YMCA Australia response to FSP consultation 

While we acknowledge that in their broad interpretation, the six key requirements provide a comprehensive basis for the operational framework and enhancement of Family Support Program (FSP) services, we would like to highlight some omissions and areas of concern. In many respects, some of the issues we raise relate to accepted definitions and assumptions that underpin some of the fundamental principles contained in the requirement statements. These are issues that will require greater clarity as the operational framework for the delivery of FSP services is further developed and finessed.

The first key requirement relating to collaboration raises questions about how collaborative relationships can best be established and fostered in a context of competitive tendering and complex contractual arrangements.

Service providers, regardless of their formal partnerships or governance arrangements will need to determine what collaboration means for them in a practical sense regarding funding allocations, data collection, information sharing, networking and the use of intellectual property. In this respect, collaboration needs to be viewed and supported not only as a vehicle to enhance service delivery in the present, but to also build in mechanisms that facilitate 'forward thinking' and future strategic planning. This will anticipate the needs of changing community dynamics and other external factors such as economic downturn which will have a significant impact on the coping abilities of many families. This is where further collaborative efforts regarding research and planning will be of greatest significance.

Given the broad range of service providers that will be engaged with the FSP, all with differing governance structures, levels of infrastructure capacity and access to human and financial resources, each service provider will have a different capacity to participate in a collaborative relationship and for many organisations, this relationship will not have an equitable basis. To meet the needs of diverse service providers, the development and implementation of the FSP will need to acknowledge and support a variety of collaborative models and governance arrangements.

To ensure that truly collaborative relationships can be established and fostered under the FSP, greater consideration will need to be given to adequately resourcing this collaboration and to build the capacity of service providers, particularly those that are engaged under a consortium model.

Under a consortium arrangement, lead agencies are often required to take on a greater administrative role and significant resources and time are dedicated to the tender process and post-tender administration. To achieve a greater level of collaboration, consideration will need to be given to contractual arrangements that alleviate this administrative pressure on lead agencies to allow a greater investment of time and resources into building the capacity of agencies to be more collaborative.

Another critical aspect of building successful collaborative models will be to determine how the effectiveness, or otherwise, of collaboration will be measured and valued. While there are a number of tools available to assist in the evaluation of collaborative partnerships, one that has been utilised widely in Victoria has been the VicHealth Partnership Analysis Tool ¹. The tool is a practical mechanism for the measurement of the success of partnerships across sectors and is a resource which:

• 'assists organisations to develop a clearer understanding of the range of purposes of collaborations;
• reflects on the partnerships they have established; and
• focuses on ways to strengthen new and existing partnerships by engaging in discussion about issues and ways forward.'

While there may be practical ways of measuring the effectiveness of collaborative relationships there is also a need to incorporate less tangible factors such as 'good will' and long-term historical relationships that naturally develop in various parts of the community sector among organisations and service providers that rely on one another for support and networking capacity.

With regard to the second key program requirement related to improving access to relevant services, it will be valuable for FSP service providers to have greater clarity about how the FSP will operate and link across all relevant government portfolio areas to ensure smooth transition and referral within FSP providers and in their collaborative relationships with the broader community services sector.

In terms of enhancing access to FSP services, it will be critical for the key program requirements of the FSP to include greater recognition of the needs of non-English speaking communities and significant effort will be required to ensure greater collaboration between FSP providers, ethno-specific organisations and settlement service providers. This should also include a commitment to the provision of culturally-relevant services across all communities and in particular with consideration to the needs of Indigenous and remote communities.

In relation to the third program requirement regarding linkages it will be essential for the effective delivery of services, to have greater clarity on how the FSP will work to meet the gaps that emerge when Commonwealth funding ceases and state or territory funding commences - this is particularly important across key life transition points.

The implementation and delivery of the FSP will also need to engage in significant effort to consciously address issues of 'gate-keeping' to ensure that appropriate linkages and referrals are made and that service providers are appropriately resourced to make the right referrals, particularly relating to facilitated referrals.

A model that is working with success in the Victorian context is that which is used by Child FIRST ² to streamline services and gain an improved picture of demand.

Through offering more flexible and responsive services, as outlined in the fourth program requirement, it will be crucial for the FSP to encourage recognition and support of innovation with a particular focus on prevention and early intervention. This will require significant workforce development, a high investment of resources and further education throughout the sector. It will also be critical to position prevention and early intervention further within broader public health frameworks.

More broadly, the key program requirements of the FSP lack a rights-based focus and as foundation blocks of the FSP the program requirements need to include a greater recognition of the rights of individuals and families to access the necessary services to support them through life transitions.

Another notable absence in the key program requirements is a lack of focus on the particular need for ongoing support for service providers working in regional, rural and remote areas. Community organisations in these areas face numerous challenges around organisational infrastructure, workforce development and retention, distance from key service centres and the challenges faced by clients accessing FSP services who reside in small and remote communities.

In the first instance, greater flexibility in service models and improved pathways will be achieved through a greater level of understanding between FSP service providers and other community agencies about the mission, purpose, aims and programs that different agencies provide, or have the capacity to provide. This increased understanding of the sector will also be an outcome of the current study by the Productivity Commission exploring the contributions of the not-for-profit sector in Australia. A greater level of understanding about the sector will be an essential foundation of successful collaboration and will be critical for the effective delivery of the FSP.

Greater flexibility also requires the recognition of innovation in the sector and also the need to develop opportunities to explore innovation. While this will require ongoing and expanded resourcing, the FSP also provides an opportunity to re-think the allocation of funds and services across the broader cohort of FSP providers to support innovative practice and program delivery.

In many areas, the support and engagement of universal and targeted client groups could be achieved through building more effective linkages with the early childhood education and care sector and also with the school system. While the capacity of providers to build these linkages will fluctuate depending on funding, the education system at all levels can provide an effective and efficient pathway to services and can encourage greater participation of families in FSP services. For many communities, particularly those in rural and remote areas, the school system plays a critical role in providing support to families through engagement with prevention and early intervention programs to connect with families before they become 'at risk' or are in crisis. The 'family-centred' focus of the early childhood education and care sector also plays a critical role in supporting innovation in early intervention and prevention and should form an integral component of the functionality of the FSP.

Another central element of program design of the FSP will be to ensure that service models and the development of pathways accurately reflect available data and research. There is, however, an ongoing concern in the sector about the lack of comprehensive statistics and profiling of the issues affecting individuals and their children and to ensure the effective delivery of the FSP, there will need to be a greater investment on the part of Government towards detailed and comprehensive research into the future.

Working towards an effective 'no wrong door' approach will require the support of FSP service providers in facilitating structural change and the further development of infrastructure and human resources. This will include the further education and development of staff, changes to staffing levels, the development of additional skills and resources to support this approach. A successful 'no wrong door' approach will also require that some service providers have the resources, capacity and flexibility to access and resource staff with specialist skills, such as the capacity to employ bilingual staff.

The development of a set of service quality standards will be an essential component for the successful implementation of the FSP. Quality standards for FSP service providers will need to be underpinned by a set of common principles and will need to be outcomes focused and linked directly to service accountabilities. There will also be a need to achieve national consistency and for standards to be relevant across all jurisdictions, while also acknowledging the diversity of organisations that will be delivering the FSP and the differing contexts in which they operate. It will also be critical that the development of national quality standards will not impose additional administrative or reporting burdens on organisations.

Reforms between the Commonwealth and the states and territories through the Council of Australian Governments (COAG) in the area of early childhood education involve the development of a set of national quality standards as part of the National Quality Framework for Early Childhood Education and Care. It will be crucial for the FSP to link closely with these standards and broadly reflect their underlying principles. These standards may also be a useful tool that applies directly to the FSP. A set of quality service standards for the FSP will also need to closely reflect the National Child Protection Framework, developed and endorsed by COAG in April this year.

As mentioned previously, the capacity for data collection and information sharing across FSP service provider organisations will vary and will depend upon resourcing, collaborative models and governance arrangements. Any process of data collection or protocols for the sharing of information across service providers must be underpinned by recognition of the needs of the client as the central focus. The right of the client in making a choice about what information is collected and their capacity to give informed consent to this process needs to underpin any information sharing arrangements. Information sharing must also have as a primary aim to ensure that all clients are referred immediately to the most appropriate centre or service.

Determination of the needs of services for particular areas and where these services should be located will again need to give consideration to the rights of clients to exercise choice about how and where they access FSP services. Service uptake may be related to proximity to the home or workplace or may even be in a different area altogether. Due to sensitivities associated with accessing FSP services, it will be critical for many clients to be able to access a service that is some distance from their home, their work or both. There are particular challenges faced by clients living in small or remote communities particularly if they do not wish the fact that they are accessing a service to be known to others in their community.

As data and information that builds a picture of demand for FSP services becomes more broadly available, such as that which will be released as part of the Australian Early Development Index, there will continue to be an improved profile of where FSP services should be located and how the needs and location of services will need to remain flexible and responsive to changing community need. As with the recent response to the Victorian bushfires, there may be periods or locations of crisis that require an immediate response to support families at risk.

Depending on community profile, in some areas there may be a requirement for a universal service provider while there may also need to be consideration given to funding specialist services such as Indigenous organisations or ethno-specific organisations to ensure that clients have the ability to access the most appropriate and trusted service.

Significant consideration also needs to be given to workforce capacity and development issues. Real investment in workforce development, training and capacity building must be built into the FSP to ensure the long-term sustainability of service providers and the programs and services delivered. This is of critical importance in regional, rural and remote communities where community organisations and service providers already face deep challenges regarding the attraction and retention of suitably qualified, skilled and experienced personnel.

While it will always be crucial to give service providers funding security over the long-term and recognising that longer term contracts will ensure greater productivity, there is a clear need for flexibility in service delivery models to ensure that changing local needs are addressed. Many larger, more established service providers have significantly greater resources and highly developed infrastructure which enables a greater capacity to access funding, more so than 'smaller' organisations. There needs to be, however, a greater recognition that 'smaller' organisations have the ability, through innovation and localised, specialised knowledge, to address previously unmet need and provide an equally effective service.
As mentioned previously, there is also a significant need when determining funding allocations and processes, to give consideration to a variety of collaborative models and governance arrangements that provide a balance between universal service providers and specialist organisations. The development and implementation of the FSP needs also to acknowledge the challenges of achieving this balance and fostering effective collaboration in a context of competitive tendering for the provision of services.

Measuring performance in the community services sector is always going to be highly challenging and the achievements or otherwise of long-term outcomes are not easily identified or evaluated in the short-term. The concept of performance measurement raises a number of issues including concerns that FaHCSIA, service providers and client groups may all have different goals and objectives and there needs to be greater clarity about which, or whose, goals are we trying to meet. Similarly, it will be critical for FaHCSIA and FSP service providers to develop and agree to shared meanings and definitions of central components within the program requirements and program design of the FSP.

The achievement of positive outcomes in the long-term often rely on the interdependence of a range of programs, services and providers and it is this interdependency which will be very difficult to measure and track. When considering performance measurement it will also be valuable to consider the economic impacts of positive outcomes, particularly if those outcomes are a result of prevention and early intervention programs.

Whether a system for the distribution of available resources is based upon geographic boundaries, population density and other key demographics or relevant community indicators it will be essential for funding models not only to direct resources to areas of crisis, but to attempt to anticipate areas and communities in which future issues may arise.