MD3307 Extension of the Mayor’s No Wrong Door Initiative

1.1    The No Wrong Door (NWD) initiative was developed in response to the work of the London Recovery Board  in the wake of the Covid-19 pandemic. The programme was part of the Good Work for All mission which aimed to ‘support Londoners into good jobs with a focus on sectors key to London’s recovery’, with a strong emphasis on Londoners who had been disproportionately impacted by the pandemic and face structural inequalities. 
1.2    The initiative’s overarching vision is to coordinate skills, careers and employment support so there is ‘no wrong door’ for Londoners; and to ensure that employment and enterprise provides a secure route out of poverty. 
1.3    The NWD programme was originally approved by the Mayor under cover of Mayoral Decision (MD)2833 in 2021, with a further decision relating to UK Community Renewal match funding and GLA additional funding until 2025 approved under MD2916. Subsequent additional funding from the GLA and UK Shared Prosperity Fund to fund additional activities for the Integration Hubs was later approved by the Executive Director – Communities and Skills, under cover of DD2624 and the Assistant Director Skills and Employment (Delivery), under cover of ADD2681.
1.4    The NWD programme encompasses three strands of activity which align with GLA programme objectives:
•    Integration Hubs: GLA grant funding being provided to Sub-Regional Partnerships (SRPs) as a contribution to their costs of establishing and delivering virtual ‘Integration Hubs’ to help coordinate skills and employment services within their localities. The Hubs launched in March 2022, and delivery of the first phase will be completed on 31 March 2025, in line with the current grant agreements. 
•    A research, innovation and marketing programme to identify ways to better connect Londoners to skills and job support opportunities, including production of a minimum viable product for this, and promotional activity. The Young Foundation was commissioned by the GLA through an open invitation to tender to explore the existing employment and skills support system and the needs of Londoners trying to navigate this system. Their report was released in July 2023 and its recommendations formed the basis of the design challenge aiming to identify innovative solutions to the issues identified in the research, building on and supporting the work of the Integration Hubs.
•    The Innovation Challenge, launched in quarter 4 of 2023-24 by the GLA, is delivered by Allia Impact who were awarded a contract for the provision of the innovation challenge service through an invitation to tender. Phase one funded 15 projects piloting innovative solutions to enhance collaborations across jobs and skills training sectors for various priority groups. Phase two of the challenge is being delivered between October 2024 and January 2025 and will support three of these pilots to scale up their prototype and access expert support to access new market. 
1.5    The programme has also funded a 0.5 Full-Time Equivalent GLA post in the last two years to oversee contract management of the Integration Hubs. 
1.6     The GLA has procured evaluation partner ICF, through an open invitation to tender, to measure the impact of the programme.
1.7    Interim evaluation findings indicate strong evidence of the Hubs undertaking activities that would not otherwise be happening, filling a gap and meeting a need. ‘They provide a good Return on Investment, especially in terms of savings to system and wider health and well-being outcomes associated with better integration.’
1.8    The Hubs are well established after 2.5 years of delivering activities and events. There is positive feedback from stakeholders on the hub model and the quality of hub delivery, especially from community organisations for which the hubs are providing a new route to engaging employment and skills funders. To date (September 2024), the hubs have engaged with over 4,700 partners and 8,900 residents, exceeding their targets. Support for people with disabilities has notably been a key area in which the hubs generally have been able to add value irrespective of whether this was a priority or not for them.
1.9     However their main challenge at the end of year two (March 2024) relates to sustainability. In its latest report, ICF recommends that ‘the GLA explores the potential for continued funding in order to sustain their activities in the medium term and to safeguard the capacity improvements from the programme so far.’
1.10    The final year evaluation report (March 2025) will provide an overall assessment of the achievements, challenges, and lessons of the programme, as well as recommendations for future policy and practice.
 

2.1    Extending the current phase of the programme to September 2025 will enable the Hubs to keep the momentum and capacity to build on their knowledge base, resource their core activities and work on sustaining their activities and funding model beyond the extension.
2.2    It will also enable the GLA to design the second phase of the NWD programme which will build on the success of the original programme and will be informed by the evaluation findings and feedback from programme partners and stakeholders. A future iteration of the programme will be part of the Inclusive Talent Strategy which is a key part of the London Growth Plan currently being developed. It is expected to be delivered as part of the Supporting Londoners to Benefit From Growth programme. 
Spending proposal 
Sustaining the Hub partnership 
2.3    GLA funding is provided to the hub partnerships as a contribution to the SRPs’ costs of resourcing staff to deliver activities. These activities have been ongoing since 2022 with strong, effective partnerships developed over the period. The evaluation report has evidenced that, with current funding due to end in March 2025, there is no clear path to the Hubs being self-sustaining yet in a recognisable form, and all Hubs have confirmed that without further funding from the GLA delivery will cease after March 2025. There is also a high risk that key staff on fixed term contracts will leave post as the end of their contract approaches, without the certainty of further funding. The impact of this would be substantial, risking the loss of key relationships, collaboration and partnerships. 
2.4    The GLA recognises that the SRPs need more time to adopt a different funding model that is not 100 per cent reliant on GLA funding. The final evaluation report is due in March 2025 and its conclusions and recommendations will help inform the future of the programme and provide a useful basis for discussion between the GLA and SRPs regarding the scope and funding of NWD phase two. At this stage, the most suitable option to meet the programme objectives of bringing together employment and skills providers, funders, and other public services in London, and avoid a gap in provision, is to continue funding the current Hubs for a short period of time.
2.5    Officers are therefore recommending that up to £298,000 from the 2025-26 Skills budget be made available for the award of extension funding to the four Integration Hubs, sustaining their activity through to September 2025 and securing continuity of the programme. This figure is based on the 2024-25 programme funding levels, noting that the 2024-25 overall programme funding is £555,000, whilst it is £500,000 for the financial year 2025-26.

2.6     In addition, over the next year officers also anticipate several central government reforms to the employment support landscape, including the forthcoming Department for Work and Pensions’ Back to Work whitepaper. It is therefore recommended that some of the funding ring-fenced for the Hubs extension could be used for any additional strategic planning, research or marketing requirements in response to these changes. Alternatively, some funding could be used to help embed key lessons from the NWD programme through research or piloting activities, for example. The exact amount will be defined at a later date and agreed via the applicable decision process (see para 2.9). In the event, that no funding is needed for this, the full £298,000 will be allocated to the four Integration Hubs.
Outputs targets
2.7     Hub funding is provided for staffing resource and other costs to deliver coordination activities between employers, service providers and residents. By the end of Q2 2024-25 (the most recent reporting period to date) the programme has engaged with over 4,700 partners and 8,900 residents through their activities, well exceeding the initial targets set for the programme.
2.8    If the extension is approved, GLA officers will engage in discussions with the Hubs to agree the targets for the six-month extension, following submission of a delivery plan.
2.9    Future NWD programme level decisions within the scope of this decision will, subject to the Mayor making the decisions sought, be delegated to the Assistant Director – Skills & Employment (Delivery) via an Assistant Director Decision form. This may include approval to receive and spend additional funds secured for the programme such as those requested from government, as well as approval to spend some of the funding towards additional strategic planning or research. 
 

3.1    Section 149(1) of the Equality Act 2010 provides that, in the exercise of their functions, public authorities must have due regard to the need to:
•    eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equality Act 2010
•    advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it
•    foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
3.2    Relevant protected characteristics are age, disability, gender re-assignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.
3.3    The Hub activities outlined in this decision have been focused on priority groups such as: residents from Black, Asian and minority ethnic communities, young people with low educational attainment or special educational needs & disabilities (SEND), residents with special needs or disabilities, women returning to work, and refugees. Hubs have notably produced ‘inclusive workplaces’ toolkits, provided ‘ability not disability’ training sessions to their partners, and organised job fairs for their care leave and refugee residents. These priority groups will continue to be supported throughout the Hubs for the period of the extension of phase 1. 
 

Links to Mayoral strategies
4.1    The programme aligns with commitments made in the Mayor’s Skills for Londoners (SfL) Strategy and the Skills Roadmap for London which set the direction of travel for adult education and skills in London in the last Mayoral term and beyond. In the Skills Roadmap for London, the Mayor committed to fostering a more integrated skills and employment system, including with other public services and support, through establishing the NWD Integration Hubs. 
4.2    The programme is expected to support the implementation of the Inclusive Talent Strategy and London Growth Plan by seeking to strengthen the ability of the eco-system to support Londoners to understand and access the opportunities that are available to them within the sectors key to London’s economic growth. It will also serve as a key intervention for the Supporting Londoners to Benefit From Growth programme.
4.3    No Wrong Door, which helps Londoners access the right support at the right time to help them into good work, plays a key role supporting objective eight of the Mayor’s Equality, Diversity & Inclusion Strategy, which aims to help Londoners at risk of marginalisation in the labour market to get the skills and support they need to secure good quality jobs.
Risks arising/mitigation
4.4    Key risks and mitigation measures are outlined below. This may be refined following further stakeholder engagement. 

Considerations for the provision of grant funding and subsidy control 
4.5     Under Element 1 of the proposals (see paragraphs 2.1 to 2.8, above) direct grant awards to the London Boroughs of Ealing, Richmond upon Thames, Redbridge and the City of London Corporation would be made to extend the delivery of their existing project activity under the No Wrong Door programme. All grant recipients were originally selected for the programme following an invitation to submit proposals to establish and manage the Integration Hubs. The Grant process was run in accordance with the GLA’s Contracts and Funding Code and awards approved by the Mayor under cover of MD2833.
4.6     It is proposed that the provision of additional sums to all organisations constitutes the award of grant funding, rather payment for services, because: 
•    the sums are a contribution to the costs of existing third-party (and not GLA) projects that align with the Mayor’s priorities, but are the initiatives of the third parties in question
•    the GLA will not receive any benefit as a result, with the benefits accruing instead to Londoners.
4.7    GLA officers have carried out an analysis of the proposals against the Statutory Guidance for the UK subsidy control regime.  They have assessed that the subsidy control regime does not apply in these circumstances because the proposed award of additional funding does not constitute a subsidy.
4.8    In particular, the grant awards fail to satisfy Limb B of the four-limbed test set out in the Subsidy Control Act 2022, as none of the organisations are classified as an enterprise. They are all local authorities, none of whose funded activity involves them engaging in economic activity to offer goods or services on a market. The funding will be used to enable the provision of activities such as free job fairs, networking events to Londoners, employers and service providers. 
Conflicts of interest
4.9     There are no conflicts of interest from those involved in the drafting or clearance of this decision form.
 

5.1    This report seeks approval for the expenditure of up to £298,000 grant funding to the Integration Hubs to extend their delivery by six months to 30 September 2025, allowing time for the development and commissioning of a second phase of the programme. The GLA may choose to use some of this budget for strategic planning.
5.2    This would be funded from the No Wrong Door programme (NWD) budget in the 2025-26 financial year. The expenditure of £298,000 from the NWD programme budget in 2025-26 is agreed in principle and subject to the outcome of the normal budget-setting process for the next financial year.
5.3    The NWD programme was originally approved under cover of MD2833 in 2021, with a further decision relating to UK Community Renewal match funding and GLA additional funding until 2025 approved under MD2916. Subsequent additional funding from the GLA and UK Shared Prosperity Funding to fund additional activities for the Integration Hubs was later approved under Director Decision (DD)2624 and Assistant Director Decision (ADD)2681.
5.4    Table 1 above in paragraph 2.5 sets out the funding split for phase one of the programme up to September 2025. 
 

6.1    The decisions requested of the Mayor fall within the general powers of the GLA (exercisable by the Mayor) in section 30 of the Greater London Authority Act 1999 (GLA Act) to do anything which it considers will further any one or more of its principal purposes. Those principal purposes include furthering the promotion of social and economic development in Greater London. Section 34 of the GLA Act also allows the Mayor to do anything which is calculated to facilitate, or is conducive or incidental to, the exercise of any functions of the GLA exercisable by the Mayor. In formulating the proposals in respect of which a decision is sought, officers have complied with the GLA’s related statutory duties to:
•    pay due regard to the principle that there should be equality of opportunity for all people under section 33 of the GLA Act
•    consider how the proposals will promote the improvement of health of persons, health inequalities between persons and to contribute towards the achievement of sustainable development in the United Kingdom under section 30(4) and (5) of the GLA Act
•    consult with appropriate bodies under section 32 of the 1999 Act.
6.2    In taking the decisions requested, the Mayor must have due regard to the Public Sector Equality Duty namely the need to: eliminate discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010; advance equality of opportunity and to foster good relations between persons who share a relevant protected characteristic (age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; and sexual orientation) and persons who do not share it (section 149 of the Equality Act 2010). To this end, the Mayor should have particular regard to section three (above) of this report.
6.3     Officers have confirmed that the provision of additional funding to the current No Wrong Door funding recipients may be viewed as a conditional gift rather than a payment for the provision of services. Section 12 of the Code provides that decisions to award grant funding should generally be made on the basis of the outcome of a transparent, competitive application process. However, the officers have set out at in paragraphs 2.3 and 4.5 above the reasons why it is proposed that the GLA provide additional funding to those bodies without further competition on this occasion. 
6.4    The Subsidy Control Act 2022 requires that grant funding be assessed in relation to its four-limbed test. Officers have made this assessment at paragraphs 4.5 to 4.8 and have a concluded that the additional funding proposed does not amount to an unlawful subsidy. 
6.5    The Mayor may delegate the exercise of the GLA’s powers to the Assistant Director, Skills & Employment (Delivery) as proposed pursuant to section 38 of the of GLA Act.    
6.6    If the Mayor makes the decisions sought officers must also ensure that:
•    no reliance is placed on nor commitments made in reliance of future budgets remaining subject to the outcome of the budget setting process for future financial years
•    the GLA’s current funding agreements with No Wrong Door funding recipients are varied in accordance with those agreements before any commitment to provide the additional funding is made or any funded activity commences
•    to the extent that any of the expenditure is to be incurred on GLA staffing matters, they comply fully with all applicable GLA HR protocols and related approvals are obtained.