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CONTINUITY & CHANGE: Refreshing the relationship between Welsh Government and the Third Sector

PAVS CONSULTATION RESPONSE – Initial draftThis paper provides a first draft of the responses PAVS intends to present to Welsh Government for each of the questions posed in the consultation document.

Chapter 1 – Outline of the current basis of the relationship between the Welsh Government and the Third Sector

Q1: Are there any other key changes or developments in recent years that impact on the relationship between Welsh Government and the Third Sector and should be taken into account?

The third sector contributes significantly to all areas identified in the Programme for Government, not because it is an instrument of Government, but because voluntary action seeks to support vulnerable people and address unmet needs in communities of interest and place. The third sector must retain its independence but could undoubtedly do more to assist Welsh Government in achieving its outcomes with enhanced investment and support.

Other key changes or developments that should be taken into account are:

Increasing demand for third sector services due to welfare benefit reforms and changing demographics

Lack of growth in the Welsh economy and increasing numbers of young people who are not in employment, education or training

Rural poverty – exacerbated by rising fuel costs, lack of public transport, limited access to services, isolation and poor broadband connectivity

Reduction in Charity Commission services in Wales – more reliance on County Voluntary Councils to deliver support for charities on the ground

Sustainable development - building natural, cultural, human, social and produced capital in local communities

Increasing costs of delivering safe services and complying with legislation and regulation at the same time as funding is being reduced

Chapter 2 – Affirming and renewing the relationship

Q2: Do you agree that the analysis of the third sector and its qualities listed above are still relevant?

PAVS broadly agrees with the analysis of the third sector as set out in the consultation document. We believe there should be explicit reference to the sector’s role in making sustainable development a practical reality and in effective public engagement and participation. The qualities listed in the document are still relevant but should be expanded to include:

Altruistic, enthusiastic and innovative Capable of mobilising volunteers

Q3: Do you consider that the five strategic themes in 2.17 are still useful as a basis for ongoing dialogue?

PAVS considers that the first three themes remain broadly useful as a basis for ongoing dialogue, but would recommend strengthening the wording of the first theme as follows:

Increasing voluntary action – a more active commitment than “valuing” voluntary action

PAVS Consultation Response – Initial Draft 19th July 2013

The fourth and fifth themes are too narrow in definition and should be changed to:

Supporting sustainable third sector organisations Transforming public service delivery models

The narrative underpinning these themes needs to demonstrate a real commitment to supporting the development of sustainable third sector organisations delivering financial, social and environmental benefits (whether or not they trade as social enterprises). In addition, the unique role of the sector in engaging citizens in co-producing citizen-directed public services should be referenced in the supporting narrative.

Q4: Are there other elements you would add or consider to be more useful?

PAVS proposes adding the following two themes:

Delivering innovative solutions to meet identified needs Evaluating impact and outcomes

Chapter 3 – Supporting the Third Sector Infrastructure

Q5: The role of the Infrastructure is set out above. Please let us know if there is something you think has been overlooked.

PAVS welcomes the overall affirmation of the effectiveness of the current Infrastructure arrangements and the recognition that intermediary organisations are necessary in terms of providing support for the sector.

The current Infrastructure Partnership delivers a range of “generic” support services to the third sector, making appropriate referrals to other infrastructure organisations that offer “specialist” services. Funding generic and specialist services within the same financial envelope would risk diluting provision and reducing its overall effectiveness. However, there is scope to improve links between the generic Infrastructure and specialist providers, particularly in terms of making better use of the Wales-wide network of County Voluntary Councils to join up services on the ground, both at a local and regional level. This approach would achieve cost savings as specialist providers could reduce the overhead costs of establishing local/regional offices; increase effectiveness with improved referral pathways between organisations; and ensure that specialist services are complementary to those delivered by local CVCs.

It is also important to ensure that specialist services really are “specialist” and cannot be delivered by the generic third sector Infrastructure, either independently or in partnership with other providers. For example, CVC Development Officers provide a wide range of capacity building services to develop sustainable third sector organisations, including social enterprises. A significant number of CVC Development Officers are qualified ILM Level 5 Social Enterprise Advisors. Local/regional partnerships between CVCs, LEADER groups, Colleges and business support organisations could certainly provide effective social/community enterprise support with a fraction of the investment required to establish a standalone “specialist” service.

PAVS agrees that the format of the Integrated Delivery Plan provides a good platform from which to build. Current Infrastructure partners have agreed that County Voluntary Councils and Volunteer Centres will, in future, be able to contribute to the production of the plan from the outset, rather than simply adding a chapter to the end of what was essentially a WCVA Delivery Plan. PAVS supports the move towards developing an outcomes-focused framework for the Infrastructure Partnership Agreement.


In addition to the key roles of the Infrastructure summarised in the document, PAVS would add the following:

Brokering third sector services into statutory sector provision and identifying unmet needs (this is particularly relevant in the area of integrated community-based health and social care services)

Facilitating citizen engagement Developing the third sector workforce (paid and unpaid) Lobbying and campaigning Networking and facilitating collaboration (brokering relationships between national charities

and small, grass-roots organisations in terms of service delivery partnerships) Providing HR and Finance services – low-cost, accessible “packages of support” for third

sector organisations who cannot afford to employ specialist staff

With specific reference to the more detailed descriptions of the role, PAVS would make the following comments:

Enabling other third sector organisations to grow and develop: the funding advice, information and support service delivered by County Voluntary Councils is much more comprehensive than the description given in the document. Services include supporting the development of sustainable funding strategies, based on a mixed economy and/or social enterprise model; in-depth support for identifying potential and relevant funders (using tools such as Grantfinder and GrantNet); assisting third sector organisations to tender for contracts (which might involve establishing provider consortia); writing robust funding applications; ensuring best practice in fundraising; working with partners to develop grant-making programmes or funding policies; contributing to the development and implementation of local Funding Codes of Practice; and managing grant distribution and key-fund programmes. The service is delivered through a mix of information, training and direct work with groups.

Note: PAVS used to distribute £100,000 per annum in small capital and revenue grants to the sector funded through the Community Facilities and Activities Programme (CFAP). In recent years, this was reduced to £50,000 and restricted to capital grants only. Without any formal consultation, CFAP funding was withdrawn from County Voluntary Councils in April this year and PAVS now has minimal funding to distribute. Small grants make a huge difference to local grassroots voluntary and community groups, and provide a useful “hook” to engage groups in governance and development work. Grants that are locally managed can be used intelligently to tackle local strategic priorities and address unmet needs. PAVS is exploring the potential of establishing a Pembrokeshire Community Fund.

The issue of diversity of provision amongst County Voluntary Councils should be recognised as a strength, rather than being presented as a weakness. CVCs work with partners and use the Infrastructure core funding to lever in additional funding to deliver services that meet the needs of the local voluntary and community sector. CVC services are necessarily different as they respond to local circumstances, both in terms of identified needs and what other service providers are in the area.

County Voluntary Councils face a funding dilemma. On the one hand, there is an argument that they should “walk the talk” and establish social enterprise trading arms that bid for contracts and generate income to help them become financially sustainable. On the other hand, it is potentially problematic for a CVC to offer advice and support to third sector organisations and then bid against them for a contract. Taking a lead on third sector provider consortia; bidding for training and project evaluation contracts against private sector providers and providing services for third sector organisations (as mentioned above) offers a partial solution to this dilemma.


PAVS strongly agrees with the statement that “the focus on developing the wider sector and community action remains paramount” particularly when applied to the plethora of small, grassroots organisations that contribute significantly to community resilience and cohesion. This has been a key message in the consultation we have undertaken with voluntary and community groups and statutory organisations in Pembrokeshire.

Supporting individual volunteers and collective voluntary action: PAVS welcomes the positive support for Volunteer Centres and recognition for the valuable work they do with individual volunteers and volunteer-involving organisations. There is certainly significant potential to expand youth volunteering, particularly in terms of developing skills and personal qualities for employment or higher/further education. There is also potential to forge closer links with the private sector (through employer supported volunteering or volunteer incentive programmes). PAVS facilitates the Pembrokeshire Volunteer Organisers Network (PVON) which provides the framework for delivery of best practice advice and support, as well as helping to establish new volunteer initiatives. More resources are needed to enable volunteer centres and volunteer-involving organisations to provide long-term and in-depth support for volunteers with additional needs.

Volunteer Centres could certainly provide support for rolling out models such as Time Banking and Street Ambassadors if these are required at local level, but PAVS believes it would be a mistake to prioritise what might be described as “project based” activity over support for volunteering more generally.

Promoting good governance: PAVS agrees that good governance is paramount, but would ask that quality assurance systems remain proportionate and not a “knee jerk” reaction to high profile failures, such as AWEMA and Plas Madoc, which are not representative of the wider sector. The four County Voluntary Councils that work together as Third Sector Support – Mid & West Wales are all committed to achieving PQASSO Level 2. It is fortunate that PAVO has already achieved this externally assessed kitemark and we look forward to learning from their experiences.

Note: PAVS is keen to encourage funders to recognise the costs of governance as an eligible item of expenditure within a full cost recovery model. Many funders specifically exclude governance costs from project budgets on the grounds that an organisation would “have to do it anyway”. Lack of core funding restricts the ability of third sector organisations to strengthen their governance, which is completely counter-productive in light of the concerns over governance expressed by the Welsh Government, BIG Lottery and the Charity Commission.

Supporting public service design and delivery: PAVS agrees with the proposition that County Voluntary Councils are best placed to enable third sector organisations to contribute to the co-production and delivery of public services at local and regional level.

Note: Hywel Dda is currently establishing Population Health Groups. CVC Health & Well-being Facilitators across the Hywel Dda region have each taken the lead on specific groups and are responsible for engaging third sector service providers in the work of shaping appropriate care pathways for each of those groups. A commitment to third sector engagement in service design is contained in the Hywel Dda 3rd Sector Co-design report, which also recognises the CVC as the “pivot” for the Health Board’s relationship with the third sector.

Providing voice and representation for the wider sector: PAVS would challenge the assertion that this is the “most important role for the third sector infrastructure to fulfil”, believing that the majority of voluntary and community groups consider capacity building (organisational development and funding) and volunteering support to be equally important functions of a CVC.


Nevertheless, PAVS recognises that representation is a key role for a CVC and it is certainly beneficial for statutory partners to have a single point of contact through which to engage with a large and diverse third sector. The diverse nature of the sector makes it very difficult to arrive at a single “view of the sector”, let alone represent that view to others. Often the best that can be achieved is for a majority view to be communicated or for a third sector perspective to be presented to partners. If an organisation does not share the majority view, then it can see the intermediary organisation as a barrier, and this may give rise to some negative views about the role of the representative body. This is best countered by making it possible for organisations to contribute their own views, perhaps by making better use of social media to capture views and comments, although there is always the issue of vested interests to consider.

PAVS is an independent organisation, accountable to the wider third sector through its membership base, and is therefore best placed to articulate the voice of the sector at strategic planning partnerships objectively and impartially.

Sharing good practice and innovation: PAVS agrees that gathering information, data and statistics about the sector in Wales is an important role for the Infrastructure, and would suggest that this would be best carried out by WCVA, as the national body within the Infrastructure. The current research function of WCVA should be strengthened and expanded to provide a robust data framework to support policy development and impact assessment – a “What Works” centre1 for the third sector in Wales.

PAVS believes that the Infrastructure Partnership should apply a “digital first” approach when planning its future service delivery model. There is no doubt that new technology can be applied to various services within the Infrastructure, particularly around dissemination of information; communication; training; consultation and regional working arrangements. As can be seen from PAVS’ involvement in the Communities 2.0 programme (which builds on several years’ previous experience of delivering ICT services for the third sector), County Voluntary Councils are well placed to provide ICT development support to third sector organisations, but additional funding will continue to be needed to support this specialist service. This is an excellent example of a specialist service benefiting from being closely aligned to the generic service delivery network of locally-based CVCs.

Overall, PAVS welcomes the positive statement at 3.40 in the document and wholeheartedly supports the view that major disruption to the Infrastructure should be avoided. However, PAVS believes that the refresh does provide a good opportunity to revisit existing Infrastructure arrangements and make service improvement changes.

Q6: How might we achieve the right balance of funding and delivery across the Infrastructure nationally, regionally and locally?

The existing basis for allocation of funding amongst County Voluntary Councils appears to be relatively fair, as it makes provision for an agreed amount of minimum core funding for each CVC to function before applying a funding formula based on population, geographic area and social need. This results in a level of financial protection for rural CVCs, which would otherwise fare very badly under any system that is solely based on population figures or is linked to Local Authority allocations. The minimum funding level needs to be updated and there is a strong argument to add “number of local third sector organisations” to the list of factors taken into account to establish the supplementary allocation, but the basic concept remains fit for purpose. In time, the “core funding” allocation could potentially be calculated on a regional basis, with the supplementary allocation based on local delivery areas (counties).

1 What Works Network, a national co-ordinated UK initiative that seeks to strengthen the use of evidence for policy and practice, not only at Government level but also at the local and community levels, and indeed with end users themselves (The Guardian Professional, Thursday 7th March 2013)


The more challenging – and potentially contentious – discussion is around achieving the right balance of funding between the national and local/regional elements of the Infrastructure. It is not clear what basis has been used to establish the current allocation, which results in approximately 20% of the Infrastructure funding (£1 million per annum) being retained by the national body, with 80% (£4 million per annum) being invested in the local delivery network of 19 County Voluntary Councils and 21 Volunteer Centres. In recent discussions, it has only been possible to confirm that this is the amount of funding that the national body has always received from Welsh Government. This is not particularly helpful when trying to determine whether this level of funding remains an appropriate allocation for the future.

Consultation with our members and statutory partners confirms PAVS’ view that the support of local organisations at a local level is absolutely critical if Wales is to develop resilient communities and a strong civil society – a key priority for Welsh Government. For this reason, PAVS proposes that any future funding model enhances, or at least protects, service delivery at the local level.

In terms of regional working, the four County Voluntary Councils in Pembrokeshire, Carmarthenshire, Ceredigion and Powys are working together as Third Sector Support – Mid & West Wales under the terms of a Regional Memorandum of Understanding signed by the Chairs of each Board on 11th September 2012. This has enabled us to work more closely together without changing existing structures, allowing each CVC the flexibility to work within different geographic partnerships as appropriate (for example, Swansea City Region; Regional Learning Partnership, Health Boards, etc). However, the Regional Leadership Team (made up of the Chief Officers and Chairs of the four CVCs) is supportive of the idea of establishing a legally constituted regional body to provide a vehicle for regional income generation and to employ regional posts as the need arises.

PAVS would not object to a regional distribution of Infrastructure funding, although it would present something of a challenge that would certainly test our new regional partnership! However, the principle of having a more direct funding relationship with Welsh Government through our regional partnership is something that we would definitely welcome. We believe it is important to establish a more equal relationship with the national body in future Infrastructure arrangements, and removing their role as the sole Lead Body for the Infrastructure funding might be one way of achieving this outcome. It is hoped that equalising the status of Infrastructure partners through the funding mechanism will enable a more constructive dialogue to take place around the respective roles of all Infrastructure partners working together as “Third Sector Support Wales”.

A word of caution – it would not be feasible to implement a totally new regional funding allocation from 1st April next year. A sensible first step would be to allocate an element of the volunteer funding on a regional basis, and then move incrementally towards a new regional funding arrangement over the first three years of the new Partnership Agreement. This would allow sufficient time to respond to any local government re-organisation that might take place following the outcome of the current Commission on Public Services, and for CVCs to form appropriate regional alliances. It is also important that Welsh Government is not prescriptive as to regional structures – merged CVCs might not be the best solution, particularly if there is no agreement on regional “footprints” across different Ministerial portfolios.

Q7: Do you support the proposal to develop a Third Sector Innovation Fund on the basis outlined here?

PAVS supports the concept of encouraging regional working and engaging external partners, where appropriate, to achieve better outcomes for third sector organisations and citizens.


However, PAVS does not support the proposal to top-slice existing Infrastructure funds, the value of which has already been eroded over the past few years. It also seems almost certain that future Infrastructure funding will be affected by significant cash reductions, which will undoubtedly threaten service delivery. In this context, a 10% top-slice will be completely untenable.

Even if additional funding could be found to put into the Innovation Fund (which we recognise is highly unlikely to be the case), then PAVS would still have reservations and questions about whether this is the best approach. The Innovation Fund will have to be managed and administered, with all the associated work and overhead costs involved in that process. This represents a significant deadweight loss in a funding environment that can ill afford it. If it is a competitive process, then some regions might lose out completely, even though regional working and innovation is important across the whole of Wales. This would also contribute to inconsistencies of delivery across the Infrastructure, something that is highlighted in the consultation document as being a cause for concern. Would the funding be given for 3-year projects, in which case, some regions could miss out for the whole of the period of the funding agreement, or would it be allocated on a 1-year basis, which is not really a viable timeframe for a regional collaborative project?

Overall, PAVS believes that a better approach would be to define the outcomes that Welsh Government is seeking to achieve within the Infrastructure Partnership Agreement; invest the funding at a regional level and allow the CVCs to decide how best to use the funding to achieve the outcomes. However, unless this investment represents “new” money, there is a real risk of weakening the level of help and support available to third sector organisations at a local level.

Q8: We consider that the current Infrastructure support for volunteering is strong in many respects but could be simplified. Do you have any suggestions for how it could be improved? PAVS agrees that the current Infrastructure support for volunteering is strong, and is pleased to see that Volunteer Centres are recognised as being integral to any new framework for volunteering that might be developed. In general, Volunteering Pembrokeshire (PAVS’ Volunteer Centre) has an effective working relationship with WCVA and there is arguably less duplication in this service delivery area than any other.

At a local level, Volunteering Pembrokeshire provides a wide range of services above and beyond volunteer placements. These services include:

supporting best practice in volunteering through the Pembrokeshire Volunteer Organisers Network (PVON)

encouraging take-up of the Investing in Volunteers quality standard driving up the supply side of volunteers through a volunteer incentive scheme (Treats for

Time) delivered in partnership with Milford Haven Port Authority helping to develop employer supported volunteering programmes awareness raising events and presentations celebrating and promoting volunteering – the Pembrokeshire Volunteer of the Year Awards

ceremony is an annual event that takes place during National Volunteers Week working with partners to increase youth volunteering supporting “hard to place” volunteers – the number of volunteers with support needs has

increased significantly over recent years and looks set to continue to rise as the new Welfare Benefit reforms take effect

working with partners to establish volunteer initiatives (for example, the Volunteering in Health programme developed with Hywel Dda)

PAVS suggests the following simplifications to the existing volunteering arrangements:


Review the role of Gwirforce – it is felt this function would be better delivered by linking with existing youth forums at a local level, including the Youth Assembly, Youth Forums, School Councils, Youth Bank, etc.

Merge the Gwirvol and “core” funding for Volunteer Centres – this would enable Volunteer Centres to deliver a flexible, holistic person-centred service as well as reducing the time spent monitoring against different outputs for different funding streams

Merge the Gwirvol and Volunteering in Wales grant funding streams to provide a unified fund to support all-age volunteering

Allocate the new merged grant funding stream to CVCs/VCs at a regional level to enable strategic investment in local/regional volunteering projects to meet locally identified needs2

Chapter 4 - Engagement

Q9: Do you agree with the proposals for development of the TSPC and meeting structure?

The purpose of the TSPC needs to be clearly articulated and, if this is not possible, then there is no strong argument for continuing to meet in this way. TSPC membership is made up of national, intermediary or umbrella organisations and it is difficult for local groups to relate to the process. TSPC representatives must be accountable to those they represent and cascade information, as well as collecting views from the grassroots – for this to happen, the agenda must matter to people working on the ground.

If a decision is taken for the TSPC to continue, then PAVS would not agree with the proposal to develop a smaller Strategic Leadership Group as this would make the group even more “elitist” in nature, something that was identified as an issue in the pre-consultation discussions. As an alternative, PAVS would propose opening up the meetings as widely as possible through the use of social media and video conferencing to enable third sector organisations to contribute “virtually” to the discussion. Again, as mentioned above, the agenda needs to be relevant to grassroots organisations and citizens.

Restricting meetings to an hour with so many attendees seems a waste of time for all concerned. TSPC meetings should be scheduled to last for at least half a day (3 hours) to enable a full discussion to take place around a range of topics identified at local/regional level and fed through to the TSPC (a bottom-up approach). Rather than holding isolated meetings and work streams, some thought could be given to combining TSPC meetings with a conference/ seminar to which members of local and regional organisations could also be invited.

PAVS supports the proposal that emerged from the TSPC consultation meeting on 4th July that a joint programme should be drawn up at the start of each year based on Government priorities and issues identified by the networks represented on the TSPC. PAVS also agrees that meetings should be held in different parts of Wales and that visits to local groups could be arranged for Ministers and officials by the “host” CVC.

It is important to dispel the widely held view that if you are not “at the table” then you are excluded from decision making and have less chance of receiving funding. The need for transparency and inclusion is paramount.

2 As mentioned earlier in this response, local/regional grants programmes provide a useful “hook” to engage with organisations and provide a wide range of added-value development support. As a general principle, grants should be distributed as close to the level of project/service delivery as possible so that local intelligence can be applied.


Q10: The suggested framework for TSPC workstream activity seeks to increase the effectiveness of the contribution of the workstreams. Do you have other suggestions to add to or improve the proposal?

The idea of having clear and consistent terms of reference would certainly seem to be a sensible way forward – no workstream should be established unless there is mutually agreed clarity of purpose and outcome. It is absolutely vital that the TSPC is not just about process but remains focused on achieving outcomes.

The proposal in the consultation to introduce a regional dimension to the TSPC is to be welcomed. A regional forum could bring together local, regional and national organisations to address an agenda driven by identified needs at a local/regional level, as well as celebrating success and sharing learning. The regional forum could also nominate representatives to work at a national level, where required.

Q11: Do you agree that the existing biannual cross-portfolio Ministerial meetings should be replaced by a more flexible pattern of meetings with Ministers which focus on timely and specific issues of mutual interest/concern?

PAVS believes that it is important to retain Ministerial commitment to meet with the third sector at regular intervals throughout the year. Ministerial meetings need to be built upon and improved, not abolished or diluted.

It is suggested that ministerial meetings should be focused on key issues that are causing real problems, allowing time for in-depth conversations to take place with third sector organisations and members/service users. Again, PAVS would propose making better use of new technology to enable Ministers to engage more directly with the wider sector – an on-line question and answer “webinar” perhaps?

Ministerial meetings should, if possible, be held in different parts of Wales and combined with visits to local/regional voluntary sector groups. Ministers could also take advantage of existing arrangements to engage with Infrastructure partners – attending the annual 2-day residential event, for example.

Chapter 5 – Working together nationally, regionally and locally

Q12: What can be done to ensure that the Third Sector’s contribution to the Programme for Government is recognised and maximised?

PAVS believes that there needs to be a balance between maintaining the independence of the third sector – which is paramount – and enabling appropriate collaboration that improves the lives of citizens in Wales. Voluntary and community groups are often established in response to an identified need. It is highly likely, therefore, that there will be synergy between the Programme for Government and the third sector. This does not mean, however, that the third sector is an instrument of Government – rather it is an important partner in delivering a fair and sustainable Wales.

If Welsh Government wants to maximise the third sector’s contribution to the Programme for Government, then it could use the Partnership Agreement to task the Third Sector Infrastructure with delivering specific outcomes around key issues, such as fuel poverty, homelessness, employment, domestic abuse, digital inclusion, etc. PAVS believes that the Partnership Agreement should reference the three cross-cutting themes of Tackling Poverty; Sustainable Development and Equalities & Social Justice contained in the Programme for Government.


In terms of recognising the contribution of the third sector, the Infrastructure could – and should -collate data to measure the impact of the sector’s work in relation to specific policy areas, such as tackling poverty or climate change. The national body within the Infrastructure (WCVA) is best-placed to lead on this work.

Q13: The proposal is for a greater Third Sector involvement in regional working. How would you wish to see that achieved?

There is no doubt that regional working is complicated because of the number of different regions that exist. Currently PAVS is working in a number of different regional configurations – Health Board; Police; Regional Learning Partnership; Economic Regeneration Partnership. Basically, we use our networks in a flexible way to engage appropriate local groups in regional activity, working through CVC facilitators.

WACVC (Wales Association of County Voluntary Councils) is understandably reluctant to commit to wholesale regional configuration based on the 6 “collaborative organisational areas” for public service delivery in case this changes. Local Government reorganisation remains a distinct possibility, dependant on the outcome of the current consultation on public services. Until the Commission reports in December 2013, there remains considerable uncertainty over public service boundaries and County Voluntary Councils need to continue to work alongside 22 Local Authorities. For this reason, PAVS would not recommend any irrevocable change of legal structures to create regional County Voluntary Councils at this stage.

As mentioned earlier in this document, the four County Voluntary Councils in Mid & West Wales have formally signed a Memorandum of Understanding, which enables them to work better together regionally without changing existing structures. The Memorandum of Understanding is supported by an Action Plan which deals with a range of commitments, including regional representation (based on identifying regional “thematic” leads); quality assurance; exploring the potential of regional posts; shared services; shared procurement, etc. The Memorandum of Understanding is underpinned by a commitment to make better use of digital technology to address the geographical challenge – the region accounts for over 50% of the land mass of Wales! The Mid & West Wales regional collaboration uses the “adopt or justify” approach when implementing the Memorandum of Understanding.

PAVS suggests that that the best way of ensuring third sector engagement at a regional level will be to include regional outcomes and performance indicators in the Partnership Agreement, supported by an appropriate investment of funding at a regional level. Because the range of regional partnerships is diverse, it will be important to ensure that the outcomes and indicators are as flexible as possible as it is impossible to be prescriptive in such a fast-changing political environment.

At this stage, PAVS does not recommend the imposition of specified regional structures. WCVA, County Voluntary Councils and Volunteer Centres must be allowed to decide for themselves how best to deliver the regional outcomes and to report against the regional performance indicators through the Partnership Agreement monitoring process.

Q14: Do you agree that the model of commissioning set out in 5.17 should be adopted within the Code of Practice?

PAVS supports the model of commissioning set out in 5.17 and agrees that it should be adopted – and enforced - within the Funding Code of Practice. However, the Code must make it clear that a range of options can be adopted to secure (purchase) the services that are being commissioned, including the award of grants.


It is important to retain an outcomes based model in whatever commissioning framework is finally adopted, based on a process of co-production. There is no doubt that the challenge going forward will be to transform service delivery models and to manage change during the transition period.

The Funding Code of Practice should also include a commitment to full cost recovery (FCR), which includes governance costs. The irony of the current position is that governance costs are often excluded from an FCR model on the basis that “it would have to be done anyway” even though Welsh Government and other statutory partners appear to lack confidence in the governance of third sector organisations in the wake of high profile failures such as AWEMA and Plas Madoc.

Further thought needs to be given to establishing a protocol governing the separation of functions within the commissioning cycle. There is often a reluctance amongst statutory partners to discuss commissioning frameworks with third sector service providers because it somehow compromises the impartiality of the process. However, Local Authorities and Health Boards routinely play a part in service design and then go on to deliver those services in-house. The same flexibility ought to be afforded to third sector organisations, particularly third sector intermediary bodies, otherwise the concept of co-production is seriously undermined.

Q15: Community development and community resilience is an important part of the Welsh Government and Third Sector relationship. How would you like to see our proposals in this area taken forward?

PAVS completely agrees with the statement in the consultation document that community groups and local volunteers should receive the support they need to thrive and achieve their aims. County Voluntary Councils and Volunteer Centres work at grass-roots level to provide a wide range of capacity building services including training, organisational development and support for fund-raising.

Whilst acknowledging the importance of providing in-depth support to the most deprived communities in Wales (which is currently delivered through Communities First and associated programmes), it must be recognised that these programmes do not address rural poverty. Rural poverty is difficult to tackle because it is “dispersed” poverty, present in small, isolated communities spread across a wide geographic area. There is an inherent danger in spatial targeting based solely on WIMD scores – rural poverty and isolation are not taken into account, but really need to be considered.

PAVS believes that town and community councils have an important role to play as “community leaders”, working closely with County Voluntary Councils, LEADER groups and Communities First Partnerships to engage local people in delivering local solutions to meet local needs. In Pembrokeshire, there are approximately 80 town and community councils operating across the County but they all work in different ways, ranging from full engagement in active Community Associations delivering local action plans to simply reviewing planning applications and referring issues to the County Council for them to deal with.

By working more proactively with third sector infrastructure organisations, town and community councils could use their precepts more effectively to support local service delivery. For example, one community council in Pembrokeshire contributes to maintaining the local community mini-bus because transport has been identified as a major problem for people living in that community.

For town and community councillors to become recognised “community leaders”, it is important that there are more contested elections and that elected councillors are prepared to take control of the local community agenda; communicate better to improve accountability and consider the use of precepts for local delivery of locally needed services.


Encouraging people to volunteer in local communities is also fundamental to developing resilient communities. Volunteer Centres clearly have a role to play in this aspect of community development, supporting communities to choose appropriate mechanisms to get more people interested in volunteering. Such mechanisms might include time-banking; volunteer incentive or community reward schemes; established programmes such as Street Ambassadors, or other “bespoke” initiatives developed by local people themselves.

It has been suggested that developing “pools” of volunteers would also be useful, for example, Pembrokeshire Association of Community Transport Organisations have a pool of volunteer drivers that can be deployed across a number of community transport groups. The same principle could potentially be applied to other groups of volunteers, for example, environmental volunteers, volunteers working in health and social care, etc.

The importance of a small grants programme to “oil the wheels” of community development cannot be over-stated. As mentioned earlier in this response, PAVS has many years of experience of distributing small grants and key funds to support community-led, grassroots projects. The withdrawal of the small grants element of CFAP earlier this year means that we can no longer provide this support and this will definitely have a negative impact on small scale community projects. This issue has been identified as a key concern in our consultation with groups in Pembrokeshire, with many identifying the difficulty of finding relatively small amounts of core funding to continue to deliver effective services in the community.

Decisions about grant distribution should be taken as close to the level of delivery as possible to allow local intelligence to be applied to grant-making decisions. Often decisions taken at a national level lead to duplication of activities with organisations from outside the area coming in to do things that are already being done by small, locally-based groups. This can have a detrimental effect on community resilience, which depends on a strong network of small groups operating at community level.

Our members have also identified the resiliency challenges to rural communities caused by rising petrol and diesel prices and increased fuel poverty. Possible community-led solutions include car clubs, community transport and lift share schemes, as well as using broadband connectivity (where it exists) to enable remote home working and encouraging low-impact economic development in communities to provide employment for local people. Generic support for these initiatives can be provided by the local CVC and Volunteer Centre, working in partnership with other organisations, such as LEADER groups and community councils.

Chapter 6 – Local Compacts

Q16: Do you consider that Local Compacts, as described in this chapter, have a continuing role in shaping the relationship between the Third and Public Sectors in Wales?

PAVS considers that local Compacts do have a continuing role to play in terms of shaping the relationship between the third sector and the public sector.

Through the 3rd Sector Co-design work undertaken with Hywel Dda, an over-arching regional Compact has now been signed by the CVC and Local Authority in each County and the Hywel Dda Health Board. The 3-County Compact is designed to be supported at a local level by Codes of Practice for funding, volunteering, partnership working and communication, with an agreed protocol for dispute resolution. Work is currently ongoing within the Pembrokeshire Voluntary Sector Liaison Group to finalise these Codes of Practice and develop a revised action plan. It is hoped that this work will help sharpen the focus of the Compact and strengthen the relationship between the third and public sectors in Pembrokeshire.


The main problems in terms of establishing an equal and reciprocal partnership between the third and public sectors relate to disparities of funding and power. As a County Voluntary Council, it is difficult to behave and be treated as an equal partner when compared to the significant financial and human resources of the Health Board and Local Authority.

In terms of “power”, the Chief Executives of the Health Board and Local Authority have a direct employer relationship with the people in their organisations and have the power to instruct employees to do whatever is required. For the Chief Officer of a CVC, the position is very different. There is no way he/she can simply issue an instruction to the local third sector to do something as the third sector is made up of a plethora of relatively small, independently managed organisations with their own funding and charitable objects. The CVC Chief Officer can only effect change by communicating and influencing, which is a much longer term and less certain process.

PAVS accepts that good Compact arrangements help to address these imbalances but they must be equally binding on all partners, without the usual “get out” clauses that are applied when things become problematic.

Q17: Do you agree with the proposal (Option 2) to develop existing frameworks to impose greater control or influence over local compacts and only introduce new statutory obligations if this approach fails over time?

PAVS agrees with this proposal, but only on the basis that Welsh Government sets out clear guidance and declares its intention from the outset to introduce new statutory obligations if this approach fails. Welsh Government is also asked to ensure that legislation that is currently being drafted does not weaken the position of the third sector. For example, the current Sustainable Development Bill makes it possible for the third sector to be excluded from Local Service Boards (LSB). Whilst we appreciate that Welsh Government cannot place a statutory duty to co-operate on third sector organisations, there should be a statutory duty on Local Authorities to ensure appropriate third sector representation at the LSB through the County Voluntary Council (or successor organisation).

It would also be helpful if funding streams that are currently “passported” through statutory partners could be moved to County Voluntary Councils – this would certainly encourage a more enthusiastic commitment to joint working from public sector colleagues!

Our feeling is that Compacts will only work if all parties are willing to make them work – being forced into this through legislation is likely to achieve the opposite effect. Compacts will only work if there is a hearts and minds commitment from all partners – forcing people to take part in a process does not equate to proper engagement in the delivery of shared outcomes.

Chapter 7 – Framework documents

Q18: Do you agree that the Voluntary Sector Scheme should be revised on the suggested basis?

PAVS agrees that the Voluntary Sector Scheme should be revised to take into account any changes that might come about as a result of the current consultation. Care will need to be taken that the essence of the Scheme remains intact and that any changes are properly considered to minimise the chance of “unintended consequences” arising in future.


Q19: Do you agree that the Code of Practice for Funding the third sector should be strengthened and updated? Are there particular issues you think should be addressed in the revision?

PAVS agrees that the Funding Code of Practice should be updated in light of the various changes that have taken place since it was first published, particularly around commissioning, tendering and procurement. The following issues should be addressed in the revision:

Advance payments for third sector organisations - in many instances, claims can only be made on the basis of reimbursement of defrayed costs. This means that third sector organisations must have sufficient working capital to manage the cash-flow implications, but it is very difficult to build up a strong balance sheet when so many funding sources are not based on outcomes but on inputs/outputs and specifically preclude the possibility of generating a year end surplus. The Funding Code of Practice (a) must make it possible for third sector organisations to generate and retain surpluses that can be used to build up sufficient levels of reserves to manage a negative cash-flow position and (b) provide for advance payments whenever there is an issue with working capital;

Full cost recovery – as mentioned earlier in this response, it is absolutely essential that third sector organisations are allowed to include a financial contribution towards governance in any full cost recovery calculation of project/service delivery costs. In many cases, this is specifically excluded on the grounds that the organisation would have to “do it anyway” – but how are third sector groups supposed to build up sufficient core funding to pay for their governance costs? This issue must be addressed within the Funding Code of Practice, particularly when good governance in the third sector is under scrutiny following AWEMA;

Volunteer expenses – it must be made clear in the Funding Code of Practice that volunteers should be reimbursed their out-of-pocket expenses at a rate that does not disadvantage them when compared to paid staff members. Individual volunteers do, of course, always have the choice as to whether or not to claim expenses (with many choosing not to do so) but the Funding Code of Practice must provide protection against volunteers being exploited. This is particularly important when trying to encourage people in poverty to take up volunteering;

Proportionate financial monitoring arrangements – it is recommended that all financial monitoring arrangements are based on a robust risk assessment and are proportionate to the amount involved. The current financial monitoring processes applied to European funded projects are completely disproportionate and result in valuable staff resources being wasted on “bean counting” exercises. It seems that monitoring processes are predicated on the assumption that fraud is taking place, rather than assuming that people are not usually setting out to defraud but are more likely to be using the funding to carry out activities that will deliver the required outcomes! If an organisation has a good track record in managing public money or if a relatively small amount of funding is involved, then monitoring should be “light touch” only.

Q20: Do you agree that the existing Action Plan should be superseded by the Integrated Delivery Plan, Annual Report and Workstream Framework?

In principle, PAVS supports the idea of replacing a static action plan with a more dynamic planning process that includes the production of an annual Integrated Delivery Plan (developed jointly by Third Sector Infrastructure partners); an Annual Report on the Voluntary Sector Scheme and structured reports from the TSPC workstreams.

As mentioned earlier in this response, more work will need to be undertaken to identify the work programme for the TSPC and its sub-groups.


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