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Child Support Collection and Enforcement (Deduction Orders) Amendment Regulations 2009

Volume 712: debated on Wednesday 1 July 2009

Motion to Approve

Moved By

That the draft regulations laid before the House on 3 June be approved.

Relevant document: 16th Report from the Joint Committee on Statutory Instruments.

My Lords, I beg to move that the draft Child Support Collection and Enforcement (Deduction Orders) Amendment Regulations 2009, which were laid on 3 June 2009, be approved.

Noble Lords will be aware that some non-resident parents are determined not to accept financial responsibility for their children. Unfortunately, they demonstrate this by failing to pay their child maintenance and building up arrears. The Child Maintenance and Enforcement Commission already has a number of tools it can use to enforce payment when this happens. For example, it can use a deduction from earnings order, which is an effective method of collecting both ongoing liabilities and arrears in many cases. However, in some cases, a deduction from earnings order cannot be used or is ineffective; for example, because the non-resident parent is self-employed or frequently changes jobs. The Government want the commission to be able to take quick and effective action to enforce payment of child maintenance in all cases where a non-resident parent is failing to comply. With this is mind, we set out our proposals for tougher enforcement in our White Paper, A New System of Child Maintenance, in December 2006.

Subsequently, the Child Maintenance and Other Payments Act 2008 inserted powers into the Child Support Act 1991 which would allow the commission to use deduction orders to collect child maintenance from an account held by a non-resident parent with a deposit-taker or from funds held by a third party. Because deduction orders will be administrative they can be made without going to court first and can therefore get money flowing for children more quickly. They will provide an additional tool that can be used alongside existing methods of collection and enforcement.

The regulations before us today will implement the powers taken to enable both regular and lump-sum deduction orders to be used on accounts held by deposit takers, which will normally be banks or building societies. These regulations do not make provision for deduction orders to be used on funds held by third parties, such as solicitors. The commission has decided to use deduction orders on bank and building society accounts first because it believes that orders on these accounts have the greater potential for collecting child maintenance. The regulations have therefore been developed in close consultation with representatives from the banking sector which will be responsible for operating the orders. The commission will go on to assess the scope for further regulations which will enable it to use lump-sum deduction orders on funds held by third parties. This will involve working with a number of stakeholders, including solicitors and other government departments.

I should make it clear that, where there are arrears of child maintenance, the commission will do all it can to make an arrangement with the non-resident parent to pay those arrears before a deduction order is made. The commission would much prefer child maintenance to be paid, for example, by direct debit, which will not incur any additional charge for the non-resident parent and is much easier and cheaper for both the commission and the deposit-taker to administer. However, if the non-resident parent fails to make a satisfactory arrangement to pay, the commission will use what information it has to first liaise with deposit-takers in order to identify a suitable account on which to make an order. In doing so, the commission will ensure that it does not make an order on an account which is specifically excluded by the regulations. This would apply where, for example, the non-resident parent has no beneficial interest in any of the funds in it because they are operating it solely as a trustee.

The regulations also prevent the commission from making a lump sum deduction order on an account which is used wholly or in part for business purposes. However, it may make a regular deduction order on such an account, but only where it is used by the non-resident parent as a sole trader. If the Commission decides to make a regular deduction order, the deposit-taker will be required to deduct regular amounts of ongoing maintenance and/or arrears from the non-resident parent’s account. The commission will send a copy of the regular deduction order to the deposit-taker, specifying details of the account, the amount, the dates on which deductions are to be made and when it will take effect. A copy of the order will also be sent to the non-resident parent. The deposit-taker will have a legal duty to make deductions from the account specified in the order and pay the relevant amount to the commission. The deposit-taker will also be able to deduct an amount up to a maximum of £10 towards its administrative costs before making each deduction. This takes account of the fact that deposit-takers will be required to process deduction orders manually because they operate differently from direct debits and standing orders and cannot be automated.

Safeguards will be in place to protect both the non-resident parent and the deposit-taker. The amount of each deduction will not exceed 40 per cent of the net weekly income used in the current maintenance calculation, and the deposit-taker must not deduct an amount that will put the account into overdraft. The regulations also set out clearly the circumstances where either the non-resident parent or the deposit-taker can apply for a review of a regular deduction order. This includes, for example, where there has been a change in the amount of the maintenance calculation in question or an incorrect amount has been specified in the order due to an error. Both the non-resident parent and the deposit-taker will have a right of appeal to a county court—or sheriff in Scotland—against the making of the order and against a decision following an application to review the order. If the commission decides to make a lump-sum deduction order the deposit-taker will be required to deduct a lump sum from the non-resident parent’s account in respect of a specified amount of arrears. The order will operate in a similar way to a third-party debt order from a court but, because it is administrative, the process will be quicker.

The primary legislation makes provision for a number of safeguards in respect of lump sum deduction orders and the regulations set them out as an integral part of the process. The commission will initially send the deposit-taker and the non-resident parent a copy of an interim order which will specify details of the account and the arrears to be collected by a final order. The interim order will also instruct the deposit-taker to freeze up to the amount specified in the order. Both the non-resident parent and the deposit-taker will have 14 days to make representations to the commission against the proposals in the interim order.

At any point throughout the process, from receipt of the interim order until the funds are paid to the commission, both the non-resident parent and the deposit-taker may apply to the commission for consent to release some or all of the funds from the account. The non-resident parent might do this where, for example, there is an existing written contractual obligation to make a payment to another party. The deposit-taker might do it where, for example, it already has a written agreement with the account holder that a specific amount in the account is held as security against a loan.

A robust appeals process will also be in place. Both the non-resident parent and the deposit-taker will have a right of appeal to a county court—or sheriff in Scotland—against the making of the order and a decision following an application for consent to release funds. The commission will not make a final order until the time allowed for an appeal, 21 days, is passed and will not instruct the deposit-taker to transfer funds until any appeal against the making of the final order is resolved. The deposit-taker will have a legal duty to comply with the requirements of the order and pay the specified amount to the commission. The deposit-taker may also take up to a maximum of £55 towards its administrative costs before making the payment to the commission. This aligns with the amount a deposit-taker can currently take for administering a third-party debt order made by a court which requires deposit-takers to follow a similar process.

Noble Lords should be aware that the new powers inserted into the 1991 Act made provision for regulations to allow both regular and lump-sum deduction orders to be made on a joint account. However, these regulations do not include such provisions. We recognise that these new powers are unprecedented and, therefore, the commission will use them carefully, particularly on initial implementation. That is why the safeguards are built into the process. It is also why the commission is planning to start to introduce deduction orders using a small dedicated team so that implementation will be at a low volume and controlled.

The impact assessment, which was published alongside the draft regulations, says that this policy will be fully evaluated by the commission in September 2010. If that evaluation finds evidence that excluding joint accounts from the scope of deduction orders is reducing their effectiveness, we will introduce further regulations to extend provisions so that orders can be made on joint accounts. The evaluation will also enable the commission to collect information which will allow it to assess the potential for and likely benefits of increasing the number of deduction orders made in the future. In the mean time, the provisions in these regulations will enable the Child Maintenance and Enforcement Commission to start to use deduction orders both as an additional enforcement tool and as a means of encouraging ongoing compliance.

My Lords, I am satisfied that the statutory instrument before us is compatible with the European Convention on Human Rights and I commend the regulations to the House.

My Lords, I thank the Minister for introducing these regulations. We on these Benches understand why the Government have brought them forward. My honourable friend Mr Andrew Selous supported them in another place, and they have our support here.

These measures might be sensed to have a draconian feel about them, but the estimate of £2 million raised in the first year is mere drop in the ocean compared to the £3.8 billion owed by non-resident parents—a figure growing by £10 million a month. It would be of interest if the Minister could tell us how many parents caring for their child do not get any of the money to which they are entitled from the non-resident parent.

Electronic tagging in extremis to impose a curfew or the ability to remove travel documents or passports, should that come about, represent considerable powers, although, of course, the latter would be effective only where UK citizens are concerned. Perhaps the most significant move is to put for the first time into law the power to access directly a citizen’s bank account and to remove money to give it to that person’s child or children. I think I understand the process by which accounts of individuals and sole traders will be accessed, but not individuals trading as companies and partnerships, or anyone with joint accounts. Does not the Minister expect that this loophole—or gaping chasm, one might think—will be quickly discovered and that partners will soon be appearing on bank accounts to render them out of reach? I understand that accounts held on behalf of clients by solicitors are also protected. The rationale may be right but it is another way out for recalcitrant parents.

I also note that an administration fee will be charged. The Minister talked of this. How will the department calculate this and will it be charged irrespective of circumstances and the amount involved? Meanwhile, the cost to the banks and building societies of providing information requests and delivering money will be considerable. Has this been properly estimated by the Government and are the deposit takers satisfied?

This operation to address the huge shortfall of recovering overdue moneys will in future be in the hands of the Child Maintenance and Enforcement Commission. How will CMEC go about sequencing deduction orders and what will be its priority?

I hope that the Minister will endeavour to address my concerns. If they are not covered in his response, perhaps he will give noble Lords the answers in writing. He might also tell noble Lords how the review promised for 2010 will be analysed, shared and debated. At the beginning of my remarks I indicated my support for these regulations. I hope that the Government have got it right and that a future Government will not be forced to return to this issue.

My Lords, it is a pleasure to follow the noble Lord, Lord Taylor of Holbeach. I am happy to concur with him that these orders should proceed. In his very important penultimate point, he asked what would happen with regard to the 2010 CMEC review. I certainly hope that it will be published. It is very important to debate these powers, particularly in the early years as we see how they pan out in practice. The commission should understand that Parliament does not provide administrative powers of this kind—I think that the Minister mentioned unprecedented powers—lightly. We will be watching very closely to see how they work and whether they achieve the policy aim and are used in a fit and proper manner, as was intended in Sections 22 and 23 of the Child Maintenance and Other Payments Act 2008. I concur that the House will want to keep a watching brief as these regulations start to be implemented.

I remember vividly the good debates that we had when discussing Clauses 22 and 23 of the 2008 Bill, as it then was. I was very clear in my own mind that these powers were required for self-employed people. Non-resident parents who are subject to contracts of employment are much easier to handle if they are acting in bad faith in seeking to elide payments for their children. Deduction of earnings orders are a far easier, simpler, better understood and better controlled process. The evidence that was laid before the House last year certainly convinced me that the Child Maintenance and Enforcement Commission required specific powers where self-employed people were involved, as the quantification of where the money and the assets were was very much harder to ascertain and took time to establish. The people who suffer most as a result of that are the children who do not get the money to which they are entitled under the legislation.

Self-employed cases represent only 8 per cent of the caseload. I have studied this matter since 1991. I keep saying that I have no alibi. I was there at the time and I feel deeply responsible for the legislation, which has been so fraught in its many manifestations. However, that percentage represents 96,000 self-employed, non-resident parents with liability outstanding. That is a big caseload which needs to be dealt with. I hope that these powers will be used proportionately. I agree that they are necessary but they must be used very carefully indeed. Non-resident parents who are in the sights of the commission using these new administrative procedures need to understand clearly what is facing them before it is safe to use these powers. In that regard I do not think that sending a copy of the interim order to the deposit holder does that by itself. The Minister may say that there will be a letter. It may be only one page of A4 but it needs to make crystal clear that the new system will be different. These parents may have struggled with the old CSA, now CMEC, for years. Indeed, a lot of them have. Some of them have acted in worse faith than others, but this is a different procedure altogether. Simply providing a photocopy of a legal document, which is probably quite impenetrable to people who are untutored in these things, is not sufficient in my view unless it is accompanied by something which explains in plain Queen’s English what is now facing the people against whom these powers will be arraigned.

I also think that the accuracy of the system—I want to come back to this in a minute—still leaves a lot to be desired. I have real fears that although most of these orders will be used against people who deserve to have them imposed, some who do not fall into that category may get caught up in these provisions. Therefore, we need to be careful to make the system as accurate as possible. The Minister said that these unprecedented powers need to be used with care. I say amen to that. I like to think that they will be used only as a last resort; that is, when there is no other way to get the non-resident parent to face up to his or her responsibilities. Establishing a case against any such non-resident parent who is the subject of these orders must be done to the same standards that are used in assessing court cases under the current system. As I am sure noble Lords will know as we discussed this when the 2008 Bill was going through, at the moment the commission has powers to go to the court. My clear understanding was that very special care would rightly be taken before any case was taken to the court by the commission. I would not like to think that just because we were slipping into an administrative route rather than a judicial route the standards would be any less rigorous in terms of getting the evidence, presenting it clearly and making sure that the case against the non-resident parent was just and merited the use of these powers.

I would also like to think that very clear guidance will be given to staff. The impact assessment tells us that 11 staff will be given three days’ training. I am a bit concerned about that. If they start to handle 500 cases a month, as the impact assessment statement tells us, I am not certain that they will have the capacity to be able to do that safely. I hope that the Minister, on behalf of the House, will satisfy himself that the guidance and training that these staff will get is fit for the purpose for which it is being given.

I also note an increasing use by CMEC of ordinary bailiffs rather than court bailiffs, which concerns me. There are some safeguards in using bailiffs who are part and parcel of magistrates’ courts and the sheriff court system in Scotland. Just using a centralised system of bailiffs means that the same care in how some of these orders are prosecuted might not be guaranteed.

Perhaps the Minister would prefer to write to me on this judicial point. I understand that, under the Court of Appeal case of Rowley v the Secretary of State for the Department for Work and Pensions, there is no right of compensation for an action when an administrative procedure of this kind is used as opposed to any other kind of procedure. It would be helpful if the noble Lord, Lord Taylor, anyone else who is interested in this debate and I could be reassured about that important point.

There is also a feeling that the recovery process is mechanical—that it is a steamroller operating automatically. Once the initial series of appeals, reviews and the rest of it are over and it is in the statutory recovery process, there is no avenue for anyone to consider again whether the amount of debt due or the liability is right or whether the assessments have been conducted properly. I have some concerns about that. Noble Lords will know that there is now a welcome introduction to things like the so-called options service, which sometimes give the possibility of a face-to-face interview. More than anything else, people who are subject to this statutory machine for recovery of debt feel that they do not have a chance for someone to listen to their case. I notice that DWP report 503 on relationships, separation and divorce, by NatCen and co-authored by Professor Nick Wikeley and others, found the pursuit of debt to be a remote processing system. If we are using this new administrative heavyweight machinery and there is some evidence that there is a remoteness in the processing system, there is a potential flaw that some people could fall through some of the systems and get hurt in a way that is disproportionate to the liabilities that they were allowed to owe.

Accuracy continues to concern me about the whole operation of the CMEC proposal. Will the Minister ask the department to get the commission to explain how the accuracy figures are supposed to work? I have studied them for some time. The latest figures, for March 2009, show that on the basis of the “right to the nearest penny” test—I do not understand how that test is conceived and put together—84 per cent of the current system was right to the nearest penny, as was 91 per cent of the old system. That does not equate or relate to the evidence on the ground of people saying that their assessments are inaccurate. On the so-called “cash value” accuracy test in the March 2009 figures, 96 per cent of the current system is said to be accurate in terms of its cash value and 98 per cent of the old system is supposed to be accurate. These data are impossible to fathom. I can make no sense of them because they are meaningless. The Minister is careful about these things. Perhaps he will go back and try to make sense of these figures. A letter to explain what is going on to me and, possibly, the noble Lord, Lord Taylor, would be very welcome.

As far as I can see, the last CSA standards report was published in 2003-04. It said that 65 per cent of liability orders were wrong. That was some time ago and I know that there have been improvements, but 65 per cent of liabilities being inaccurate is not a strong base on which to start using administrative powers of this kind. I think that the Minister will continue to take an interest in accuracy.

I think that just short of £4 billion of debt is still to be collected; we will not know until the commission’s next annual report is published. It would be helpful if the Minister could say when that is likely to be. In the past, annual reports of the commission and the CSA have slipped by sometimes for not weeks but months. I just hope that we will get the annual report in July as expected. Only then will we be able to discover what the trends and the outstanding debts are. Knowing when the annual report is to be published would be useful information which might reassure some of us.

In addition to that, the commission has commissioned two reports from PricewaterhouseCoopers. One report is on the age of outstanding debt and the other is about collectivity of the debt. I hope that by now they have been received by the commission. If they have, I trust that they will be published. I hope that the Minister will insist that they are published so that we can all look at the exact trends in relation to the debt.

Finally, the Minister said something about the appeal process which caused a question mark to appear in my mind. I understand perfectly that the Explanatory Memorandum says that there will be an appeal process, which is welcome so far as it goes. Perhaps the Minister will confirm that the appeal process is only about the correctness or otherwise of the laying of the order to the deposit taker. I do not think that it is about the merits of the liable debt. If an appeal is lodged within the 21-day period, can the non-resident parent then say, “Well, I am appealing not because the order has been laid incorrectly to the wrong bank, for the wrong reason or for the wrong amount, but because I cannot afford to pay this because it will affect my second family”? Does the appeal process stretch to a non-resident parent being able to appear in court and say, “Well, actually I do owe X thousand pounds, but for the following 16 reasons I can only afford to pay it back at a reduced rate other than that in the draft order which has been served on me”? If that is true, it would obviously encourage a great many non-resident parents to avail themselves of that appeal. Allegedly, in many cases, some of them have been trying to establish that for a long time.

I know that I have given quite a list of concerns, but I finish by saying that I support the view of the noble Lord, Lord Taylor, and that these orders are required. I hope that they will be used carefully and as a last resort. I hope that they achieve the £2.1 million that they are set to try to recover for children. That is an ambitious target and I will be very surprised if it is reached. But in a year’s time, come 2010, whenever the commission reviews the success or otherwise of these orders, the noble Lord, Lord Taylor, and I, and no doubt other Members of the House, will want to continue to have this discussion to make sure that the orders are being used efficiently and successfully, and to the benefit of the children who, ultimately, are those we are most concerned about.

My Lords, I thank the noble Lords, Lord Taylor of Holbeach and Lord Kirkwood, for their contributions and for their support for this order, although they were not without some questions and reservations. That was the tenor of the debate. Perhaps I may start with the point made by the noble Lord, Lord Taylor, about the number of children who have been supported by the current system, which was the thrust of his question. It is estimated that around 250,000 of the current caseload are not compliant, but looking at the performance over the years and the number of children who are benefiting, as of March 2008, we see that some 749,000 children have benefited from the CSA’s efforts.

Going back to March 2005, the figure was 561,000. Thus the numbers have risen from 561,000 to 623,000 to 740,000 at March 2008, and to a provisional figure based on internal calculations about the impact, post the removal of Section 6 compulsion, of 810,000 at March 2009.

My Lords, I thank the Minister for giving way. I shall try not to interrupt too frequently, but I asked how many children are not receiving any money at all rather than how many are actually doing so. That presents a different side of the equation. If the figures are not to hand, I am quite happy for the Minister to write to me.

My Lords, I am happy to write to the noble Lord in as much detail as I can, but I should stress that some 250,000 of the current caseload are non-compliant—that is, where money is not moving—but they are just the caseload in the statutory system, not those outside it. Some may have been outside the statutory system for a long period while others may be newly outside it once the Section 6 compulsion has been removed. In terms of the amount of maintenance collected, in the period to March 2009 it was £1.1 billion, up from £798 million in March 2005, so more money is flowing.

Both noble Lords referred to the nature of the accounts we are seeking to reach with these orders. The noble Lord, Lord Taylor, said that if they will not facilitate access to joint or third party accounts, that is an obvious loophole, and indeed the same point was made by the noble Lord, Lord Kirkwood. I remember the debates we had on this when we considered the Bill last year. As I said when presenting the order, we are focusing on the accounts that we have identified because we believe they are the most fruitful ones from which to garner resources for children, but if our review shows that the potential loophole is being exploited, obviously we have primary powers to address it, and we would do that. The noble Lord, Lord Kirkwood, made the point that this is really about self-employed people, and he is absolutely right that deductions from earnings orders almost by definition cannot apply if someone does not have earnings in terms of a salary or a wage.

The noble Lord, Lord Taylor, asked about the administration fee. It is set down in regulations and is the sum that will be levied by the deposit-takers for providing their services. Both noble Lords raised issues around the review. If that review leads to the need for further legislation, clearly there will be a consultation exercise and, quite properly, there will be debates in Parliament, particularly when regulations are brought forward. In terms of publishing the impact of that, I am sure that there will be one means or another by which that can happen. Noble Lords are thoroughly adept at securing debates on these issues whether there is a formal Motion before the House or not, and it is important that such debates should take place.

The noble Lord, Lord Kirkwood, referred to the training that was identified in the documentation. I should stress that at the start we are approaching this in a fairly low-key way to make sure that it works properly. I think that a figure of 140 cases per month was mentioned in the impact assessment, but the commission has developed specialist training in conjunction with officials with expertise in the policy. They developed the process with the bank section and detailed guidance is already available to deposit-takers.

My Lords, I do not want to interrupt the Minister either, but I think that the figure is 500 cases a month. I think that eventually 140 cases, steady state, might be successful. My reading of the impact statement is that up to 500 cases are being traded, which is different from 140.

I shall go back to the impact assessment, but I thought that the figure of £2 million was reached by working with 140 cases, which means 1,680 a year at an average of £1,300. That is what drives the sum of £2 million. However, I shall see if further detail on the point is made available by the time I finish my contribution.

The noble Lord, Lord Kirkwood, also said he thought that the commission was not being heavy-handed in its collection processes and that the deduction orders would be a kind of last resort. They will not be in all cases. As I said, we would seek to go down this path only if other mechanisms for trying to encourage non-resident parents to pay proved to be unsuccessful. The arrangements that are currently available to the original Child Support Agency and now the commission comprise deduction from earnings orders, liability orders, bailiffs, third-party debt orders, charges on property, orders for the sale of property, driving licence disqualification and imprisonment. Indeed, in the 12 months to the end of January 2009, a total of 120,970 enforcement actions were carried out. The most recent enforcement figure includes 30 non-resident parents receiving prison sentences, 510 receiving suspended prison sentences, 30 non-resident parents receiving suspended driving licence disqualifications and five being disqualified from driving. We do not apologise for that because it is right that the commission should be tough on those who simply refuse to pay. Indeed, we will have a debate tomorrow during our consideration of the Welfare Reform Bill on further measures set out in that legislation so that we are able to reach those people who will do everything they possibly can to avoid meeting their obligations to their children. It is shocking that this needs to be done, but it is only right that we pursue it. Reverting to the discussion we have just had, I am advised that the noble Lord is right. Some 500 cases per month are dealt with and 140 cases end in deduction, which I believe is the point he sought to press.

On the appeal process, an appeal against the calculation may be made to a tribunal. The grounds for appeal against a lump sum deduction order show that the regulations do not actually restrict the grounds for appeal. For example, an appeal may be made where it appears that the amount set out in the lump sum deduction order is wrong or the liable person considers that a reasonable arrangement to pay has been reached. An appeal may also be made to follow on the commission’s refusal to consent to release frozen funds. However, the circumstances where the commission may give such consent are set out in the regulations and therefore it is implicit that a court would consider a repeal against the commission’s refusal to release funds only if it related to any of those circumstances.

On the grounds for appeal against a regular deduction order, the regulations again do not restrict these grounds. For example, an appeal may be made that the amount of the regular deduction order is wrong or the liable person considers that a reasonable arrangement has been made to pay the arrears again, and it may also be made against any decision following an application for a review of a regular deduction order. In these circumstances it is implicit that the court would consider the appeal only if it related to the circumstances in which an application review can be made as set out in the regulations.

The noble Lord, Lord Kirkwood, sought an assurance that these powers will be used proportionately. Deduction orders will be used only where there are arrears of child maintenance. As I said earlier, the commission will provide the non-resident parent with every opportunity to pay before a deduction order is considered, and there is the right to seek a review. The noble Lord asked for an update on the figures for the age and collection of debt, and I am certainly happy to write to him to ensure that he gets the most recent data we have. He also referred to issues around accuracy. That has been a long-standing challenge for the commission, but the data show that there has been continuing improvement, and certainly the operational improvement plan made a significant step change to the operation of the then agency and now the commission.

The noble Lord, Lord Kirkwood, asked about the Rowley case. I shall get an update on that and make sure that he receives it. He referred to child maintenance and options. That is what we used to refer to as the information and support service when we were debating the Bill. The thrust of that service is to support particularly those parents who were forced to use the statutory system because that is what the legislation required, and to encourage people, again as we debated in the Bill, to seek to make their own arrangements outside the statutory system. It is really focused on that.

I have some data about the extent to which the option service has been used. Since the repeal of Section 6 of the Child Support Act, which, as I said, previously compelled people on benefits to use the Child Support Agency, approximately 260,000 parents with a child maintenance interest have made benefit claims through Jobcentre Plus. All these have been offered support from child maintenance options, with approximately 110,000 accepting the support and 150,000 choosing to decline it. The proportion choosing to accept a referral to options has risen since the launch of the service and currently around 50 per cent of the offers are being accepted. I hope that gives the noble Lord a measure of where we are on that service.

I hope I have answered the points that each noble Lord was pressing; I am happy to come back if they think I have not. I have committed to write to noble Lords on a couple of points and I am happy to do that. However, if there is nothing further, I commend the regulations to the House.

Motion agreed.