Quality Frameworks for Homelessness and Related Services – Literature Review and Environmental Scan

5 Components of a national quality framework

5.1 Introduction

This section draws together the key aspects of research carried out to date and moves towards identifying the potential components of a national quality framework for Australia's homelessness service sector.

The material presented in this section is based on:

desktop research, including a literature review and an environmental scan of existing quality frameworks operating in the homelessness service sector across Australian states and territories and overseas;
key lessons drawn from the case studies (summarised in Chapter 4, with further detail provided in Appendix A); and
a series of consultations, which involved semi-structured interviews with 23 sectoral experts and 32 service providers from 30 organisations across the homelessness sector. The findings of the consultations are described throughout the analysis in the next two sections of the report. A more complete summary of the consultations is provided in Appendix A and a list of the stakeholders consulted is also included in Appendix A.

This chapter covers the following areas:

The aims and objectives of a potential national quality framework, including a brief discussion about the different tensions which need to be balanced in the development of a single national system.
The key components of a national framework , including some preliminary analysis of the benefits and disadvantages of the different mechanisms which may be available to support this.
Conclusions and issues for further consideration.

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5.2 Aims and objectives of an accreditation system

Consultations with representatives from sectoral peak bodies and from service provider organisations provided a range of views about the objectives, appropriateness and components of a potential national quality framework for the homelessness service sector (refer to Appendix B for a more complete summary of the topics discussed and the different views of stakeholders).

The interviews highlighted the concerns and frustrations of those currently working within the sector, particularly with regard to funding and workforce capacity issues, the lack of integration between services and between services and government, which is considered to be an obstacle for service quality improvement. There was a high level of consistency in the views expressed across the different stakeholder groups.

Overall, most stakeholders were supportive of the development of a national quality framework, including an accreditation system for homelessness services that would ensure professional services are provided to homeless people in a range of settings. There were significant concerns expressed by both service providers and peak organisations about the resource burden that the implementation of such a system may have on smaller services (discussed further below). In some cases, stakeholders were particularly concerned about how, for example, new accreditation processes at a national level would interact with existing standards and regulatory processes currently in place at a state and territory level.

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Stakeholders also identified a number of strategies to assist in the implementation of a quality framework which may alleviate the burden associated with introducing accreditation procedures and standards. These ideas are considered throughout this section and in Section 6: Implementation processes and impacts.

As the homelessness service system is vast, there are many competing considerations which will impact on the success of a new national quality framework. The aims and objectives of the system will need to be clear and comprehensible to a range of different stakeholders, each with a varying capacity to navigate a complex regulatory environment. A number of considerations will need to be addressed in implementing a new framework, including:

The appropriate scope of the elements of the quality improvement system. The range of services that fall within the homeless service sector span accommodation services (temporary/crisis through to medium and long-term accommodation), through to referral and counselling services, mental health services, financial services and peak/advocacy organisations. The same type of accreditation system, for example, will not necessarily be appropriate for all of these services; indeed some services such as advocacy and peaks may have a role in delivering and or developing the processes. An accreditation system - if indeed this is an agreed component of the national quality framework - will need a clear framework to encompass the varying needs of services along this spectrum and will likely need to be implemented progressively to different types of services in different stages.
The rights and the standard of service to be guaranteed by the new arrangements. There is considerable variation in the degree of protection provided to homeless people currently in the different jurisdictions across Australia and overseas. While some countries aim to maintain very high standards and guarantees of housing and accommodation for homeless people, Australian jurisdictions, in some instances, provide very minimal protections and standards. The nature and extent of the rights to be guaranteed will need to be carefully considered and appropriately resourced, and accompanied by training and service capacity infrastructure to support the level of service guarantee that becomes reflected in the accreditation processes. This is considered further, below.
Balancing regulation with the need to maintain supply. The Australian Government's vision (as expressed in the White Paper) is to halve the overall number of homeless people in Australia by 2020 and to offer supported accommodation to all 'rough sleepers' by 2020.²⁰² The introduction of higher standards and increased regulation for some current providers of homelessness services (particularly accommodation in boarding houses, caravan parks etc) will potentially have an impact on the availability and supply of affordable accommodation. The major challenge for the development of a quality framework is to balance competing demands of service quality with availability. This can be achieved by making standards which are applied attainable through providing appropriate levels of support to services and by providing incentives for compliance so that the White Paper's vision can be realised.

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The stakeholders and service providers who were consulted identified a number of objectives that a national quality framework should set out to achieve. They included:

Professionalisation of the sector: Many homelessness services are dependent on a volunteer or low wage-earning workforce, which places limitations on the level of service and experience that can be expected from staff. Stakeholders noted the importance of improving the quality of staff training, guidance and support, of retention strategies and of standards for professional behaviour.
(Note: Stakeholders noted that in Queensland the Industrial Relations Commission recently ruled that there should be a pay increase of between 8% - 30% for the non-government and community services sector. The changes will be partially funded by the Queensland Government.)²⁰³
Minimal overlap of accreditation processes: If an accreditation model is to comprise an element of the quality framework, then the keys to its success and uptake will be that it is user-friendly and does not place an unnecessary burden on services. A key theme among interviewed stakeholders was the importance of developing a system that does not result in senior service staff or coordinators 'sitting at a computer' for extended periods of time completing accreditation documents when they could be on the 'frontline' assisting people.
The importance of developing an accreditation system that is compatible with other accreditation schemes, so that services are not required to undertake multiple and overlapping accreditation processes, was highlighted in a number of interviews.

There were particular concerns expressed by some stakeholders about how national accreditation would 'fit' with other accreditation or processes that are already in place to regulate homelessness services, as well as with community, welfare and housing services more generally. This is a particular concern when regulation has only recently been introduced at a state level and it has required considerable time and resources to be committed by services to adjust to the new system (for example in Tasmania and Victoria).

One stakeholder noted that it would be important to allow services to adjust to new state-level measures first before introducing another layer of national regulation, especially if it isn't clear how the different regulatory regimes interacted.

Stakeholders were also interested in continuity between any national regulation regarding accreditation and standards for public and community housing, and regulation of the homelessness sector.
A system that regulates more than the 'SAAP services': Some stakeholders noted that it is important that any new quality framework regulates a whole range of environments in which homeless people receive services, not only the services previously funded by the Supported Accommodation Assistance Program (SAAP). For example, they argued that dormitory or boarding house style accommodation is in need of some level of regulation.
A framework that is flexible and encompasses the diversity of the community and services available: Stakeholders were particularly concerned that if, for example, the 'bar was set too high' for accreditation this would lead to a withdrawal of services from smaller organisations valued at less than $500,000 or $1 million. One representative stated that the 'risk is that welfare organisations will walk away'.
Stakeholders emphasised the need for flexibility in the system so that small or remote services have to complete less onerous accreditation processes, or are supported in some way to 'get over the line'.
Moving people out of crisis accommodation quickly: Sector-wide issues were identified by some stakeholders that could potentially be addressed by a national quality framework. In particular, the need to move people as quickly as possible from crisis and temporary accommodation into stable accommodation was highlighted as an important intervention to reduce the risk of long-term homelessness. The insecurity of temporary living was described as exacerbating other factors such as mental health, confidence, daily living skills and employment, and as entrenching long-term homelessness.
Standards supporting a continuum of care: Another sector-wide issue identified by stakeholders is the need for the introduction of standards which will promote a continuum of care whereby people who have had experiences with homelessness are still supported in some way after they exit homelessness.
Nationally consistent regulation: All but one stakeholder perceived it to be important that a national quality framework be developed rather than state-based frameworks. Some of the reasons given for why a national system is preferable included making it easier for larger services to deliver services across jurisdictions, and improving both the consistency for clients and the simplicity of expectations.

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5.3 Potential components of a national quality framework

5.3.1 Human rights-based legislative framework

There are many different ways to encourage service improvement in the homelessness service sector. The type of framework deemed most appropriate for Australia will depend on the extent to which the government wishes to implement a service guarantee or an underpinning framework of human rights legislation.²⁰⁴

National Human Rights Consultation Committee, 2009, About the National Human Rights Consultation, Share your Views, www.humanrightsconsultation.gov.au/

Where international human rights conventions have been introduced into domestic law, as in the disability sector, this has acted as a powerful driver of national consistency in standards and practice.

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The Australian Government is currently investigating which rights and responsibilities matter to us as a society, whether these rights and responsibilities are adequately protected and promoted in contemporary Australia and how they might be better protected and promoted. The National Human Rights Consultation Committee, chaired by Father Frank Brennan, will report to government by September 30^th 2009. Potential legislative recommendations from this review could substantially remake the landscape around developing service standards and add a judicial motivation to aligning practice with human rights obligations.

Many of the leading practice approaches to homelessness service provision are underpinned by a legislative framework (e.g. Scotland: see Section 2.14.1 of the Legislative and regulatory context section of this document). A legislative framework can guarantee minimum rights in law, such as entry into the service pathway via assessment and the provision of temporary accommodation until a longer term response can be developed. This approach is consistent with the human rights approach embodied in the Universal Declaration of Human rights and the International Covenant on Civil and Political Rights (ICCPR) and the International Covenant on Economic, Social and Cultural Rights (ICESCR).

One of the reasons why a legislative framework is perceived to be one of the strongest social policy responses to homelessness is that it provides a process for recourse in the law to enforce the rights embodied in legislation. While the types of remedies available will vary depending on the specific legislation developed, there are advocacy groups and homeless legal centres that can leverage the rights contained in the legislation to access accommodation for homeless people by bringing an action in the courts. This may be by way of administrative review and/or other legal actions.

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A key component of many legislative frameworks is the establishment of an independent body to oversee complaints and grievances, to reduce the burden on the court system and to streamline the process of enforcing the intention of the legislation, particularly for disadvantaged and marginalised groups. Some of the different types of independent review/complaints mechanisms are discussed further below.

One advantage of developing a legislative system is that it provides a clear incentive for services to comply, as the alternative is to operate illegally. As experience from the other areas of regulatory reform has shown (such as the introduction of the Goods and Services Tax through the Goods and Services Tax Act 1999), the need to support services in the process of becoming accredited (financially and through education) is critical to ensuring the success of such a system.

There are limitations in the Australian Constitution which restrict the capacity of the Australian Government to legislate directly in relation to homelessness services (as they relate to housing). These limitations are discussed elsewhere in this document at Section 2. The key issue for the Australian Government is to achieve the cooperation of the states and territories, either in committing to national standards and legislation or in developing their own state-based legislation based on nationally agreed principles. The role of stakeholder engagement is discussed further below.

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Features of a legislative framework

There are a number of different features to be considered in developing a legislative framework:

Enshrining minimum standards, duties and/or a service charter that is adopted into national legislation or is incorporated into state and territory legislation. This may include the development of nationally agreed standards that services commit to delivering as part of their service charter. This type of approach is based on placing duties on services and government agencies to provide a minimum response to all people who approach their service.
The protection of rights in legislation. This approach could enshrine certain rights for all people and provides a standard by which the Australian government could be held to account. Legislating to enforce the right to be assessed and provided with temporary housing would require a system to be put in place so that homeless people are directed to an appropriate coordinating service and not turned away when they approach a service which is at capacity.
Extent of existing or potential future regulation of related sectors particularly housing and health. The capacity of service standards or legislative requirements for homelessness may or may not be enforceable in key related areas such as public/social and community housing and key health services required to support homeless people. For example, there is variable regulation of the boarding house sector across Australia at present, despite this sector forming a major role in the low-cost private rental market utilised by people at risk of homelessness. This raises questions of the applicability to and staging of accreditation processes from crisis accommodation to other forms of housing support.
Impact on and relationship with other legislation. Similar to above, the legislative framework would need to be developed so that it interacts with other legislation in a sensible and clear fashion and does not place multiple, overlapping (and especially directly competing) demands on services or government agencies. Many services have multiple funding sources and may be subject to a variety of requirements.

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A number of consulted stakeholders and service providers indicated their support for a 'rights-based' legislative framework for service delivery. Some expressed their support for the Supported Accommodation Assistance Program (SAAP) legislation in that it represents an human rights-based approach, the basic principle of SAAP being that if you are homeless you are deserving of shelter. The Bill of Rights enacted in Victoria was considered by some to be a good model for a national legislative framework.

'There are practical and symbolic implications to enacting homelessness legislation. Having legislation brings a valuing and appreciation and structural importance to the task of responding to homelessness. And in addition to the legislation, you need a mechanism to activate it and not let it be a dusty relic.' (Sectoral stakeholder)

One challenge raised by stakeholders of enacting legislation was the difficulty of defining 'homelessness services' and identifying which organisations would fall within the legislative system.

'How will we define homeless services? Currently this would be the specialist services - potentially residualising the homelessness response to the large crisis model. We need to keep a broad and encompassing definition to allow innovation and inclusion of new forms of response.' (Sectoral stakeholder)

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A number of stakeholders suggested that a national quality framework would best be implemented by way of a national legislative framework administered by the states and territories. This framework would enable the tailoring of service standards in recognition of the issues which are unique to particular geographies. The need for the framework to be sufficiently flexible and responsive to different localities was seen as crucial.

'Government has responsibilities in terms of setting the expectations and then embedding that in a legislative framework and then the states and territories will work in partnership with providers to administer the framework and establish improvement plans.' (Service Provider)

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5.3.2 Continuous quality improvement framework

Regardless of the type of national quality framework developed (whether it is mandated through legislation, voluntary or linked to funding), most leading practice regulatory models will involve some type of continuous quality improvement framework.

Victoria, Tasmania and Queensland have developed a system based on continuous quality improvement, although neither the Tasmanian nor the Victorian model is legislatively based. Legislation is often an appropriate way to ensure minimum standards and protections are in place. A separate accreditation scheme linked to funding and based on a continuous quality improvement framework may be an appropriate way to establish incentives to aspire to improved service practices.

Continuous quality improvement aims to provide more than simply basic protections; it puts in place a process for review and for improvement. Both the Victorian model and the Tasmanian models involve self-assessment according to predetermined standards and then review by an external third party monitor in order to gain full accreditation.

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The Victorian model provides valuable insights in relation to how a national quality framework may cover a wide range of issues, including consumer rights, access to services, assessment, referral, exit planning, data recording and building partnerships across different sectors.

An important feature of effective quality framework is the ease with which it may be understood and implemented by the organisations which will need to comply.. Rationalising the number of standards with which services will need to comply may assist this process. For example, the accreditation process could aim to guide services through the process of complying with other key pieces of legislation, such as anti-discrimination legislation, disability legislation, and health service legislation. Alternatively, it could provide advice and direction about where to go to find out about additional standards required under the law, even if they do not fall within the homelessness service accreditation process.

An auditing and evaluation function is a potential component of a continuous quality improvement framework. Auditing is performed to assess the reliability and performance of organisations in terms of their internal control. It is usually carried out on a statistical sample of services and provides an incentive for compliance.

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All stakeholders in homelessness policy and services have a part to play in the process, and roles need to be clearly and explicitly defined. The roles inherent in funding, legislative frameworks, standards development, audit and compliance, grievance and disputes, and service improvement need to be linked in a transparent and comprehensive framework. Roles are sustainable on an ongoing basis when they are appropriately tasked, with adequate funding and with authority to exercise their responsibilities.

A number of consulted stakeholders supported a continuous rolling program of service quality improvement, backed by supportive mechanisms including incentives. This approach was considered to be an effective means of driving organisational change from within, with a focus on improving processes and workforce capacity.

Some stakeholders also commented on the importance of client feedback as an integral element of the continuous service quality improvement model.

'I support a quality improvement cycle: reviewing and evaluating in a fair, frank and fearless way from a consumer's perspective and then addressing whatever issues arise out of consultation.' (Service provider)

'The value to us [a service operating under the Victorian framework] is that we put in place a management cycle to look at what we are doing and how we can improve. We prefer this quality improvement framework rather than the quality assurance audit approach. This process also has an audit component but it's not just tick a box.' (Service provider)

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5.3.3 Minimum standards and a tiered framework of standards

Some accreditation schemes implemented as part of a quality framework have sought to respond to varying levels of resources available to different services, recognising that smaller operators may have different objectives to larger services working towards holistic service delivery and towards best practice. This may be achieved through tiered frameworks of standards and through offering provisional licences.

In Queensland for example, the maximum time period for accreditation of supported residential accommodation is three years. If a service does not meet all of the requirements then a further, shorter period may be granted subject to certain conditions.

In the community housing sector, the tiered design of registration standards supports the diversity of providers in the sector nationally and could apply well to the diversity of types and sizes of agencies providing homeless services.

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The tiered approach in community housing is multi-factorial - where an organisation's registration status identifies the scope of operations (A, B, C) and the level of attainment against the standards (1, 2, 3). So a registration status, e.g. B2 or C1 etc., communicates detailed information about an organisation's capacity and is sensitive to progress with quality improvement strategies.

Similarly in the child care service sector, there have been moves towards developing a regulatory framework based on a three-tiered system of accreditation. Services are accredited according to whether they are 'provisional,' 'operating effectively' or a 'centre of excellence'. A 'provisional' service would receive active assistance and support to address aspects of its operations that required improvement.

While there was reluctance among stakeholders to introduce such a system into the child care sector (because of the anxiety it may cause parents who place their children in provisional centres), these concerns may not have the same level of application in the homeless service sector.²⁰⁵

If registration is to apply beyond funded services, extension to micro services and to private sector providers will require high levels of voluntary compliance by these stakeholders. This would be maximised by:

early engagement in consultations around appropriate standards, and involvement of key stakeholders in the sectors as sponsors of the processes;
support for quality improvement actions through personal relationships, training and reputation enhancing processes for those involved;
clear and well articulated links to established regulatory frameworks (e.g. the Building Code of Australia); and
commercial incentives, in the case of private sector providers.

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The majority of consulted stakeholders supported the introduction of minimum standards. Aspects of service provision including accommodation quality, staffing training, qualification and level of supervision were singled out to be addressed by the standards. Linkages between services and processes for referring people to appropriate services were also prioritised by the consultations.

Stakeholders identified a need for minimum standards to include an assessment process. One stakeholder was concerned about the need to build into the standards an assessment process for all people who come into contact with homelessness services, so that appropriate decisions could be made about the level of client need. As this stakeholder argued, 'not all people who become homeless have high and complex needs' and there is a risk of pathologising everyone who is homeless.

A number of stakeholders pointed out the importance of ensuring the system is not administered on the basis of the 'lowest common denominator' but rather that standards are inspirational and encourage organisations to strive for service quality improvement. The provision of incentives for the attainment of high standards was seen to be integral to this approach.

'People want to know what 'really good' looks like as well as what 'getting over the line' looks like. ' (Sectoral stakeholder)

'Instead of looking for lowest common denominator we need to look for the highest. It is not good enough that we look at criteria for quality assurance and consider how we can just do the minimum to meet that. We should aim for the highest or the best. And there needs to be some sort of encouragement for the attainment of higher status. Incentives might be funding, or they might be recognition, for example awards with a small monetary incentive or conference attendance for staff attached. It is about providing a reward to the service and the people in the service.' (Sectoral stakeholder)

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A number of stakeholders commented on the benefits of introducing minimum standards within the sector as a means of improving perceptions of the sector's workforce and of service provision models and confidence in the sector from external parties, including government.

'Introducing some objective standard whereby organisations can measure themselves can give the sector greater confidence and a greater ability to attract corporate and philanthropic funding, for example. It also enables the sector to attract higher calibre people, both as employees and board members. So for organisations to be able to say 'we are doing well by some objective standard' is a good thing.' (Sectoral stakeholder)

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5.3.4 Registration processes

At minimum, the accreditation process can provide a register of homelessness support services, their location and the types of support offered by each. The register would be a potential source of data collection for research and for service planning. As such, it would require regular maintenance to ensure accuracy and validity of information.

The development of a national framework for accreditation and data collection was supported by a number of stakeholders, in that centralised data collection would allow for comparisons to be made across regions and across client groups. The limitations of the data collection mechanisms implemented through the Supported Accommodation Assistance Program (SAAP) framework were highlighted:

'SAAP achieved some consistency through the national data collection framework. But data collection [under SAAP] was limited to the service types that were on the ground. So there was a whole lot of invisible stuff going on that was not recorded or reported.' (Service provider)

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5.3.5 Charters of rights

The White Paper on homelessness proposes the introduction of national service charters for mainstream services, and accreditation for funded specialist homelessness services, to improve service provision within the sector by maintaining high quality service delivery and by encouraging consistency and best practice service delivery. The ability for services to recruit and retain a 'highly trained, multi-skilled and well educated workforce' is one of the key tenets of this approach.²⁰⁶

Some stakeholders thought that it may be appropriate to include a homelessness charter of rights either in the legislation or in national principles in order to inform the development of specific state and territory frameworks. A charter has been developed in the ACT, which is a statement of principles and rights that services and government agencies seek to uphold.

The charter developed in the ACT is not enforceable in law; it is a statement of principles. It is accompanied by a service guarantee which communicates the practical effects of standards to stakeholders - what they can expect from each service and the dispute resolution processes available to them.

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5.3.6 Review and complaints mechanisms

A national quality framework would include of a process for service quality review and for receiving of complaints and grievances. In terms of compliance with standards, this issue was raised by a number of stakeholders in relation to the question of what is driving compliance. The importance of providing drivers other than funding was highlighted in terms of the effectiveness of service quality improvement.

A voluntary compliance system was considered to have significant benefits and to potentially be more appropriate than a system of compulsory compliance. The drivers put in place in the sector to encourage compliance would include marketing and fundraising benefits. Making resources available to support smaller organisations in seeking compliance was highlighted as important in the application of such a system.

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There are many ways in which a compliance function can be implemented. Some of the options are:

Internal review, which involves a process for complaints to be dealt with internally by the service itself at first instance.
Self-assessment processes, by which organisations are encouraged to continuously improve their own standards. This may be complemented by an audit and inspection regime whereby organisations are infrequently inspected by an external body, without warning.
A number of stakeholders commented on the potential benefits of self-assessment regimes as an integral component of audit processes in that they may contribute to workforce capacity development within organisations.

'In terms of self-assessment, it is good to encourage organisations to become their own harshest critics, so when it comes to an external assessment they are well and truly ready. But admittedly this is difficult in a sector that feels criticised, as they do in community housing and in the homelessness service sector.' (Sectoral stakeholder)
Peer review processes, which may form part of a continuous quality improvement model and through which professionals working within organisations would be trained to review other organisations. The peer review processes which have been implemented in Victoria as part of the Quality Improvement Council (QIC) standards and the accreditation processes were seen to be a helpful approach by some stakeholders. They were particularly praised as offering a supportive model of quality improvement and one in which experts were assessed by peer experts, rather than by a bureaucrat who may be perceived as unaware of the realities of service provision on the ground.
'[Another] big advantage of QIC is peer review, so they train peers to review you. So professionals working in the area are the people who conduct the review. This model, which is applied in Victoria, could be applied nationally.' (Service provider)

'The peer review framework in Victoria acknowledges that a lot of bureaucrats have never run a service, so the people who actually work in services are assessing the services. This is a more realistic approach: best practice within constraints.' (Service provider)
Establishment of an independent organisation, such as the Homelessness Advocacy Service (HAS) in Victoria or the Complaints Resolution and Referral Service for the disability sector, to handle complaints that can not be resolved internally. These organisations may investigate complaints and also engage in advocacy to improve access to and quality of services for homeless people. It could be led by a government/Non-Government Organisation (NGO), peak/advocacy or accreditation specialist.
Some stakeholders commented on the benefits of an accreditation system being administered by an arm's-length accreditation body, rather than by government directly. Such a system has been implemented in the sector in Victoria, and it was considered to facilitate a more open and honest approach from service providers. The cost implication, however, of utilising a private sector arm's-length accreditation organisation was raised as a concern among stakeholders, particularly if service providers are required to bear the cost of accreditation.
Ombudsman review. It is possible that the Ombudsman could review complaints relating to homelessness services.
Processes for informing people about their rights. As part of the accreditation and review process, structures to support homeless people and those at risk of homelessness to understand their rights, need to be in place. Case workers, advocates or counsellors may be the most appropriate people to handle these aspects of the process as people approaching homelessness services are often unable and unaware of the ways they can access assistance.

If a process for independent review and complaints is established then it will need to address a number of potential issues. While some of the issues will relate to the standards of certain services and to the appropriateness of the way they work with clients, issues about access to services will also arise.

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5.4 Conclusions and issues for further consideration

This section has set out some of the potential components of a national quality framework within the homelessness services sector, including:

a broad rights-based legislative framework to replace the SAA Act (which incorporates some aspects of the SAAP framework);
a continuous quality improvement framework;
the establishment of minimum standards for services, including the potential for a tiered framework of standards;
a registration system for services;
a charter of rights for homeless people, which may or may not be enshrined in legislation; and
review and complaints mechanisms.

The discussion of the potential components of a national system has considered the issues raised by sectoral stakeholders and service providers who were consulted as part of this research, and is reflective of their views.

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The risks and benefits of the various regulatory and accreditation models are considered in the context of the current structure of the homelessness service provision sector and the challenges of developing a framework which is appropriate to the range of organisations operating within it.

The consultation revealed broad agreement among stakeholders on the most appropriate components of a system. The establishment of a regulatory rights-based framework was supported by many as a basis for the introduction of a national system which would support the objectives contained in the White Paper on homelessness for ensuring a client-centred approach to service quality improvement.

Stakeholders' experiences of existing accreditation systems which are currently operating in some states, particularly Victoria, have provided some useful insights into what aspects have worked well and what components might be suited to a national framework. The implementation of a continuous service quality improvement model, similar to the system which has been implemented in Victoria, was supported by a number of stakeholders. Particular aspects of this model, including self-assessment and peer review processes, were highlighted by organisations as beneficial for service quality improvement and workforce capacity development. Such a system was considered preferable to what was perceived as a 'tick-a-box' approach represented by a quality rating system.

The majority of consulted stakeholders considered the implementation of minimum standards for services to be an essential aspect of a national framework, however a number also stressed the importance of standards being inspirational rather than based on the 'lowest common denominator'.

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Other potential components of a national quality framework, including a charter of principles and rights, were supported by some stakeholders, although views varied in relation to whether these principles should be enshrined in legislation.

Audit and review processes were considered by stakeholders to be important components of a system, however views on the form this should take were varied, with many supporting self-assessment and peer review processes alongside external audit mechanisms.

The challenges of implementing a national framework are explored in the following section, particularly with regard to the processes of implementation - including timing and resourcing - and the importance of risk-mitigation strategies to deal with issues which might arise during this process.

Ibid., p.viii
Details of the decision can be found at: http://www.ja.com.au/CSIR_home/article.aspx?id=13673. The Qld Government has committed to funded part of the increase: http://www.communityservices.qld.gov.au/about/budget/2009-10/documents/bh-new-funds-fact-sheet.pdf
National Human Rights Consultation Committee, 2009, About the National Human Rights Consultation, Share your Views, www.humanrightsconsultation.gov.au/
Australian Government Department of Education, Employment and Workplace Relations, A National Quality Framework for Early Childhood Education and Care, First wave of public consultations on reform proposals, August and September 2008 – Summary of outcomes, viewed at www.deewr.gov.au/EarlyChildhood/OfficeOfEarlyChildhood/EarlyChildhoodEducation/Documents/Summary%20of%20consultation%20outcomes%20(revised).rtf
Australian Government, 2008, White Paper - The Road Home: A National Approach to Reducing Homelessness, p. 43

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