Some of the comments clearly indicate a lack of assessment and planning into the suitability of the accommodation location. 

The Independent Children’s Homes Association’s response to the government’s analysis of the unregulated national standards consultation

The Independent Children’s Homes Association’s response to the government’s analysis of the unregulated national standards consultation

The consultation analytical report highlights areas of concern that we do not think are acknowledged. In fact, our opinion is the consultation responses add weight to the argument for registration and inspection at a setting level.

One serious concern is the government asking consultees to help distinguish between ‘care’ and ‘support’.  

This must be defined legally and is likely to be at the Judicial Review early next year.  It is our position that legally, if under 18, they are children.  Many are subject to a ‘care’ order not a ‘support’ order so until such time as there is, all 16 and 17-year-olds must receive care whatever setting they are in. Whilst saying this, ICHA does agree that there should be different quality standards for supported accommodation than those for children’s homes.

The authors of the analytical report did not acknowledge in the methodology section the woefully inadequate sample size of children and young people – just 45 young people consulted.  Further, their only way to contribute was using an online questionnaire, excluding the voices of many children and young people.  Offline questionnaires should also have been available.

We disagree that the responses in the consultation are as clear cut as the Minister’s statement that, ‘these reforms received strong support through our public consultation, including our consultation aimed at care experienced young people.’  Critically young people consulted overwhelmingly stated that Ofsted should inspect the accommodation.

The highest consultation response rate (over 70%) for registration and inspection at the setting level stated this was the best way to ensure high standards. The main disadvantage identified was cost.

Some of the comments clearly indicate a lack of assessment and planning into the suitability of the accommodation location.  This will continue if we do not inspect individual settings.  The need for this is reinforced both by the proportion of Ofsted requirements that relate to management issues in children’s homes, as well as some of the consultation responses from providers that intimate accommodation is in unknown or unsuitable locations:

There are likely be too many provisions to inspect, particularly with the flexible pop-up nature of supported accommodation.’

The report stated, ‘the concern that some sub-standard settings might not be inspected during provider-level inspections and that, as a result, poor practice and safeguarding issues could be overlooked by the Ofsted inspectorate was expressed by 33 respondents.’

A proportionate response to the concerns over where accommodation would be the introduction of location assessments. With regards to location assessments consultation responses included:

While we could get all the addresses checked before we put them onto the local framework, one of the huge benefits of our model is that we can be flexible. So, for example, if a particular property is a target for unwanted attention – from criminals e.g., child sexual or criminal exploitation, county lines, cuckooing – or from neighbours, we can re-assign that property to a different project.’

Three respondents commented that affordable areas were often those with higher crime rates and poorer community facilities so that this could again act as a driver for increased costs, intimating currently, accommodation is in high crime areas.

We are also concerned and surprised by submissions from a provider in the charity sector:

‘We would be particularly concerned if each individual setting had to have an allocated person similar to a registered manager who had completed formal training programmes, as this would incur significant extra costs for providers if this had to be done across every setting.’

‘…if staff were required to complete specific qualifications, then this would incur significant costs to enable staff to complete these courses.’

These responses demonstrate why, at the very minimum we need registration of managers and assurance that location assessments are in place, as are properly trained staff and critically, a legally accountable individual.

Children and young people deserve better than ‘pop-up’ homes run by untrained and unqualified staff.  Whilst accepting that the increase in costs will need to be addressed, the concern about location assessments and admissions that children are moved when risks are found in the area, are factors at the heart of why changes to the law and raising of standards are necessary.  One respondent commented that ‘we cannot move our homes’; our response would be that ‘you can sell them and purchase property in a suitable location’. 

Notes to Editors

The Independent Children’s Homes Association Ltd (ICHA) is the voice of providers of residential child care services and resources across England and Wales. We are a Not-for-Profit Limited Company.

ICHA’s Vision: ‘Exemplary Residential Child Care.’

ICHA’s Mission: ‘A member-led organisation driving excellence in residential child care through innovation, collaboration, and sector leadership’.

ICHA represents both large and small providers.  Some members have just one home whilst others have many homes across a wide geographic area.

Peter Sandiford


07597 982533