GUIDANCE ON THE CAREER FRAMEWORK FOR HEALTH

Transcription

1 Health Workforce Directorate Workforce Planning and Development Unit Education and Training Team T: F: E: NHS Board HR Directors Regional Workforce Directors NHS Board Workforce Planning Leads Copied to NHS Board Chief Executives 11 March 2009 Dear Colleague GUIDANCE ON THE CAREER FRAMEWORK FOR HEALTH This letter provides NHS Boards with guidance on the role of the Career Framework for Health which was launched by the then Minister for Health & Community Care in October In particular, it responds to requests from NHS Boards for: (a) some clarity about the relationship between the Career Framework, the Agenda for Change Knowledge and Skills Framework (KSF) and the Scottish Credit and Qualifications Framework (SCQF); and (b) some details about several demonstration projects currently underway which are intended to provide practical examples of how the Career Framework can be used, in conjunction with the NHS KSF. The guidance also makes clear, again in response to requests from NHS Boards, that the Career Framework is an enabling tool. It is designed to support NHS Boards with workforce planning and service redesign and to help individual members of staff, with transferable, competence-based skills to progress in a direction that meets workforce, service and individual needs. Use of the Career Framework is not mandatory and does not supersede or detract from the obligations on NHS Boards in relation to Agenda for Change. The KSF remains the overarching competency framework for NHS staff and the target of ensuring that all relevant employees have an agreed 1

2 KSF Personal Development Plan by 31 March 2009 is not affected by this guidance. This guidance has been developed in collaboration with Skills for Health and NHS Education for Scotland (NES) and has benefited from input from HRDs, SWAG and Regional Workforce Directors. I am very grateful for all those contributions to what has been a complex piece of work. Further information about the Career Framework is available on the Skills for Health Website ( Any queries about this letter or the attached guidance should be directed to Sally White, Workforce Planning and Development Unit, Health Workforce Directorate, Scottish Government (sally.white@scotland.gsi.gov.uk). Action NHS Board HR Directors are asked to ensure this letter is brought to the attention of all Area Partnership Forums. Yours sincerely Ricky Verrall Head of Workforce Planning and Development Unit 2

3 Annex 1 Career Framework what is it? Changing demands on the NHS require a workforce which is well trained, flexible and adaptable. The Career Framework for Health is a UK wide development conceived by the Department of Health and subsequently passed to the UK Sector Skills Council (Skills for Health). It was launched in Scotland in October 2006 following positive and constructive responses to a Scottish Government consultation exercise. It can support NHS Boards in meeting those demands through workforce planning, service redesign and implementation of flexible career routes for all NHSS staff (not just those in Agenda for Change pay bands). The Career Framework is an enabling tool which sets out a common language and currency to support career planning. It does this by mapping the entire NHS Scotland workforce into a nine level core skills and competences framework. The nine levels represent a clustering of roles which are grouped according to complexity, responsibility and the level of experience and knowledge needed to carry them out. These nine levels do not directly read across to Agenda for Change (AfC) pay bands and it is important to note that the Career Framework has no direct link to pay. It is concerned only with defining the level of knowledge, competence, responsibility, and associated experience, required for the delivery of roles within NHS Scotland. The Career Framework model is shown at Annex 2. At present, this model has been used most extensively with clinical staff and the clinical titles associated with the nine levels reflect this. However, what the Career Framework attempts to capture and provide structure for is the wide range of jobs and roles available in the NHS, clinical, non-clinical and other support roles, that have not traditionally benefited from a career progression framework. It defines the practice and competence needed at each level of the framework which, in turn, allows for the benchmarking of existing roles/individuals and the identification of comparable roles across professions/staff groups. The roll-out of the Career Framework and the existence of other different national frameworks has led to some confusion amongst stakeholders. The different frameworks are described more fully below in the section headed How Does the Career Framework Relate to:. In drawing this guidance together we have encountered the view from some 3

4 stakeholders that much of what the Career Framework is intended to deliver can also be secured through the application of the tools provided by Agenda for Change, including the Knowledge and Skills Framework (KSF). However, Agenda for Change does not apply to all staff groups and some service users have stated that they find the Career Framework more visually engaging when presenting workforce information. Successful use of the Career Framework, for individuals covered by Agenda for Change is dependant on all staff having robust KSF outlines and Personal Development Plans (PDPs) so that career planning and role redesign can be realised. Using the KSF and Career Framework together as appropriate can help design new ways of working by thinking in terms of competences and using these as building blocks, rather than thinking solely in terms of staff grading or pay band. The starting point is to determine what the member of staff is required to do in their role and identify a suite of competences which can be incorporated within the KSF post outline. Building from there, the Career Framework helps to put into context where a post sits within the nine level framework and may give an indication of an aspirational route that individual staff can follow to secure their career goal. Each of the different national frameworks relates to the central theme of how best to describe the level and range of knowledge and skills needed within NHS Scotland. Used in combination, these frameworks provide an important set of tools for HR staff, trainers and workforce planners. How Does the Career Framework Relate to: Agenda for Change Agenda for Change is the system of pay and conditions of service for many staff in the NHS (it does not include doctors, dentists or the most senior management layer) and incorporates three key strands: - Job Evaluation: The job evaluation system has been designed to ensure equal pay for work of equal value and provides a robust method of evaluating the wide range of jobs in the NHS. It considers 16 different factors and can be used to assess changing roles quickly and accurately. This ensures that staff are paid according to the job they do, recognising the knowledge and skills required, level of autonomy and many other factors. 4

5 - Terms and Conditions of Service: Harmonised conditions of service have been introduced under Agenda for Change including hours of work, leave arrangements and overtime payments. This helps break down some of the barriers that previously existed and supports the development of flexible roles to meet service re-design. - The Knowledge and Skills Framework (KSF): This is the overarching competency framework for many NHS staff. Every AfC post will have a KSF outline based on the job description for that post detailing the knowledge and skills to be applied within the post. Employees and their line managers are required to have a joint discussion on the knowledge and skill requirements detailed within the KSF post outline and agree development needs through the KSF Development Review Process. This review process is the means for providing evidence of continuing capability and development within the post. Agreed development needs and how these will be met are recorded on KSF Personal Development Plans. NHS Boards have been set a target of ensuring that all relevant employees have an agreed KSF Personal Development Plan by 31 March Used in conjunction with the KSF, the Career Framework is a tool that can support both individual development and workforce planning. It also allows service/ team structures to be drawn up as part of service redesign. The Scottish Credit and Qualifications Framework (SCQF) The SCQF is a national framework that can be used to describe and compare achievements in learning. It uses two measures to describe qualifications and learning programmes: level (how complex) and volume (how much). The framework comprises 12 levels, and can be applied to all forms of learning, from academic and vocational qualifications to learning in the workplace. Each SCQF level includes a variety of different qualifications and their associated credit points. Level descriptors exist to show how each level becomes increasingly demanding by changes to factors such as complexity and depth of knowledge, links to associated academic, vocational or professional practice, and the degree of autonomy exercised by the learner. These descriptors set out the characteristic generic outcome of each level. They are intended to provide a general, shared understanding of each level and to allow broad comparisons to be made between qualifications 5

6 and learning at different levels. More details are available at This is not to suggest that if a member of staff attains a certain qualification they can expect a corresponding pay band. This would not be the case. Just as there is no direct read across between Agenda for Change pay bands and level descriptions in the Career Framework, there is no direct read across to the Career Framework or Agenda for Change for qualifications mapped to SCQF. Attached at Annex 3 is a table showing indicative SCQF levels and example qualifications at various levels of the framework. These are illustrative examples only in order to offer guidance to staff using the Career Framework. National Occupational Standards (NOS) and National Workforce Competences (NWC) Both NOS and NWC underpin the Career Framework. NOS and NWC share the same robust development process in healthcare settings and are devised by Skills for Health in partnership with the health and social care sectors. They are statements of competence, describing the skills and knowledge needed to carry out a wide range of work; and set the standards for how that work should be carried out. Skills for Health has created an extensive database of competences, each related to a different health-related task or function e.g. mental health and renal care. The UK database of NOS is linked to NHS KSF and can be accessed through the Skills for Health website or through e- ksf. ( ). Both NOS and NWC describe the performance criteria, knowledge and understanding that are required to carry out work effectively. They describe what individuals need to know and do regardless of which role is performing a particular activity. NOS and NWC are essentially the same, having been through the same initial quality assurance process. The only differences are the way in which they are funded; and that NOS have gone through an additional approval stage for use in support of SVQs, which are themselves mapped directly onto NOS. Both sets of competences are methods for NHS Scotland staff to demonstrate they have the knowledge and/or skills necessary for the roles they are in, whether or not those roles require a specific educational or vocational qualification. 6

7 How Does the Career Framework Help Staff A crucial part of the thinking behind the Career Framework was that it should encourage lateral as well as vertical career progression in other words it should help to simplify the process for moving from one role to another at the same level of competence, or to prepare for the competences that are needed when planning a vertical career move. For example, when populated with exemplar Agenda for Change job descriptions and KSF post outlines, the Career Framework enables a member of staff to plan their progress across existing professional areas or to plan a second career. When used in conjunction with KSF the Career Framework can support an individual member of staff by: More clearly illustrating career options; Supporting career moves in all directions; Encouraging skills development based on competences; Allowing an individual to identify their transferable competency based skills clearly; and Allowing an individual to consider more fully their own developmental needs for career progression. How Does the Career Framework Help Improve Patient Care and Provide Organisational Benefits? The NHSScotland workforce must be flexible, competent and confident of their ability to provide quality accessible modern health care. The organisation and patients benefit from skilled staff that have the competences to deliver modern health care. The Career Framework, taken together with the NHS KSF, shows how an individual can work in NHS Scotland and develop, through changing roles and learning at work, transferable competency based skills in a way that meets their needs, organisational needs and patient needs. How The Career Framework Relates to The Workforce Response to Better Health, Better Care A Force for Improvement The workforce has a significant role to play in the implementation of the Scottish Government publication Better Health, Better Care: Action Plan which sets out a series of actions to bring the concept of a mutual NHS to life. A Force for Improvement: The Workforce Response to Better 7

8 Health, Better Care is a workforce framework which sets out the vision for the NHS Scotland workforce within the wider UK and global context. It describes the challenges to be faced and identifies the strategic actions required to deliver the vision while protecting flexibility at local level. The Career Framework sits as an enabling tool under that as a flexible careers and skills escalation structure allowing individuals to progress in a direction that meets the needs of the workforce, service and individual. How Does the Career Framework Help With Role Redevelopment The Career Framework, taken together with the NHS KSF, can support NHS Boards in the design and implementation of new roles. For example, when service areas are being redesigned, rather than thinking of the profession or grade of staff undertaking each of the roles, consideration could instead be given to the competences required to get the job done. This in turn can lead to the development of new roles and/or the benchmarking of existing roles against the required competences and level of practice. Staff who aspire to take on the role can then identify what the required competences are, assess the extent to which they currently have those competences and, if they fall short, plan their development as appropriate. At an organisational level, identification of competences for new roles within the NHS can be used to direct training and education provision, and identify organisational planning needs. More guidance and detail in validating a particular level within the Careers Framework is available through the Skills for Health website: The CF level descriptors contained there provide details of each level over 8 areas:- Knowledge, Skills, Training and Experience Supervision Professional and Vocational Competence Analytical/Clinical Skills and Patient Care Organisational Skills and Autonomy/Freedom to Act Planning, Policy and Service Development Financial, Administration, Physical and Human Resources Research and Development 8

9 The descriptors set out the generic characteristics of each level. The final Career Framework level is the result of a calculation which takes into account the different levels in each area in relation to the job description and KSF post outline. Therefore it is not necessary to be at the same level right the way across the descriptors. It is weighted according to the importance of that descriptor for that job. Skills for Health are currently developing a web based tool which will attribute a CF level to a role. This should become available July 2009 and in the meantime Skills for Health can advise on the level for a role should that be necessary. How Does the Career Framework Help Workforce Planners The Career Framework provides an opportunity to consider workforce planning in a different way. By using Career Framework based Workforce Profiles (Xmas Trees), workforces can be aggregated to produce a visual representation of the organisation, service or department by Career Framework level. A toolkit to support workforce planners in this process can be accessed through the Skills for Health website: For example, the tool can be used to illustrate a desired profile or skill mix for a particular service area; or to take stock of the effect that workforce redesign has had, or will have, on the shape of the existing workforce. In this way, workforce planners, along with service and financial planners, should be better able to formulate strategies to meet their preferred profile e.g. by developing new roles and/ or individuals, or by directly recruiting to new posts. This approach may be of particular use to workforce/service planners and professional leads when considering their future workforce projections which are required to be submitted to SGHD on an annual basis. The visual representation of their current and future workforce may assist determining the impact of skill mix. In using the tool with actual staff numbers, NHS Boards: can review the career pathways that are available and highlight potential staff progression difficulties; identify where both strengths and gaps exist in terms of staff competences across the workforce; 9

10 see potential difficulties in the staffing profile i.e. too few or too many staff at a particular level; and show the profile they are aiming to achieve and the related effect that these activities would have on the shape of their workforce. Xmas Tree Modelling Diagrams Xmas trees provide a visual representation of the workforce based on scales that indicate increasing skill levels. They can be produced using either the 9 levels of the Career Framework or the Agenda for Change pay bands as shown in the following examples. Diagram 1 shows the whole workforce mapped to the Career Framework model. Diagram 1. Total NHS workforce by Whole Time equivalent Each of the nine branches of the tree represents the number of staff working at each level of the Career Framework. A typical profile of the NHS workforce would have narrower branches at the top and bottom and wider ones in the middle, resembling a Xmas tree. 10

11 This approach can be used to represent: the whole NHS Workforce (including those staff not covered by Agenda for Change); particular areas of activity, or patient care; or particular locations e.g. an individual NHS Board Diagrams 2 and 3 show two other types of Xmas tree mapped to Agenda for Change pay bands : Diagram 2 is a Service tree which shows all the different staff working in one service, in this example, endoscopy. These types of tree are useful for analysing the skill mix in a multi-professional team. Diagram 3 is a Staff group tree, showing all the staff in one group, Healthcare Scientists in this example. These can be used to highlight potential opportunities for, or problems relating to, career progression. 11

12 Diagram 2 Endoscopy service tree Diagram 3 Imaging staff tree 12

13 Modelling the workforce using Xmas trees, or combinations of them, can enable current and/or future workforce scenarios to be represented in a visual way. This allows workforce planners, service planners and financial planners to reach a common view of the workforce situation. Individual and Team Profiling Analysis of current staff deployment models show widely varying patterns of staff carrying out the same tasks in different settings. In some cases this means that staff are spending time doing things that are really for others. The Career Framework can be used to carry out an individual or team assessment by looking at jobs or roles in terms of clusters of competences required for specific functions that are not based on staff groups or grades. Analysis of competences required for those tasks allows for more streamlined staff patterns and possibly standardised models to emerge, freeing up staff time which might serve to shorten the patient s journey through care or allow more patients to be treated. This would lead to potential productivity gains (good for service and patients) and proper matching of staff skills to functions (good for staff and patients). There are 2 tools to support workforce planners in the process:- The first can be accessed through the Skills for Health website: The second is a skills maximisation toolkit which can be accessed through the NES website : Consistent Use of Level Descriptions Currently, within Scotland, there are near identical jobs which have been given a variety of titles. Similarly, there are posts with the same title but with different roles, responsibilities and competences. Like AfC, the Career Framework provides a common language that facilitates the description of the level of jobs as well as roles, skills and educational qualifications across the NHS Scotland workforce. The consistent use of titles and level descriptions provides greater clarity for all stakeholders and supports good governance regarding role expectations, educational preparation and impact evaluation. For example, recent work regarding the Advanced Nursing Practice Toolkit 13

14 has used level 7 of the Career Framework to benchmark this key level of nursing practice, the core and specific competencies, exemplar job descriptions and educational development needs in a consistent and transferable way. (See - ) Working in this way to provide guidance and tools supports: Employers and service leads - to support consistent planning and decision-making regarding the development of such roles, where they may already exist and where they may need to be developed. Education providers - to provide a focus for the development, provision and dissemination of programmes of educational development which meet the key elements of this level of practice and match closely with the expectations and requirements of employers, commissioners and practitioners themselves. Practitioners - to measure their own development, capabilities and role expectations against a consistent benchmark for this level of practice. Similar work can be undertaken for each level of the Career Framework. Equality Assessments The Career Framework has been impact assessed at a national level under equalities legislation and has been shown to have no negative impact on diversity. Use of the Career Framework is more likely to enhance and promote diversity as the process of data gathering is developed and becomes more robust and streamlined. NHS Boards in Scotland are asked to undertake equality impact assessments on their local implementation of the Career Framework. Demonstration Projects It is recognised that NHS Boards may need some clarity about the practical implementation of the Career Framework. To this end the Scottish Government Health Directorate is working with, and providing financial support to, three Boards on four demonstration projects that relate to levels 2, 4 and 7 of the Career Framework. See annex 4 for more details. 14

15 CAREER FRAMEWORK MODEL Annex 2 S K I L L S & C O M P E T E N C I E S L E A R N I N G & D E V E L O P M E N T LEVEL 9 (MORE SENIOR STAFF) Staff with ultimate responsibility for decision-making and full on-call accountability. LEVEL 8 (CONSULTANT PRACTITIONERS) Staff working at a very high level of clinical expertise and/or have responsibility for planning services. Non-clinical examples might be, for example Divisional Manager. LEVEL 7 (ADVANCED PRACTITIONERS) Experienced clinical practitioners with high level of skill and theoretical knowledge. Will make high level clinical decisions and manage own workload. Non-clinical staff will typically be managing a number of service areas. LEVEL 6 (SENIOR PRACTITIONERS) A higher degree of autonomy and responsibility than level 5 in the clinical environment. Non-clinical staff who would be managing one or more service areas LEVEL 5 (PRACTITIONERS) Registered practitioners consolidating pre-registration experience and getting ready for a higher level of functioning. Non-clinical examples might include Management Acccountant LEVEL 4 (ASSISTANT PRACTITIONERS) Some work involving protocol based care under the supervision of a registered practitioner. Non-clinical roles can include IT support worker and Technician. LEVEL 3 (SENIOR HEALTHCARE SUPPORT WORKERS) Higher level of responsibility than Healthcare Support Worker. Non-clinical roles can include ward clerk and community food worker LEVEL 2 (HEALTHCARE SUPPORT WORKERS) Works under the direction and supervision of healthcare professionals and supports the multidisciplinary team in the delivery of high quality care Non-clinical examples are housekeeper and receptionist. 2 LEVEL 1 (SUPPORT WORKERS) Non-clinical staff in roles that require very little formal education such as catering assistant or domestic assistant. 1 The diagram outlines the Career Framework Levels, the appropriate Clinical level title (in brackets), a brief clinical level descriptor and, for illustration, some possible non-clinical role examples 15

16 Note: This diagram at Annex 2 is a slight adaptation of the version on the Skills for Health website and from the one formally launched in These adaptations are simply to reflect generally recognised terms in Scotland, which may differ from those used elsewhere in the UK (eg at level 4 we have used the term assistant practitioner rather then assistant/associate practitioner). They do not affect the substance of the Career Framework or represent a departure from the Career Framework launched in

17 CAREER FRAMEWORK LEVEL INDICATIVE SCQF LEVELS Annex 3 EXAMPLE QUALIFICATIONS LEVEL 9 LEVEL 8 LEVEL 7 LEVEL 6 LEVEL 5 LEVEL 4 Level 11/12 Masters Degree Doctorate SVQ5 Level 11/12 Masters Degree Doctorate SVQ5 Level 11 Post Grad Certificate/ Diploma Masters Degree Level 9/10 Ordinary or Honours Degree Graduate Diploma SVQ 4 Level 8-10 Diploma HE Ordinary or Honours Degree SVQ 4 Level 7/8 HNC HND LEVEL 3 Level 6/7 SVQ3 HNC LEVEL 2 Level 5/6 SVQ 2 LEVEL 1 Induction Standards For Healthcare Support Workers (HCSW) Note: The levels on the framework are indicative only. They can be broadly linked to qualifications and SCQF levels but this will only be a rough guide there will be exceptions. Learning required at each level will vary according to the occupational groups into which the role falls and the KSF outline for each particular role. However, in general, the following level(s) of qualification (in areas related to the work being undertaken) might be expected for roles which appear at the same level of the Career Framework. The learning required for each role should be considered in conjunction with the Career Framework level descriptors 17

18 Annex 4 Demonstration Projects The four demonstration projects are underway in NHS Lothian, NHS Greater Glasgow and Clyde and NHS Tayside and should, when complete, provide Boards with a clearer picture of the practical implementation and benefits of the national Career Framework in Scotland. It is anticipated they will also show the relationships between the Career Framework and other workforce development tools/frameworks, for example Agenda for Change, the KSF, the SCQF and NOS. There is a methodology for collecting data across the project sites to capture and share learning and a forum to bring the Boards together to share experience and problem solve. It is intended to produce and publish case study material from the projects, and undertake a collective impact assessment and evaluation of the projects once they are complete. It is anticipated that the evaluation reports and analysis resulting from these projects will further support Boards in understanding better how the Career Framework can be used to benefit their organisation. A summary table giving more detail of each individual site is overleaf. 18

19 PROJECT TITLE Generic Support Worker (Level 2) Mental Health & Learning Disabilities Services (Levels 2 4) ORGANISATION NHS TAYSIDE NHS LOTHIAN Advanced Practice in the Care of Older People (Level 7) NHS GREATER GLASGOW & CLYDE Allied Health Professional (AHP) Advanced Practitioner in Acute Medical Receiving (Level 7) NHS GREATER GLASGOW & CLYDE DESCRIPTION Assist those exiting the 20 week SVQ2 level programme (which provides 50% of an SVQ2) and entering NHS employment at level 2 of the CF. The funding received will enable the cohort to complete the last 50% of the SVQ2 in the workforce. To assist workforce development in integrated mental health and learning disabilities teams and introduce new roles from levels 2, 3 and 4 of the CF in mental health and learning disabilities services. To scope the role of existing Care Managers within Rehabilitation and Assessment Directorate and develop a model of advanced practice in the care of older people for a nurse or AHP. Develop an Advanced Practitioner role crossing boundaries of Physiotherapy and Occupational Therapy within Acute Medical Receiving. By capitalising on shared expertise, extending current roles to provide a more flexible service which is more responsive to patient needs and current service demands. 19

20 PURPOSE & AIMS The SVQ2 programme is run by the NHS Tayside Healthcare Academy. The Academy aims to help unemployed and excluded groups into employment and long term healthcare careers. The 20 week programme aims to broaden the existing recruitment pool and develop a more robust skill mix. Also to clarify the different competency levels of the support staff to enable progression and development. To develop new and advanced roles to mitigate the impact of MMC. It will provide a supporting structure to facilitate workforce development. Scope current roles equating to levels 2-4. Identify and agree roles, job descriptions and KSF outlines. Identify and pilot specific training packages Evaluation. Key driver is to make care of older people more attractive career option. To review related current roles and assess fitness for purpose To design a new and sustainable role at the Advanced Practitioner level (level 7 of CF) incorporating clinical, education, leadership and organisational skills. Further develop/reinforce competency based approach to role design and skill acquisition. Aims to eliminate duplication and improve multi-disciplinary team working. Real challenge to get staff out of professional silos and embracing the benefits of cross team working. Further develop/reinforce competency based approach to role design and skill acquisition. Ensure that competences developed use NOS and KSF. Support vertical/horizontal career progression and succession planning. 20

21 Ensure that competences developed use NOS and KSF. BENEFITS & OUTCOMES Improve retention by maximising potential of support staff. Build transferable skills/development opportunities for support staff Work towards competency based model of care delivery. Create a workforce which matches patient need/ is flexible to change. Evaluation on various levels: Contribution to overall redesign of clinical teams and services. New role profiles to be utilised and shared Employees can enhance and develop nationally recognised skills leading to career progression. Patient will be cared for by healthcare support worker/assistant practitioner who is fit for purpose. Better use of beds. Improved patient care through co-ordinating role. Advanced clinical skills. Transferable skills/development opportunities for staff. Improved multidisciplinary team working. Evaluation of case manager role. Improve patient care, through quicker initial response / increased throughput by reducing duplication. Advanced clinical skills. Transferable skills greater development opportunities for staff. multi- team Improved disciplinary working. Evaluation of specialist therapy case management role. 21

22 Academy s programme Placements Students individual progress Their individual contributions to the departments where placed. Wider considerations eg social inclusion, Dundee jobless stats. Evaluation of the project itself and its use of the CF. Reduced length of stay (to help achieve 18 week targets). Enhanced and sustainable job opportunities within Board. Address recruitment and retention challenges within specialty. Evaluation of the project itself and its use of the CF. Reduced length of stay. Enhanced sustainable opportunities. and job Address recruitment and retention challenges within work area. Further integration between professionals. Evaluation of the project itself and its use of the CF. Evaluation of the project itself and its use of the CF. 22