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Initial learning from the
government’s response to
the COVID-19 pandemic
Cross-government

                              REPORT
                              by the Comptroller
                              and Auditor General

                              SESSION 2021-22
                              19 MAY 2021
                              HC 66
We are the UK’s                       We support Parliament
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In 2019, the NAO’s work led to a positive financial impact
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Initial learning from the
government’s response to
the COVID-19 pandemic
Cross-government

Report by the Comptroller and Auditor General
Ordered by the House of Commons
to be printed on 17 May 2021
This report has been prepared under Section 6 of the
National Audit Act 1983 for presentation to the House of
Commons in accordance with Section 9 of the Act

Gareth Davies
Comptroller and Auditor General
National Audit Office
13 May 2021

HC 66 | £10.00
Lessons learned reports
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                               010746    05/21   NAO
Contents                                                                                       This report can be found on the
                                                                                                                                   National Audit Office website at
                                                                                                                                   www.nao.org.uk
                                                                                                                                   If you need a version of this
                                                                                                                                   report in an alternative format
                                                                                                                                   for accessibility reasons, or
                                                                                                                                   any of the figures in a different
                                    Foreword by the Comptroller                                                                    format, contact the NAO at
                                    and Auditor General 4                                                                          enquiries@nao.org.uk

                                    Summary of learning 6

                                    Introduction 8

                                    Risk management 12
                                                                                                                                   The National Audit Office study
                                                                                                                                   team consisted of:
                                    Transparency and public trust 16
                                                                                                                                   Leon Bardot, Heather James,
                                    Data and evidence 19                                                                           John Fellows, Pauline Ngan
                                                                                                                                   and Alberto Vanzo under the
                                    Coordination and delivery models 23                                                            direction of Sian Jones.

                                    Supporting and protecting people 27

                                    Financial and workforce pressures 30

                                    Appendix One 34

                                    Appendix Two 37

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4 Foreword Initial learning from the government’s response to the COVID-19 pandemic

Foreword by the Comptroller
and Auditor General

The scale and nature of the COVID-19 pandemic              The COVID-19 pandemic has stress-tested the
and the government’s response are without                  government’s ability to deal with unforeseen events
precedent in recent history. The pandemic continues        and potential shocks. Government has often acted
to be a major challenge for government, public             at unprecedented speed to respond to a virus which
sector bodies, as well as people across the UK and         has caused dramatic disruption to people’s lives,
worldwide. Many people have died, and many lives           public service provision and society as a whole.
have been adversely affected. The overall long-term        Government had to continue to deliver essential
impact and cost of the pandemic remains uncertain          public services, while reprioritising resources to
but will be substantial.                                   deliver its response to the COVID-19 pandemic and
                                                           supporting staff to work from home. In its response,
To date, the National Audit Office (NAO) has
                                                           government has had to streamline decision-making,
published 17 reports focusing on key parts of the
                                                           work across departments and public bodies and
response where there is scope for government to
                                                           use a range of delivery structures. Departments will
learn lessons from this experience about how it does
                                                           need to reflect on the lessons learned to ensure that
and should operate. This report brings together our
                                                           they capitalise on the benefits and opportunities
initial thoughts on this learning across six themes:
                                                           these new ways of working have brought.
•    risk management;
                                                           While the response to the pandemic has provided
•    transparency and public trust;                        new learning from both what has worked well and
                                                           what has not worked well, it has also laid bare
•    data and evidence;                                    existing fault lines within society, such as the risk
                                                           of widening inequalities, and within public service
•    coordination and delivery models;
                                                           delivery and government itself. The relationship
•    supporting and protecting people; and                 between adult social care and the NHS, workforce
                                                           shortages, the challenges posed by legacy data and
•    financial and workforce pressures.                    IT systems, and the financial pressure felt by parts
                                                           of the system all require long-term solutions.
Initial learning from the government’s response to the COVID-19 pandemic Foreword 5

The challenges posed by the pandemic have                   This report provides our initial thoughts on the
highlighted the importance for government of                learning government can draw from its response to
adopting a systematic approach to preparing for             date, based on fieldwork which was mostly carried
high‑impact events, evaluating its performance              out in 2020. We aim to refine this thinking as we
frequently, and acting quickly on learning                  continue our work. Government will recognise
points while adhering to required standards of              and has already acted on some of these learning
transparency and accountability even in emergencies.        points, but given their importance, we reiterate
This goes beyond meeting legal (or audit)                   them in this report. These issues, as well as more
requirements. It involves adhering to the standards         recent developments in the government’s pandemic
that government has set for itself to maintain and          response, will be further explored in our future work.
strengthen public trust. Also, if government can            And we will continue to draw out lessons from the
build resilience into systems and delivery chains,          government’s response to the pandemic to support
and develop consistently robust horizon scanning,           its own evaluation of its performance and provide
risk management and operational management                  Parliament and the public with timely reporting for
capabilities across government, this will help it to cope   accountability and learning.
better with future emergency responses while also
improving business-as-usual activities.
                                                            Gareth Davies
6 Summary of learning Initial learning from the government’s response to the COVID-19 pandemic

Summary of learning

We have identified learning for government from its
initial response to the COVID-19 pandemic across
six themes. Our main messages across these six
themes are set out below.

  Risk management
                             Identifying the wide-ranging consequences of major emergencies and developing playbooks for
                             the most significant impacts.

                             Being clear about risk appetite and risk tolerance as the basis for choosing which trade-offs
                             should be made in emergencies.

  Transparency
  and public trust           Being clear and transparent about what government is trying to achieve, so that it can assess
                             whether it is making a difference.

                             Meeting transparency requirements and providing clear documentation to support
                             decision-making, with transparency being used as a control when other measures, such as
                             competition, are not in place.

                             Producing clear and timely communications.

  Data and evidence
                             Improving the accuracy, completeness and interoperability of key datasets and sharing them
                             promptly across delivery chains.

                             Monitoring how programmes are operating, forecasting changes in demand as far as possible,
                             and tackling issues arising from rapid implementation or changes in demand.

                             Gathering information from end-users and front-line staff more systematically to test the
                             effectiveness of programmes and undertake corrective action when required.
Initial learning from the government’s response to the COVID-19 pandemic Summary of learning 7

Coordination and
delivery models        Ensuring that there is effective coordination and communication between government
                       departments, central and local government, and private and public sector bodies.

                       Clarifying responsibilities for decision-making, implementation and governance, especially where
                       delivery chains are complex and involve multiple actors.

                       Integrating health and social care and placing social care on an equal footing with the NHS.

                       Balancing the relative merits of central, universal offers of support against targeted local support.

Supporting and
protecting people      Understanding to what extent the pandemic and government’s response have widened
                       inequalities, and taking action where they have.

                       Providing appropriate support to front-line and other key workers to cope with the physical,
                       mental and emotional demands of responding to the pandemic.

Financial and
workforce              Placing the NHS and local government on a sustainable footing, to improve their ability to
pressures              respond to future emergencies.

                       Ensuring that existing systems can respond effectively and flexibly to emergencies, including
                       provision for spare or additional capacity and redeploying staff where needed.

                       Considering which COVID-19-related spending commitments are likely to be retained
                       for the long term, and what these additional spending commitments mean for long-term
                       financial sustainability.
8 Introduction Initial learning from the government’s response to the COVID-19 pandemic

Introduction

1    In May 2020, the National Audit Office (NAO)                        2     The NAO’s reports on the government’s
published its first report on the government’s                           response to the COVID-19 pandemic cover many
response to the pandemic, an Overview of the                             of the key programmes, such as the employment
UK government’s response to the COVID-19                                 support schemes (the Coronavirus Job Retention
pandemic. We noted that this report would help                           Scheme and the Self-Employment Income Support
identify a risk‑based series of descriptive and                          Scheme), the Bounce Back Loan Scheme, NHS Test
evaluative reports where government faced                                and Trace, and the supply of personal protective
particular challenges and there was most to learn.                       equipment, as well as more cross-cutting themes
Since then we have published a further 16 reports                        such as procurement during the pandemic and
on the government’s response to the COVID-19                             local government finance. A full list of our reports
pandemic, as well as regularly updating the                              is provided in Appendix One and a list of the
estimated costs of the government’s response                             recommendations from these reports is provided
on our website.1                                                         in Appendix Two. By the end of April 2021, the
                                                                         Committee of Public Accounts had held sessions on
                                                                         16 out of the 17 reports we published. Appendix One
                                                                         also provides a list of the Committee’s COVID-19
                                                                         reports that had been published by 1 May 2021.

1   All of the reports are available on the dedicated COVID-19 section
    of our website at: www.nao.org.uk/about-us/covid-19/ and the cost
    tracker is available at: www.nao.org.uk/covid-19/cost-tracker/
Initial learning from the government’s response to the COVID-19 pandemic Introduction 9

3      By the end of March 2021, the estimated            4     This report draws out learning from the reports
lifetime cost of measures announced as part               that we have published to date, as well as other
of the government’s response was £372 billion             work we have published that covered the COVID-19
(Figure 1 on page 10). The largest programmes,            pandemic, such as our good practice guides on
by estimated lifetime cost, are the Coronavirus Job       fraud and error and operational delivery,2 our report
Retention Scheme (£62 billion), NHS Test and Trace        on The adult social care market in England,3 and our
(£38 billion) and self-employment income support          Departmental Overview 2019-20: Department for
(£27 billion). Figure 2 on page 11 highlights the         Work & Pensions.4 It sets out this learning across
estimated lifetime costs by lead department, with the     six themes:
highest-spending departments being HM Revenue
& Customs (£111 billion), the Department of Health        •     risk management;
& Social Care (£92 billion) and the Department for        •     transparency and public trust;
Business, Energy & Industrial Strategy (£59 billion).
                                                          •     data and evidence;

                                                          •     coordination and delivery models;

                                                          •     supporting and protecting people; and

                                                          •     financial and workforce pressures.

                                                          We will continue to draw out learning from the
                                                          government’s response to the pandemic from
                                                          our future work.

                                                          2   National Audit Office, Good practice guidance: Fraud and error,
                                                              March 2021, available at: www.nao.org.uk/report/good-practice-
                                                              guidance-fraud-and-error/ and National Audit Office, Improving
                                                              operational delivery in government: A good practice guide for senior
                                                              leaders, March 2021, available at: www.nao.org.uk/report/managing-
                                                              operations-senior-leaders-guide/
                                                          3   Comptroller and Auditor General, The adult social care market in
                                                              England, Session 2019–2021, HC 1244, March 2021, available at:
                                                              www.nao.org.uk/report/adult-social-care-markets/
                                                          4   National Audit Office, Departmental Overview 2019-20:
                                                              Department for Work & Pensions, October 2020, available at:
                                                              www.nao.org.uk/report/departmental-overview-2019-20-department-
                                                              for-work-pensions/
10 Introduction Initial learning from the government’s response to the COVID-19 pandemic

Figure 1
Breakdown of the estimated lifetime costs of the government’s response to the COVID-19 pandemic
by programme, March 2021
The programmes highlighted in this diagram accounted for 79% of the estimated cost of the government’s response announced up to
31 March 2021

                                                                 Coronavirus
                                                                Job Retention
                                                                  Scheme
                             VAT measures4                                               NHS Test
                                                                    £62bn                and Trace
                             £10bn
                                                                                           £38bn
                         Vaccines
                         £10bn                                                                                       Self-employment
                                                                                                                     income support
                                                                                                                     £27bn
          Universal Credit
          £10bn
                                                             Total estimated
                                                              lifetime cost                                              Devolved administrations
         Further health                                          £372bn                                                  £26bn
         services spend
         £14bn

                                                                                                                   Bounce Back Loan Scheme
     Business grant funding     3                                                                                  £23bn
     £18bn

                                                                                                     Business rates measures
                     Rail and bus measures                                                           £21bn
                     £18bn

                                                                   Personal protective equipment
                                                                   £18bn

    Support for businesses
    Support for health and social care
    Support for individuals
    Support for other public services and emergency responses

Notes
1   Figures are rounded to the nearest billion.
2   The area of each bubble is proportional to the estimated cost of the programme.
3   Business grant funding includes the Closed Business Lockdown Payment, the Innovate UK Business Support Package, the Retail, Hospitality
    and Leisure Grant Fund and the Small Business Grant Fund.
4   VAT measures include reduced VAT rates and VAT deferrals, except for the temporary VAT zero rate on personal protective equipment, which
    has been included in the personal protective equipment measures.
5   The programmes shown in this diagram account for £294 billion of the estimated lifetime costs of the government’s response. The remaining
    cost (£78 billion) relates to support for individuals, businesses, health and social care, and other public services and emergency responses.

Source: National Audit Office COVID-19 cost tracker
Initial learning from the government’s response to the COVID-19 pandemic Introduction 11

Figure 2
Breakdown of the estimated lifetime costs of the government’s response to the COVID-19 pandemic
by lead department, March 2021
HM Revenue & Customs, the Department of Health & Social Care and the Department for Business, Energy & Industrial Strategy
accounted for 70% of the estimated costs of the government’s response announced up to 31 March 2021

                                                                HM Revenue
                                                                 & Customs
                                                                    £111bn

        Other lead departments
        £12bn                                                                                   Department of
                                                                                              Health & Social Care
                                                                                                       £92bn

      Ministry of Housing,
      Communities &
      Local Government                                      Total estimated
      £11bn                                                  lifetime cost
                                                                £372bn
                                                                                                                     Department for Business,
                                                                                                                     Energy & Industrial Strategy
                                                                                                                     £59bn
    Department for Transport
    £18bn

                                                                                              HM Treasury
                               Department for
                                                                                              £46bn
                               Work & Pensions
                               £21bn

Notes
1   Figures are rounded to the nearest billion.
2    The area of each bubble is proportional to the estimated cost response by each lead department.
3    Spend on responses may not appear in a lead department’s accounts. For example, HM Treasury is the lead department for support
     to the devolved administrations (£26 billion). However, these items appear in the accounts of other government departments.

Source: National Audit Office COVID-19 cost tracker
12 Risk management Initial learning from the government’s response to the COVID-19 pandemic

Risk management

                                                           5     The government’s response to the COVID-19
 Learning                                                  pandemic aims to protect people from exposure
                                                           to the virus, ensure that those infected are cared
                                                           for and mitigate damage to the economy. As well
            Identifying the wide‑ranging                   as ongoing risks, such as those related to exiting
            consequences of major                          the EU, government has had to manage the risks
            emergencies and                                generated by the pandemic and the risks associated
   developing playbooks for the                            with its own response measures. The pandemic and
   most significant impacts.                               government’s response so far have highlighted the
                                                           importance of carrying out robust risk planning and
                                                           being clear about risk appetite and risk tolerance as
              Being clear about
                                                           the basis for choosing which trade-offs should be
              risk appetite and risk                       made in emergencies.
              tolerance as the basis for
   choosing which trade-offs should be
                                                               Risk planning
   made in emergencies.
                                                                         Identifying the wide-ranging
                                                                         consequences of major emergencies
                                                                         and developing playbooks for the
                                                                         most significant impacts.

                                                           6    Government lacked a playbook for many
                                                           aspects of its response. For example, pre-existing
                                                           pandemic contingency planning did not include
                                                           detailed plans for:

                                                           •     identifying and supporting a large population
                                                                 advised to shield. The testing of plans and
                                                                 policies for the identification and shielding of
                                                                 clinically extremely vulnerable (CEV) people
                                                                 were not objectives of Exercise Cygnus, an
                                                                 exercise carried out in 2016 to assess the UK’s
                                                                 preparedness for an influenza pandemic;
Initial learning from the government’s response to the COVID-19 pandemic Risk management 13

                                                            •     managing mass disruption to schooling on the
Key facts from our published work                                 scale caused by COVID-19. The Department
                                                                  for Education’s emergency response function
19                                                                was designed to manage disruptions due to
                                                                  localised events such as floods.
Ministerial directions
published in 2020                                           No playbook can cover all the specific circumstances
                                                            of every potential crisis. Nevertheless, more detailed
                                                            planning for the key impacts of a pandemic and

35% to 60%                                                  of other high-impact low-likelihood events can
                                                            improve government’s ability to respond to future
Estimated percentage of loans                               emergencies. It may also bring other benefits,
                                                            such as creating new relationships and improving
from the Bounce Back Loans
                                                            understanding between organisations.
Scheme that may not be repaid

                                                                Risk appetite and trade-offs from
5% to 10%                                                       acting quickly

                                                                             Being clear about risk appetite
HM Revenue & Customs’
                                                                             and risk tolerance as the basis for
planning assumption for the
                                                                             choosing which trade-offs should
percentage of payments from
                                                                             be made in emergencies.
the Coronavirus Job Retention
Scheme that were due to
fraud and error                                             7     Once the scale of the COVID-19 outbreak in
                                                            the UK became apparent, the government made
                                                            several rapid, large-scale spending decisions and
•    employment support schemes. Instead,                   implemented some measures at pace. For example,
     HM Treasury and HM Revenue & Customs                   the food box deliveries for CEV people were up and
     (HMRC) told us they drew on economic                   running within days of being announced. In a matter
     contingency planning designed for financial            of weeks, personal protective equipment (PPE) and
     rescues, developed following the credit crisis;        ventilator procurement were set up, employment
     draft policy work on wage subsidy schemes;             support and business loan schemes were up and
     and lessons learned from other countries, such         running, and the campaigns to house rough sleepers
     as Germany;                                            and deliver school meal vouchers were designed
                                                            and implemented. Government was also quick
•    financial support to local authorities, such as        to announce unringfenced funding (£3.2 billion
     mechanisms for compensating authorities                between March 2020 and April 2020) to help local
     for a fall in income. The Ministry of Housing,         authorities address the financial pressures caused
     Communities & Local Government (MHCLG)                 by the pandemic.
     told us it had stress-tested its response to an
     economic shock as part of its contingency
     planning. However, the economic impact of
     the pandemic exceeded the economic shock
     assumed for this stress-testing; and
14 Risk management Initial learning from the government’s response to the COVID-19 pandemic

8     To enable speed of action, government relaxed                             •      The Department for Business, Energy &
controls and streamlined spending approvals,                                           Industrial Strategy (BEIS), in conjunction with
recognising that this would lead to an increased risk                                  the British Business Bank (the Bank), has
of fraud and error:                                                                    estimated that between 35% and 60% of
                                                                                       loans from the Bounce Back Loans Scheme
•      In designing employment support schemes,
                                                                                       may not be repaid, and this represents both
       HMRC acknowledged that it would need to
                                                                                       credit and fraud risks. In March 2021, the
       make certain trade-offs between its normal
                                                                                       estimated value of these loans was between
       approach of preventing as much fraud and
                                                                                       £16 billion and £27 billion based on loans
       error as possible and ensuring grants reached
                                                                                       to date. BEIS and the Bank are working on
       claimants quickly. HMRC drew up longlists
                                                                                       estimating what proportion is due to fraud.
       of potential controls for both schemes. In
       total it identified 42 potential controls for the                        •      By January 2021, the Department of Health &
       Coronavirus Job Retention Scheme (CJRS),                                        Social Care (DHSC) had spent £10.2 billion on
       of which 24 were implemented by the go-live                                     PPE, with an estimated lifetime cost of around
       date and 57 for the Self-Employment Income                                      £15.2 billion. The Government Counter Fraud
       Support Scheme (SEISS), of which 38 were                                        Function has assessed a high risk of fraud
       delivered by the end of April 2020. HMRC’s                                      in the procurement of PPE. DHSC has yet to
       planning assumptions were that between                                          estimate the size of this potential fraud.
       5% and 10% of payments from the CJRS
                                                                                While some controls were relaxed, the overall
       and between 1% and 2% of payments from
                                                                                framework set out in Managing Public Money has
       the SEISS were due to fraud and error. In
                                                                                remained in place throughout the pandemic as the
       September 2020, this amounted to between
                                                                                basis on which accounting officers should make
       £2 billion and £3.9 billion for the CJRS and
                                                                                decisions to ensure that public funds are used in
       between £130 million and £270 million for
                                                                                the public interest.
       the SEISS.
                                                                                9    Government accepted other trade-offs from
•      The number of Universal Credit claimants
                                                                                acting quickly, such as paying higher prices for
       roughly doubled in 2020 and the Department
                                                                                goods than it would have paid before the pandemic.
       for Work & Pensions (DWP) suspended some
                                                                                For example, DHSC experienced increasing global
       controls such as face-to-face appointments
                                                                                competition to buy ventilators and made purchases
       to support vulnerable people during lockdown
                                                                                primarily on the offer’s credibility, not price. It also
       and manage demand. Of Universal Credit
                                                                                paid high prices for PPE because of the global surge
       payments, £1.7 billion (9.4%) were overpaid in
                                                                                in demand for these goods and export restrictions in
       2019-20 before COVID-19. DWP accepts that
                                                                                some countries.
       the increased caseload and easements made
       to the process of applying for benefits will lead
       to a further increase in fraud and error levels.

Post publication this page was found to contain an error which has been corrected (Please find Published Correction Slip)
Initial learning from the government’s response to the COVID-19 pandemic Risk management 15

10 Government focused on getting some
                                                                             Figure 3
programmes up and running quickly, recognising
                                                                             Ministerial directions published in 2020
that they may need to be amended as they went.
For instance, due to limitations in the datasets
available, initially some 870,000 CEV people were                                                                   10        COVID-19-related,
                                                                                                                              at least partly on
                                                                                                                              value-for-money
identified centrally as eligible for support to help
                                                                                                                              grounds
them shield. A further 420,000 were identified
as eligible by 12 April 2020 and another 900,000
people by 7 May 2020. When the Bounce Back
Loan Scheme was launched on 4 May 2020
                                                                                                                    4         COVID-19-related
                                                                                                                              on other grounds
                                                                                                                              (for example, breach
(seven days after it was announced), the Bank                                                                                 of spending limits)
had a reporting portal for lenders, but this

                                                                                                                    5
required manual data entry for each application.                                                                              Not related
An automatic reporting functionality was introduced                                                                           to COVID-19

in mid-June 2020. Governance arrangements of
some programmes were also redesigned during                                  Notes
the response (for example, see paragraph 30).                                1   Six ministerial directions were published in 2019 (four on
                                                                                 value-for-money grounds).
                                                                             2   The total does not include the Prime Minister’s Personal Minute
11   Some departments made good use of                                           issued to the Cabinet Office Permanent Secretary on 28 June 2020
ministerial directions to proceed with programmes                                to authorise an exit payment.

where they lacked assurance over value for money.                            3   The ministerial directions have been categorised by the National Audit
                                                                                 Office. The categorisation has not been agreed with HM Treasury.
Due to the speed at which programmes were being
implemented, accounting officers could not gain                              Source: National Audit Office analysis of GOV.UK data

assurance over the value for money of several
COVID-19 response measures. These included the
Bounce Back Loan Scheme, the Local Authority
Discretionary Grants Fund and the Retail, Hospitality
and Leisure Business Grants Fund. As prescribed by
Managing Public Money, some accounting officers
obtained directions from ministers to proceed with
these programmes. In 2020, 19 ministerial directions
were published, compared with an average of five
per year between 2017 and 2019 (Figure 3).5

5   Ministerial directions are formal instructions from ministers telling
    their department to proceed with a spending proposal, despite an
    objection from their permanent secretary. Permanent secretaries, who
    are directly accountable to Parliament for how the department spends
    its money, have a duty to seek a ministerial direction if they think a
    spending proposal breaches any of the following criteria: regularity
    (if the proposal is beyond the department’s legal powers, or agreed
    spending budgets); propriety (if it does not meet “high standards of
    public conduct”, such as appropriate governance or parliamentary
    expectations); value for money (if something else, or doing nothing,
    would be cheaper and better); and feasibility (if there is doubt about
    the proposal being “implemented accurately, sustainably or to the
    intended timetable”).
16 Transparency and public trust Initial learning from the government’s response to the COVID-19 pandemic

Transparency and public trust

                                                            12 In responding to a new virus and global
 Learning                                                   pandemic, government faced exceptionally
                                                            challenging circumstances. The public sector
                                                            has needed to respond in unprecedented ways
             Being clear and transparent                    while seeking to maintain and build public trust.
             about what government is                       Central to this is setting clear objectives, being
             trying to achieve, so that                     transparent about what actions were taken and
   it can assess whether it is making                       why, the trade‑offs being made, and providing clear,
   a difference.                                            consistent and timely communications.

                                                              Objectives
           Meeting transparency
           requirements and providing                                     Being clear and transparent about
           clear documentation to                                         what government is trying to achieve,
           support decision-making,                                       so that it can assess whether it is
   with transparency being used as a                                      making a difference.
   control when other measures, such
   as competition, are not in place.
                                                            13 Detailed objectives help to ensure that
                                                            the success of programmes can be measured.
                Producing clear and                         For example, HM Revenue & Customs (HMRC)
                timely communications.                      agreed clear principles for its employment support
                                                            schemes, including that the claim process should
                                                            be simple and the grant calculation straightforward.
                                                            Although the Bounce Back Loans Scheme achieved
                                                            its initial objective of quickly supporting small
                                                            businesses, a lack of more detailed scheme‑specific
                                                            objectives will make it difficult to measure its
                                                            ultimate success.
Initial learning from the government’s response to the COVID-19 pandemic Transparency and public trust 17

Key facts from our published work                          Evidence to support decision-making

148                                                                    Meeting transparency requirements
                                                                       and providing clear documentation
                                                                       to support decision-making, with
New guidance documents and
                                                                       transparency being used as a control
updates to existing material
                                                                       when other measures, such as
published by the Department                                            competition, are not in place.
for Education between
16 March and 1 May 2020
                                                          14 Transparency, including a clear audit trail to
                                                          support key decisions, is a vital control to ensure

25%                                                       accountability, especially when government is having
                                                          to act at pace and other controls (for example,
Percentage of contracts                                   competitive tendering) are not in place. On the
with a value over £25,000                                 ventilator programmes, we found sufficient record
awarded in response to the                                of the programmes’ rationale, the key spending
                                                          decisions taken, and the information departments
pandemic up to 31 July 2020
                                                          had to base those on. However, in the procurement of
where the contract awards
                                                          personal protective equipment (PPE) and other goods
were published within the
                                                          and services using emergency direct awards during
90-day target                                             the pandemic, we and the Government Internal
                                                          Audit Agency found that there was not always a

0.07%                                                     clear audit trail to support key decisions, such as
                                                          why some suppliers which had low due diligence
                                                          ratings were awarded contracts. HMRC initially
Spend on communication as
                                                          ruled out publishing the details of every company
a percentage of government’s
                                                          claiming furlough payments, which might have
expected total investment in
                                                          alerted some employees that their employer was
purchasing and manufacturing                              acting fraudulently.
COVID-19 vaccines for
the UK, deploying them in                                 15 We found that many of the contracts awarded
England and supporting global                             during the pandemic had not been published
efforts to find vaccines as at                            on time. Of the 1,644 contracts awarded across
                                                          government up to the end of July 2020 with a
8 December 2020 (£8 million
                                                          contract value above £25,000, 75% were not
out of £11,702 million)
                                                          published on Contracts Finder within the 90-day
                                                          target and 55% had not had their details published
                                                          by 10 November 2020. The Cabinet Office and
                                                          DHSC acknowledged the backlog of contract details
                                                          awaiting publication and noted that resources
                                                          were now being devoted to this, having earlier
                                                          been prioritised on ensuring procurements were
                                                          processed so that goods and services could be
                                                          made available for the pandemic response.
18 Transparency and public trust Initial learning from the government’s response to the COVID-19 pandemic

                                                            17 Communications from government were not
    Communications and public engagement                    always clear and timely. For example:

               Producing clear and                          •     guidance on PPE (issued jointly by DHSC,
               timely communications.                             Public Health England and NHS England &
                                                                  NHS Improvement) changed 30 times up to
                                                                  31 July 2020, including material and relatively
                                                                  minor changes. While frequent updates were
16 Effective communication and public
                                                                  needed to reflect an increased understanding
engagement are crucial to ensuring that COVID-19
                                                                  of a new virus and a rapidly changing policy
response programmes succeed. Effective
                                                                  position, social care representatives raised
communication helps achieve policy objectives
                                                                  concerns about the guidance, including that the
and strengthens public trust by helping the public
                                                                  frequency of changes made it confusing; and
understand what the government is doing, why,
and what it means for them and their communities.           •     the Department for Education calculated
                                                                  that, between 16 March and 1 May 2020, it
•     In our work, we found examples of effective,
                                                                  published 148 new guidance documents and
      clear and consistent communications.
                                                                  updates to existing material. Stakeholders told
      For instance, HMRC developed a range of
                                                                  us that guidance was often published at the
      communication and engagement plans for
                                                                  end of the week or late in the evening, putting
      its employment support schemes. It notified
                                                                  schools under pressure, especially when
      self-assessment taxpayers that they may have
                                                                  guidance was for immediate implementation.
      been eligible for the Self-Employment Income
                                                                  When the guidance was updated, schools were
      Support Scheme, reached out to some of the
                                                                  not always clear what changes had been made.
      largest employers to check if they intended
      to apply for the Coronavirus Job Retention
      Scheme, and worked with ethnic minority
      and faith‑based organisations to publicise
      the schemes.

•     Despite government advertising and
      communications relating to NHS Test and
      Trace, reported levels of non‑compliance with
      self-isolation requirements were high.

•     DHSC has acknowledged variation in the
      public’s perception of COVID-19 vaccines,
      with some groups more hesitant than others.
      Designing effective targeted communications
      will be important if the optimum level of
      vaccine take-up is to be achieved.
Initial learning from the government’s response to the COVID-19 pandemic Data and evidence 19

Data and evidence

                                                   18 The insight generated through reliable data
Learning                                           is crucial to the way government delivers services
                                                   for citizens, improves its systems and processes,
                                                   and makes decisions. Our work has repeatedly
             Improving the accuracy,               emphasised the importance of evidence-based
             completeness and                      decision-making at all levels of government
             interoperability of key               activity and the problems that arise when data are
 datasets and sharing them promptly                inadequate. The pandemic has again highlighted
 across delivery chains.                           the role of high-quality data in enabling effective
                                                   service delivery, monitoring and improvement.
                                                   It has generated new datasets and data collection
         Monitoring how programmes                 processes that can be used to inform future
         are operating, forecasting                service delivery.
         changes in demand as far as
 possible, and tackling issues arising               Accuracy, completeness and sharing
 from rapid implementation or changes                of data
 in demand.
                                                                    Improving the accuracy,
                                                                    completeness and interoperability
          Gathering information from
                                                                    of key datasets and sharing them
          end-users and front-line
                                                                    promptly across delivery chains.
          staff more systematically
          to test the effectiveness of
 programmes and undertake corrective               19 Timely sharing of data has been vital for
 action when required.                             providing front-line services and managing the
                                                   response at the national level. For instance, while
                                                   the Department of Health & Social Care (DHSC) and
                                                   the Cabinet Office ran their programmes to increase
                                                   the number of ventilators separately, they worked
                                                   toward the same overall targets and exchanged
                                                   progress data daily. The Ministry of Housing,
                                                   Communities & Local Government (MHCLG)
                                                   introduced a monthly survey of cost pressures and
                                                   income losses experienced by local authorities
                                                   due to the pandemic. Despite some data quality
                                                   issues, it provided an important dataset that several
                                                   departments have used to shape their responses.
20 Data and evidence Initial learning from the government’s response to the COVID-19 pandemic

                                                           20 However, timely sharing of data has not always
Key facts from our published work                          occurred, and legacy IT issues remain challenging:

95%                                                        •     NHS Test and Trace (NHST&T) publishes a
                                                                 large volume of data every week which helps
                                                                 understand the progress of COVID-19 and
Proportion of Self-Employment                                    tracing performance (Figure 4). However, local
Income Support Scheme                                            authorities did not initially have access to all
claimants who were satisfied                                     the NHST&T data they needed to deliver their
or very satisfied with their                                     local pandemic response.
experience up to August 2020
                                                           •     By 22 March, when shielding was
                                                                 announced, 870,000 people had been

815,000                                                          identified centrally as clinically extremely
                                                                 vulnerable (CEV). It took three weeks to identify
Number of clinically extremely                                   and communicate with a further 420,000 CEV
vulnerable people whose                                          people. This was largely down to the challenge
details were passed to local                                     of extracting usable data from different NHS
authorities to check if these                                    and GP IT systems.
people needed help
                                                           Figure 4

375,000
                                                           Estimated number of people in England
                                                           infected with COVID-19, receiving positive tests,
                                                           transferred to the tracing service and reached
Number of clinically
                                                           by NHS Test and Trace
extremely vulnerable
people who were sent                                                                                    People with COVID-19
                                                                           1,943,000
letters advising them to                                                                                (estimated)
shield but did not receive a
follow-up call due to missing                                                           Tested positive by
                                                                           44%
                                                                                        NHS Test and Trace
or inaccurate telephone
numbers provided in                                                                    Transferred
                                                                           39%
NHS patient records                                                                    to tracing

                                                                                     Successfully
                                                                           32%
                                                                                     traced

                                                           Note
                                                           1   Data relate to the period from 28 May 2020 to 4 November 2020.

                                                           Source: Comptroller and Auditor General, The government’s approach
                                                           to test and trace in England – interim report
Initial learning from the government’s response to the COVID-19 pandemic Data and evidence 21

21 In responding to the pandemic, government
has expanded the range of data that it can use for          Monitoring performance, flexing
decision-making. For example, MHCLG now has                 government’s response and
data on the potential scale of the population in            forecasting demand
England which either sleeps rough or is at risk of
doing so. At the start of the outbreak, there was no                  Monitoring how programmes are
systematic national process to collect a wide range                   operating, forecasting changes
of information from care providers, other than on                     in demand as far as possible, and
vacant beds (for instance, on levels of personal                      tackling issues arising from rapid
protective equipment and workforce absences).                         implementation or changes in demand.
For care homes, a tool commissioned by NHS
England & NHS Improvement (NHSE&I) in 2019                23 Government has been able to take remedial
was adapted and expanded, and data have been              action to address some issues arising from rapid
collated since early April 2020. Government has           implementation, and improve performance.
also taken steps to improve the quality of its data.      For example, the Department for Education and its
For example, NHST&T received advice from the              contractor acted quickly to solve initial problems
Office for National Statistics and a rapid review by      experienced by schools and families on its free
the UK Statistics Authority.                              school meal voucher scheme. This resulted in
                                                          improved performance. In terms of vaccines,
22 Limitations in the accuracy and completeness
                                                          NHSE&I has had to continually review and adapt its
of the data used and collected by government
                                                          deployment plans to ensure it could respond to the
have affected some pandemic response measures.
                                                          latest information about which vaccines had been
For example, NHSE&I sent letters to all those advised
                                                          approved, which groups in society needed to be
to shield. However, missing or inaccurate telephone
                                                          vaccinated, how many doses of vaccines would be
numbers within NHS patient records meant that the
                                                          available, and when and how those vaccines needed
shielding programme could not follow up these letters
                                                          to be deployed. The Department for Digital, Culture,
with calls to some 375,000 CEV people. While it was
                                                          Media & Sport adjusted elements of its response to
known to all parties that a proportion of telephone
                                                          take account of the pandemic’s progression and the
numbers in NHS records were missing or inaccurate,
                                                          impact it has had on the arts and culture sector.
the shielding programme agreed to use telephone
numbers from NHS records as a starting point to
follow up hard-copy letters. The Government Digital
Service shared with local authorities the contact
details of people that could not be reached, so local
authorities could check if these people needed help.
Local authorities also struggled with inaccurate
contact information.
22 Data and evidence Initial learning from the government’s response to the COVID-19 pandemic

24 Data limitations affected the government’s              •      The staff utilisation rate for contact tracers
ability to assess the effectiveness and value for                 fell to under 1% in August 2020. NHST&T
money of some measures, which made it harder                      was initially unable to reduce staffing levels
to adapt its response and manage the risks of                     to meet its target utilisation rate of 50% due
rapid implementation:                                             to lack of flexibility in contracts. The utilisation
                                                                  rate then rose, ranging between 10% and
•    MHCLG attempted to collect data from local
                                                                  56% in October 2020.
     authorities on basic care provision for CEV
     people but was unable to identify a workable          •      NHST&T did not predict the scale of
     solution acceptable to local authorities by                  increased demand for COVID-19 testing
     the end of July 2020, when the programme                     in September 2020, when schools and
     ended. Local authorities reported that bringing              universities reopened, and could not satisfy the
     together data on basic support provided by a                 demand for tests until mid-September 2020.
     mix of local authority and voluntary groups was
     too burdensome. In the absence of these data,             Validating interventions by gathering
     MHCLG accepted that it had some assurance                 end‑user feedback
     that local authorities were meeting basic needs
     given that local authorities had provided similar                    Gathering information from
     support for a number of years. Its engagement                        end-users and front-line staff
     with local authorities also gave it some                             more systematically to test the
     assurance that they were meeting basic needs.                        effectiveness of programmes
                                                                          and undertake corrective action
•    While HM Revenue & Customs (HMRC) monitored
                                                                          when required.
     the take-up rate of the Self‑Employment Income
     Support Scheme among different age and
     gender profiles, it does not have data to             26 Gathering feedback from end-users and
     monitor take-up rates among different ethnic          front-line staff is essential for monitoring the
     groups, as these data are not necessary for           effectiveness of interventions and improving
     the administration of taxes.                          existing processes. For example, HMRC carried out
                                                           surveys of employers, employees and self-employed
25 Government’s ability to forecast changes
                                                           people who accessed the employment support
in demand, and to update programmes based on
                                                           schemes. The high satisfaction scores recorded
updated demand, has been variable:
                                                           gave HMRC confidence that it was delivering a good
•    During March 2020, in response to changes             customer experience to claimants. On the other
     in planning assumptions approved by the               hand, while NHS provider organisations told us they
     Scientific Advisory Group for Emergencies,            were always able to get the PPE needed in time, this
     NHSE&I revised down its estimate of the               was not the experience reported by some front-
     peak number of ventilator beds that could be          line workers, particularly Black, Asian and minority
     needed. In April, based on the lower demand,          ethnic staff. Public Health England’s stakeholder
     ministers adopted new targets for the ventilator      engagement to better understand the impact of
     programme to provide additional resilience            COVID-19 on Black, Asian and minority ethnic
     in the system and prepare for a potential             groups reported deep concerns about the support
     second wave.                                          that these workers in health and care settings
                                                           received, stating that “it was recognised that a lot
                                                           has been done since the start of the pandemic
                                                           to improve access to PPE and mitigate risk, but
                                                           concerns were expressed that these safeguards
                                                           were not applied equally across ethnic groups”.
Initial learning from the government’s response to the COVID-19 pandemic Coordination and delivery models 23

Coordination and delivery models

                                                        27 The pandemic response has involved
Learning                                                extensive coordination between departments,
                                                        arm’s-length bodies, local and national government,
                                                        and public‑private collaboration. Delivery chains
          Ensuring that there is                        have often been complex and involved multiple
          effective coordination and                    actors. Against this backdrop, setting out effective
          communication between                         governance arrangements, with clear responsibilities
 government departments, central                        and accountabilities, is vital to delivering outcomes.
 and local government, and private
 and public sector bodies.                                  Cross-government coordination and
                                                            public-private collaboration
          Clarifying responsibilities
                                                                      Ensuring that there is effective
          for decision-making,                                        coordination and communication
          implementation and                                          between government departments,
 governance, especially where                                         central and local government, and
 delivery chains are complex                                          private and public sector bodies.
 and involve multiple actors.
                                                        28 The pandemic response involved examples
           Integrating health and social                of effective cross-government and public-private
           care and placing social care                 sector collaboration:
           on an equal footing with
           the NHS.
                                                        •     Policy and operational staff at HM Revenue
                                                              & Customs (HMRC) and HM Treasury (HMT)
                                                              worked closely to develop the employment
         Balancing the relative merits                        support schemes, with HMT leading on policy
                                                              design and HMRC leading on administrative
         of central, universal offers
                                                              design, implementation and administration.
         of support against targeted
 local support.                                         •     The Ministry of Housing, Communities & Local
                                                              Government’s (MHCLG’s) initial engagement
                                                              with local authorities on supporting clinically
                                                              extremely vulnerable people to shield was
                                                              directive rather than consultative. It recognised
                                                              that it needed to improve engagement with
                                                              local authorities and moved to a collaborative
                                                              approach. The small number of local authorities
                                                              we spoke to criticised government’s engagement
                                                              with them in the first few weeks of the initiative,
                                                              with some noting that engagement improved
                                                              over summer.
24 Coordination and delivery models Initial learning from the government’s response to the COVID-19 pandemic

Key facts from our published work                           Figure 5
                                                            Organisations involved in purchasing,

17                                                          manufacturing and deploying vaccines in England

                                                            Access to vaccines and manufacturing capability
Lead departments involved
in the COVID-19 response                                    Prime Minister        •    Overall direction and strategy

which had an estimated                                      Vaccine               •    Identifying vaccines, securing access
                                                            Taskforce
lifetime response cost of                                                         •    Developing manufacturing capacity
more than £1 million, as of                                                       •    Enhacing ability to deliver rapid
                                                                                       clinical trials
end of March 2021
                                                            Pharmaceutical        •    Developing and manufacturing vaccines
                                                            companies

More than 7                                                 Deploying vaccines

                                                            Joint Committee       •    Advising on priority groups for vaccination
Organisations involved in                                   on Vaccination
                                                            an Immunisation
purchasing, manufacturing
and deploying vaccines                                      Medicines and         •    Approving vaccines for use
                                                            Healthcare
in England                                                  products
                                                            Regulatory
                                                            Agency

4.7m                                                        NHS England
                                                            & Improvement
                                                                                  •
                                                                                  •
                                                                                       Operational delivery of the deployment
                                                                                       Administering vaccines
Number of food boxes delivered                              Public Health         •    Storing and distributing vaccines
to clinically extremely vulnerable                          England
                                                                                  •    Supplying other goods
people between 27 March and                                                            (for example, syringes)

1 August 2020 through private
                                                            Source: Comptroller and Auditor General, Investigation into preparations
sector contracts                                            for potential COVID-19 vaccines

•    The Cabinet Office worked with industry to
     develop new, or modify existing, ventilator or           Responsibilities for decision-making,
     anaesthesia machine designs to meet standards            implementation and governance
     that the Medicines and Healthcare products
                                                                              Clarifying responsibilities for
     Regulatory Agency developed for rapidly
                                                                              decision-making, implementation
     manufactured ventilators, and to increase
                                                                              and governance, especially where
     manufacturing capacity to build each design at
                                                                              delivery chains are complex
     a much greater scale than usual. This involved
                                                                              and involve multiple actors.
     securing new factory capacity for each design,
     managing global supply chains and ensuring
     regulatory approvals were in place.

•    The purchase, manufacturing and deployment of
     vaccines involves extensive cross-government
     and public-private collaboration (Figure 5).
Initial learning from the government’s response to the COVID-19 pandemic Coordination and delivery models 25

29 Effective governance and clear responsibilities
and accountabilities are important for an effective           The relation between health and
rapid response in an emergency. For example, the              social care
Department for Work & Pension’s (DWP’s) clear
                                                                            Integrating health and social care and
prioritisation of paying benefits and suspension
                                                                            placing social care on an equal footing
of other activities enabled it to process an
                                                                            with the NHS.
unprecedented number of claims during the first
lockdown. This was supported by clear governance
within DWP. On the other hand, we found that several      31 Issues predating the pandemic made
organisations had responsibility for approving,           responding to the crisis more difficult in some areas.
maintaining and distributing personal protective          The relationship between adult social care and the
equipment (PPE) from the pandemic influenza               NHS has been challenging for decades. We have
stockpile. There were issues with warehousing,            reported on successive efforts to integrate the
logistics and quality of stock.                           two sectors: there have been 12 government white
                                                          papers, green papers and consultations, and five
30 Government has modified the                            independent reviews on integration over the past
governance arrangements of key pandemic                   20 years. Certain aspects of the initial pandemic
response programmes:                                      response reflected a greater emphasis on health
                                                          than on social care. For example, national bodies
•    NHS Test and Trace (NHST&T) initially had an
                                                          initially provided more PPE support to hospitals
     unusual organisational relationship with the
                                                          than to social care. NHS trusts received 80% of
     Department of Health & Social Care (DHSC).
                                                          their estimated PPE requirement through national
     Although NHST&T was subject to DHSC’s
                                                          schemes between 20 March 2020 and 31 July
     financial, information and staffing controls, its
                                                          2020, whereas social care providers received
     head, the executive chair, did not report to the
                                                          10% of their estimated requirement (based on
     DHSC’s ministers or permanent secretary, but
                                                          the information available at the time).6 DHSC told
     rather to the Prime Minister and the Cabinet
                                                          us that it took different approaches to providing
     Secretary. Since NHST&T is embedded within
                                                          PPE to social care and trusts during the pandemic.
     DHSC, these dual reporting lines brought risks
                                                          Social care providers, which are mostly private- or
     of unclear accountability. We did not undertake
                                                          voluntary‑sector organisations, either obtained PPE
     a systematic review to determine if these risks
                                                          from wholesalers (as they did prior to the pandemic)
     had materialised and had seen no evidence
                                                          or from local resilience forums and DHSC’s helpline,
     that they had.
                                                          which it set up to respond to emergency requests,
•    In September 2020, a faster process                  whereas trusts received PPE directly from the
     for approving vaccines expenditure was               cross‑government PPE team set up by DHSC.
     introduced by government and the governance
     for vaccines activities was revised. DHSC
     appointed a single senior responsible officer
     to oversee deployment to create a unified
     programme to reduce duplication, streamline
     responsibilities, facilitate cross-departmental
     working, and increase transparency
     and accountability.

                                                          6    Distributions to trusts include a very small volume of PPE delivered to
                                                               other healthcare settings.
26 Coordination and delivery models Initial learning from the government’s response to the COVID-19 pandemic

32 In responding to the pandemic, DHSC                      •    in May 2020, the government launched NHST&T,
has increased its focus on social care. DHSC                     bringing together a national programme
outlined how, under the current Care Act 2014,                   for testing and tracing. By July 2020, local
its oversight of the social care market had been                 authorities had started to set up their own
limited. Stakeholders reported DHSC’s limited                    locally run contact tracing schemes to cover
engagement with, and understanding of, the sector                the minority of cases that the national service
going into the pandemic. Prior to COVID-19 there                 could not reach, working in conjunction with
was no process in place to collect a wide range                  NHST&T. In August, NHST&T reduced the
of data from providers regularly. In response to                 number of national-level contact tracers and
COVID-19, DHSC has increased the data it obtains                 designated a proportion of its specialist tracing
on care providers and it intends to legislate for                staff to work exclusively to facilitate those local
new powers to collect further data. As part of its               authorities that had their own scheme. By the
adult social care winter plan, DHSC carried out a                end of October, 40% (60) of local authorities
review of risks to local care markets and service                had a scheme in place, with a further 46% (69)
continuity issues, offering targeted support. It also            planning to set one up; and
re-established a director‑general post with sole
responsibility for social care, increased its policy        •    while the Culture Recovery Fund accepted
                                                                 applications from across England, one of its
team threefold and set up specific teams to provide
                                                                 goals was to help ‘level up’ cultural resources
support and challenge to local government on the
                                                                 for deprived communities. This was reflected
COVID-19 response.
                                                                 in the funding criteria. An analysis by the
                                                                 Department for Digital, Culture, Media & Sport
    Central and local delivery models                            found that the 10% of local authorities most
                                                                 in need of levelling up were more successful in
            Balancing the relative merits of central,
                                                                 their grant applications than those least in need.
            universal offers of support against
            targeted local support.                         34 Universal offers of support can be developed
                                                            at speed but may not always be as cost-effective
                                                            as targeted offers. A government review of the
33 Pandemic response measures have employed
                                                            shielding programme concluded that, due to
a combination of universal offers and targeted
                                                            the speed and context in which the programme
delivery models. For instance:
                                                            was developed, it was largely offered universally,
•     the Everyone In campaign was rolled out across        resulting in poor targeting and inefficient use of
      England to provide accommodation for all rough        funds. The review noted that, should shielding
      sleepers. For the winter of 2020, the campaign        be needed again, adopting a local support model
      was supplemented with a targeted programme            could improve flexibility and, potentially, be more
      focused on the areas with large numbers of            cost-effective.
      rough sleepers;
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