Cover Letter
Ms Kate Gumley
Chair, Homelessness Working Group
Department of Families, Housing Community Services and Indigenous Affairs
PO Box 7576
Canberra Business Centre
ACT 2610
Submission to the National Quality Framework (NQF) Consultation for the specialist homelessness sector
The Council to Homeless Persons (CHP) welcomes the opportunity to make a submission to the National Quality Framework consultation and commends the efforts made by FAHCSIA to support the sector to engage in face to face and written submission to the process.
Please feel free to contact me should you have any questions in regard to our submission.
Yours sincerely,
Michelle Burrell
CEO
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1. Introduction
The Council to Homeless Persons (CHP) welcomes the opportunity to make a submission to the National Quality Framework (NQF) consultation and commends the efforts made by FAHCSIA to ensure that the sector has opportunity to engage in face to face and written submission to the process.
CHP is the peak body representing individuals and organisations with an interest or stake in homelessness in Victoria. Our mission is to work towards ending homelessness through leadership in policy, advocacy and sector development.
CHP supports the objective of 'the Road Home' in achieving a NQF and with other State representative bodies has determined the following principles to guide this work.
2. Guiding principles
- National homelessness legislation that has a consumer outcomes focus, including a right to housing, progressively realised.
- A national quality framework that focuses on consumer participation and outcomes, including a robust complaints mechanism, will support quality service delivery.
- A national quality framework must embed continuous quality improvement (CQI) in both standards and accountability and/or accreditation processes.
- Experience tells us that financial investment will be needed to achieve a national quality framework at both a service and a system level.
- Commitment and resources will be required to support sector capacity and workforce development to achieve sustained service quality.
- While it will be challenging to achieve, we want a response to homelessness identified as a key deliverable in a range of National Partnership Agreements (NPAs), including the NPAs for Disability, Healthcare, Indigenous Reform and Education. We seek clarification for how the Federal Government will achieve this.
- We support a principal of transparency of all parties in service accountability to consumers through consumer participation in service delivery and CQI process; and in relationships between the funded sector, government and potential external accreditation providers.
- A continuous quality improvement process will not occur over night and will require state, territory and federal government commitment to a defined strategic process, including support to organisations to achieve the best outcome.
- We must build on the quality systems and accreditation processes that are already established and embedded in many service funding agreements to recognise existing service quality work and reduce the regulatory burden. Accreditation under an existing specialist homelessness accreditation system should satisfy under the NQF.
- A staged process to the development and implementation of standards needs to allow for the different capacity of services to achieve quality requirements. This will include allowing those more advanced to undertake external accreditation while other services are being supported to achieve service quality.
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3. Previous submissions
CHP submitted recommendations to the House of Representatives Standing Committee on Family, Community, Housing and Youth Inquiry into the content of Homelessness Legislation and have since welcomed the recommendations of the 'Housing the Homeless' (November 2009) report, notably:
- rec. 11. Legislation should provide overarching principles to underpin standards and an accreditation framework; more prescriptive standards should be expressed in complementary non legislative agreements with state and territory governments and service providers.
- rec. 12. A national service charter should be developed to guide mainstream services in service delivery to homeless people and to set specific minimum quality standards for specialist homelessness services, leading progressively to accreditation.
- rec. 13. A national regulatory system based on core standards should be developed in consultation with key stakeholders
- rec. 14. Consultation should occur with key stakeholders at Commonwealth and State levels on the essential components of core standards and an accreditation framework for specialist homelessness services
- rec. 15. Reciprocal recognition of existing quality service frameworks should be ensured.
The following response builds on our 2009 submission through a direct response to four key questions, bearing in mind the goals of the 'The Road Home' report (December 2008). Following this, we discuss and make specific recommendations regarding embedding quality in mainstream agencies work with people experiencing or at risk of homelessness.
4. How do we achieve (continuous) quality improvement across a diverse sector?
Continuous quality improvement (CQI) models where services benchmark their progress against standards and plan and report against specific improvements over time will ensure quality improvement across a diverse sector. While some standards may be generic, the evidence and response to them will vary depending on the type and context of service provision; but quality benchmarks and improvements can be set for any organisation to ensure that it continually improves towards agreed goals and delivers a responsive service to its client group.
A NQF with a strong focus on consumer participation and outcomes will support quality improvement. Continuous quality improvement will be achieved if consumer participation is embedded through a charter, standards and accreditation or other monitoring and review processes if these require organisations to ensure that consumers have appropriate, direct and ongoing input into service delivery goals, objectives and outcomes.
The Victorian quality requirement to develop a consumer participation plan has significantly advanced the thinking of specialist homelessness organisations on the role of consumers in service planning and delivery. A benefit of this approach is that organisations can benchmark goals and progress against their own plan, accommodating sector diversity.
Outcomes of this approach have included improved client feedback mechanisms; regular consumer focus groups; service planning workshops; consumer participation in aspects of direct service employee interviews; and consumer representation on, or reports to Boards. This work has been supported by training kits, workshops and shared resources led by the sector and funded by the Department of Human Services (DHS) through small grants.
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Embedding continuous quality improvement in mainstream organisations working with people experiencing or at risk of homelessness.
To achieve the goals of 'The Road Home', close work between specialist homelessness and mainstream services will require a consistent understanding of quality and a common focus on continuous quality improvement. CHP believe that these goals could be substantially supported by embedding continuous quality improvement (CQI) in the funding or quality requirements of mainstream services in their work with people experiencing or at risk of homelessness. This CQI requirement could be required against the mainstream services' response to homelessness.
Further, this could be entrenched though accountability measures in working with homeless consumers under a universal platform in non-housing National Partnership Agreements. Arguably, these accountability measures could be further operationalised through the inclusion of associated KPIs for Departmental Secretaries.
A further benefit of a shared CQI approach is that NQF outcomes can be effectively measured and celebrated across a diverse sector; and in mainstream sectors. Initial benchmarks are documented, as are planned improvements and outcomes and these outcomes can include consumer feedback.
It is important that a CQI approach does not transition to a quality assurance process; as not only momentum for continuous quality improvement, but opportunities to measure joint and specific sector success over time will be lost.
5. Is there a case for compulsory standards?
Compulsory standards have been welcomed by the Victorian specialist homelessness sector and consumers as
- embedding a common language and understanding of quality in service delivery;
- allowing for a degree of confidence in cross referral; and
- an accountability tool when services are not performing to standards.
Standards have also been welcomed as reflecting the unique work of the homelessness sector, such as a strong rights based focus and taking a holistic approach to people with complex needs, as underpinned in the Supported Accommodation Assistance Act.
This acceptance has been balanced against a strong need and request to reduce regulatory burden and overlap between various service standards. There have been a number of mapping exercises completed, such as the Deloitte's consultation (2008) for the DHS that identified the plausibility of establishing a common set of case management standards while allowing for a small number of specialist standards to reflect different service types. This approach is supported by CHP.
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6. Is there a case for compulsory accreditation?
External accreditation is costly. When achieved through a considered approach in partnership with the sector, this investment will support quality service outcomes, risk management and sector capacity building into the future. Compulsory accreditation does have benefits, but can be a risk if not well timed and supported.
If outcomes are genuinely quality focussed, consideration will be given to 'readiness for accreditation' rather than compulsory accreditation within short, predetermined timelines. If accreditation is enforced without adequate time, resource or support there is a high risk that the process leads to a 'tick the box' approach to quality assurance, not quality improvement. That approach will not support practice reflection and will more likely create a focus on 'quick fix' policies and paperwork, creating sector and consumer cynicism.
A timed, well supported approach will allow for a greater focus on and cross sector confidence in, sector practice, cross referral and work with mainstream services, as outlined in 'The Road Home' report (December 2008). A staged process to the development and implementation of standards and accreditation will allow for the different capacity of services to understand and achieve quality requirements.
- It will support sector knowledge and capability and, if peer support models are encouraged, sector development.
- It will allow those more advanced to undertake external accreditation while other services are being supported to achieve service quality; and allow for learning and practical requirements developed by 'accreditation ready' services to be shared with services with less capacity.
- It will support a more successful and cost effective accreditation outcome.
The Victorian experience of standards development and accreditation work has been seen as successful by most in the sector, although as rushed for smaller services. The standards development work was undertaken over a five year period, with initial accreditation work over two or more years.
Victoria was well placed to achieve accreditation, given earlier work on a Consumer Charter of Rights; so it is expected that a longer period of time would need to be allowed for a NQF to take into account the context and diversity of services across Australia.
Accreditation work at 'arms length' from government will support quality improvement over quality assurance through more open discussion of quality, not compliance. External accreditation providers, or peer support and review models, will support open discussion on challenges and improvement requirements that are not limited by funding relationships or power differentials with government. This in turn supports sector capacity building.
Mutual recognition of and building on the quality systems and accreditation processes that are already established and embedded in many service funding agreements will support a flexible and useful approach to accreditation. Allowing choice of accreditation provider will provide flexibility for organisations. These approaches will also highlight existing service quality work and reduce regulatory burden for services.
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7. How do we support the sector to achieve standards and quality work?
The development of a NQF should facilitate capacity building and sustainability across the sector, consistent with 'The Road Home' requirements. A commitment to resource and support the sector in standards development that includes consumer involvement will support robust and sustainable outcomes.
While quality service delivery is the responsibility of funded organisations, sector accreditation has been an additional requirement in Victoria. There is huge diversity across other sectors in the level of funding provided to organisations by funding bodies to support government required accreditation. Small services, such as youth refuges in Victoria have estimated around $40,000 in direct time and resource cost to reach homelessness specific accreditation readiness. Larger organisations with dedicated quality positions have estimated around $120,000 to reach this stage. Victorian organisations have indicated that this expenditure has limited their capacity to adequately support and resource staff and consumers and to take on any innovative work. Anecdotally, people were working long hours to achieve results, particularly in smaller services and there were concerns about the sustainability of this work.
Quality and accreditation work requires adequate time, support and resource and to take into account accompanying sector development requirement to ensure this kind of service overload is avoided.
Adequately resourced sector support and development positions with good quality ICT capacity will deliver value for investment through capacity to create common resources, run joint projects for like or diverse service types, generate discussion, provide workshops and training, support peer mentoring and generate pro bono support to the work from business and other professions.
Sector support positions have the capacity to liaise with accreditation providers to detect early indicators of areas where sector benchmarks are low, thus planning for training and sector support. These benefits and outcomes have been fed back to the DHS and peak bodies from the Victorian specialist homelessness sector, from the allocation of 1.5 EFT provided across the two key peak bodies throughout the process.
This work has been supplemented by dedicated funds to small projects. Funds are now sought to ensure continuing 'quality improvement' grants to services or groups of services. These are envisaged to support continuing sector discussion and recognition of quality work and support capacity building.
CHP would encourage the Australian government to resource similar positions in state peaks, and in states and territories where no peak exists, to use this opportunity to establish this capacity.
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8. Workforce development
The delivery of high quality service requires a high quality, well supported workforce. We must improve our ability to attract and retain highly qualified, innovative and enthusiastic people to our sector.
CHP welcomes the commitment of 'The Road Home' to enable the sector to achieve much needed workforce development. Consistent with the broader community services sector, the specialist homelessness sector experiences significant difficulty in recruiting and retaining appropriately qualified staff. A major contributing factor is poor pay equity against government or comparable community sectors; followed by 'on the job' stressors such as matching client demand to resource; lack of affordable housing options for clients and staff; competing work requirements; lack of career pathways; and the capability, including infrastructure, of organisations to provide quality supervision and professional development opportunities.
Closer work with mainstream services can be seen as providing new opportunities for workforce development, through shared learning and resources, co-work and collegiate support, dedicated project or specialist work opportunities and employment pathways. Effective results can be achieved if a NQF provides a clear focus on addressing longstanding and increasingly challenging workforce issues. Without this focus, the future sustainability of the sector is at risk.
CHP would take this opportunity to stress that here in Victoria, the workforce is operating to a recognised, accredited standards; that is, we have a quality workforce. That now needs to be matched by both federal and state governments to ensure proper remuneration as part of a comprehensive and meaningful workforce strategy. This needs to specifically include a commitment to fully fund the costs of any outcomes for the national pay equity case, currently being heard.
Thank you for the opportunity to make this submission. If you have any queries, please contact Michelle Burrell on 03 9419 8699 or michelle@chp.org.au.