Ask people working in the social care sector what they think of the children's green paper and most will say they support the government's commitment to children and young people and its vision for the services delivered to them.

However, as the deadline for the consultation on Every Child Matters approaches on 1 December, it is becoming clear that many child care organisations have major doubts about its proposals. Community Care has gauged views to find out what issues agencies will be flagging up to the government in their submissions.

The agenda for children and pace of change
For some groups, the green paper's flaws are fundamental.

Lisa Payne, principal policy officer at the National Children's Bureau, describes the three-tier model that underpins the paper - universal services for all children, support services for children at risk and targeted services for those in the child protection system - "as like three jigsaw puzzles that are trying to be put together".

While Payne supports the establishment of the five broad outcomes against which all services will be judged, she believes the government hasn't thought through how the three tiers of services will meet these. She also argues it is a "significant disappointment" that the Children and Young People Unit's overarching strategy for children was not published, giving more substance to the outcomes-based approach.

Meanwhile, Liz Garrett, Barnardo's head of policy, says the proposals fail to take into account disabled children, refugee children and those in trouble. She is also concerned the government is taking a punitive approach to children.

"The whole tone of the youth justice paper [published with the green paper], when put alongside proposals in the Antisocial Behaviour Bill, suggests there is a different set of principles," she explains.

Helen Goody, senior project officer at the Local Government Association, believes the paper over-emphasises structural changes instead of focusing on outcomes.

Payne describes the government's timescale for change as "ludicrous". Measures to introduce children's trusts, children's services directors and information sharing are expected early next year. Plans for a common assessment framework to assess children's needs are to be designed by March 2004 and introduced next September. But these do not have "a hope in hell" of working in that time period, she adds.

Integrating education, health and social services
Two of the most controversial proposals are for every local authority, by 2006, to appoint a director of children's services with statutory responsibility for children's education and social services; and to set up a children's trust to oversee these services, plus some community and acute health services too.

Fears that this could see the end of social services directors and lead to education becoming the lead agency in children's services have led to criticism from the Association of Directors of Social Services.

A statement from the National Union of Teachers says amalgamating the chief education officer and director of social services roles under a "one size fits all" approach could lead to responsibilities specific to these posts becoming lost or confused. "The sensible desire for greater integrationÉ must not be interpreted as requiring a merger of education and children's social services."

The green paper is surprisingly quiet on bringing children's health services into the mix, especially as Victoria Climbi' was seen by health professionals on several occasions. Connections are made between poor health and the below-average academic performance of the most vulnerable children.

However, Fiona Campbell, co-ordinator of the democratic health network at the Local Government Information Unit, says this is too narrow a view of children's health.

"Improving children's education is ultimately going to contribute towards improving their health but there are other things that impact on this," she adds.

Goody agrees. She says the green paper is not ambitious enough in its view of children's well-being. Youth justice and the police are mentioned "but not explicitly enough".

"Housing and leisure services are crucial to the life chances of children," she adds.

Solicitor Chris Webb-Jenkins, of Browne Jacobson, which specialises in public sector law, says that if the government is serious about integrating health with education and social services then the new children's director will have to take on the statutory responsibility for children's health, including taking over the budget from primary care trusts.

That the green paper is not prescriptive about what children's trusts will be expected to do - "there is no mention of them inheriting duties from the NHS" - makes it difficult to know what legal obligations children's directors will have, says Webb-Jenkins. He can see a situation "where a children's trust can't provide a service because of a funding decision by the primary care trust".

The ADSS supports determining the shape of children's trusts locally, but calls for the government to exercise caution over this "as yet untried model". Integration can be achieved "without the need to establish a separate trust body".

Plans for a lead professional - whether they be a teacher, social worker or housing officer - to be the co-ordinator of services for individual children are given short shrift by groups in many sectors.

The British Association of Social Workers says it could lead to education professionals or housing directors being given control, while the NUT believes the lead professional should be a distinct role and not added onto teachers' existing responsibilities.

Permanence agenda
Baaf Adoption and Fostering says there is no recognition of the impact on children of having the state as a continuous parent.

In its highly critical submission, Baaf calls for a separate policy and funding stream for kinship care supported by performance indicators, to encourage more councils to use it.

It calls for all councils to use the principles of concurrent planning - where two different care plans are developed - for all children who may not be able to return home. Baaf also believes there is a need for a greater expansion of foster care recruitment to meet the government's ambitions.

Resources

One of the key questions has concerned how the changes are going to be paid for. Last week an extra £100m specifically for safeguarding children was announced. The new money will be available from April. But many regard the extra cash as a fraction of what is needed.

Others are concerned about a lack of ringfencing. The NUT submission says: "The danger is that the removal of ringfencing between education and social services funding streams will lead to a lack of transparency and increase the possibility of both services in different areas suffering a loss of funds."

The ADSS supports the idea of rationalising funding streams, and calls for a joint agency approach to commissioning services, but says this alone will not reduce costs.

Children's minister Margaret Hodge believes any extra spending will be offset by savings.

Workforce
Improving the pay and support for the children's workforce should be one of the first proposals introduced according to the ADSS. It adds: "Routes into social work need to be both graduate- and career-based and should be accessible to child care workers as one of the professional alternatives from a common baseline qualification."

The Fostering Network says the green paper continues to view foster carers as volunteers rather than professionals. The network's submission pinpoints the failure of the green paper to deal with allowances for fostered children, payments for their carers and better support.

Vicki Swain, campaign manager at the Fostering Network, describes the green paper as a missed opportunity. "The government wants to recruit more foster carers, and says it is looking for 'radical and imaginative' ways to achieve this. Yet the most obvious way - ensuring foster carers are properly supported, financially and practically - has not been considered."