FIS has submitted its response to the Ministry of Housing, Communities and Local Government’s (MHCLG) Call for Evidence on the Strategy for Built Environment Professions, Trades and Occupations.
In our response, which you can view here, FIS asserted that competence is not only a matter of individual skill or organisational capability, it is a condition created or undermined by how projects are procured, contracted, programmed and governed. Procurement is the control point at which our sector’s four core risks – design, time, cost and cash – are either managed or passed downstream to those least able to control them. The Construction Quality Improvement Collaborative reaches the same conclusion independently, ranking lowest-price procurement and procurement routes as the top two barriers to improving specialist design.
Our priorities, with the questions where each is argued:
- Procurement is the lever. Route, appointment timing, scope and risk allocation decide whether competence can be exercised at all. Put the procurement record, contract and a live Design Responsibility Matrix in the Golden Thread, and use the Procurement Act 2023 to enforce uptake of the Construction Playbook (Q6, Q12, Q16, Q23).
- Fix the design development process. Stages should be evidence-based decision points, not vague milestones, with detail classified as confirmed, nominal or unresolved. 51% of CQIC respondents disagree that design responsibilities are clearly defined (Q23, Q31, Q33).
- Post-award price reduction strips investment out of projects. Around two-thirds of specialists are asked to cut price after appointment. Those cuts come out of supervision, out of value engineering the system, or out of the labour rate — rarely out of margin (Q33, Q38).
- Treat payment as a competence measure. Specialists extend 60–78 days of credit to larger clients; retentions are never released on time for 65% working with national housebuilders. Firms that cannot forecast cash cannot invest in supervision, training or evidence (Q38).
- Training is an absorption problem. Short-notice pipeline, aggressive procurement and poor payment practices remove the return on investment required and force companies to use more contingent labour (Q76).
The full FIS response, which is available here, provides the detailed evidence, recommendations and supporting data behind these positions.