is that the Council are not proposing to save 7.8million a year,

but only 1.57m a year. As it states in Januarys paper Adults and Community Services

could potentially save on 2011/12 figures 1.57million on service users with Low and

Moderate needs only13

. Recommendations in Januarys report are that the proposed

changes to the FACS eligibility criteria and any savings be part of the budget setting process

for 2014/15. Therefore, the Council is estimating that they can save 1.57m from Adult

11North Yorkshire County Council (2013) Item 3, Revenue Budget 2013/14 and Medium Term Financial Strategy paper to the Executiveon 24

thJuly 2013.

12Bradford Council (2013) Report to January Executive Committee, 15

thJanuary 2013, Fair Access to Care Services, page 5.

13Ibid, Page 6.


10/28

10

Social Care and that these savings can be incorporated into next years Council budget

2014/15. What is not clear is how the Council has arrived at the 1.57m figure. If all people

who would currently be classified with moderate needs would no longer be eligible for

care then surely the Council should be saving all of the 7.8million that it costs to deliver

care to these people. There must be an answer but it is not clear.

If we accept the Councils 1.57m figure to be saved using the 2010/11 figure of 2079

people classified as having moderate needs, then the Councils estimated current figure of

850 people with moderate needs suggests that on current demand it would only be saving

around 620,000 if the proposed change in the FACS criteria is implemented.

In Januarys FACS paper to the Executive, it states that the real financial savings will come

from managing demand and the predicted future costs of packages of care is currently

estimated to increase by 6.6m in 2015 and 21m in 2021 and therefore this demand needs

to be managed14

. Yet, these figures released by the Council include all care packages and

they do not state how much of this increase can be attributed to moderate needs andtherefore potential savings in the future.

But perhaps more importantly, if the Council is stating that there will be 1,000 more service

users by 2015, which is in 2 years time, why has the current figure from the Council for

those with moderate needs decreased by 60% and the total number of care users

identified by the Council in 2010/11 (8779 as shown in table 1) is roughly the same (8,500)

as those that the Council are claiming are currently on their books. If as claimed, there are

to be a 1,000 more demands on the Councils care services, surely we should currently see a

noticeable increase in all people eligible for care, but we do not.

Again, it appears that the Council do not have an accurate understanding of the numbers

involved nor of the basic financial information for how much they will be able to save now

or in the future. Given that the proposed changes to the FACS el igibility criteria is solely

based on financial rationale, these inaccuracies call into question the central purpose of

their proposals and it cannot proceed with the current financial information provided.

Additionally, what is further troubling about the Councils financial rationale is that within

Januarys Executive paper it states that it is unlikely that this (1.57m) can be saved in the

first year of change due to the phasing of the changes, and it will be incremental dependent

on the rate and outcome of reassessment15

. Therefore, by the Councils very ownadmission, it is highly unlikely that there will be any savings in 14/15 and therefore no

savings can be made within the next financial year, contrary to current budgetary plans.

A report by the Audit Commission in 2008 revealed that when a large number of Councils

changed their FACS criteria they did not tend to experience lower care costs in the short

term and that any costs reductions took longer than a year to come to fruition16

. Therefore,

there is a strong indication that the Council will not save any money in changing the FACS

criteria in the short term and therefore their assumption that these savings can be made in

the next financial year (14/15) are unrealistic and over-stated.

14Bradford Council (2013) Report to January Executive Committee, 15

thJanuary 2013, Fair Access to Care Services, Page 6.

15Ibid, Page 6.

16Audit Commission (2008). The Effect of Fair Access to Care Services Bands on Expenditure and Service Provision.


11/28

11

In the Audit Commissions analysis of the comparison between local authorities

expenditure on social care, it states that overall, because there is normally a higher number

of lower cost moderate users in an area than more costly substantial service users, then

changing the thresholds from moderate to substantial has a relatively small effect on

budgets and so the tightening of FACS bands is not a particularly powerful weapon for

controlling costs17.

A further study of local authorities, by the London School of Economics (LSE), concluded that

restricting eligibility criteria may not generate the desired effect of reducing demand for

care services. The LSE found that a process called up-coding can take place whereby care

managers in areas of restricted eligibility are more likely to classify a user as needing a

higher FACS rating than might be suitable18

.

This is more likely to take place in authorities with a substantial threshold than in those

areas with a more generous eligibility threshold. It states that policy changes aiming at

tightening eligibility criteria, for instance, might lead to shifts in the interpretation by front-line workers of the different FACS groups, and to a relaxation in the need circumstances

required to meet the new heightened eligibility threshold19

.

In essence, because the FACS criteria are more restricted in an area that has set its

eligibility at substantial, care managers in these areas are more likely to be more generous

with the interpretation of the criteria and thus those with moderate care needs are more

likely to be classified as having substantial needs. Therefore, increasing the FACS criteria

does not necessarily reduce the demand for care services as anticipated.

Therefore, Bradford Council cannot be sure that changing the FACS criteria will save them asmuch as they anticipate. There is a large question mark over how much money the Council

actually will save from its proposal. It is seriously concerning that Bradford Council is

proposing to cut services to over 2,000 vulnerable people in Bradford on the basis of

affordability when they neither have an accurate understanding of how much they will save

nor when these savings can be made.

North Yorkshire County Council

As a point of comparison against the inaccurate information provided by Bradford Council,in a recent Executive paper, North Yorkshire County Council (NYCC) had no trouble in

confirming their proposals to increase the FACS eligibility criteria from moderate to

substantial would save them 1.4m a year by 2015-16, with 2,600 people currently being

assessed as having moderate needs. They state that 800k would be released in 2014-15,

600k in 2015-16, then 1.4m per annum from then on20

. This accurate financial modelling

is in complete contrast to the lack of information given by its neighbour, Bradford Council.

17Audit Commission (2008). The Effect of Fair Access to Care Services Bands on Expenditure and Service Provision

18Fernndez, Jos-Luis and Snell, Tom (2012) Survey of fair access to care services: (FACS) assessment criteria among local authorities in

England. Discussion paper, 2825. PSSRU, London School of Economics and Political Science, London, UK.19

Ibid. Page 5320

North Yorkshire County Council (2013) Item 3, Revenue Budget 2013/14 and Medium Term Financial Strategy paper to the Executive

on 24th

July 2013.


12/28

12

As noted by Bradford Council in their proposals, as part of the proposed cuts, all moderate

service users would need to be reassessed as Councils are obliged to consider the effect on

people of withdrawing their care services, which may result in service users being assessed

at a higher level such as substantial. North Yorkshire also recognises this and allocates

additional funding to address these extra pressures of reassessing all of their 2,600 service

users with moderate needs. However, Bradford Council does not.

As noted in NYCCs July report, Raising the eligibility threshold under FACS would require

additional short-term staff capacity to undertake the required number of individual

community care and financial reassessments21

and thus NYCC will release 1.1m in order to

support delivery of the savings proposals relating to the review of the FACS criteria. Given

that Bradford does not budget for the extra workload needed to undertake a significant

proportion of reassessments, it brings their financial assumptions into doubt.

Prevention and Early Intervention

In the January FACS Executive paper, Bradford Council recognises that in cutting services to

moderate users it will be necessary to continue to maintain a strong focus on prevention

and early intervention. This is in fact forms part of the rationale in Option 1 as the preferred

option set out in the Executive paper.

The Council are proposing to keep services like telecare, meals on wheels, smart technology

and equipment and make them available to those on low` and moderate needs but they

do not allocate any further resources to these services to help with the logical increase in

demand. No matter how much technology you give someone to assist their needs, it will not

help them with basic everyday duties such as cleaning, getting dressed or getting out of thehouse. These proposals in no way properly compensate for the loss of care services and take

no account of the psychological impact of increased levels of isolation and loneliness that

may occur.

The Council further states that savings will need to be balanced against continued

investment in voluntary sector support and other Council services which would meet low or

moderate needs22

and that some of these savings could be used to put into voluntary

organisations and other Council services to meet low and moderate level needs savings

from the cuts to eligibility23

.

The point in raising this is that at no point does the Council state how much money it will be

providing or the savings that will be made available to the voluntary sector in order make up

for cuts in Council services. In effect, the Council are simply proposing to save money by

transferring the burden of care onto the voluntary sector without paying for it.

Section 2 of the Care Bill currently going through the Houses of Parliament, will place a legal

duty on local authorities to take steps to prevent, delay or reduce adults needs for care and

21North Yorkshire County Council (2013) Item 3, Revenue Budget 2013/14 and Medium Term Financial Strategy paper to the Executive

on 24th July 2013. Page 5.3722

Bradford Council (2013) Report to January Executive Committee, 15th

January 2013, Fair Access to Care Services, Page 6.23

Bradford Council (2013) Fair Access to Care Services Consultation Page

www.bradford.gov.uk/bmdc/Consultations/fair_access_to_care_services
http://www.bradford.gov.uk/bmdc/Consultations/fair_access_to_care_serviceshttp://www.bradford.gov.uk/bmdc/Consultations/fair_access_to_care_serviceshttp://www.bradford.gov.uk/bmdc/Consultations/fair_access_to_care_services


13/28

13

support24

. A local authority must provide or arrange for the provision of services, facilities or

resources, or take other steps, which it considers will contribute towards preventing or

delaying the development of adults care needs and support & reduce the care needs for

adults in its area. A local authority must also have regard to the importance of identifying

adults in the authoritys area who have needs for care and support which are not being met

by the local authority due to eligibility.

Whilst these are welcome steps to help prevent the need for more formal care, what the

legislation masks is that the local authority does not necessarily have to pay for these

services, only ensure that such preventative services are available in their local area. Section

2(3b) of the Care Bill states that a local authority can charge for delivering such services but

any charge can only cover their costs25

.

Therefore, whilst the Council state that they will use some of the savings from increasing the

criteria to offset the damage done in cutting these services, in many cases the Council will

be able to legitimately charge for the same services labelled preventative services thatthey have just been taken away from people. Such a development would not be in the best

interests of the 2,000 vulnerable people in Bradford nor the many who would not be able to

afford it and therefore get no care at all.

Right of Information

Under the Care Bill, Section 4 will make it a legal obligation for Councils to provide and

maintain a system for providing information to people in their area, whether they are

getting formal care or not, regarding information and advice relating to care and support foradults and support for carers

26.

As part of their proposals to cut services, Bradford Council state that an adult with any level

of need still has the right to a community care assessment, as do carers. If the persons

needs are not eligible, which in the future will be people with moderate needs, Bradford

Council will nonetheless still be under a duty to provide advice and information to these

people about how to meet the needs they do have, and information about what might be

available in the community, or from other sources, to support them.

Whilst the provision of these services is welcome, such informational support is no way nearenough for someone that needs regular help with feeding, getting dressed and various other

delay tasks. The only information that the Council will provide to a person is what their

needs are and which organisations can help them if they pay for these services. The Council

will be simply transferring the cost burden from themselves onto vulnerable Bradfordians,

who in many cases will not be able to afford the care that they need nor able to seek out

their own care packages which are essential in order to try and live independent and healthy

lives.

24Care Bill (2013) http://services.parliament.uk/bills/2013-14/care.html- Section 2

25Care Bill (2013) http://services.parliament.uk/bills/2013-14/care.html- Section 2(3b)

26Care Bill (2013) http://services.parliament.uk/bills/2013-14/care.html- Section
http://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.html


14/28

14

As part of their consultation, Bradford Council is seeking views on the availability and

suitability of current information and advice services in the area. At a recent meeting of the

Bradford and District Disabled Peoples Forum on 4th

June held in response to the Councils

proposed cuts, most groups that attended thought that there was not enough information

available for current and possible service users in Bradford. They thought that the

information available was not accessible enough and that more funding needs to be madeavailable for advice and information to be improved.

In David Wards Social Care summer survey in 2012, access to information was an issue

raised by nearly everyone contacted in the course of the research. Many people said that

they found it difficult to access information and advice on care and support, particularly

when they first tried to engage with the system. Several of the groups consulted expressed a

strong preference for receiving information face to face. A number of respondents

suggested that GPs could play a greater role in signposting services for care users.

A recent study by the Joseph Rowntree Foundation

27

, focusing on the needs of ethnicminority communities, found that many find it difficult to access timely information about

services in Bradford, often leading to participants not receiving services or benefits that they

are entitled to. The Government has previously allocated 32million to local authorities to

improve access to information and to set up a national online information tool covering

both health and care.

Given that there is a commitment by the Council to provide information, the proposed cuts

will result in thousands of people needing to access informational services with

consequential budgetary implications. If the level of information currently held is not

comprehensive enough and there is a large increase in demand for information, then the

Council will need a significant investment in its advice and informational services. However,

the Council does not commit any new funding for these services. With no additional funding

streams allocated to informational services, it makes it very questionable how the Council

will realise this as part of the reduction in services without additional resources.

In summary, the burden of future care costs has led the Council to propose to cut services to

all people with moderate needs and to replace service provision with information on

where they can go to pay for the care that they need themselves. It is not known how many

people this will affect, how much money the Council will save, if its cost projections are

accurate or where extra resources for the increase in demand for preventative and

informational services will be found.

The basic premise of the Councils proposals is based on financial arguments and they have

fundamentally failed to justify their proposals on a financial cost savings basis. We do not

accept the evidential base for the Councils proposals.

27Cattan, M & Giuntoli, G (2010) Care and support for older people and carers in Bradford: Their perspectives, aspirations and experiences.


15/28

15

6. Who will be affected by the proposals

As highlighted in the previous section, we do not have a definitive answer from the Council

on how many people will be affected by the changes to the FACS criteria. North Yorkshire

County Council states that it collects information on its Adult Social Care users on a

database in order to manage their care needs. This information includes client type, FACSlevel and equality profile

28. This is why they were able to model the number of people

affected by their proposals and the cost savings resulting from this.

Those with moderate care needs require some help with the real basics in life such as

getting out of bed safely and getting dressed, washing, cleaning the house, help with work,

education or domestic paperwork and help to get out of the house and socialise with other

people. This alone does not provide a clear picture of the types of people who will be

affected by the policy change and its important to put a human face on the thousands of

people who will have their services cut if the Councils proposals go ahead.

Older People in Bradford

The Council states that the largest group affected by the proposals will be older people. In

the Equalities Impact Assessment report to the Councils Executive Committee in January, it

states that the highest number of people who will be affected by the proposals are those

over 80 who are disproportionately represented as having moderate` needs29

. In the

Councils figures for 2010/11 in table 1, it states that 22% of over 65s are classed as having

moderate needs, which is just below 15% of the total number of people the Council

provides care for.

Four out of ten (36 %) respondents to a national survey stated that due to the withdrawal of

funding for their support, they were not able to fulfil basic personal care tasks such as

washing once a day, getting dressed, eating home-cooked food or getting out of the

house30

. If older people do not get the care and support that they need, their conditions

deteriorate and it costs more in the long term to tackle their needs.

At a recent meeting of the Bradford and District Disabled Peoples Forum on 4th

June held in

response to the proposals, feedback from older people at the meeting was that they

thought that it is hard to access services now and difficult to get provision currently fromthe Council.

Other than the obvious health and wellbeing effects on older people caused by the

withdrawal of services and the inability to pay for their own care, perhaps the most

damaging effect on holder people is loneliness. The Royal Voluntary Service states there are

342,000 people in Britain over 75 years of age who say they feel trapped in their own homes

through lack of suitable transport and 9% of older people say that they feel that they have

28North Yorkshire County Council (2013) Item 3, Revenue Budget 2013/14 and Medium Term Financial Strategy paper to the Executive

on 24th July 2013. Page 73.29

Fair Access to Care Services - Report of the Interim Director of Adult and Community Services to the meeting of the Council Executive to

be held on 15 January 2013.30

Scope et al (2013) The other care crisis: Making social care funding work for disabled adults in England


16/28

16

lost their independence as they are unable to get out and about31

. Nearly three-quarters of

over 75s who live alone feel lonely and more worryingly, those that do live alone, are in

contact with their children less often than those who live with a spouse32

.

According to a survey carried out by Age UK, on average around 10 per cent of people over -

65 believe that they are lonely or are very lonely33. Given the Office of National Statisticsestimate of 79,410

34people aged over 65 living in Bradford, approximately 8,000 older

people in the district are likely therefore to be lonely most of the time. 95% of respondents

to David Wards summer social care survey in 2012 indicated that they believed loneliness

to be a major health issue among older people in Bradford.

Research suggests that loneliness can have severe long-term health effects. For example, a

recent study found that loneliness can increase the risk of death amongst the over-65s by

almost 10 per cent35

. Loneliness is associated with a number of negative health outcomes

including mortality, morbidity, depression and suicide. A 2008 study from the University of

Chicago found that chronic loneliness is a health risk factor comparable to smoking orobesity and contributes to a suppressed immune system, high blood pressure and increased

levels of stress36

.

The reason why moderate care is so important in tackling loneliness is that for many

people, their only social contact is with the services provided to them through having this

need. Whether its through a visit by a carer or help with creating and maintaining social

contacts, services provided through moderate care helps combat loneliness with hugely

positive wellbeing benefits. Older people living alone are significantly less likely to have

visited a doctor as a result of a fall and are less likely to have interaction with someone that

can notice any deterioration in their condition.

If older people with moderate needs are not provided with help and support then their

condition will deteriorate, which is not only detrimental to that persons health, but will also

increase the probability of more expensive residential care, hospitalisation and in some

cases premature death.

Working age people with physical or learning Disabilities in Bradford

From the Councils FACS data in table 1, it states that there are 788 people in Bradfordbetween the ages of 16-64. These will be working-age disabled people who either have a

physical, mental or learning condition. These people account for 9% of the total number of

service users in Bradford.

For disabled people with progressive conditions, being assessed as having moderate needs

and no longer being eligible for care will mean the significant deterioration of their

31Womens Royal Voluntary Service (2012) Loneliness amongst older people and the impact of family connections.

32Ibid.

33Victor, C. Loneliness in older age: the UK perspective in Age UK Oxfordshire (2011) Safeguarding the Convoy: a call to action from the

Campaign to End Loneliness34

2011 Census Population and Household Estimates for England and Wales, March 201135

http://health.universityofcalifornia.edu/2012/06/18/loneliness-linked-to-serious-health-problems-deathamong-elderly/36

Womens Royal Voluntary Service (2012) Loneliness amongst older people and the impact of family connections.
http://health.universityofcalifornia.edu/2012/06/18/loneliness-linked-to-serious-health-problems-deathamong-elderly/http://health.universityofcalifornia.edu/2012/06/18/loneliness-linked-to-serious-health-problems-deathamong-elderly/http://health.universityofcalifornia.edu/2012/06/18/loneliness-linked-to-serious-health-problems-deathamong-elderly/http://health.universityofcalifornia.edu/2012/06/18/loneliness-linked-to-serious-health-problems-deathamong-elderly/


17/28

17

condition. This introduces a perversity into the social care system; where some disabled

adults will have to wait until their conditions deteriorate before they are deemed as having

substantial needs and thus eligible for care. This is backed up with recent research by

Scope which states that 41% of respondents to their survey said that they were unable to

get out of the house due to inadequate social care and with 35% saying that they could not

work due to lack of social care37.

Care at the moderate level enables and supports working age disabled people in

employment. This makes them more self sustainable, increases wellbeing and is a financial

stimulus to the local economy. Should more working-age disabled people not be eligible for

care, then they may no longer be able to sustain work with wellbeing implications for those

concerned and increased pressure on welfare budgets.

Tim has a visual impairment. He has received support from the Council for several years, but

his care package has been reduced. He has been told that if he still wants support with

shopping, he will have to pay for it himself38.

Setting the national eligibility threshold at substantial would also badly affect those with

physical and learning conditions as these conditions can fluctuate. These peoples conditions

can vary between having different levels of need either moderate or substantial. Some

disabled people are assessed as having moderate needs on a good day, but then lack the

support they need to keep well or to help them cope during more difficult periods and thus

have a higher level of need.

Someone who has a stroke and leaves hospital may have substantial needs at first. But

through support and treatment, their condition gets slowly better until they only havemoderate needs. But because they live in an area that only provides support with

substantial needs, this important care and support is taken away and their condition

deteriorates. The example of Matthew below illustrates this problem.

Most of the time Matthew needs help with just one or two everyday tasks, and a little help

with his work and family life. But Matthew has a fluctuating condition, and because of a

reduction in the care and support services he receives, has been bedridden for weeks39

.

Regarding learning disabilities, the National Autistic Society said substantial criteria for

those who should receive social care completely "overlooks" autistic people who would notbe recognised as needing support. Many people with autism already struggle to have their

condition identified where fewer than half of English Councils have any system in place for

diagnosis, and some can be particularly vulnerable to neglect and abuse40

.

Furthermore, some people with high functioning autism or Asperger syndrome may only

need some seemingly low levels of support, such as help with social skills and managing

about the house (e.g. with bills and organising cleaning activities). Frequently, these types of

need are not recognised by Councils as being substantial, yet without this help, this group


38 Ibid.39

Ibid.40

Tracey McVeigh (2013) The Observer Newspaper, Autism Charity condemns new rules on eligibility for social care June 30th

2013.

http://www.guardian.co.uk/society/2013/jun/29/autism-charity-eligibility-social-care
http://www.guardian.co.uk/society/2013/jun/29/autism-charity-eligibility-social-carehttp://www.guardian.co.uk/society/2013/jun/29/autism-charity-eligibility-social-carehttp://www.guardian.co.uk/society/2013/jun/29/autism-charity-eligibility-social-care


18/28

18

are at risk of developing more severe problems, such as social isolation and severe mental

health problems.

Sarah has a learning disability and lives independently. For several years, she enjoyed going

to a local day centre once a week. The council has now stopped funding people with

moderate needs so Sarah is now stuck at home41.

As stated earlier, what is even more worrying is that the number of people living with

learning difficulties is increasing in Bradford and therefore there will be even more people in

the future that do not receive any paid care and support services from the Council.



19/28

19

7. The financial benefits of intervention and early prevention

What we and the Council do agree on are the benefits that intervention and early

prevention can have on the welfare of people with needs. However, what we fundamentally

disagree on is what we deem as intervention and early prevention and the amount of

services that should be provided.

In their review of social care for adults Emerson, Hatton and Robertson (2011), found that

prevention is typically categorised into three levels:

- Primary prevention which seeks to eliminate or reduce need by reducing the

probability of it initially occurring.

- Secondary prevention which seeks to eliminate or reduce need by intervening in the

early stages of the development of the need in order to reduce the probability of it

escalating.

- Tertiary prevention which seeks to eliminate or reduce need by providing effective

support to people who already experience such a need to prevent further disabilityor disadvantage and, as far as possible, to restore functioning

42.

In our view, providing support and care services at moderate needs adheres to all three

levels of prevention but particularly tertiary prevention where you are providing services to

people who are already experiencing a need and to manage or prevent the deterioration of

their conditions. This is because to be assessed as having moderate needs, a person will

already have to be presenting effects of a condition they are suffering from in the form of

the deterioration in their health, wellbeing and functionalities.

In effect, providing services at moderate level needs is a very effective form of interventionand early prevention. As we will explain, delaying morbidity and the deterioration of

conditions improves wellbeing outcomes for individuals but also saves money in the long

run and justifying the resources used to pay for moderate care needs.

What happens when you dont provide moderate care?

When a person does not get the care they require, their health needs are likely to escalate

resulting in declining health and wellbeing. In many cases, if a person has a care need which

needs to be addressed and they do not get paid care from the Council, the person will be in

a worse financial position as they will either have to pay for the care that they need

themselves or in the case of working age adults lose income from employment that they

cannot undertake. In all cases, with deterioration in a persons health, this results in

increased costs to the state when they re-enter the care or health system with a higher level

of need.

A recent survey by the charity Scope found that two in five disabled people are failing to

have their basic needs met, with almost four out of ten unable to eat, wash, dress or get out

of the house, which has led to nearly half withdrawing from community life and one third

42Emerson, Eric, Hatton, Chris Hatton & Robertson, Janet (2011) Prevention and Social Care for Adults with Learning Disabilities


20/28

20

being unable to work or take part in volunteering or training activities after losing their care

package43

.

The Linkage Community Trust agreed with this assessment noting that people with lower

levels of need slip through the net and that they had seen increasing numbers of people

reaching crisis as a consequence44.

Preventative support has to be tailored to the individual but whether its low level support

like personal or home help, cooking or cleaning or whether its more social aspects such as

helping to manage budgets or help communicating with family and friends, interventions of

this kind can prevent peoples needs from unnecessarily escalating. Providing support at

moderate really can mean the difference between a person being able to live at home in

their own community or having to go into residential care following a crisis.

When giving evidence to an All Party Parliamentary Group investigation into social care

reform, the NHS Confederation stated that they were not surprised that many councils havetightened eligibility criteria given cuts in local government finances but affirmed that when

peoples needs are not met by the social care system, they turn to the NHS, which

experiences the impact in the form of increased demand for emergency and unplanned

work, and delays in discharging people from hospital45

.

Therefore, by reducing eligibility and pushing people out of the formal care system, councils

are simply pushing the financial burden on addressing care needs from themselves onto the

NHS. Furthermore, because there is a delay in people entering the care or NHS system, they

do so at a higher level of need than they would been when assessed by the local authority

originally and therefore the costs to the taxpayer in dealing with that person are increased.

In effect, if eligibility is reduced from moderate level needs, over 2,000 people in Bradford

will be pushed out of the care and support system with the risk being that they re-enter it at

a higher level of need and at a substantially higher cost.

Financial benefits of prevention and intervention

It is very important to focus on the costs associated with the cuts to moderate needs

because as the Council is making an argument that moderate needs are no longeraffordable, it is important to demonstrate that this is a false economy and that it is actually

cost-effective to invest in moderate level needs.

The British Red Cross delivers schemes across the country that provide people, following a

crisis or admission to hospital, with practical and emotional support in order to improve that

persons wellbeing and increase resilience to be able to cope in the future46

. The purpose

behind these programmes is to reduce the likelihood of future avoidable readmissions to

43Joint APPG Disability & Local Government Groups Inquiry (2013) Promoting Independence, Preventing Crisis: Making Social Care reform

work for disabled adults44

Ibid.45

Ibid. Page 3646

Deloitte (2012). The economic impact of care in the home services: A report commissioned by the British Red Cross, November 2012.


21/28

21

hospital and support their emotional wellbeing by helping them to live safely and with

increased confidence in their own homes.

Based on analysis by Deloitte of six of these schemes, Deloitte found that they were

delivering substantial savings to health and social care commissioners. Savings per user from

these schemes are estimated to range from 168 to 704 giving a rate of return between40%-280%

47.

As a direct result of providing preventative care, savings are produced by preventing

admission or readmission to hospital, reducing length of hospital stays and preventing or

minimising the use of expensive domiciliary and residential care. The British Red Cross

schemes were estimated to have the potential to save commissioners around 8m across

these six schemes alone, which on average implies an overall return of 149%, thats 1.50

back for every 1 spent on preventative care48

.

The analysis by Deloitte goes further stating that the savings they discovered can becategorised into savings by both the NHS and the local authority. The six schemes are

estimated to cost health and social care commissioners approximately 5.4m but prevented

the need for 13.4m of expenditure thus saving healthcare commissioners 3.2m, and social

care commissioners 4.8m49

.

In another British Red Cross study they demonstrate further that savings can be realised

from preventative care. In association with the New Economics Foundation, they conducted

an independent economic analysis of the costs which could have been incurred by the state

to treat and deliver care to five people, had preventative services not been used. They

estimated that early care and preventative work delivered by the British Red Cross deliveredsavings of between 700 and 10,430 per person, which is a minimum return on investment

in preventative care of over three and a half times the cost of the service, and in most cases

significantly more50

.

The charity Scope has also completed significant modelling of the financial benefits to the

NHS and councils of investing in preventative care and meeting moderate needs. By

analysing four different interventions, modelling by Deloitte for Scope estimates significant

returns of up to 53% in any investment in providing moderate needs with an average

return greater than 30%51

. In other words, for every 1 spent on care and support for

people with moderate level needs, an average of 1.30 will go back to the NHS, local andCentral Government, and individuals themselves52

.

With cuts by local government in care and support services over the past ten years through

increasing eligibility thresholds, the London School of Economics suggests that social care

for disabled people alone is underfunded by at least 1.2 billion or 0.17% of public

expenditure53

. However, if we apply the Deloitte analysis to the potential cost savings in

47Deloitte (2012) The economic impact of care in the home services: A report commissioned by the British Red Cross, November 2012.

48Ibid.

49Ibid.

50 British Red Cross (2012) Taking Stock: Assessing the value of preventative Support51

Scope et al (2013) Ending the other care crisis: Making the case for investment in preventative care and support for disabled adults52

Ibid.53

Scope et al (2013) The other care crisis: Making social care funding work for disabled adults in England


22/28

22

investing in moderate needs to the tune of 1.2billion, then Scope suggests that closing this

gap could lead to a profit of 355m with a potential return of 39% to the NHS and local

authorities54

.

If we extend such modelling on investing in moderate care needs in Bradford and use the

Councils figure of7.8m a year to deliver these services, then this is actually saving theCouncil and the NHS anywhere between 10.14m (130% return), 11.7m (150% return) or

27.3m (350%).

The Councils current proposals to stop preventative and moderate services will cost more

in the long run and could result, as a conservative estimate, in further costs of 2.34m to the

Council and NHS. Therefore, the Councils whole rationale for cutting services to save money

is based upon a false premise and a faulty economic model.

54Scope et al (2013) Ending the other care crisis: Making the case for investment in preventative care and support for disabled adults


23/28

23

8. National changes to FACS and Social Care

It is very important to set the Councils proposed changes to the FACS eligibility criteria

within the national context.

Under Clause 13 of the Care Bill, it introduces a national minimum eligibility criterion55. Theminimum threshold for peoples care and support needs will be a legal minimum guarantee

of care which must be met by local authorities in all areas. Local authorities will not be able

to restrict eligibility above this threshold and it will come into effect by April 2015.

Councils will still have the opportunity to provide extra care and support to service users if

they wish to do so but they will not legally be able to provide less care than the minimum

that people will be legally entitled to.

The rationale for making these changes is to stop the postcode lottery of care, where

different authorities set different levels of eligibility for care. Because care eligibility is setlocally, should a person move from one local authority to another, it is possible that their

care needs will no longer be met once they move. This will ensure that people across the

country can expect a certain legal minimum level of care wherever they are or wherever

they move to.

For those councils that are currently providing care and support at a more restricted level

then the proposed new national minimum, the Government will be providing funding that

will support those Councils in providing a more generous social care system. The

Department of Health estimates that the additional cost of local authorities meeting the

national eligibility criteria is likely to be around 23 million56

.

As part of these changes, the Department of Health will be implementing a completely new

system of eligibility criteria, getting rid of the four different levels of assessed need low,

moderate, substantial and critical` and replacing it with one minimum level. Should your

assessed needs meet this eligibility, then whatever your needs are, a suitable care package

will be provided. The Department of Health states that their aim is to continue to improve

the assessment framework so that it supports personalisation, prevents and reduces needs

wherever possible, and helps people connect better with their communities57

.

In order to assist in implementing a new eligibility system and to help provide advice andsupport to the Government, the Department of Health has established a working group, the

Care and Support Transformation Group, which will include the Department of Health and

key members from the care and support sector.

The draft national minimum eligibility threshold was published in June 2013 and is out to

consultation until 29th

November 2013. Following this initial consultation, a new version of

the criteria will be published for public consultation from Spring 2014. Following this

consultation, regulations to enact the new threshold will be laid before Parliament under

55Care Bill (2013) http://services.parliament.uk/bills/2013-14/care.html- Clause 13

56Department of Health (2013) Draft national minimum eligibility threshold for adult care and support: A discussion document

57Ibid.
http://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.htmlhttp://services.parliament.uk/bills/2013-14/care.html


24/28

24

the affirmative procedure (which means that Parliament will debate and vote on the

regulations) in autumn 2014, and will come into effect from April 2015.

Whilst setting a new national minimum for eligibility and giving people peace of mind that

wherever they live, they should legally be able to expect the same level of service, is

certainly welcome, the national minimum counts for very little if the level at which is set istoo high.

As first announced in the Chancellors Comprehensive Spending Review for 2013, the new

national minimum eligibility criteria will be set at the equivalent ofsubstantial needs from

2015. The Government states that they are setting the new standard at substantial

because 87% of councils, as identified by The Association of Directors of Adult Social

Services (ADASS), have set their eligibility for 2013/4 at substantial` or above58

.

As highlighted in responses to David Wards summer care survey in 2012, there was concern

that setting the national minimum at substantial would lead to some local authoritieslevelling down and cutting services from moderate to substantial. However, as confirmed

by the Department of Health those local authorities who provide care and support to meet

moderate needs of which 12% do at present, will be free to decide to continue to do so59

.

What is striking however is that the Council are trying to change the eligibility criteria just

shortly before the whole system will change. The Council will be spending hundreds of

thousands of pounds to change their eligibility criteria only just before having to spend even

more money changing their system again when the new FACS criteria becomes operational

in 2015.

Rather than having to face two changes in FACS criteria in subsequent years, surely it makes

more sense to continue the current system of eligibility, thereby protecting thousands of

peoples care services, until the Council will have to make some changes in 2015 when

implementing the new FACS criteria.

Funding for joined up health and social care

As part of the Comprehensive Spending Review in June 2013, the Chancellor made another

important announcement committing 3.8bn into a programme of integrated health and

social care across the country. 2bn of this money will be from a direct transfer from theNHS to local authorities. The integrated budget will be overseen by local Health and

Wellbeing Boards. The 3.8bn investment in more joined-up preventative care is expected

to save 1bn alone.

The fund will help to ensure that health and social care services work together to improve

outcomes for local people by ensuring better information sharing, intervening early so that

older and disabled people can stay healthy and independent at home, which will help avoid

unnecessary hospital admissions and reducing A&E visits.

58Association of Directors of Adult Social Services (2013) ADASS Budget Survey 2013

59Department of Health (2013) Draft national minimum eligibility threshold for adult care and support: A discussion document


25/28

25

Merging budgets in this way will help drive down costs to hospitalsby tackling expensive

pressure points in the system (like A&E), by preventing ill health and keeping people out of

hospital, and by allowing people to stay in their homes and live independently.

Bradford itself has made good progress in trying to integrate health and social care.

Established in November 2010, the Integrated Care Management Board was set up to shapethe future of integration of care and health support in Bradford, Airedale, Wharfedale and

Craven.

Reporting in December 2012, the Board stated that four of the pilot/test sites in Bradford

set up in Bradford are now operational with each having identified a small number of

patients around which services are integrated60

. Cath Doman, Head of Community Health

Services at NHS Airedale, Bradford and Leeds confirmed that these integrated pilots are

linked to groups of GP practices and will test out integrated community teams made up of

community health services, social care services and voluntary and community services, and

will be organised by one team, with one manager61

. However, a progress report inDecember noted that the pace of reform in Bradford in addressing the problems of a split

health and social care system has been slow.

However, what is significant about the new money available from the Government is that it

represents a new opportunity with additional funding to invigorate the process of

integrated care in Bradford. It presents a very interesting opportunity for the Council to

work with the NHS in not only funding more preventative care post hospital admission, but

to actually fund social care services at the moderate level. As evidentially established

earlier, providing moderate level care is a proven tool in saving significant amounts of

money both for the local authority and the NHS. A 1.30 savings for every pound spent62

.

If Bradford Council worked jointly with local hospitals and local Clinical Commissioning

Groups through the Health and Wellbeing Board to apply for some of the 2bn fund to

undertake more preventative work, then the Council may be able to afford to continue to

provide care at the moderate level. Rather than trying to save money in isolation, Bradford

Council has a very good argument to suggest that providing moderate care is an effective

preventative measure that saves money both for Clinical Commissiong Groups and local

hospitals. In effect, the Council will be funded to provide services at moderate needs.

Therefore, rather than doing a quick cut and shut job on the provision ofcare services dueto concerns with available funding, with a bit more effort, Bradford Council has a real

opportunity to safeguard and improve current adult social care services and by doing so

they will be able to continue to provide social care services at the moderate level to

thousands of vulnerable people in Bradford.

60http://www.bdct.nhs.uk/wp-content/uploads/Implementation-of-the-Integrated-Care-for-Adults-Programme-in-Bradford-Airedale-Wharfedale-Craven.pdf61

http://www.thetelegraphandargus.co.uk/news/local/localbrad/9523398.Elderly_health_care_in_Bradford_set_to_be_simplified/62

Scope et al (2013) Ending the other care crisis: Making the case for investment in preventative care and support for disabled adults
http://www.bdct.nhs.uk/wp-content/uploads/Implementation-of-the-Integrated-Care-for-Adults-Programme-in-Bradford-Airedale-Wharfedale-Craven.pdfhttp://www.bdct.nhs.uk/wp-content/uploads/Implementation-of-the-Integrated-Care-for-Adults-Programme-in-Bradford-Airedale-Wharfedale-Craven.pdfhttp://www.bdct.nhs.uk/wp-content/uploads/Implementation-of-the-Integrated-Care-for-Adults-Programme-in-Bradford-Airedale-Wharfedale-Craven.pdfhttp://www.bdct.nhs.uk/wp-content/uploads/Implementation-of-the-Integrated-Care-for-Adults-Programme-in-Bradford-Airedale-Wharfedale-Craven.pdfhttp://www.thetelegraphandargus.co.uk/news/local/localbrad/9523398.Elderly_health_care_in_Bradford_set_to_be_simplified/http://www.thetelegraphandargus.co.uk/news/local/localbrad/9523398.Elderly_health_care_in_Bradford_set_to_be_simplified/http://www.thetelegraphandargus.co.uk/news/local/localbrad/9523398.Elderly_health_care_in_Bradford_set_to_be_simplified/http://www.thetelegraphandargus.co.uk/news/local/localbrad/9523398.Elderly_health_care_in_Bradford_set_to_be_simplified/http://www.bdct.nhs.uk/wp-content/uploads/Implementation-of-the-Integrated-Care-for-Adults-Programme-in-Bradford-Airedale-Wharfedale-Craven.pdfhttp://www.bdct.nhs.uk/wp-content/uploads/Implementation-of-the-Integrated-Care-for-Adults-Programme-in-Bradford-Airedale-Wharfedale-Craven.pdf


26/28

26

9. Bradford Cares

You may wonder why it is the official dictum to label services which we provide to adults

who need assistance to live healthy, active and engaged lives as Adult Social Care. If we

look up care in the Oxford English Dictionary, it states that to care is to take thought for,

provide for, look after, take care of and to have regard, fondness, or attachment for aperson.

However, when we talk of care for adults across the country, what we mean to say is

support services, not care. If we meant care then we would not have under funding of

services by local authorities, people cleaned and fed in only 15minute appointments and

horrible abuses in some of our care homes. Some have lost touch with what we mean when

we talk of caring for someone.

Bradfordians have always cared though about the way that we treat the most vulnerable

members in our city. Thats why we have always made sure that adult support services aremade available to people that need it and in fact we do this when 87% of other local

authorities dont.

It is to the credit of Councillors in Bradford in all political Groups that Bradford retains the

FACS eligibility criteria at the moderate level. It is apparent that not many local authorities

across the country fought as hard as we did to keep our level of services to vulnerable

people because since, 2005, there has been a huge increase in thresholds for FACS

eligibility.

In 2005/06, 53% of the 152 local authorities in England provided care and support to thosewith substantial needs and above and 40% provided services at moderate needs. But by

09/10 eligibility threshold had increased so that 72% of local authorities provided care at

substantial needs and above and by 2012/13, 83% cent were only providing services at the

higher threshold ofsubstantial needs63

. Now according to ADASS there are 87% of Councils

have set their eligibility for 2013/4 at substantial or above with only 12% of Councils

providing moderate needs64

.

As a direct result of this a study commissioned by Scope found that 69,000 disabled adults

(18 to 64 years) with moderate level needs and 8,000 with substantial level needs had

already fallen out of the system65

. They note that if all Councils were to raise their eligibilityto the substantial` level, a further 36,000 disabled adults would lose the support they

receive, or 105,000 disabled adults in total66

.

However, this demonstrates that the changes since 2010 only represents 15% of the

changes to FACS. The biggest change 19%, came before any austerity measures were

implemented by the Coalition Government. Whilst this demonstrates that adult social care

has been chronically underfunded by governments and by local authorities, it is also

symptomatic that Councils have not fought hard enough to keep an appropriate level of

63 Age UK (2012) Care in Crisis 201264

Association of Directors of Adult Social Services (2013) ADASS Budget Survey 201365

Scope et al (2013) The other care crisis: Making social care funding work for disabled adults in England66

Ibid.


27/28

27

care and support to vulnerable adults in their areas. It shows that they did not care enough

to fight to keep these services and we must not make the same mistake in Bradford.

On Monday 15th

July, David Ward MP, the local Liberal Democrats and the Bradford and

District Disabled Peoples Forum were joined by Rt. Hon Paul Burtsow MP, the former Care

Services Minister, Scope, Age UK Bradford and up to fifty local organisations and care usersto launch Bradford Cares, in the Carlisle Business Centre.

Bradford Cares67

was our opportunity to come together with key stakeholders and care

users to speak with one voice, making a statement to the Council that we should not put up

with a poorer standard of care for our loved ones in Bradford.

Just because other councils have increased their eligibility criteria and the Government has

set their new national minimum at a level we believe is too high, denying hundreds of

thousands of people the care and support that they need and deserve, it does not mean

that Bradford has to follow their bad example. Why should we settle for a poorer standardof care then we currently have for our vulnerable residents when, with a bit more hard work

the money can be found to maintain existing levels of care.

The sole purpose of adult social care in Bradford should be to help people remain liv ing as

independently as possible for as long as possible in the setting of their choice. Therefore, it

is imperative that we care enough to give as big an opening as we can into social care

system by keeping eligibility at moderate which will help delay the need for chronic, more

expensive care, and therefore help people to live more independently, to reduce longer

term expenditure for Adult Social Care departments and to help people live the lives of their

choosing.

We care about how we treat the most vulnerable people in Bradford, local organisations

care, and the Council now needs to demonstrate that they care also by not going through

with a proposal that will adversely affect the lives of thousands of people in Bradford.

67http://bradfordcares.org/en/
http://bradfordcares.org/en/http://bradfordcares.org/en/http://bradfordcares.org/en/http://bradfordcares.org/en/


28/28

11. Conclusion

In this paper we have demonstrated that whilst Bradford Council is experiencing both

austerity and demographic pressures on their budget, they have comprehensively failed to

set out the financial rationale for making devastating and fundamental service cuts to the

lives of thousands of people in Bradford.

Bradford Councils plans to increase the FACS criteria and save money are financially

unsound.

The most disappointing aspect of the Councils proposals is that with the future funding for

integrated social and health services, it represents a once in a lifetime opportunity to

fundamentally change the relationship between service users and support providers. With

more political will, Bradford Council could actually save money and create an environment

that would both secure the provision ofmoderate services and provide better, more

holistic health and social care across Bradford.

To sum up, below is list of all the reasons why the Councils proposed social care cuts should

be cancelled forthwith:

- There are fundamental inaccuracies with the data provided by the Council - we still do

not know how many people will be affected by the cuts.

- There is no conclusive evidence about how much money the Council will save - the

accuracy of the Councils modelling offuture budgetary pressures is weak.

- There is no provision for extra resources for the services (information and preventative

services) that the Council plan to make available to those no longer eligible for care.

- Any potential savings will not be realised in the first financial year. This is contrary tocurrent financial planning in making savings in the next financial year 2014/15.

- Providing moderate care services is a crucial preventative and early intervention tool,

helping support in the early onset of conditions, alleviating the deterioration of health

conditions and the need for more expensive acute care and health services.

- Providing preventative care in the form ofmoderate care services saves millions of

pounds both for local authorities and the NHS.

- Ceasing the provision ofmoderate care will cost more to the Council in the future.

- With 2bn committed by the Government for joined up health and social care, Bradford

Council has the opportunity to work with heath and care partners to secure funding to

sustain the provision ofmoderate care services and improve health and wellbeingoutcomes, whilst also alleviating the Councils own budgetary pressures.

- With changes in the Care Bill, this will create a whole new system of eligibility criteria by

2015 it is the wrong time to make changes now.

- Bradford has always provided a higher level of services to its vulnerable citizens. It

should not change this now just because others have and care less than we do.

- And most importantly the incalculable damage that will be caused to the health,

wellbeing and basic rights to live an independent and functioning life for all those that

will see cuts to their basic care and support.

For all these reasons, we urge the Council to withdraw its proposal to change the FACScriteria.

why bradford should continue to care

Documents