108 Sea Street, West Kempsey NSW 2440
P: (02) 65631230, F: (02) 65622856
Email: michelle@ypspacemnc.com.au
1.0 Introduction/ Background
YP Space MNC is a Homelessness Assistance Youth Service that was previously funded through the Supported Accommodation Assistance Program (SAAP), now under the National Affordable Housing Agreement (NAHA) under the Specialist Homelessness Services umbrella. YP Space MNC has been operating in the Macleay region, of NSW, for over 23 years. Our region covers Nambucca to the north, Comara to the west and Kundabung to the south.
The focus of the service throughout this time has been providing 24/7 hour crisis accommodation services to young people aged between 14 years and 9 months to 17 years (inclusive). A further focus for this organisation has also been to provide tenancy support and accommodation to young people from the age of 16 to 25 years with our Exit Units, funded under the Community Accommodation Program. Essential core business of YP Space MNC from inception to the current day has been to provide support structures to young people who are homeless or at risk of homelessness and the issues that impact on young people's health and housing status. The service delivery model implemented by YP Space MNC has evolved throughout its existence to reflect the changing needs of young people who access the service, the management structures in operation at the time, the best practice and service standard structures current for the period and the changing political environment in Australia.
In 2008 YP Space MNC reconfigured its service structure, as a result of funding constraints, to ensure financial and operational sustainability and viability into the future. The reconfigured service structure has increased YP Space MNC's capacity to provide services to young people that are comprehensive, holistic and seamless. YP Space MNC now works from a comprehensive case management model, to ensure young people are engaged in the process, have a strong voice in the support they receive and have the systemic and individual issues that are impacting on them addressed. This reconfiguration process has also provided YP Space MNC the framework and opportunity to expand our advocacy services and leadership position, and has created a stable platform for our organisation to make constructive and sophisticated contribution to public policy and the accountability of the services systems we work within.
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YP Space MNC's Key Vision
YP Space MNC Inc acknowledges that young people of all cultures and minority groups are often the most disadvantaged group within our community, due to experiences of poverty, mental health issues, homelessness, family breakdown, lower socio-economic status, decreased access to education and training, drug and alcohol use, trans-generational trauma, sexual and physical violence and often social perception. All of which are identified pathways that lead to social exclusion and lack of basic human rights. YP Space MNC Inc also recognizes that young people often experience a sense of dispossession and disconnection to self, spirit and community through these experiences and the overt importance of connection to community lessens in comparison to basic survival needs.
YP Space MNC seeks quality of life and provision of Basic Human Rights as an outcome for all young people in Australia, not just service access. The underlying principle of any new homelessness services National Quality Framework should have strong foundations in accountability, transparency across sectors, particularly equal accountability & transparency across government and non-government agencies and be based from a social justice perspective to ensure the rights of people who experience homelessness in all it's forms are upheld.
YP Space MNC wants to see the development of legislation and accreditation/ quality framework systems that ensures:
- the basic human rights of young people experiencing homelessness;
- the right to housing, with National Legislation that governs this right;
- the rights of young people to access tailored and effective support;
- the rights of young people to have access to community participation and the resources to support this;
- the rights of young people to have access to client-focused programs based on respect and dignity;
- the rights of young people to not have a 'one size fits all' service system/ program structure enforced upon them;
- the rights of young people to be the authors of their own lives and not the product of government policy;
- the rights of young people to question the support they receive and advocate for themselves if it is not what they believe is ethical or effective;
- Government and Corporate sectors are governed accountably and transparently, in line with the non-government sector.
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2.0 Response to the Key Identified Questions
YP Space MNC views the foundation of any regulatory frameworks for service systems who work with people who experience homelessness as essentially being built on the principles of Social Justice, human rights and individual tailored responses.
2.1 What is quality service provision?
What is needed in a NQF to take into account the scope and diversity of service responses across Australia to ensure these are maintained?
Do you agree with the characteristics of quality service provision outlines above?
What other key characteristics or elements should be included to describe quality service provision?
Social Justice and Inclusion
Any governing regulatory system needs to acknowledge the structural issues of homelessness (poverty, trauma, domestic violence, family disconnection) and ensure that early intervention strategies are a key priority for service provision. The NQF needs to ensure that services eligibility criteria do not excluded the most vulnerable groups and individuals within our community and does not put 'blame' on the survivors of systemic disadvantage. This is particularly relevant to mainstream & allied service systems, whose core business is not directed at working exclusively with people who are homeless or 'at risk' of homelessness.
The Governments pus towards Social Inclusion, while seemingly connected to Social Justice principles reflects a strong economic participation component, that does not reflect the 'need' for firstly ensuring basic human rights for a large number of individuals and families in our community are met.
The core elements of Social Justice - Rights, Access, Equity and Participation - need to be embedded into any regulatory framework developed for our service systems.
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Empowerment and Strengths Based Practice Principles
It is essential that any new legislation on homelessness have at its core the rights of young people, and people in general, to be the authority in their own lives. New quality framework systems need to provide a platform to create a legislative culture, service delivery and management systems that moves towards mobilizing and promoting informed decision making by young people who experience homelessness, realistic support structures and collaborative, seamless and localized approaches that realistically address the systemic issues that impact on homelessness and social exclusion for young people within Australia. The principles of 'rights based approaches' and empowering young people through capacity building strategies that celebrate and capitalise their strengths need to be embedded into legislation and regulatory practices. A new NQF needs to govern service systems to ensure they work with young people in a way that promotes their skills, knowledge and resilience and creates a culture and environment that celebrates young people and their participation.
Any National Quality framework should have at it's core a consumer participation and consumer outcome focus, ensuring that people experiencing homelessness are the drivers of their support, and have the right to determine the outcomes of the support initiated. It is essential that any system put into place has a clear and transparent complaints and grievance process to ensure consumers have a clear line of recourse should they believe the service they receive is not ethically based.
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Whole of Community Response to homelessness
The White Paper on Homelessness - The Road Home indicated that the new federal direction in terms of homelessness is to break down the service system and community silos and ensure that 'homelessness is everyone business'. This position opens up and broadens the legislative and regulatory platform to govern multi- levels institutions within our community. It is essential, as such, that Quality framework systems are built on Social Justice Principles so that economic rationalisation and profit margins do not exclude homeless people from receiving appropriate support. This is particularly important with the push (in the White Paper) to develop stronger partnerships with the Corporate sector and to see a 'no wrong door' approach into homelessness support, through greater responsibilities by mainstream services in responding to homelessness.
Any National Quality Framework needs to ensure that ALL systems and institutions - including Government, non-government, community and for-profit agencies - are regulated with the same legislation, accountability and transparency.
Resources would need to be provided to ensure that ALL workers within mainstream services receive adequate training to build their capacity to be able to respond effectively to issues of homelessness & the systemic underlying issues. The risk factors associated with this new movement into a whole of community response to homelessness is the damage that can be done on a first encounter. Young people particularly make long term decisions on accessing support based off the 'first contact' they have with service provider agencies. If this first contact is not appropriate, discriminatory or lacking accurate information then the opportunity to reach young people in need of support can be dramatically affected. A 'no wrong door' approach is commendable, yet not realistic considering the complexity of homelessness and the issues associated with it. This approach would require extreme resource commitment, to not only mainstream and allied service systems, but to all the small community groups (eg Social groups, Card Groups, Knitting Groups) to ensure education is provided to their members - and how then do we monitor these contacts and the outcomes from them? Would these service/ social systems be accountable to the Quality Framework being developed?
The resources required to implement this model would equate to more effective outcomes by providing appropriate resources to existing Specialist Homelessness Services.
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Localisation and community context
Homelessness is a complex issue with multiple inter-related and connected social and systemic issues. To further complicate the issues, we also see a vast difference in the practice implemented by Specialist Homelessness Services, Mainstream and Allied services in Metropolitan and Rural/ Regional areas. The reality is that the majority of service systems who work with homeless people do so from a social justice, social inclusion, rights and accountability framework, to ensure services provided are effective and ethical for the people who utilise these services. Yet reality also indicates that localisation and community context plays a large role in the availability, capacity and identifiable outcomes achieved by these service systems.
Metropolitan areas have greater access to partnerships due to larger amounts of organisations in the location; greater access to Corporate Sponsorship and connection to Community responsible corporate agencies; increased access to policy advocacy due to location and often higher volumes of workers due to larger amounts of funding being available for Metropolitan areas. Rural and Regional services are often smaller community based and managed agencies that work within multiple service systems due to the lack of available resources and services to refer to or make partnerships with; rural and regional services often have less staff due to funding constraints and large geographical areas to cover due to the context of their community. What is a quality outcome for someone from a Metropolitan area versus a Rural and/or Regional area can be vastly different.
The introduction of an Accreditation process for Specialist Homelessness Services and other service systems engaged in working with homeless people will see a huge administrative burden imposed on services that are already under-funded, pushed to capacity and restricted in their service delivery due to funding constraints. The reality is that current Funding climate and Application processes ensures that services are Governed Accountably; are financially secure, viable and accountable; have strong project management skills; and are accountable, connected and encourage participation from and with their local community. The administrative burden that would be introduced by the introduction of an Accreditation system would see more time being devoted to administrative tasks, with less time being devoted to on-the-ground case work with people experiencing homelessness to achieve quality and effective outcomes for people accessing services. The local community context will also have an effect on the type of intervention implemented with people accessing services. Regional and rural areas often have a large geographical area to cover, through the implementation of Outreach programs, with limited funding available, which further decreases real time spent with people accessing services. To increase Administrative duties puts these rural and regional services in danger of spending more and more time on paper work and regulatory practices and decreases the opportunity for real outcomes for the people accessing their services.
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The current changes to the Legislation from the roll-out of the 'Keep them Safe' program and recommendation from the enquiry has also further burdened Non-government agencies. Community Services have announced the 'shared responsibility' of caring for young people and children who experience unstable home environments, with all young people not identified as in 'significant risk' being referred on to NGO's - with no increase in resources for NGO yet a huge increase in their work and case load, including administration.
The issue of services being funded across multiple funding stream is also a consideration, in terms of the regulatory burdens already in place for these organisations. Introducing yet another regulatory process would further increase the administrative burden on these agencies and could pose a serious impact on quality service provision due to capacity issues.
Sector Development
Sector Development and the appropriate resources to implement effective Sector Development and capacity building should also be a key consideration within the development and roll-out of a new National Quality Framework. With the multiple system involvement, when working with people who experience homelessness, it is essential that all systems are provided the appropriate resources to ensure their skill development, understanding and commitment to a quality framework is of the highest level. Reforming and adapting the existing SAAP regulatory systems would be the most cost effective avenue for Specialist Homelessness Services but yet would still required financial commitment to ensure all existing services have the same capacity to adhere to the new practice.
All these issues need to be taken into consideration when discussing the development of a 'one size fits all' regulation and monitoring framework for these diverse service systems.
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2.2 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?
What quality approaches support stronger cross sector service integration and improved service delivery?
The Mainstream and Allied services involved with working with people who are homeless or 'at risk' of homelessness is extensive Key agencies, for example Hospitals and Health Care centres, Education Institutions and Employment Agencies are often ineffective at identifying and responding to individuals who are experiencing homelessness or who are 'At risk' of homelessness. The reality is that all service systems are focused on their own core business and looking outside of this involves an increased capacity that most agencies just don't have the resources for. Policies and procedures of large institutions do not adequately assess someone's risk of homelessness and can further isolate people who are homeless due to ineffective responses and often outright discrimination.
Policy reform needs to occur on all systems levels, including Health, Education and Training, Indigenous Affairs, Justice, Employment and Disability to ensure a consistent approach to working with individuals in our country, regardless of their issues, and in recognition of the complex nature and systemic issues associated with homelessness. Deliverable targets, more than just an agreement to abide by a Charter of Rights, need to be built into these service systems as well to ensure an appropriate response to homelessness within our community's mainstream systems. Streamlining existing regulatory mechanisms to include the vulnerable target groups in our communities are a must and will ensure accountability, not just service standards and documentation to be completed and ticked off.
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2.3 Potential Components of a National Quality Framework
The existing legislation, the Supported Accommodation Act 1994, and the Performance Monitoring Framework regulatory practices implemented by SAAP and DoCS (Community Services) funded services in the community sector have ensured that quality service provision has been provided to all people accessing the SAAP service system for multiple years. What needs to be recognised is the comprehensive and effective work that has been achieved by Specialist Homelessness Services, under difficult funding and resource limitations, in the past and that we should be building on these successes and service quality.
Accreditation may be a positive avenue, yet it is highly resource intensive and can at times create a 'status quo' platform, through the setting of minimum standards as opposed to continuous quality improvement.
Any National Quality Framework developed needs to be based off a Continuous Quality Improvement framework, to ensure that status quo mentality and the achievement of 'minimum' standards is not good enough.
The difficulties and challenges for implementing a CQI process is the resource intensity of the system, and the large volumes of agencies, services and sectors that would be regulated under these systems. Administrative burden is a real threat under a new system, particularly for community based services who are already resource poor and not funded at an appropriate level to support the work they currently do, without the added time extensive requirements of CQI and/or Accreditation processes.
From experience of working with and within various service systems Accreditation processes are resource intensive and certainly do not equate to 'Quality Service Provision' but is more in line with Quantity Administrative practice. Often the current practice is to devote extensive amounts of time to the administrative requirements of an Accreditation process a few months before the Audit and External Evaluation of a service - does this equate to Quality Service Provision? These current processes do not support or encourage quality service or accountability.
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2.4 How would a NQF relate to existing state & territory quality systems?
As noted previously Accreditation and service standards cab be positive approaches to ensuring quality service provision, with clear lines of accountability, sector support and increased resources to meet the resource demands of such processes. The Specialist Homelessness Service, under SAAP sector has been governed by service standards for years and have achieved successful outcomes in terms of quality service provision through these standards.
Comprehensive evaluation of existing accreditation and regulatory models needs to be undertaken, across all levels of the process. Accreditation can be extensively resource intensive and as such would need to be funded correctly to achieve effective outcomes. That being said, accreditation, with minimum standards, does not necessarily equate to quality service provision or the protection of human rights, social inclusion or social justice.
Due to the complexity of homelessness and the multiple inter-related systemic issues that are associated with homelessness, a National Quality Framework and the national targets for reducing and responding to homelessness would need to be embedded in multiple service systems - not just the homelessness and housing sector. Deliverable targets for responding effectively to homelessness would need to be embedded into the Health, Education, Disability, Employment and Aboriginal sectors of our social and service systems to ensure the complexity of the issues associated with homelessness are being addressed from a realistic, transparent and responsible framework.
Put simply a complete reform of all the Quality Service Systems already in place, within all sectors and service systems, would need to be implemented to ensure a unified, transparent and targeted response to the issues associated with homelessness. While these sectors are already working from Accreditation and Good Practice Principles, these are not specific to homelessness or the associated systemic and social issues that impact on homelessness
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3. Concluding Comments
The development of new accountability frameworks governing the ever expanding homelessness sector would need to be based on principles of social justice and human rights. Ensuring that all service systems (including government, corporate, non-government, community) are governed equally, accountably and transparently, with effective and comprehensive reporting requirements will need to be an essential goal of any new legislation on homelessness. Ongoing and timely consultation, with community services with experience and knowledge of the sector, needs to occur. This consultation process needs to move past just the metropolitan areas to incorporate regional and rural service systems, to ensure the legislative stance is reflective of all individuals and communities needs.
Due to YP Space MNC's extensive history and experience in working within the youth homelessness sector in a rural/regional area, we would be pleased to provide any further information on the issues impacting on the young people who experience homelessness within our region, and on the policy issues that impact on our service delivery structure and program development. Young people need to have a voice in the services available to them and in how these services are regulated.