How To Implement A Risk Management Strategy

Risk

As school leaders, risk is something that we are incredibly familiar with. We have processes in place to ensure safety on school trips, that our site is secure and that the staff who work for us are screened in accordance with safeguarding legislation.

These systems are woven into the fabric of school life, often without issue or incident.

However, there are other types of risks to our schools – beyond the operational – that require more consideration and focus to allow us to mitigate them appropriately.

By taking a strategic approach to risk management, your school can be proactive and make well-informed and timely decisions.

What does risk management involve?

The process of risk management involves six steps; identification, assessment, measurement, management response, monitoring and reporting.

As an organisation, you should have a process that outlines how you follow these steps to ensure that the management of risk is clearly articulated, understood and implemented by key stakeholders.

At a strategic level, risk management should be linked to your school development plan and its objectives; specifically the risks that will impede you from implementing your plan effectively.

What types of risk are there?

It’s easy to fall into the mindset that everything is a risk i.e. an accident on a school trip or a break-in at school. While these are all risks, as outlined above, they will likely already have comprehensive mitigation measures in place.

Unless you have reason to believe that your measures are not working or are out of date, an audit identifies areas of concern or some other variable factor has changed, then these types of risk need not feature on your strategic and ‘live’ risk register (or similar document).

Risk management does not equate to voiding risk altogether as this is often not possible. It’s about forward thinking, taking appropriate action at the right time and ensuring that you’ve done all that you can to reduce the impact of any risk.

If your management actions are effective and the risk can be deemed ‘low’ then you are managing risk effectively.

Strategic risks usually fall into five main categories; governance, educational, financial, external and compliance.

Operational risks, as outlined above, may be incorporated into your risk management process but only if there is a significant impact upon your progress towards your strategic objectives.

Chances are, serious operational risks would be covered under one of the other five types of risk. Here are some examples of risk for each category:

Governance
Constitution or structure of your LGB (numbers, attendance, committees), capacity of the LGB in terms of skillset and time, conflicts of interest.

Educational
Outcomes, Ofsted, curriculum, provision, staffing etc.

Financial
Limited income, insurances, procurement, internal controls, cash flow, inadequate information or reporting, asset management.

External
Reputational, demographic changes, pupil numbers, community, changes in government policy.

Compliance
Failure to meet legislative requirements, poor knowledge of responsibilities and regulations, audit issues.

How do we manage risk?

Where a risk has been identified, you need to be able to quantify both its probability of occurrence and the relative impact if it does occur.

When you have identified the measures you are going to put in place to mitigate the risk, you should then assess what effect these measures will have on both the likelihood and impact.

You should expect a lower probability of it happening or a lesser impact if it does after you have taken management action.

In the academy sector, this risk assessment process is documented on a risk register. In the maintained sector, you may have an LA risk register template that you use or you may record it in another way.

There are four main approaches to risk; tolerating (accepting and managing), treating (controlling or reducing), transferring (contracting out or insuring) and terminating (avoiding). The approach you choose to manage each risk will depend on your context and your resources.

To be clear on accountability and responsibility, you should determine who ‘owns’ each risk. This will likely be the person who is responsible for implementing the mitigating actions. While we know that the ‘buck’ stops with the headteacher, risk management is everyone’s responsibility. Line management and reporting to your LGB should incorporate the risk management process, ensuring that the accountability chain is robust.

How can we make sure our risk management process is fit for purpose?

When a risk has been successfully mitigated to what you determine to be an ‘acceptable’ level, there should be a point where this risk is removed from the risk register.

This means that the focus of risk management is not diluted and that priority is given to current and ‘live’ risks. In the future, it may be that some risks ‘return’ and at that point, they can be revisited.

When it comes to managing strategic risk, it’s important that the process is integrated into existing structures and systems. This ensures that it is a regular topic of discussion.

The more people that are involved in the identification, assessment and management of risk, the less likely it is that the process will become subjective or overlooked.

Risk management may appear to be an onerous administrative process but when it’s well implemented, it can help you to protect your school, staff and students as well as save money, provide stability and help you to make smart decisions about the use of time and resources.

Risk Management: Self-Evaluation

  • Do we have a formal risk management process?
  • Is it explicitly linked to our strategic objectives?
  • How do we categorise risk?
  • Is our assessment of risk robust?
  • What is our approach to risk?
  • Are accountability lines clear in terms of risk management?
  • How do we communicate management action in terms of addressing risk?
  • How does our governance structure support risk management in terms of scrutiny and challenge?
  • How do we keep our risk management process objective?
  • How do we determine whether a risk should be removed from the risk register?

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Written for: Primary School Management Magazine (@primaryleaders)

Is Your MAT Mismanaged?

MAT Mismanagement

Almost every day we read a news article about a MAT scandal. Whether it be a financial notice to improve, a poor Ofsted report or a failure of governance, these stories have become all too common.

The questions that are often asked are: why has it taken Ofsted, the DfE or the ESFA to come along for people to realise how bad it is? Why hasn’t something been done before?

A MAT cannot lose all of its money or shift from good to special measures overnight. These things happen over time. 

So how do you know if you’re working in a mismanaged MAT? What are the symptoms you should be looking out for that may lead to a detrimental diagnosis?

In my experience, there are three key areas that you should assess to determine whether your MAT is being mismanaged:

Governance
  • Consider the constitution of your Board and Governing Bodies. Determine whether they are the right people to undertake these roles in terms of their values, skillset, personal interests and capacity. 
  • Review the governance self-evaluation systems that are in place. Consider how objective this process is, how often it is undertaken and how effective your MAT is at following up on areas for development. 
  • Evaluate the effectiveness of your Scheme of Delegation. Determine how well it is adhered to and whether it is effective in operation. 
  • Assess the quality of your meetings in relation to schedule, agendas and records of discussion. Evidence of accountability, scrutiny, challenge and support should be clear and documented.
  • Consider the level of transparency of your governance systems. You should be able to clearly articulate your decision making process and justify the actions of governors both to local stakeholders and external bodies.
Leadership
  • Consider the capacity of your leaders in relation to delivering sustainable improvement within your MAT. 
  • Assess how well your leaders tackle poor performance and conduct and whether they execute their role as leader fairly, equitably and consistently.
  • Determine how well your leaders apply the policies of your MAT. Consider how you ensure that MAT systems and processes are followed in relation to education, employment law, finance and compliance.
  • Review the performance management processes for your leaders to ensure that they focus on MAT determined core competencies beyond education specific targets. Consider finance management and people management as indicators of leadership quality.
  • Consider how well the leaders within your MAT respond to challenge and the opportunity to collaborate. Issues within these areas can indicate an underlying cultural problem that can erode the effectiveness of the MAT over time.
Finance
  • Consider the level of experience of your finance staff and the qualifications they hold in the context of the role that you expect them to perform. Assess their ability to provide correct and timely information and whether they present it in an audience-appropriate way.
  • Determine how your finance team responds to challenge and scrutiny both within meetings and from external bodies. Questions that cannot be answered or data that cannot be supported is a red flag that should not be ignored.
  • Review the financial systems within your MAT to ensure that there are appropriate checks in place to act as an ‘early warning’ system. An external audit report should not be the first time that you learn about financial issues within your MAT. 
  • Assess the value of the MAT central team in terms of the capacity that they add to the schools and whether the relationships between the financial team and local school leaders enables sound financial management.
  • Consider how the finance function integrates with other areas across the MAT including school development planning, curriculum planning, staffing strategy and capital expenditure. A financial team that works within a silo cannot be effective.

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Written for: Primary School Management Magazine (@primaryleaders)

Should your MAT consider GAG pooling?

money, growth, GAG pooling

In the world of Academies, GAG pooling is seen as something of a taboo. Though it first featured in the Academies Financial Handbook in 2013, it has been until recently, largely ignored. 

With the increasing financial pressures on the sector and the depletion of resources throughout the system, it has steadily risen to the top of the agenda. 

The DfE, the ESFA and numerous financial experts all cite the process of GAG pooling as a way to further increase efficiencies and improve the effectiveness of MATs.

The Academies Benchmark Report 2019 by Kreston, states that:

“To enable financial governance to continue to improve it is essential that MATs become more centralised. This will, in turn, facilitate GAG pooling which will enable MATs to ‘look after‘ the financially weakest schools in the system.”

In a letter to auditors in June 2018, Theodore Agnew, the Parliamentary Under-Secretary of State for the School System said:

“I would like to share more widely across the audit sector several key points that will help boards govern more effectively and make best use of the freedoms they have. We are aware that a substantial proportion of trusts are still hesitant about implementing some of the freedoms and mechanisms to enable this.”

He encourages auditors to discuss these freedoms with their clients; GAG pooling being at the top of the list.

He said: 

“This is one of the greatest freedoms a MAT has. The opportunity to pool GAG is particularly valuable, in particular, to simplify the provision of support to weaker schools in a MAT until they can grow their pupil numbers. It is worth remembering that a MAT is a single financial entity.” 

Interestingly, out of the 350 Trusts represented in the Kreston report, only 3 are currently GAG pooling. In the opinion of Kreston, it is clear that ‘there is something holding the sector back’.

There’s no doubt that moving to a GAG pooling model requires a significant shift in both the mindset of leadership and governance and the culture, systems and processes of the organisation. 

But with approximately 50% of MATs showing an in-year deficit, an increasing number of MATs having a cumulative deficit and continually depleting reserves sector-wide, why are so many MATs reluctant to GAG pool?

The Kreston report states that MATs said they were not GAG pooling because:

  • The politics were challenging (SLT, Trustees, LGBs) 46%
  • Financial position 22%
  • It was too difficult to implement 14%
  • They will do it or are seriously considering it 5%
  • Other reason 13%

The issues surrounding the ‘politics’ of GAG pooling include:

  • The belief that school-level funding allocations are for the benefit of the students in a specific school and therefore should not be redistributed  
  • The concern that the deployment of resources from a central perspective would disadvantage individual schools and students 
  • The reduction in the autonomy of schools, Headteachers and Local Governing Bodies 

If the financial landscape was rosier, it’s clear that GAG pooling would remain an overlooked clause hidden in the depths of the Academies Financial Handbook. But with the financial future of the sector looking increasingly bleak, MATs may find themselves having to grasp this nettle.

If you’re open-minded to the concept or are actively considering GAG pooling and you’re wondering how best to approach it, then I’ve put together a list of frequently asked questions to help you navigate this largely uncharted territory. 

What options do we have in relation to GAG pooling?

In truth, though the concept is outlined in the Academies Financial Handbook, the actual ‘how’ is not so clearly defined. GAG pooling can mean any one of the following:

  1. Receiving all school funding centrally and allocating resources to individual schools and to the centre (removing the need to top-slice a ‘management fee’)
  2. Allowing school allocations to continue at a local level but pool reserves and other specified incomes streams (whilst continuing to top slice a ‘management fee’)
  3. In addition to the top sliced ‘management fee’, top slice an additional specified amount for central reserves/contingency
  4. Increase the percentage of the management fee and from this, create a centralised reserve
How could we use these pooled funds?

Again, it depends on where the money comes from, how much of it is pooled and the overarching strategy of the MAT. Outside of school allocation, (however this is determined), the money can be used for:

  • Supporting the financially weaker schools in the MAT
  • Creating a contingency for cashflow, unforeseen emergency costs, building maintenance, ICT replenishment etc.
  • Increasing central resource and achieve efficiency savings MAT-wide (through centralisation and procurement)
  • Funding projects cross-MAT to support improvement and build capacity
In what situation would GAG pooling be most effective?

If there are clear inequities across your schools funding with surpluses and reserves varying to the extreme, you can argue a case for GAG pooling. The ESFA, though it monitors individual school performance, is more interested in the overall financial sustainability of the MAT as a whole. GAG pooling is one way to secure that. For financially vulnerable schools, joining a MAT should provide them with adequate protection rather than expose them to further threat.

If all of the schools in the MAT are running close to the red line, then you could argue that pooling these funds would not achieve much at all; like shifting the deck chairs around on the Titanic. If your central budget is not capable of generating surpluses either, then your MAT will likely need to consider a more drastic approach to bring things back into line and secure sustainability. 

But redistributing funds away from the schools it was intended for is not right!

You could argue that having a ‘management fee’ does exactly the same thing as GAG pooling but is simply called something different.  When you look at the size of or uses of the ‘management fee’ in some MATs, it could be said that they are GAG pooling already, with some reserves and contingencies sitting centrally. The difference with this is that the route to challenge and scrutiny by the schools is stronger and more defined in terms of quantifying the value for money provided by the MAT. In fact, I worked with a Head recently who said they felt the management fee that they paid their MAT was too low and they would gladly pay more to enable the MAT to do more for them. 

If the MAT has a large amount of cash sitting in the bank but ‘cannot’ use it, it will merely be an onlooker as one or more of its financially weaker schools fail; thus negligent in its financial stewardship. In these cases, if the sole purpose of GAG pooling is to secure long-term financial sustainability of the MAT, then GAG pooling in some form should be a no-brainer.

So how do we reconcile the inequity that GAG pooling creates in the schools that are financially effective?

MATs need to decide how committed they are to GAG pooling and whether they are in it for the long term. Depending on the level of need and ‘pooling’ that needs to be done, MATs might consider some form of internal loan and repayment system to overcome short-term difficulties. If the GAG pooling mechanism is being used as a means to secure sustainability in the short term – either until funding becomes adequate, pupil numbers increase, or further local efficiencies can be achieved – then the MAT can account for the internal redistribution and repayment of funds. This mitigates the perspective of schools ‘losing’ or ‘giving away’ their reserves and being ‘penalised’ for their financial efficiencies. This option should be considered carefully, taking into account context, the level of need, the financial position and the long-term goals of the MAT. GAG pooling in any form needs to be articulated clearly in relevant MAT policies including the Reserves Policy.

What if there are other reasons that we need to use the reserves/pooled resources?

Implementing a transparent system around the management of these reserves is essential. If your MAT is pooling reserves to secure tighter financial control, it should implement a process whereby schools can apply for funds as and when they need it. The MAT should ensure that the criteria for decisions taken and the prioritisation of expenditure are clear so that no school feels like it has been unfairly treated. The Academies Financial Handbook states that an appeals process for such circumstances be articulated clearly in MAT policies. My advice is that the more specific you are around the allocation of pooled resource, the less chance there is that complications will arise further down the line. Ambiguity fosters distrust. If the MAT doesn’t have a robust process for managing GAG pooled resource and cannot justify its expenditure decisions, then appeals may be lost and the impact on the relationships within and the culture of the MAT may be devastating. 

What about the National Funding Formula?

If the National Funding Formula achieves its goal to balance funding across UK schools, then this will ‘iron out’ any imbalance that the GAG pooling process is designed to achieve – thus making GAG pooling, at least at its extreme, redundant. Instead, the focus will shift back to the ‘management fee’ and value for money of the MAT. 

Our MAT isn’t in financial difficulty – should we still consider GAG pooling?

If your MAT is in a sound financial position but determines that it could add more value if it had more control over its funds, then this is where GAG pooling becomes particularly contentious; especially if you’re opting for Option 1 – total control over school allocation. In effect, it means that your MAT is saying that it will override the methodology of the funding formula and all its component parts and determine itself how much money each school needs – in other words, ‘acting like a Local Authority’ (Robert Hill). This is where the argument in relation to the autonomy of Headteachers and Governing Bodies grows strong. If a MAT opts for this type of GAG pooling, it indicates a significant shift in culture, operation and autonomy beyond what is currently common in the sector. These ripple effects will impact on the role of the Head, the management of the schools and the way in which the Scheme of Delegation operates. 

Before going down this path, the Trustees and central team need to be clear about what they are trying to achieve and whether GAG pooling is really the best way to do it.

Our MAT is looking to grow – should we be looking at GAG pooling?

Much of your decision making in relation to GAG pooling will depend on the points made above. However, growth does pose both financial opportunities and threats to a MAT. If your MAT is looking to grow, GAG pooling is just one piece of the puzzle and should be considered in relation to the context, strategy and objectives of your MAT both in its current and future state.

For those MATs who are looking to grow or are already in a growth phase, download my Guidance for Growth Tool, written for Capita SIMS, to enable you to articulate your vision for growth, test and risk-assess your strategy and identify actions to implement your strategy successfully. Just click the image below:

Cover, guidance, tool, growth, MAT
So how do we move forward?

In summary, there isn’t a one-size fits all answer to GAG pooling. You’ll need to assess the current position of your MAT and identify your long-term challenges, priorities and goals to see if it is the right path for you. 

For additional advice in relation to GAG pooling, get in touch with your auditors who will be able to provide you with bespoke, detailed guidance and support.

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Download: Guidance Tool for MAT Growth

Poster, ask questions, frame

On behalf of @CapitaSIMS, I have written a MAT Growth self-evaluation tool for MATs that are preparing for or entering a new phase of growth.

The Guidance Tool outlines a framework containing seven key areas of focus.

Upon reviewing the seven key areas, MAT Leaders and Trustees will be able to:

  • Articulate a clear vision for growth
  • Determine the viability, sustainability and capacity for growth of the MAT
  • Establish and articulate views on autonomy and standardisation across the MAT and its functions
  • Cost the delivery model for growth and evidence best use of resource
  • Determine how the growth strategy should be phased
  • Review governance arrangements, risk management, structures and processes to oversee the operations of the MAT during and beyond the growth phase
Click the image below to download:
Cover, guidance, tool, growth, MAT

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