David Plant

Director Youth Programs

Richmond Fellowship

Ms Sarah Kirk

Project Officer

Out of Home Care Strategy

Care and Protection Services

Community Services Directorate

GPO Box 158

Canberra ACT 2601

Richmond Fellowship ACT Submission in Response to ACT Community Services Out of Home Care Strategy 2015-2020 Information Paper: Proposed Service Delivery Policy Directions April 2014

Please note that this is an initial and brief submission which presupposes a continuing consultation process.

Preamble

RFACT welcomes this opportunity to respond to the proposed strategy and offers substantial support to the major policy and service system developments proposed. In particular we welcome the emphasis on placement prevention and the strengthening of high risk families; the opportunity for comprehensive therapeutic needs based assessment of children and young people on entry and in an on-going way; the emphasis on trauma informed service responses, speedy return home and permanency of care arrangements where possible, cultural responsiveness, participation of children and young people in decision-making, extended support for transition from care, and the strengthening of and systemic emphasis and understanding which the information paper proposes to apply to accountability arrangements.

RFACT is also strongly supportive of provisions to enable case management and parental responsibility to be transferred to non-government care providers for children and young people on long-term care orders but cautions that this process must be subject to effective systems monitoring and supported by a well-resourced child rights based advocacy system. We question the concept of a lineal ‘continuum of care’ service system which, for some children and young people, has resulted in repetitive experiences of one form of care following on from a failure in a preconceived ‘superior’ form of care. In essence, we would propose that care and placement decisions should always be referenced to comprehensive understandings of the child/young person’s therapeutic and developmental status andneed, and their family/community/cultural circumstance, with decisions made on determining the best way forward rather than setting in process a litany of ‘failed’ placement options. Consistency of care is a critical component of a ‘good’ care system.

The strategy paper offers little in the way of identifying or considering the particular needs and OOHC options applicable to children and young people on short-term care or YJ orders. Considerations might include their separation from those on long term orders in some circumstances. Nor does the paper offers much in the way of identifying or considering the particular needs and OOHC options in circumstances where there is interaction between child protection concerns and the juvenile justice system, including acknowledgement of sometimes conflicting objectives and practice imperatives which impact on the well-being and best interests of the child/young person. This is a policy and practice issue which requires systematic deliberation. It is a significant issue of concern in the RFACT practice arena.

We note that the strategy paper places some emphasis on the hope that paid foster care may become a viable service delivery option in the future. In principle, RFACT would welcome this development but also cautions that both government and non-government service providers would need to work comprehensively together to establish this new field of care practice in a way which safeguards and promotes the well-being of children and young people, and which carefully monitors its capabilities and limitations.

We also note that the strategy paper offers little in the way of developing across portfolio responses to support the high needs target group identifiable as children and young people in out of home care. It could be strengthened by identifying those areas where specific health, educational, mental health, housing, vocational and other across-portfolio responses are required. These responses might include, for example, the foreshadowing of targeted health and educational outreach services, multi-agency service delivery and/or cooperation agreements.

The Proposed Strategy and RFACT’s Practice Arena

RFACT ACT Youth Programs have historically developed around the provision of group based residential care for young people (12 -17) who are on statutory care orders and/or juvenile justice orders. The organisation has a long established cultural affinity with responding to the needs of young people who are highly traumatised and difficult to place within other out of home care environments; and to working with the requirements of both child protection and juvenile justice systems. We have operated over time, a range of residential programs aimed at accommodating different service system needs, e.g. a reception house; and at targeting particular needs groups e.g. transition to independent living program; young male sex offender program. We have also, at various times, developed supportive programs in response to failing in the overall community care response in the ACT e.g. day activity and vocational training programs; and individualised programs for very high needs young people.

Our Youth Program is currently undergoing a substantial reconfiguration aimed at establishing an enhanced therapeutic response, focusing energy on individualised responses to young people through intensive case management, and facilitating a more flexible suite of residential arrangements allowing for, where possible, targeted household programs emphasising, for example, transition to independence, gender, cultural background, AOD response, family reunion et al; and of course, better managing the complexity of household resident mix. We are keen to enter into realistic discussions with CSD regarding the ways in which the best residential care and associated intensive case management and therapeutic care arrangements can be supported by purposeful and effective contracting, funding, evaluative and accountability arrangements. We do note that current arrangements are in many ways counterproductive. The strategy paper’s identification of fixed and variable costing formulas is welcomed but goes only part way to acknowledging the funding issues associated with maintaining a standing commitment to service infrastructure (including baseline staffing and associated requirements), plus the flexible step-up/down capacity requirements of increasingly complex models of response. For example, RFACT used to characterise its service as ‘residential care’. It now characterises three interrelated service types: residential home care; intensive case management, and therapeutic response (assessment, planning and implementation), with ongoing foreshadowing of additions to this service array. It is unlikely that this complexity can be effectively facilitated or accountability delivered through the mechanism of a single ‘residential care’ funding agreement.

Current thinking would suggest that future developments in this evolving model of care could include a range of different staffing arrangements within the residential context including, if possible, paid foster care; extension of service to enable step-up/step-down care options regarding return to family, kinship care, independent and semi-independent living, and assertive outreach to those who disengage from service. A key ingredient for these potential developments is the capacity to deliver an intensive and adaptive case work service. This requirements is contained, currently in embryonic stage, within our currently proposed service reconfiguration arrangements.

We question any concept which suggests that it is effective to require all out of home care providers to directly provide the full suite of possible services. There will be a substantial need for inter-agency arrangements which enable specialisation and the sharing of services across agency clients. It occurs to RF that, where parental responsibility has been allocated to a non-government provider, purchasing arrangements which enable and support effective interagency/shared service delivery would need to be set in place. There is a role for CSD in ensuring and facilitating the development of such arrangements (through for example, standardisation of interagency agreement) so as to ensure that competitive processes, cherry picking and agency commercial interests do not intervene.

Key Points and Recommendations Arising

  1. Transference of case management and parental responsibility to non-government care providers for children and young people on long-term care orders must be subject to effective systems monitoring and supported by a well-resourced child rights based advocacy system.
  1. Care and placement decisions should always be referenced to comprehensive understandings of the child/young person’s therapeutic and developmental status and need, and their family/community/cultural circumstance, with decisions made on determining the best way forward rather than preconceived notions of a continuum of care process which might set in process a litany of ‘failed’ placement options. Consistency of care is a critical component of a ‘good’ care system.
  1. The strategy paper offers little in the way of identifying or considering the particular needs and OOHC options applicable to children and young people on short-term care or YJ orders. Considerations might, for example, include their separation from those on long term orders in some circumstances (such as residential care placement).
  1. The strategy paper offers little in the way of identifying or considering the particular needs and OOHC options in circumstances where there is interaction between child protection concerns and the juvenile justice system, including acknowledgement of sometimes conflicting objectives and practice imperatives which impact on the well-being and best interests of the child/young person. This is a policy and practice issue which requires systematic deliberation.
  1. RFACT would welcome the development of paid foster care as a viable service delivery option but cautions that both government and non-government service providers would need to work comprehensively together to establish this new field of care practice in a way which safeguards and promotes the well-being of children and young people, and which carefully monitors the capabilities and limitations of this service delivery modality.
  1. The strategy paper offers little in the way of developing across portfolio responses to support the high needs target group identifiable as children and young people in out of home care. It could be strengthened by identifying those areas where specific health, educational, mental health, housing, vocational and other across-portfolio responses are required. These responses might include, for example, the foreshadowing of targeted health and educational outreach services, multi-agency service delivery and/or cooperation agreements.
  1. RFACT are keen to enter into realistic discussions with CSD regarding the ways in which the best residential care and associated intensive case management and therapeutic care arrangements can be supported by purposeful and effective contracting, funding, evaluative and accountability arrangements. We do note that current arrangements are in many ways counterproductive. The strategy paper’s identification of fixed and variable costing formulas is welcomed but goes only part way to acknowledging the funding issues associated with maintaining a standing commitment to service infrastructure (including baseline staffing and associated requirements), plus the flexible step-up/down capacity requirements of increasingly complex models of response. For example, RFACT used to characterise its service as ‘residential care’. It now characterises three interrelated service types: residential home care; intensive case management, and therapeutic response (assessment, planning and implementation), with ongoing foreshadowing of additions to this service array. It is unlikely that this complexity can be effectively facilitated or accountability delivered through the mechanism of a single ‘residential care’ funding agreement.
  1. RFACT questions any concept which suggests that it is effective to require all out of home care providers to directly provide the full suite of possible services. There will be a substantial need for inter-agency arrangements which enable specialisation and the sharing of services across agency clients. It occurs to RF that, where parental responsibility has been allocated to a non-government provider, purchasing arrangements which enable and support effective interagency/shared service delivery would need to be set in place. There is a role for CSD in ensuring and facilitating the development of such arrangements (through for example, standardisation of interagency agreement) so as to ensure that competitive processes, cherry picking and agency commercial interests do not intervene.

David Plant

Director of Youth Services

Richmond Fellowship of the ACT Inc.

Mobile:- 0427 773 094

Email:-

27/05/2014

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