Probation Circular

IMPLEMENTATION OF APPROVED PREMISES PERFORMANCE IMPROVEMENT STANDARDS
PURPOSE
To require Chief Officers of Probation, Boards and the Chairs of Voluntary Managed Committees (VMCs) to implement the Performance Standards for Approved Premises.

REFERENCE NO: 19/2006 ISSUE DATE: 15 May 2006 IMPLEMENTATION DATE: 29 May 2006 EXPIRY DATE: March 2008 TO: Chairs of Probation Boards Chief Officers of Probation Secretaries of Probation Boards CC: Board Treasurers Regional Managers AUTHORISED BY: John Scott Head of Public Protection and licensed Release Unit ATTACHED: Annex A - Performance Standards

ACTION
Chief Officers and Chairs of VMCs are asked to ensure that the Standards are disseminated to relevant senior managers and Approved Premises, as well as offender managers. All Approved Premises are to undertake annual audits using the Standards and to submit the results of the audits to the Public Protection Unit. The first audit should be completed by 31 July 2006.

SUMMARY
The Performance Standards seek to introduce a national framework to support and evaluate the delivery of public protection and interventions by Approved Premises. The purpose is to establish a benchmark which will facilitate the safe supervision of high risk offenders and establish public confidence in our work.

RELEVANT PREVIOUS PROBATION CIRCULARS
PC15/2005 – National Standards 2005 PC37/2005 – The Role and Purpose of Approved Premises PC15/2006 – Guidance on Implementation of Practice Recommendations

CONTACT FOR ENQUIRIES
Felicity.Hawksley@homeoffice.gsi.gov.uk or 0207 217 0773

National Probation Directorate
Abell House, John Islip Street, London, SW1P 4LH

INTRODUCTION 1. At present, there are no nationally agreed operating standards specifically for the delivery of services in Approved Premises and no methodology for assessing performance of Premises over and above the occupancy target. As part of the wider NOMS agenda, work has been ongoing to develop a set of Standards which can be used in all Premises to evaluate current performance and identify areas for improvement. This draws on earlier work undertaken as part of the Approved Premises Pathfinder Project. The draft Standards were circulated in January, and the final version, attached as Annex A to this Circular, reflects the outcome of testing undertaken in three probation areas. . THE STANDARDS 2. The Standards focus principally on the role of Approved Premises in delivering public protection and provide a mechanism for externally validating some aspects of performance in the Approved Premises Estate. They represent a vital tool in maintaining and driving up standards of delivery of risk assessment and management within Approved Premises. As such, they complement the wider work on the Risk of Harm Action Plan, including the risk of harm training currently being rolled out to Approved Premises staff. The Standards do also establish threshold requirements in respect of other key areas such as diversity, prevention of self-harm and suicides, and drugs. It should be noted however that they are primarily intended as improvement standards and will not provide a comprehensive audit tool for all aspects of work in Approved Premises. The Standards are consistent with the approach being undertaken in developing the Quality Standards Portfolio for NPS by the Regions and Performance Unit. THE AUDIT PROCESS 3. Approved Premises are required to undertake an audit of their Premises using the Standards at Annex A. It may be helpful when setting up the audit process to consider using colleagues from other Approved Premises to undertake the audit or validate the scoring. Senior managers may also wish to consider adopting a common approach to audit and scoring so as to ensure consistency across a Probation Area or Region. As part of the audit, Approved Premises should draw up, in conjunction with the senior manager responsible for the Premises or in the case of the Voluntary Managed Premises (VMC), with the Chair of the Committee, an improvement plan. Details of the scores and plan should be recorded on the form at Appendix 1. One copy of the form should be submitted to Felicity Hawksley in the Public Protection Unit, Ground Floor, Abell House, John Islip Street, London SW1P 4LH 9 (electronic versions to approvedpremises@homeoffice.gsi.gov.uk) and one to the relevant regional manager by 31 July 2006. A national audit report will be produced in due course. 4. Progress in delivering the improvement plan should be monitored locally every three months by the relevant senior manger. Reviews should be recorded in writing and copied to NPS regional mangers. The audit process should be repeated on an annual basis at each Premises and updated action plans produced.

PC19/2006 – Implementation of Approved Premises Performance Improvement Standards

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Annex A

Approved Premises Performance Improvement Standards

Contents
AP1 Resources for High-Risk Work AP2 High Risk MAPPPA Arrangements in Place and Known AP3 Risk Management and Enforcement AP4 Monitoring and Surveillance AP5 Compliance and Enforcement AP6 Relationship with Local Community AP7 Suicide /Self Harm AP8 Illegal Drugs Policy and Procedures AP9 Resettlement & Reintegration AP10 Diversity/Maximising Inclusion APPENDIX 1 Scoring sheet

1

AP1

Resources for High-Risk Work

Description:
The Approved Premises has resources necessary to enable it to carry out work for the management of high risk of harm offenders.

Evidence of how the criterion will be met:
• • • • • • • • • • • • Regular health and safety risk assessment is carried out on the building. Specific health and safety work relating to the safe management of high risk cases. Approved Premises can store confidential information safely. Approved Premises has CCTV that assists with the management of high risk cases. Approved Premises has sufficient staff to monitor residents, carry out room searches and curfew checks. Approved Premises follows its policy for dealing with controlled entry and exit of the building. Approved Premises follows its policy on dealing with violent situations. Regular engagement with/contributions to MAPPA work. Relevant paperwork including up-to-date OASys accompanies all referrals Mandatory use of ‘personal attack alarms’ to assist staff safety. A structured regime which facilitates the provision of enhanced supervision and monitoring of high risk offenders. An up to date contingency plan is available, which is reviewed regularly and shared with the emergency services.

Methods for Managers to check and local area senior managers to audit and verify;
• • • • • Copies of health and safety risk assessments, resident entry and exit and action plans. Copy of Approved Premises contingency plan. Inspection of CCTV system and record of compliance with the personal alarms policy. Interviews with Approved Premises manager, staff and key MAPPA staff. Approved Premises has policies on controlled entry and exit of the building and on dealing with violent situations. 2

• •

Meetings between Approved Premises and MAPPA staff. Documentation evidencing regime and resident compliance rates.

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AP2

High Risk MAPPA Arrangements in Place and Known

Description:
Offenders subject to MAPPA have the relevant public protection plan in place.

Evidence of how criteria will be met:
• • • • •

Assessments should be based on OASys and Approved Premises supervision plan. MAPP level at which residents are being managed is recorded clearly on the resident’s file/case record A public protection plan/up to date risk assessment is in the resident’s file, together with minutes of MAPP meetings. An up to date risk management plan is in the resident’s file. Regular joint meetings between the Approved Premises staff, MAPPA and field offender manager in line with the MAPPA arrangements and PC 15/2006. Regular reviews of the resident in team meetings.

Methods for Managers to check and local area senior managers to audit and verify;
• •

Review offender records and OASys documentation. Outcome of National Standards monitoring.

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AP3

Risk Management and Enforcement

Description:
The case file shows that all relevant documentation is completed and available at the Approved Premises on respect of risk management and enforcement.

Evidence of how criteria will be met:

Offender records containing all relevant and up to date documentation, e.g. OASys assessment and Supervision Plan (as required in PC 15/2006), offender contact log, MAPPA arrangements and information to facilitate an emergency recall. Evidence of effective case management/liaison with offender manger and appropriate sharing of information Approved Premises has policy on emergency recall. Approved Premises has police contacts for emergency recall and breach of bail. Duty manager and ACO rota.

• • • •

Methods for Managers to check and local area senior managers to audit and verify;
• • • •

Approved Premises records. Offender records, eg keywork notes, e mails between Approved Premises and offender mangers, notes of review meetings with offender mangers Policy on recall and breach of bail. Evidence of police contacts.

5

AP4

Monitoring and Surveillance
Description:
Staff carry out monitoring and surveillance in line with Approved Premises Handbook, local Approved Premises policy (including drug and alcohol testing) and individual risk management plans.

Evidence of how the criterion will be met:
• • Approved Premises staff use OASys and Approved Premises Supervision Plan to identify those residents needing monitoring and surveillance. Approved Premises has systems and procedures which are compatible with local area policy, for recording and communicating information, including interface with local MAPP. Approved Premises has policy and procedure for drug/alcohol testing. Staff understand their monitoring and surveillance roles. Feedback to Offender Manager on monitoring and surveillance work with the resident. Approved Premises has a confidentiality policy.

• • • •

Methods for Managers to check and local area senior managers to audit and verify;
• • • • Approved Premises policy on curfew checks, use of ‘tagging equipment’, room checks, door entry and CCTV. Policy meet standards set out in Approved Premises Handbook. Drug and alcohol testing policy and procedure. Evidence that manager is checking that policy and processes for monitoring and surveillance are being followed.

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AP5 Compliance and Enforcement
Description:
Responsibility for the monitoring of compliance and the enforcement of orders/licences is clearly defined with appropriate systems in place. There is evidence of effective enforcement in all cases and clear evidence and documentation with regard to the link with risk management.

Evidence of how criteria will be met:
• •

Clear case records that note an offender’s attendance/non-compliance and any necessary enforcement action. Committee policy and guidance documents on enforcement conform to the requirements of National Standards, area enforcement policy and the agreed Approved Premises rules. Periodic quality assurance exercises to ensure enforcement practice is being followed. Action on enforcement takes place within the agreed National Standards timetable. Arrangements with police for arrest of residents.

• • •

Methods for Managers to check and local area senior managers to audit and verify;
• • • • • • •

Case records. Interviews with Offender Managers. Interviews with Approved Premises staff. Copy of Approved Premises rules. Area enforcement action. Interview with local police. National standards monitoring with regard to enforcement.

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AP6

Relationship with Local Community

Description:
A robust, proactive strategy for developing links with the local community and a policy for managing those relationships.

Evidence of how the criterion will be met:
• • • • • • • • • Local community support group based at Approved Premises eg where appropriate friends of the Approved Premises group. Approved Premises active in local community group where appropriate. If appropriate, residents active in local community events. Approved Premises has written strategy for community engagement. Senior managers and Approved Premises Managers meet local neighbours. Approved Premises has policy and process for dealing with complaints from neighbours. Use of police intelligence. Local ward councillors/MPs briefings. Record of complaints and use of complaints procedure.

Methods for managers to check and local area audit to verify:
• • • • • • Copies of policies. Reports by local manager on relationship with neighbours. Records of meetings with neighbours Minutes of community liaison meetings . Evidence of resident participation in local events. Reports on complaints and use of complaints procedure.

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AP7

Suicide/Self harm
Description:
Approved Premises should have in place a policy and robust supporting procedures and systems for work with offenders who are assessed as high risk of suicide or self harm.

Evidence of how the criterion will be met
• • • • • •

Protocol in place to ensure sharing of information between HMPS and probation area/Approved Premises Liaison with prisons, mental health practitioners and services. Procedures in place for notifying staff and on-call managers of potential risk. Staff trained to identify risk and to respond appropriately. Procedures in place for notifying key partners and stakeholders. Requirement that staff carry out regular and frequent checks to locate whereabouts and condition of all residents and systems in place for recording these checks. Medication systems which are compatible with NPD operational instructions and the local Health and Safety requirements. Strategy for supervising offenders who are at risk of suicide/ self harm. Staff trained in First Aid.

• • •

Methods for Managers to check and local area senior managers to audit and verify;
• • • • • •

A written policy for working with offenders who are assessed as at risk of suicide and or self harm. Evidence that information is sought at the referral stage of risk of suicide or self harm Documentation to evidence supporting arrangements with local medical and mental health services. Evidence of staff training (including relief staff). Evidence of systems for communicating risk to other key partners and stakeholders. Evidence of regular and frequent checks carried out by staff on all offenders. Interviews with all Approved Premises staff including awareness of selfharm and deaths in Approved Premises policy. 9

AP8

Approved Premises and Illegal Drugs.
Description
Approved Premises has a policy and procedure for dealing with residents who are using illegal drugs. All Approved Premises will have facilities for on site drug testing and supporting policies, procedures and protocols

Evidence of how the criteria will be met
• • • • Approved Premises has a drugs policy and procedure. Approved Premises has a policy regarding the role of the unit in the provision of drug treatment. Staff are aware of the Approved Premises procedures. The requirement for drug testing (PC 05/2006) is incorporated in Approved Premises documentation which is made available to offenders, prisons and key stakeholders. Management Committees will incorporate drug testing into their Annual Business Plan/report and all Approved Premises will have facilities and equipment for on site drug testing. Probation areas/Management Committees will require reports on testing and treatment from Approved Premises managers and partners. Staff will receive training and support in the administration of testing. Arrangements will be in place with partner agencies to facilitate entry into treatment. Staff are trained and receive briefings on working with illegal drug misusers. Approved Premises has policy for storage and handling of prescribed medication and the disposal of 'sharps'. Approved Premises will have in place a policy and supporting procedures for the disposal of any illegal drugs found in Approved Premises.

• •

• • • •

Methods for Managers to check and local area senior managers to audit and verify;
• • • • • Copy of Approved Premises drug policy and procedure. Facilities and equipment available on-site Access to Area drug treatment resources. Approved Premises staff interviews. Copies of testing and training audits.

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• •

List of staff who have attended drugs training. Protocols for working with partner agencies. Key work records reflect Approved Premises adherence to testing and entry into treatment.

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AP9

Resettlement and Reintegration
Description:
The Approved Premises has enables residents to access housing advice services to facilitate move-on resources for the residents either through Supporting People arrangements and appropriate referrals to local authorities and other housing providers.

Evidence of how the criterion will be met:
• Residents have a written resettlement plan prepared by the offender manager or Approved Premises key worker based on OASys and other risk management tools. Residents have access to housing advice services. High-risk resident resettlement issues feature on the local MAPPA agenda Approved Premises has links to local Supporting People services. Approved Premises are part of local Supporting People policy.

• • • •

Methods for local managers to check and local area senior manager to audit on behalf of NPD;
• • • • Copies of resettlement plans in residents’ files. Approved Premises mentioned in local Supporting People and Homelessness strategies. Evidence of residents accessing resettlement or housing advice services. Minutes of MAPPA meetings.

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AP10 Diversity/Maximising Inclusion
Description:
The Approved Premises regime is designed for a broad range of offenders. Assessment and support arrangements should exist so that women, ethnic minority offenders, residents who are gay, lesbian, bisexual or transgender and offenders with disabilities can fully participate in the Approved Premises interventions.

Evidence of how the criterion will be met:
• • • • • • • • Approved Premises are explicitly included in the Area Diversity Plan. Approved Premises have their own annual Diversity Plan. All staff receive training in diversity. Diversity objectives are set in appraisals Approved Premises provide data on admissions and departures based on race, ethnicity, gender and disability. Provision of meals to cover all dietary needs. Access to interpreting and translation services. Staffing profile of Approved Premises in relation to resident group. A sufficient range of interventions are available to ensure broad access to the residents. Regular consultation with women, black and minority ethnic and offenders with disabilities over potential opportunities to maximise inclusion. Offender feedback questionnaires, broken down by race and gender, used to demonstrate to offenders that Approved Premises develop its policies based on their feedback. Completion of any Race Equality Impact Assessments. Process for dealing with complaints exists and is public.

Methods for Managers to check and local area audit to verify:
• • • • Area and Approved Premises documentation including Diversity Plans. Copies of reports on admissions, departures, and resident feedback. Resident feedback reports. Interviews with senior managers, Approved Premises managers and deputy managers and all other Approved Premises staff. List of community and faith resources, Approved Premises Diversity Plan and reports on reviews. Race Equality Impact Assessments. 13

Posters advertising community and religious resources. Reports on the usage of the complaints procedure.

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Scoring Approach APPENDIX 1
Name of Approved Premises Date of audit Each criterion will be scored as: 0. 1. 2. 3. 4. Criterion
AP1 Resources for High-Risk Work

………………………………………. ……………………………………….

Name of manager completing audit ………………………………………. Name of senior manager reviewing audit …………………………………… No evidence A small amount of evidence. Some evidence. Considerable evidence. Standards fully met. Areas for Development Score

AP2

High-Risk MAPPPA Arrangements in Place and Known

AP3

Risk Management and Enforcement

15

AP4

Monitoring and Surveillance

AP5

Compliance and Enforcement

AP6

Relationship with Local Community

AP7

Suicide/Self-Harm

AP8

Illegal Drugs Policy and Procedures

16

AP9

Resettlement & Reintegration

AP10 Diversity/Maximising Inclusion

Total Score Maximum Potential Score

40

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