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Queensland Shelter and Homelessness Task Force – National Quality Framework response
This national quality framework consultation response has been prepared by Queensland Shelter in consultation with the Homelessness Task Force, homelessness service providers, and people experiencing homelessness. These parties chose to concentrate on questions of specific interest, which were raised during our discussions, trusting that issues not addressed in this submission will be covered in other responses.
Question one: What is needed in a NQF to take into account the scope and diversity of service responses across Australia and to ensure these are maintained?
The Homelessness Task Force (HTF) and Qld Shelter believe that first step in developing a National Quality Framework will involve an audit of existing State and Territory standards agreements, at departmental and service agreement levels, to identify strengths, commonalities, and examples of good practice to be included within an NQF.
Development of an NQF should recognise and complement existing initiatives designed to improve service delivery, establish common standards, and reduce administrative compliance burdens.
For instance, the Queensland Compact provides an example of current initiatives germane to an NQF. Within the compact, the Qld Government agrees to actively reduce duplication, compliance costs, and unnecessarily prescriptive funding agreements, while the Qld Government and not-for-profit sector undertake to work together to investigate and implement improved funding arrangements that balance expectations and funding levels. The NQF should build on existing groundwork in the areas of streamlining quality compliance and mutual recognition of standards.1
Current Compact undertakings that may support the development of a NQF include improving online reporting capabilities to reduce services' administrative burden.
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The HTF and QShelter support FAHCSIA's intent to standardise delivery of quality services. However, HTF are concerned that new standards may lead to the creation of preferred providers such as large entities that are better resourced to meet increased compliance and reporting requirements, to the detriment of smaller organisations.
HTF and Qld Shelter agree that quality standards should avoid repetition, be applicable regardless of service type, size location, or structure, contribute to quality outcomes for clients, and not duplicate contract management processes2.
HTF and Qld Shelter believe that while homelessness services should be held accountable to higher standards than mainstream agencies, the latter will benefit from the adherence to common standards such as those currently being developed by the Department of Communities. We believe that the NQF should also inform service delivery for entities including Qld Health, local government authorities, police services, and public transport utilities.
New standards should not increase a service's administrative burden. Existing accreditation under Communities and Housing standards should be recognised under a national system. Additional compliance imposts should be matched by equivalent funding and resourcing or they will detract further from client contact at a time when services are negotiating reduced outcomes under new service agreements, while trying to absorb increased staffing costs. The outcome of the national equal pay campaign and test case before Fair Work Australia, seeking a 17% wage increase for social and community workers nationally, may have a similar effect upon all state and territory services.
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An NQF should take into account the scope and diversity of existing responses by:
- Including an audit of existing state and territory service standards to identify best practice,
- Complimenting existing initiatives, such as the Queensland Compact, to streamline quality compliance and mutual recognition of standards,
- Supporting common standards such as those currently being developed across the Qld Department of Communities portfolio,
- Avoiding repetition while applying to all services regardless of size, location, or structure, and
- Recognising compliance with Qld community services standards and housing accreditation
Question Three: How can mainstream and allied services be encouraged and supported to identify and respond to people who are homeless or at risk of homelessness?
The Qld Department of Communities is currently developing a set of common service standards across five areas including human and legal rights; governance and organisational management; human resources; safety, wellbeing and rights; and feedback, complaints, and appeals, which may be applicable for Communities, Child Safety, Disability Services, Housing and Homelessness, Community Mental Health, Home and Community Care, and Queensland Health service areas. While the common standards would also apply to NGOs, their application should be expanded to include all state and federally funded services that have contact with people experiencing or at risk of homelessness such as transport, police and education, local government authorities, corrective services, and justice.
The Productivity Commission's report on the contribution of the not-for-profit sector - members of which may be defined as allied services - and recommendations on establishing a national regulatory environment state that:
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The lack of simple, consistent, and equitable regulation has a direct, negative impact on the sector, resulting in higher compliance costs for no greater protection of stakeholders....As a consequence, resources that would have been best used to serve the community, including assistance provided to low income and disadvantaged people, are drawn into unnecessary, administration and compliance costs.
NFP's compliance costs are minimised when they have to face a single clear set of requirements... with common reporting standards and requirements where one report satisfies most, if not all, requirements. 3
The NQF should be contained in funding agreements with not-for-profits in instances where the government purchases specialist services or invests in developing sector or service capacity of NFPs.
HTF and Qld Shelter support Homelessness Australia's recommendation that homelessness responses, including minimum service standards, should be contained within national disability, health care, Indigenous reform, and education partnership agreements.
The Homeless Persons Legal Clinic submission, cited in the Housing the Homeless - A National Standards and Accreditation Framework for Services, argues that allied and mainstream services can be encouraged to improve service delivery for homeless persons through the inclusion of minimum service standards in prospective homelessness legislation:
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In addition to these standards, the new legislation could provide a Charter of Rights and Responsibilities for Consumers that clearly sets out their rights, responsibilities and mechanisms for redress when their rights have been violated. This approach would provide a national framework of rights and minimum standards while at the same time not being so prescriptive as to be only applicable to a small set of services. 4
HTF and Qld Shelter support the establishment of a national charter of consumer rights for people experiencing homelessness.
HTF and Qld Shelter also agree that improving accountability measures, which are often limited to internal grievance procedures, and compliance monitoring may be done by developing external accreditation and complaint mechanisms as suggested by HPLC in its Housing the Homeless submission.5
Mainstream and Allied services can be encouraged to identify and respond to people who are homeless or at risk of homelessness through:
Development of common standards across state and territory human services portfolios,
Establishment of clear common reporting standards and a national regulatory environment for not for profit organisations,
Inclusion of minimum service standards in national disability, health care, Indigenous reform and education partnership agreements, and
Creation of a charter of consumer rights that informs service delivery across mainstream and allied services.
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What quality approaches support stronger cross sector service integration and improved service delivery?
A number of Qld housing and homelessness networks have developed coordinated and united services systems that integrate health, mental health, drug, alcohol, financial, and legal services to support people experiencing homelessness. These partnerships not only seek to strengthen relationships between housing and support services but include allied organisations where possible and provide local responses, aligned with housing and homelessness services area office catchments rather than broader Department of Communities service areas, which often include several area offices.
Two examples of improved cross sector service integration are the Inner City Brisbane Under One Roof consortium and the Gold Coast Homelessness Network Integrated Support Team Protocol. Both provide for the creation of common assessment tools, memorandums of understanding between organisations, and joint case management between partnering support agencies and housing providers.
A key tenet of both initiatives is that local networks with a history of collaboration should be supported at local rather than regional levels. Existing networks formed around a geographic or community of interest should continue to function autonomously with support from the Qld Government's Department of Communities through its proposed Community Action Plans, to build upon existing structures that address local rather than regional needs, which dilute their efficacy.
Quality approaches that support stronger cross sector service integration include:
- Coordination and support of existing localised Qld housing, homelessness, health and support provider partnerships that utilise early intervention, joint case management and cross-service client support such as the Inner City Brisbane Under One Roof initiative and the Gold Coast Homelessness Network Integrated Support Team Protocol.
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Question five: What currently works well in your state or territory?
The HTF and Qld Shelter believe that the current Qld Standards for Community Services provides clear and effective guidelines for individual organisation's service delivery for clients in the areas of:
- Accessibility of Services
- Responding to individual, families, and communities
- Participation and choice
- Confidentiality and privacy
- Feedback and complaints
- Protecting safety and wellbeing.
Qld quality standards guidelines for recruitment and selection; staff induction, training and development; employee and volunteer support; and effective governance are also considered effective.
Federal recognition of specialist homelessness services and housing providers' Communities standards compliance will reduce compliance burdens. As such, Federal recognition of State compliance under an NQF is considered essential.
What would you change in existing quality systems to improve outcomes for people experiencing homelessness?
The HTF and Qld Shelter consulted with a number of people experiencing homelessness is preparing this submission to ensure that consumer perspectives are not overlooked in deference to providers.
Those consulted cited being treated with respect and with regard to their individual situations as one of the most important characteristics of quality service provision. They regarded a supportive relationship with a case manager, within a transitional or SAAP housing framework, as significantly beneficial.
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Those consulted expressed dissatisfaction with the existing shelter system preferring to sleep on the streets rather than engage with system that depersonalises them, treats them like a number, and uses case management meetings as a means of monitoring rent payments.
One client stated that refuges:
'treat you like jail with rules about what you can do and when. Case management happens once so they can cross it off their list and then only to check that you are paying your rent, with no encouragement to engage or persevere with a case plan'.
They stated that there needs to be movement within the housing continuum that provides long term housing that addresses a client's locational, environmental, and social needs while freeing up SAAP and transitional housing places so that others can benefit.
They agreed that quality service provision should consider a clients individual situation. For example, one client stated that upon release from a correctional institution she was placed in a high crime environment alongside other ex-offenders. Another with a history frequent drug rehabilitation said that quality service provision should allow her to be placed in long term housing removed from high drug use such as an inner city boarding house or fringe suburbs.
All endorsed the Supported Accommodation Program while commenting that reduced staff turnover would enhance quality service provision.
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People seeking assistance rated having a single and consistent contact person or case manager who is familiar with and able to navigate a fragmented system as a highly valuable aspect of quality service delivery. Current systems, that purport to empower a homeless person by providing them with circular referral information frustrates clients who often lack basics such as transport or a telephone and find the service system fragmented and inaccessible.
According to people experiencing homelessness, quality service provision would require a system that:
- treats them with respect,
- fosters a supportive relationship with a case manager, which is enhanced by low staff turnover,
- produces outcomes that respond to a client's personal, locational, environmental and social needs,
- recognises and negotiates differences between service systems, and
- Provides a single point of contact that holistically addresses a client's needs.
- Queensland Compact: Compact Governance Committee Action Plan November 2008-November 2010 available at http://www.communityservices.qld.gov.au/department/about/corporate-plans...
- Streamlining quality standards working group common standards evaluation criteria.
- Productivity Commission- Contribution of the Not For Profit Sector research report p.115 available at http://www.pc.gov.au/projects/study/not-for-profit/report
- Housing the Homeless- Report into the Inquiry into Homelessness Legislation, House of Representatives Standing Committee and Family, Community, Housing, and Youth. November 2009 ACT. P. 105.
- Ibid p.107