Homelessness NSW welcomes the opportunity to submit to the consultation on the development of a national quality framework. We believe that national homelessness legislation should provide overarching principles to underpin standards and an accreditation framework; more prescriptive standards should be expressed in complimentary non-legislative agreements with state and territory governments and service providers. Such legislation would be an overarching instrument under which other legislation, relating to housing and funding of service providers and support services, would be situated. This national homelessness legislation should have a consumer outcomes focus, including a right to housing, progressively realised.
What is quality service provision?
Definitions of quality service
The definitions provided regarding quality service provision capture the broad range of characteristics that a good quality service should possess.
Legislation and standards that are framed within a human rights perspective will deliver quality services that focus on the rights of individuals who use them. A national quality framework that focuses on consumer participation and outcomes, including a robust complaints mechanism, will support quality service delivery.
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What is needed in an NQF to take into account the scope and diversity of service responses across Australia and to ensure these are maintained?
To capture the scope and diversity of service responses across Australia, Homelessness NSW suggests that a generic set of standards be developed that all services report to. A further set of standards could be developed for specialist homelessness services to capture the characteristics of crisis and other service models.
Do you agree with the characteristics of quality service provision as outlined?
A national quality framework must embed continuous quality improvement (CQI) in both standards and accountability and/or accreditation processes. Across Australia, services will be at different levels of development regarding the development of quality systems
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.
What other key characteristics or elements should be included to describe quality service provision?
A philosophy of continuous quality improvement embeds quality as a core part of all service business, rather than a point in time activity that becomes a chore to achieve. Service quality must be continually reviewed and redefined in accordance with changing need.
Quality service provision is innovative and able to respond to changing consumer and political need guided by mechanisms such as state and federal homelessness strategies. CQI frameworks support innovation through inspiring leadership at all levels of the organisation.
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Mainstream and allied services
How can mainstream and allied services be encouraged and supported to identify and respond to people who are homeless or at risk of homelessness?
While it will be challenging to achieve, Homelessness NSW seeks 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. Without this mechanism, experience tells us that it will be a challenge to gain the engagement of the broader service system in accepting their responsibility regarding homelessness prevention and service access.
Homeless people with complex needs such as acquired brain injury or co-morbid mental illness and substance misuse issues for example regularly fall through all the service gaps due to siloed service responses and thinking. Without mandated targets that State and Territory governments must deliver on, it will remain a challenge to gain the input of mainstream and allied services.
What quality approaches support stronger cross sector service integration and improved service delivery?
Development of a NQF must include adequate resourcing to support a major communication strategy across Australia, including joint education, training and support for service integration. As universal services should already be working with homeless people and those at risk of homelessness, this should enhance and build on mainstream regulatory systems currently in operation.
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Potential components of a national quality framework
Homelessness NSW supports the development of an NQF utilising a CQI approach:
- A focus on quality and not just on accreditation will, over time, support the broad change management process that is underway for service delivery to homeless people and those at risk of homelessness.
- A staged approach to CQI that supports services to embed quality in their service delivery, rather than a focus on passing a 'point in time' accreditation process.
- A national quality framework that focuses on consumer participation and outcomes, including a robust complaints mechanism, will support quality service delivery.
- Mechanisms to reduce regulatory burden, building on what is already in place. Assessment of the range of regulatory and quality mechanisms already used across programs such as codes of practice, guidelines, charters and CQI programs must be undertaken to establish benchmarks and streamline additional work required to address specific homelessness standards across the whole government / non government service spectrum.
- 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.
- Investment in the process to support development of sustainable systems and outcomes. CQI is a leadership and management tool for assessing and improving an organisation. Whole of organisations need to be supported to achieve and sustain quality requirements, not just individual workers or specific services.
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How would a national quality framework relate to existing state and territory quality systems?
Homelessness NSW advocates strongly for a framework that acknowledges the quality work already achieved within the homelessness sector. 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.
Other quality frameworks
What lessons can we learn from existing quality frameworks?
NSW experience in undertaking CQI within the NGO health arena has been highly effective in supporting the development of robust, client focussed services. A key component of this work has been the resourcing of support workers within the NGO sector to assist services as part of the change management process.
What would you change in existing quality systems to improve outcomes for people experiencing homelessness?
- Reduce and streamline workload in meeting standards as part of reducing regulatory burden. This is important to support the diverse range of service size and models.
- Develop generic service standards for multiple service providers, with a smaller set of more detailed standards for specialist homelessness services, reflecting their core business and expertise.