ILC Commissioning Framework - written feedback form

Date / Saturday, 17 November 2018
Organisation name (if applicable) / The Salvation Army State Social Command
State/territory / Victoria
Contact person / Jason Davies-Kildea (Captain)
Email address /

Preliminary Comments

The Salvation Army is an international Christian movement with a presence in 126 countries and a reputation built on 150 years of compassionate care and advocacy. In Australia, the Salvos are widely known and relied upon to deliver practical responses to individuals, families and communities in crisis.

Whilst we interact on a daily basis with people from all walks of life, we recognise a particular calling to those who might otherwise fall through the gaps of our social security nets, those who find themselves on the margins of our communities, and those who struggle to have their voices heard. This support for disadvantaged Australians is driven by our values: human dignity, justice, hope, compassion and community. We share our community’s belief in a ‘fair go’ for all, which grounds our commitment to social justice and a particular interest in the health and wellbeing of those most vulnerable in our society.

Consequently, we have developed strong partnerships and expertise in specialist areas such as homelessness, addictions, family violence, mental health, crisis and emergency services. Disabilities are commonplace amongst this client group, especially mental illness but also physical disabilities, intellectual disabilities and Acquired Brain Injury (ABI). The feedback in this submission is based primarily on The Salvation Army’s experience in the Barwon NDIS trial site, which has illuminated a series of challenges for the full inclusion of especially hard-to-reach, highly disadvantaged and socially marginalised clients.

An evaluation of the Barwon NDIS trial confirmed that people withcomplex needs were not able access servicesfor a variety of reasons, including physical, social, locational and individual barriers. In December 2014,Barwon mental health services reported that 49people who were eligible for the NDIS had declined or withdrawn from the serviceand another 46 people who had receivedmental health support under the previoussystem no longer qualified for supportunder the NDIS. The place of mental health services under the NDIS has always appeared vulnerable and recent moves by the Commonwealth Government have underscored that vulnerability. This is compounded by an environment that is rife with reforms, which could easily see some highly disadvantaged people slip between the gaps of the NDIS, aged care, and state-based services.

The ILC Policy Framework explicitly prioritises assistance to people with a disability regardless of whether they have an NDIS plan or individually funded package (IFP). This is a welcome commitment for many of the people with whom The Salvation Army work, who may not initially (or perhaps ever) gain access to an IFP or NDIS plan, due to the nature of their disability and/or other contributing factors.

Our experience tells us that when economic and social forces shape systems towards the needs of the majority, then minority groups fall further through the gaps and their disadvantage becomes increasingly entrenched. Those in our community who suffer multiple levels of socio-economic disadvantage, including intergenerational unemployment, low levels of educational attainment, mental illness, homelessness and addictions are particularly vulnerable. For the NDIS to fulfil its promise to the Australian community, all of its structures and processes must ensure that no one with a disability gets left behind.

  1. The proposed outcomes for ILC and the best ways to measure them
Questions you might like to consider:
  • Do you agree with the nine outcomes outlined in the Consultation Draft? Is there anything else the Agency should consider?
  • Do the nine outcomes cover everything you would expect to see in ILC?
  • How should we measure each of the nine outcomes?
  • How can people with disability, their families and carers and the broader community stay involved in measuring outcomes as ILC rolls out?
  • Is there anything we should consider in setting up our data collection processes?
  • Is there anything else you would like to tell us?

The Salvation Army supports the ILC’s focus on outcomes, including the nine areas outlined in the Consultation Draft. However, we are concerned that the implementation of this focus has the potential to unintentionally exclude already disadvantaged and marginalised individuals. This is particularly the case in the area of mental health, which has been experienced as a last minute ‘add-on’ to the NDIS, and which requires a distinct approach that is yet to be fully realised in current NDIS systems.
The literature on outcomes highlights three key areas to watch: measurement, causality and shifting priorities.

What gets measured

Seemingly small differences in the methodology of measurement can produce significant variations in results. Timing is a good example – when and how often you decide to measure something will impact upon the degree of progress towards an outcome. Results will also vary between individuals or families who have different capacities and who are dealing with varying degrees of complex problems. The amount and type of support provided is another factor that can have different results at different times over a period of engagement.
People with disabilities whose situation is made more complex by co-occurring issues such as homelessness or drug addiction present a greater challenge for outcomes measurement because other contextual factors may impede their progress.
The measurement of outcomes also provides challenges to prevention and early intervention approaches because it’s much more difficult to measure something that didn’t happen because of a successful intervention or preventative program.

Causality

Another contested area relates to how you evaluate the causes of positive change. This requires clear and demonstrable program logic matched with validated measurement tools.
Different tools produce different results and this can vary again based on who uses the tools. Whether the outcome is measured by the worker, the client or jointly agreed is another variable. When there are multiple workers or multiple agencies involved, the question of how shared outcomes are managed arises. In addition, there are some instances in which, despite the best efforts of any individual or organisation, the desired outcome is not reached due to circumstances beyond anyone’s control.
Environmental considerations such as access to housing, income support, and employment opportunities need to be factored into systems of outcome measurement, not to absolve anyone of responsibility but to ensure that accountability for outcomes doesn’t extend beyond what can be reasonably controlled.

Shifting priorities

Finally, but perhaps most importantly, the movement towards outcome measurement has been shown to change practice in ways that are not always positive. Essentially, what gets measured becomes what gets valued. This leads to a propensity to not only measure those items that are easier to quantify but also to engage with those clients that are more likely to achieve the outcomes that are required. “Gaming”, “creaming” and “cherry-picking” all refer to the familiar consequences of a push towards more quantifiable and higher levels of outcomes. At the other end of the scale, this results in further entrenching the disadvantage of people with high and complex needs, who are less likely to achieve outcomes easily and who therefore struggle to access the services they need.
In the absence of clear criteria or principles around eligibility for ILC services, the chances that more challenging clients will become excluded is even higher.
This is The Salvation Army’s key concern relating to the implementation of the ILC Framework – that more complex and marginalised individuals with disabilities may end up being excluded because achieving the required outcomes in their case becomes too difficult or too expensive or both.
  1. How to prepare the sector for outcomes-based performance measurement
Questions you might like to consider:
  • What are the biggest challenges for organisations moving to outcomes based funding?
  • What can the Agency do to help organisations meet those challenges?
  • What can people with disability, their families and carers do to help organisations get ready?
  • Is there anything else you would like to tell us?

In addition to the concerns raised in response to Question 1, additional factors to be considered regarding an organisational shift to outcomes-based funding include:
  • The capacity of available funding to sufficiently provide for the necessary organisational infrastructure costs that sit behind frontline service delivery, including management structures; ITS; property and vehicle costs; HR, OHS and finance systems supports, just to name a few examples.
  • The ILC Commissioning Framework does not include provision for staff training. In a rapidly changing environment with high levels of demand upon staff, funding for training, staff availability and backfill provisions will be critical to consistent, quality service delivery.
  • The implications of funding uncertainty in situations where achievement of outcomes is impeded due to circumstances beyond an organisation’s control – eg. economic downturn, housing affordability, unemployment rates, etc.
  • Robust safeguards that ensure that pressures upon organisations to achieve outcomes are not passed on to their clients or result in the exclusion of more difficult or challenging clients. Because it has not yet been completed, it is unclear whether the Quality and Safeguarding Framework will fulfil this function. A good framework will not only measure the outcomes for those who get into the system but will also have a mechanism for tracking who gets excluded and why.

  1. How to grow social capital in the sector, particularly volunteering
While there are many different definitions of social capital, in this context social capital means things like volunteering or the relationships that organisations have with others in the community that contribute to the work of the organisation and help people with disability and their families.
Questions you might like to consider:
  • The Agency would like to see things like volunteering grow in ILC. What can the Agency do to make sure that happens?
  • What barriers might there be to growing social capital?
  • What types of activities work well when delivered by volunteers?
  • Is there anything else you would like to tell us?

The Salvation Army has thousands of active volunteers across Australia and is a firm supporter of the role of volunteering in the community. Volunteering provides clear benefits for those individuals involved, the organisations they help out and the wider community.
These benefits are best seen in the context of value-adding to organisational capacity, systems and structures above and beyond core activities. Obviously, volunteers are not a sustainable substitute for a skilled, paid workforce, neither do they come without cost. The selection, training, coordination and support of volunteers requires the commitment of resources that are frequently not taken into account.
People with disabilities may also find that participation in volunteering gives them opportunities to contribute that are valuable to their own sense of wellbeing and inclusion within the community.
  1. How to prepare the sector for the requirements of the ILC sourcing process
The Agency is moving to a nationally consistent framework for ILC. Funding will be provided to organisations through an open competitive grants process.
Questions you might like to consider:
  • What are the biggest challenges for organisations moving to competitive grant funding?
  • What can the Agency do to help organisations meet those challenges?
  • Is there anything else you would like to tell us?

The Salvation Army acknowledges some positive features of the ILC Commissioning Framework, including that the competitive basis for the grants allocation will take into consideration the benefits of smaller boutique services with specialist service offerings and skills. We also support the notion of co-investment as long as this is not seen as an opportunity for Government to pull back from its own responsibility to fully fund services.
However, we also have a number of concerns:
  • The grant approach means that services have to reapply potentially annually dependent on the activity stream, which has implications for grant writing, retaining and sustaining staff, managing budgets etc.
  • The grant scheme doesn’t come into place until after the cessation of Victoria’s PDRSS block funding, which potentially leaves a significant gap in the service system. The experience of the Barwon NDIS trial was that funding was inflexible and prescriptive, didn’t match the provisions it was replacing in the Community Managed Mental Health System and struggled to meet the needs of the individuals with fluctuating mental health presentations.
  • The role of LAC providers is unclear, there is a suggestion of potential conflict of interest but LAC is also listed under activity stream 5. The rollout of LAC and its relationship to ILC also raises geographic gaps until there is a clearer picture of what full coverage will look like. What does seem clear is that a large provider capturing the breadth of disability services under the NDIS is less likely to be also able to meet the distinct needs of niche target groups such as homeless people with co-occurring AOD issues.

  1. Rural and Remote
The Agency would like to make sure that ILC meets the diverse needs of people with disability across the country.
Questions you might like to consider:
  • What does the Agency need to consider when rolling out ILC in rural and remote areas?
  • How can we encourage and support growth in ILC type activities in rural and remote areas?
  • What things work well in supporting organisations working in rural and remote areas?
  • Is there anything else we need to consider?
  • Is there anything else you would like to tell us?

The Salvation Army’s experience in rural and remote areas highlights some significant differences to service delivery in metropolitan settings:
  • Distance to and between services is a key factor, increasing isolation and reducing service accessibility. This is especially difficult for people who don’t drive or have access to a vehicle. Outreach workers necessarily expend significant hours in their week on the road.
  • The number of service providers is much more restricted, in many cases a single provider is the only option. This can create relational challenges, particularly for individuals with complex needs and/or challenging behaviours. If the relationship with the sole provider is compromised, the person may not receive any service.
  • Connection to related services is also much more limited, so people with multiple issues are less likely to be able to access the range of supports they need. Workers face similar challenges trying to create joined-up solutions with fewer options available.

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