Anglicare SA response to FSP consultation 

Anglicare SA's 150-year history in the delivery of effective family support services across South Australia has provided us with a broad range of collaborative experiences with State and Federal funding bodies. Anglicare's Family, Community and Enterprise Services delivers more than 90 programs, involving 500 staff, 400 foster carers and 500 volunteers, to South Australian families and communities. We are therefore supportive of the overarching aims of the Program Operational Framework in enabling service providers to deliver effective, efficient, flexible and responsive services in relation to client and community need. We also offer strong support for an output and outcome based accountability framework.

The six key requirements identified in the discussion paper are all important ingredients in the delivery of effective family support services. They are all, in varying forms and operational structures, components of the current framework for the delivery of these services. In bringing these requirements together under the FSP umbrella we are concerned that there is no provision for the evaluation of their ability to be combined under one structure, and whether any additional key requirements will be needed to facilitate and enable this integration. We therefore consider an examination of the way these key requirements can and will be combined to be an additional essential element in the Program Operational Framework.

The third of the six key requirements, Ensuring Services Link Families and Children with Other Relevant Community Support Services, includes a component on the sharing of client information without compromising privacy and confidentiality and in consistency with legal requirements. Anglicare SA supports such a measure and sees the value of it. We have experienced the benefits of systems to facilitate this process, particularly in our Communities for Children programs, where we have multiple partner organisations. However, we are also wary of the need to be vigilant about the maintenance of confidentiality and privacy, as outlined in the key requirement. We support measures taken to assist in the sharing of relevant client information where it will assist in the effectiveness and accessibility of services for clients. However we recommend that this process be undertaken with close and careful scrutiny to issues of privacy and confidentiality and that these issues be given high priority at every stage of the establishment of all information sharing processes.

The fourth of the six key requirements, Offering More Flexibility and Responsive Service Delivery Approaches, has been of significant value in the success of Anglicare's service delivery approach. Our organisation has a strong history and reputation for flexibility and responsiveness that has played a significant part in achieving outcomes for clients. We support flexibility and responsiveness as ideals and as part of an effective approach to service delivery. However, all innovative actions and practices, like any others, need to be monitored to ensure their ability to deliver quality and results-based services to clients. Within Anglicare SA we have internal quality monitoring processes with which we are able to assess the effectiveness of delivery approaches that are flexible and responsive. The establishment of such a monitoring system that allows room for these innovative actions while also maintaining outcome-based vigilance is a complex matter. We therefore recommend that resources be allocated to the consideration and establishment of such a monitoring system, and that priority be given to it.

Anglicare SA's long experience in delivering services to South Australian families has provided us with strong evidence of the barriers to delivering flexibility for clients posed by short-term and rigid contract arrangements. Anglicare recognises the need for monitoring to ensure the quality services and argues that this performance assessment, consistent with the FSP principles and operational framework, can be achieved in contracts that allow the rolling over of funds. We would support a model similar to that currently being considered within DEEWR of a 3 + 3 + 3 year contract with reassessment at each 3-year point. These contracts would allow providers the security needed to respond to changing regional and client need while guaranteeing continued support to vulnerable families in their progress towards independence and wellbeing. The current 3-month notification of refunding or winding up of programs also poses a barrier to adequately supporting and engaging all clients. Longer time-frames are needed to discuss and arrange alternate services for clients or to plan for staffing, management and infrastructure necessary for the continuation of services.

Anglicare supports the continued diversity of providers to give clients choice and provide a range of models and increased flexibility. Increased opportunities for partnerships and mentoring relationships between smaller and larger providers would enhance this capacity.

In order to achieve greater efficiency and flexibility Anglicare would support the establishment of a central, constantly updated database with information on all services available and for referrals to be made. Anglicare staff have worked with such models on a smaller scale and found them highly successful in providing improved service pathways. Client confidentiality and privacy in the establishment of such a database must be prioritised.

In addition to a central database Anglicare supports the allocation of increased resources to technological service delivery pathways. A multiplicity of access points to services and a range of entry and referral points are essential to improve service pathways. Increased use of the internet amongst the community needs to be matched by internet accessibility for as many services and programs as possible, both for self-referring services and organisational intake processes. Online access to services would be a significant step in improving service pathways for new and existing clients. Beyond the additional use of technology, Anglicare supports continued efforts to provide as diverse a range of entry pathways and access points for services as possible to ensure maximum client accessibility.

In supporting and engaging both universal and targeted client groups Anglicare has found the value of appropriately designed KPIs, including the specification of client groups and percentages, to be invaluable. However, the allocation of these KPIs needs to be carefully researched at regional and local levels and must be led by the service provider in consultation with the community. These targets can then account for existing programs within the region and local community need. Such targets set by funding bodies at a distance will be unable to accurately capture specific population service needs.

Anglicare has experienced considerable difficulty in delivering services to CALD clients when an interpreter is required and is unavailable or unable to be funded. Lack of provision in funding for interpreters poses a significant threat to the delivery of services to this very vulnerable client group. Anglicare SA would welcome increased resources allocated and a more accessible interpreter service for CALD clients. Privacy and confidentiality must be protected through the use of these services and the recognition that the utilisation of family members as interpreters is rarely appropriate. Increased allocation of funding for the translation and rewriting of pamphlets and other written information in a range of languages is also essential for improved service delivery to CALD groups.

We have experienced some difficulties in supporting clients in regional and remote areas of South Australia under the current contract system. Some of these families are those most in need of services, but most commonly used funding and contractual models do not provide enough flexibility for the delivery of services to these groups. The needs of providers are currently not adequately addressed in contracts for services in these areas and Anglicare would welcome further investigation of the range of models required to deliver services effectively to these families.

Overall, Anglicare SA argues that Program Design can be most improved by contracts and performance assessments that focus on the achievement of outcomes rather than on the mechanisms and processes used to achieve these outcomes. This approach will allow providers the flexibility to work with communities and target groups to provide services in a manner that is most appropriate for them and can meet their needs, while simultaneously facilitating performance assessment that accurately captures the effectiveness of the service in improving the experiences and wellbeing of clients.

Many of the points outlined in our response to Theme 2, above, are most relevant for achieving a 'no wrong door' approach. Multiple access and entry points, online access to services and an up-to-date database of services will all contribute to this end. A centralised database, such as the CISSA Directory, provided it is maintained, has proved extremely effective in improving accessibility for clients.

A strong focus on networking between providers and between government and providers is essential in keeping knowledge of services up-to-date and in maintaining community knowledge and links. This process is currently often informal and too reliant on incidental connections and relationships. A government facilitated system of networking forums would be welcomed by Anglicare as a key way to prioritise the forging and maintaining of these links, so as to ensure the capacity of the sector to deliver flexible and integrated services to clients.

Anglicares Communities For Children program is a highly successful example of one of the ways in which government and a range of providers can combine to deliver flexible and innovative services, responsive to need. Anglicare subcontracts a range of other providers and community organisations to deliver the Communities For Children services, ranging from one-off workshops to ongoing regular programs. We have found enormous benefit in the collaborative connections forged through this process and have utilised this shared knowledge and experience to tailor services to client needs and respond quickly to changes in clients' circumstances and requirements.

Anglicare SA argues that some standards and benchmarking do need to be built into staffing requirements but that these need to provide the flexibility to account for the experience base many staff bring to the workplace. Formal qualifications are often unable to adequately capture these strengths that often play key roles in excellent performance amongst service delivery staff. Anglicare is also concerned about the inability of rigid standards to account for community involvement in programs and the staff involved in collaborative and partnership services. These relationships and the involvement of these groups greatly enhance the quality of the services provided to clients and their experiences of positive outcomes. Standards that are too stringent would restrict or exclude these relationships and the involvement of community members and staff with valuable skills. Anglicare therefore cautions against standards that are too strongly based on formal qualifications and are unable to recognise the value an individual's experience and/or role in the community or organisation would add to the delivery of a service. Standards need to be service and program specific to allow for these strengths to be utilised. Anglicare supports benchmarks that are performance-based, and argues that the onus should be on the provider to allow these performance standards to be met through outcome measures rather than solely through generic qualifications-based criteria.

Anglicare SA already employs staff based in government departments and in other organisations. We have found that these shared working experiences can prove effective. However, the implications for staff of being located remotely, away from their organisational base, need to be considered carefully, and provisions made for strong organisational links to be maintained. These arrangements need to be initiated locally within groups and organisations who have existing knowledge of the community and its needs to ensure that client access to services does not suffer.

Anglicare's three major concerns in determining the range of FSP services required for a region or community are the existence of complementary services, the location of service shopfronts to minimise duplication and competition of services, and the involvement of the community in the process.

Our experience in delivering an extensive suite of services often in collaboration or co-operation with other providers has given us ample evidence that the involvement of a community's existing resources and services greatly improves outcomes for clients. The networking of existing services with newly introduced programs enables the addressing of clients' complex needs with maximum efficiency and effectiveness. In communities in which few existing services are in operation consideration needs to be given to ways of bringing outreach complementary services from neighbouring regions or establishing clear and accessible pathways to these services for clients, as the ability to engage with families on the range of difficulties they face significantly improves positive outcomes in each area.

Anglicare SA has found that where two or more providers offer similar services from sites in close proximity the effectiveness of the services are reduced by the distance some clients have to travel to access the concentration of shopfronts, and the need by providers to operate in an environment of competition rather than knowledge and best practice sharing. In these situations clients experience confusion and hesitancy about which provider to approach and the opportunity to establish complementary services is reduced. In the provision of services to vulnerable clients an environment of provider competitiveness is counter-productive, but unavoidable where participation targets must be met. Anglicare therefore argues that the locating of providers sites a reasonable distance from each other is essential in determining where services should be situated.

The importance of community involvement and input into the planning and audit process undertaken to determine the range of FSP services required by a region cannot be overstated. Opportunities to provide input in a range of forms and forums must be provided to all sectors of the community at every stage of the audit and decision-making process. Community understanding of and support for the FSP services established in the region is essential for the achievement and maintenance of client access to services and public awareness and understanding of services. These factors play a role in determining both the capacity for providers to deliver services to those in need and on the quality of outcomes for clients.

Anglicare SA is less concerned with the way in which catchment areas are specified than with the need for consistency of a single system of specification across all levels of government, departments and agencies. Current inconsistencies create significant difficulties in the management of services and in targeting services appropriately for communities. Changes in area specifications also cause significant difficulties and inefficiencies in reporting procedures and management. Anglicare therefore argues that the most important factor in determining a catchment area specification system is the consistency of those area specifications across all government funding bodies.

Anglicare SA supports the output and outcome based performance assessment system. We have utilised an internal performance monitoring system on this basis and found significant success for clients.

The short time-frames and insecurity of current funding arrangements continue to prove hurdles in the provision of effective and efficient services to families and communities. The current two and three year funding contractual format does not provide adequate time or security for providers or their clients. Anglicare supports a system of continued funding subject to review, such as the 3 + 3 + 3 year system currently being explored by DEEWR, as a way of balancing security of funding and the continued provision of quality services to those in need with performance monitoring and quality assurance.

Consistent rates of pay across the sector in regional, remote and urban regions, and consistency of pay between government and non-government positions also creates enormous difficulties for providers in retaining staff and developing a quality workforce. These issues need to be addressed at contract level, with renumeration parity across the sector built into and ensured in all contracts. Anglicare has found difficulties in recruiting experienced staff as contract terms do not allow us to offer parity of renumeration for staff with experience who are working in the government sector. We have developed effective training and development programs for new graduates to cope with this issue, but then are unable to retain these staff as their skills are valued in the public sector where salary scales are higher. We have experienced similar difficulties in recruiting and retaining staff for positions in rural and remote regions, often in communities who have the greatest need and whose needs demand experienced and highly skilled staff. This disparity needs to be addressed as a matter of urgency if appropriateness, security and quality of service provision, in an outputs and outcomes based performance assessment model, are to be achieved and maintained.

Anglicare SA argues that a rational and transparent system for the distribution of resources requires two key changes to the tendering process. Firstly, the current time-frames set for the submission of tenders are usually to short. The common four or five week period between the announcement of a funding opportunity and the deadline for submissions does not allow providers enough time to consider their capacity and appropriateness for the delivery of the services in conjunction with their existing service delivery commitments, for the forming of valuable collaborative tender applications with other organisations, and the preparation of the application itself. Similarly, the time allocated to contractual agreements and funding allocation often sees funds unable to be transferred on time and providers beginning services using their own funds before receiving payments retrospectively. This poses a significant threat to the diversity and flexibility of service delivery as many smaller providers struggle to cope with the delay in payments.

Secondly, feedback on unsuccessful tender applications must be an automatic and formal part of the funding process. Transparency of funding distribution cannot be achieved without explanation as to why particular applications are successful while others are not. This feedback must directly address the tender's selection criteria and the organisation's ability to meet those criteria as demonstrated in the application document.