Response to the HM Treasury - June 2016
We believe a new money guidance body must have a clear remit, a narrow focus on commissioning and managing commissioned services, and a clear primary accountability.
The new body should set expectations in commissioning, and evaluate against these expectations. However, it should avoid engaging in regulatory or “self-regulatory” activities (dictate standards that overlap with existing regulations) outside of this. While it should consult with all stakeholders, the new body should have the interests of consumers at its heart and have a clear primary accountability to the public interest.
Projects relating to the infrastructure of the sector, or the relationships between different bodies, should generally be initiated by market participants (creditors and debt advisors, with appropriate stakeholder input).
The new body does not necessarily have to specify any general way for hand-offs to be built into contracts. Commissioning arrangements that allow respondents flexibility in hand-offs may be the best way to achieve innovation and efficiency. The new body should not be prescriptive. Instead it must create a commissioning environment that allows sector bodies to leverage their expertise to offer the best service to the public.
Tendering processes should encourage bidders to seek the best partners and work to ensure the most effective hand-offs. The new body will need to consult the sector to ensure different approaches to monitoring outcomes are understood and FCA expectations are taken into account. Core outcomes can be built into the commissioning process.