Draft guidance on young people's services is too vague, say experts

What constitutes "sufficient" young people’s services in a local area is notoriously hard to define.
Amid criticism that current guidance is too long and vague, the Department for Education has unveiled a revised version of what sufficient services should look like.

At two-and-a-half pages long, it is just one-sixteenth the size of the current guidance, issued by the Labour government.

But as a consultation on the content gets under way, sector figures have been quick to point out a number of apparent shortcomings.

The National Youth Agency, which has launched a commission to feed the sector’s views into the consultation, has already suggested the guidance is too ambiguous, with chief executive Fiona Blacke calling for it to set out "what councils must do rather than should do".

A tally of the document shows that there are only two "musts" stipulated for local authorities – the first in reference to taking into account the views of young people when making decisions about services, the second in considering service delivery by third parties.

"The use of words such as ‘encourage’, ‘should’ and ‘consider’ is a concern," says Linda Jack, member of the Liberal Democrat federal policy committee for education. "People can get around vague terms like this, so authorities need to be told what they must do."

Jack adds that the document is also light on enforcement measures for those that fail to provide a sufficient service. "This guidance doesn’t set out how authorities can be challenged if they are not providing sufficient services," she says.

"It is also deeply worrying that authorities are being told they need to determine which services can be delivered by third parties, only providing services in-house where it is ‘clearly best placed to do so’."
David Wright, chief executive of the Confederation of Heads of Young People’s Services, shares some of Jack’s concerns, but says there are some "really positive things to build on" in the document, such as the focus on young people’s wellbeing and publishing performance data.

Although the revised guidance highlights the role of young people in assessing services, Wright argues that how success in this area will be determined is unclear.

"I don’t think it is sufficient to say that a sufficient local offer can result from ‘positive feedback from young people on the adequacy and quality of local provision’," he says. "This is an important aspect that needs work. Young people will also need some level of support to report objectively on the level of quality. The big question is still what happens if a local authority fails to meet that standard? Some clarity over what that will actually mean is required."

He adds that it could be beneficial for government to make the revised guidance slightly longer.
"The government has put great stock in short guidance, but I’m not quite sure why that is a virtue," he says. "The question is ‘does this need more clarity’, and I think the answer is ‘yes’."

One of the clearest aspects of the revised guidance is the intention to involve young people in the process. Dara Farrell, vice chair of the British Youth Council (BYC), says the emphasis on listening to young people is welcome, but stresses that partici­pation must be representative of "a wide range of young views, and structured to avoid tokenism or short-term arrangements".

BYC is to launch an exercise to allow young people to feed their views into the consultation on the proposed revisions and is also exploring how it can work more closely with Ofsted to "enhance each others’ credibility and authority by empowering young people’s scrutiny role".

"Our concern is inconsistency between areas and inequality of youth representation structures across the country," Farrell says. "So when the guidance advocates local response to local need as a good thing, BYC will be monitoring the depth and quality of youth participation."

The consultation closes on Friday, 25 May.