Key information
Reference code: PCD 1291
Date signed:
Date published:
Decision by: Sophie Linden (Past staff), Deputy Mayor, Policing and Crime
PCD 1291 - Integrated Offender Management (IOM) co-commissioned services
PCD 1291 - Integrated Offender Management (IOM) co-commissioned services
Integrated Offender Management (IOM) is the national multi-agency partnership that manages the most persistent, repeat offenders. In 2021 a specific IOM framework for London was launched by MOPAC, MPS, London Probation and partners which, focuses partners on persistent offenders most likely to reoffend violently. In recognition of the importance of this work Mayoral funding has been allocated to deliver IOM interventions as part of work to address serious violence under this priority area with the Police and Crime Plan.
This decision seeks approval to co-commission with London Probation two new services to support IOM work across London. These two new interventions, one for mental health and one for service user engagement, will support current activity to reduce the reoffending of this group. MOPAC will lead the procurement, which will involve initially accepting up to £0.55m of funding from London Probation as well committing funding of £1.32m for spend between January 2023 and March 2025.
Phase two of IOM co-commissioning, which is planned to include a dedicated neurodiversity and community mentoring provision, will be commissioned during 2023 using the remaining budget.
This decision also seeks approval for the procurement strategy and delegated authority for contract award.
The Deputy Mayor for Policing and Crime is recommended to:
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Approve the acceptance of up to £0.55m of funding from London Probation to support this co-commissioning process in 2022-2025;
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Approve the commencement of a procurement process to co-commission with London Probation two new services to support IOM work across London at a total cost of £1.87m.
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Approve the carrying forward of up to £0.68m allocated to IOM commissioning for this finance year, to be spread equally across 2023/24 and 2024/25, to maximise co-commissioning resources;
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It is recommended that the Chief Executive Officer is granted delegated authority, to award contracts following procurement and for signing future documents in relation to this decision, including contracts and variations. Approval of this decision remains with DMPC as per MOPAC’s Scheme of Delegation.
PART I - NON-CONFIDENTIAL FACTS AND ADVICE TO THE DMPC
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Introduction and background
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Integrated Offender Management (IOM) is the national multi-agency arrangement that manages the most persistent, repeat offenders in London. In recent years MOPAC has worked with partners to implement a new framework for IOM in London. The IOM framework is increasing consistency in London IOM and measuring outcomes and impact. The framework has also re-focused IOM specifically on repeat offenders who in addition pose a medium to high risk of violent reoffending.
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Evidence clearly shows that persistent IOM offenders have a significant impact on the crime rate in London, with adult offenders with 11+ previous offences making up 38% of all adult reoffenders in London but committing over 75% of all adult proven reoffences. Violence is also increasing within this group, with the proportion of London IOM eligible cases with a violent index offence increasingly significantly between 2013 and 2020. For these reasons reducing IOM reoffending is a specific aim of the Police and Crime Plan.
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In addition to working with partners to implement the London IOM framework, the medium term financial plan includes funding totalling £2.1m over the three year period 2022/23 to 2024/25 to support improved IOM interventions to reduce the risk of violence posed by this group. This decision seeks approval to use £1.32m of this funding.
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Since April MOPAC has been meeting with key partners involved in IOM delivery to convene a co-commissioning process for improved IOM interventions. This has resulted in agreement to date with London Probation that they will contribute £550,000 over three years from 2022/23 to co-commission two new IOM interventions; for mental health and for service user engagement.
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An analysis of the needs and risk factors linked to IOM offending shows that mental health plays a prominent role in driving this repeat offending. The majority of the London IOM cohort have psychological problems and/or depression with almost three quarters having difficulties coping. For a significant proportion of the London IOM cohort this emotional well-being need is linked to the causes of their offending and also to risk of serious harm. The vast majority of these cases also have a substance misuse problem, alongside their mental health need (dual diagnosis), which often acts as a barrier to accessing support. London IOM practitioners consistently report in regular surveys that a lack of local mental health expertise and interventions is one of biggest gaps in effective working arrangements.
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Ensuring that services provided fit the unique needs of the people involved in IOM is also vital for effective delivery. The unique insights of current and past service users and those with lived experience are currently missing from London IOM and will play an important part in the future development of the framework and any other interventions. By providing support for service users to share insights into what would be effective for IOM, we will also ensure that IOM work can be responsive to often marginalised groups, such a service users from minority ethnic groups, persistent female offenders and those with needs around mental health and neuro-diversity.
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Issues for consideration
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This decision seeks approval to commission two new interventions for London IOM from February 2023 to March 2025, one a dedicated mental health service and one a service user engagement provision. This will be a co-commissioning process, using combined MOPAC and London Probation funding, to meet the needs as outlined about.
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The mental health service will provide dedicated Forensic Mental Health Practitioners across London to provide expert consultations, assessments and low/medium level treatment and support to IOM service users with mental health needs. These practitioners will be integrated into local IOM arrangements and in addition to the expertise they will offer colleagues and service users, they will also refer those with more serious needs on to appropriate NHS services. Crucially these workers will be pro-active in engaging with IOM service users to build their motivation to get support and understanding of their own experiences and needs. The service will also explicitly recognise the substance misuse treatment needs of this group and work with partners to address these issues as part of a co-ordinated dual diagnosis approach. The overall aim of this service will be to reduce reoffending and violence by improving the mental health of IOM service users.
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The service user engagement provision will procure a service from an organisation with expertise in working with CJS service users to collate and collect their feedback on their experience of IOM and provide ongoing insights into how London IOM is developed. This will include engaging IOM service users in any future commissioning activities in line with MOPAC’s approach commissioning, which include service user voice and co-design.
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The funding for these service will consist of £1.32m included in the MOPAC medium term financial plan 2022/23 – 2024/25 and £0.55m of funding from London Probation. This co-commissioning process will be underpinned by a Memorandum of Understanding (MoU).
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To maximise the resources for these interventions and the effective use of match funding, approval is also requested to carry forward the £0.68m MOPAC budget allocated to improved IOM interventions for this year (2022/23) to be spread evenly between 2023/24 and 2024/25.
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These two services will be evaluated as part of the wider plans for a process, performance and impact evaluation of London IOM starting in 2023.
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Financial Comments
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This decision seeks approval to commission two new services to support IOM work across London at a total cost of £1.87m for the 3 year period 2022/23 – 2024/25. Costs will be met from £1.32m included in the MOPAC medium term financial plan and additional grant of £0.55m from London Probation.
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The table below sets out the costs and how these will be funded. As part of the decision approval is being sought to carry forward funds of £0.68m to fund the project in future years, and maximise the grant funding available.
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Legal Comments
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The Crime and Disorder Act 1998 at sections 17(1) (a)to (c) places MOPAC under a duty to exercise its functions with due regard to the likely effect of the exercise of those functions on, and the need to do all it can to prevent, crime and disorder (including anti-social and other behaviour adversely affecting the local environment), reoffending in its area, and the misuse of drugs, alcohol and other substances in its area. These proposed commissioning arrangements are consistent with MOPAC’s duties in the Crime and Disorder Act 1998.
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Section 143 (1) of the Anti-social Behaviour, Crime and Policing Act 2014 provides an express power for MOPAC, as a local policing body, to provide or arrange for the provision of (a) services that in the opinion of the local policing body will secure, or contribute to securing, crime and disorder reduction in the body's area and (b) services “intended by the local policing body to help victims or witnesses of, or other persons affected by, offences and anti-social behaviour.”
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Paragraph 4.8 of the MOPAC Scheme of Delegation and Consent provides that the Deputy Mayor for Policing and Crime (DMPC) has authority to approve offers made for grant funding.
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Paragraph 4.8 of the MOPAC Scheme of Delegation and Consent provides that the Deputy Mayor for Policing and Crime (DMPC) has delegated authority to approve business cases for revenue or capital expenditure of £500,000 or above. The release of funding in accordance with the proposals set out in this decision form is accordingly to be approved by the DMPC. The delegation of responsibility for the finalisation of planning and contractual/grant arrangements, including relevant terms and the signing of agreements, to the Chief Executive Officer, is in accordance with the general power of delegation in paragraph 1.7, and more specifically paragraphs 5.4, 5.12 and 5.13.
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Officers must ensure that the arrangements comply with the Financial Regulations and the Contracts Regulations.
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The Mayor's Office for Policing Crime is a contracting authority as defined in the Public Contracts Regulations 2015 ("the Regulations"). All awards of public contracts for goods and/or services valued at £181,302 or above will be procured in accordance with the Regulations
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Commercial Issues
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This co-commissioning arrangement with London Probation will be underpinned by a MOU to define the purpose, roles and responsibilities of each commissioning partner and the agreed financial contributions.
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MOPAC will be the lead commissioner for this process and the procurement strategy for these new IOM interventions was previously approved at Procurement, Grants and Contracts Oversight Board.
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This procurement will take account and comply with the GLA Group’s Responsible Procurement (RP) Policy.
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Transport for London (TfL) will be engaged to administrate the procurement via their portal ProContract which is a web-based tendering tool. This will mean adherence to TfL governance required for tenders over the current threshold set by the Regulations.
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Public Health Approach
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The provision of improved mental health services, which will include a trauma informed approach to reducing triggers for offending and violence, is entirely consistent with a public health approach to violence reduction. Service user engagement in IOM service to improve their effectiveness and responsivity is also consistent with a public health approach to violence reduction, especially with this group of service users. Details of this approach have been shared and agreed with the Violence Reduction Unit and GLA Public Health colleagues.
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GDPR and Data Privacy
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For the new services MOPAC and London Probation will be joint Data Controllers.
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A Data Protection Impact Assessment (DPIA) will be produced to identify and minimise risks to data subjects. This document will also reflected evaluation plans for London IOM to ensure that sufficient data is available to enable this.
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All providers funded by MOPAC are required to comply with the GDPR and Data Protection Act 2018.
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Equality Comments
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MOPAC is required to comply with the public sector equality duty set out in section 149(1) of the Equality Act 2010. This requires MOPAC to have due regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations by reference to people with protected characteristics. The protected characteristics are: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation.
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The proposed mental health provision will have the explicit aim of addressing the health inequalities with the IOM cohort that lead to reoffending and multiple disadvantages and the provider will be required to deliver interventions that are culturally competent to encourage full access and engagement to those groups who may have previoysly struggled to engage with mainstream mental health services. Data shows that women in IOM typically have more acute mental health needs than men, so specific attention will be paid to their needs, as well as linking them up with the specialist London Women in CJS service to provide wrap around, gender specific, support.
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The service user engagement provision will provide clear evidence of the role and impact of protected characteristics in IOM work and allow service users to communicate this to services and IOM partners so that more responsive and effective services can be provided.
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Background/supporting papers
None
Signed decision document
PCD 1291 - Integrated Offender Management (IOM) co-commissioned services