In its response to a consultation launched by the government in May on a set of directions aimed at ensuring the BLF’s overall strategy is broadly in line with government policy, the NCVO says that several proposals would force the funder to have an undue focus on government priorities.
It says that three aspects of the directions, which the government is reviewing for the first time since 2012, would have the effect of explicitly aligning the BLF with the agenda of the government of the day, namely: changes to a clause specifying how the BLF should provide "additionality and complementarity" to the government; changes to BLF’s spending priorities; and changes to how BLF is directed to work with others.
The NCVO says that the proposed directions change the clause relating to the principles of additionality and complementarity to put more emphasis on working more closely on current government priorities, which the NCVO says would diminish the BLF’s ability to work with other funders in the sector.
It also has concerns that the new clause could undermine the distinctiveness of the BLF’s funding by adding that the BLF should complement government funding in "areas of mutual policy interest".
The response says: "The perception of BLF’s independence is critical to maintaining the public’s trust and confidence in the good causes element of National Lottery proceeds.
"If the public were to develop the perception that the good causes funding was primarily being used to replace government spending – rather than to occasionally complement it where appropriate – then considerable damage would be done to the reputation of both BLF and the National Lottery more widely."
The response also criticises the proposed changes to the BLF’s spending priorities for the same reason.
The existing directions specify three general priority spending areas for the BLF around social involvement, the capacity of sector organisations and social investment, whereas the government’s proposals extend this to seven priorities which the NCVO says are too specific.
It says that the spending priorities should be sufficiently broad to provide scope for the BLF to be responsive to developing needs among those it funds.
The NCVO is also concerned that the government is attempting to be too prescriptive about the way the BLF should work with other grant-makers, by instructing it to "collaborate, partner and match fund" without making reference to the circumstances where it would be advantageous for the it to do so.
"Without such a reference, there is a risk of creating an obligation for BLF to collaborate regardless of whether this helps further its aims," the NCVO says.
It also urges the government to include a direction for the BLF around providing "full cost recovery" for small and medium-sized voluntary organisations, which it says would help promote this type of funding across the sector, both to other funders and to those drafting applications.
The consultation runs until Friday.