“Effective Consultation”
A response from the Moore Adamson Craig Partnership to the Cabinet Office consultation paper on how the Government carries out consultations
7. What are the best methods of consultation?
We recognise the value of written consultations (question six) but we are also aware that, depending on whose views are being sought, there is a need in many circumstances for radically different approaches. We have worked with people who for reasons of educational attainment, age, culture, language or physical disability simple cannot respond meaningfully to formal written documents. Equally, there are many people who, although they are able to respond to a written document find it much more productive to engage in a verbal discussion or receive information in different forms. This inevitably means that extra resources are required in the form of skilled people to attend events, facilitate meetings and/or talk to individuals.
Our experience has shown us that public meetings are seldom well attended (even when considerable efforts are made to provide them in the “right place” or at the “right time”) unless there is a very clear focus and the issue under discussion is thought by the public/users to have an immediate and direct (and usually negative) impact upon them. Although such meetings may provide the organisation with an opportunity to address issues of concern, they are not the best way to find out what the generality of people really think and can be easily hijacked by interest groups whose views are often already well-known to the organisation. Meetings of this sort can often be counter-productive if not carefully facilitated as they can create or reinforce scepticism within organisations about the whole value and purpose of public engagement. Working with pre-existing groups (with whom ideally the organisation already has a positive working relationship) is usually the most productive and cost effective way of seeking views.
Specific efforts may need to be made to engage with particular individuals who may not be organised into pre-existing groups, those sometimes described as “the hard to reach”. We are aware of many different ways in which this can be done including peer appraisal, focus groups, electronic reference groups etc. An example of where the peer appraisal approach was used very successfully was as part of a qualitative study published by the Greater Glasgow Health Board in 2005: Supporting New Communities. Reaching “the hard to reach” is a time-consuming and often expensive process but some of this cost can be mitigated if ways can be found of sustaining contact over time so that the organisation is not always “starting from scratch” and by working with the group to help build their capacity to respond through training, practical support or funding. Our work with NHS Quality Improvement Scotland highlighted the extent to which such bodies would welcome help with this sort of capacity building and the opportunity to develop a constructive two-way relationship.
8. The options
We believe that the Code of Practice should be retained for the present as organisations are still developing their work around it and it provides a useful framework. It provides a point of reference for any organisation which is challenged legally or otherwise over its approach to consultation. We would support the idea of encouraging (although not necessarily requiring) organisations to consider other approaches and the sharing of good practice. Guidance on the cost-effectiveness of different approaches would also be useful.
Although we recognise the reasons why organisations may occasionally wish to fast-track a consultation process, we believe that at present a shortening of timescales is likely to lead to many consultation exercises being inappropriately shortened for the convenience of the organisation involved and to the detriment of effective and inclusive consultation. Issues around monitoring when a consultation period should be made shorter (or longer) than the 12 week period could become the remit of an independent Consultation Ombudsman.
We do not think that replacing the Code of Practice with a principled approach would be helpful to organisations nor lead to better engagement with the public and users at this stage. Although we are well aware that there are important issues of principle which need to guide consultations (and which we suspect are as yet to be fully grasped by many organisations), the Code of Practice and practical guidance are still essential to most organisations in getting them to take consultation seriously and to run meaningful and effective consultations. The Code would be enhanced by being associated with a vigorous programme of learning based on assessment of the cost of any consultation and how it met its stated goals of inclusion and timeliness.
9. Effective data analysis
One further point which we would like included in the definition of effectiveness is an agreed methodology of comment presentation and analysis. A very structured questionnaire may result in data which is relatively easy to analyse but such questionnaires are often seen as very limiting – the questions answered are those the originating consulting organisation thought fit to include and so may miss important points entirely. Discursive text based answers to written consultation increases the difficulties of analysing responses and this can become a very subjective process. There are some data analysis processes and techniques which begin to address this issue but we would like to see further work done to ascertain the best approach and create a transparent way of assessing the balance of opinion. Phrases such as 'On the whole, responses were positive' need some underpinning and a reference to evidence.
Caroline Millar and Colin Adamson
Partners
Moore Adamson Craig Partnership
28 September 2007