Response to
Consultation Draft of
The National Drug Strategy Consultation
National Drug Strategy 2010-2015 Consultations
MDP 701
GPO Box 9848
Canberra ACT 2601
Australasian Therapeutic Communities Association
Associate Professor Lynne Magor-Blatch
Executive Officer
Board of Directors:
Barry Evans (Chair), Garth Popple (Deputy Chair),
Carol Daws (Secretary), Gerard Byrne (Treasurer),
Eric Allan, Mitchell Giles, James Pitts & Jackie Long
- Introduction
The Australasian Therapeutic Communities Association (ATCA) is the peak-body representing Therapeutic Communities across Australia and New Zealand. Therapeutic Communities (TCs) provide an evidence-based approach to alcohol and other drug treatment which is based on the use of the community as the prime vehicle for change. As such, TCs have a strong emphasis on both self-help and mutual help within a rehabilitation setting, supported by a range of psychosocial interventions.
The ATCA currently includes thirty-seven Organisational, Group, Provisional and Affiliate Members, which represent a total of 67 TCs operating across Australasia. These services employ more than 800 staff and treat over 10,000 people annually as well as providing additional critical services such as detoxification units, family support programs, child care facilities, exit housing and outreach services. As such, therapeutic communities work at all points of the treatment spectrum, from primary prevention and early intervention, to treatment and aftercare. Twelve of our TCs are based in prison services in New Zealand and Australia, representing a growing trend in Australasia to provide treatment services within the prison setting.
TCs have been found to work with a significantly more chaotic and complex group of clients than other treatment modalities. The TC does not generally represent the person’s first treatment attempt. It is important to understand that all treatment modalities play a role in the overall treatment landscape and that ‘one size does not fit all’ when it comes to treatment for substance use.
The ATCA applauds and supports the Australian Government’s commitment to the continuation of the National Drug Strategy and notes the positive and significant results of the previous strategy which can be seen through decreased use of many substances across the community and a commitment to treatment services. The focus on the three pillars of Supply, Demand and Harm Reduction is supported.
Continued and increased emphasis needs to be given to early intervention and treatment strategies, recognizing that whilst reduction of supply is an important strategy; increased funding must also be provided to address the treatment needs of the community. As some people move out of addiction, others are recruited in. The need to maintain a focus on harm reduction strategies, which includes facilitating access to treatment, continues to be a high priority.
With the release and implementation of the Australasian Alcohol and other Drug Therapeutic Communities Standards and Support Package (2009), the ATCA is well placed as a major provider of treatment services across the spectrum, from early intervention to treatment and aftercare, to contribute to this process and to work with Government and treatment services to ensure quality services are established and maintained. The ATCA is currently seeing increased interest in the use of the therapeutic community model, as residential services across Australasia embrace the concept and address issues of quality assurance within their programs.
Additionally, many of our members are in the process of establishing new TCs as governments provide funding and release tenders for the establishment of new therapeutic communities, and this has been particularly evident within the correctional service system. Currently the ATCA includes 12 prison programs in Australia and New Zealand, and it is within the criminal justice system that most research into TC effectiveness has been conducted.
Our member agencies are also working with State and Territory governments to provide new services to Aboriginal and Torres Strait Islander peoples, to those who have co-occurring mental health and substance use disorders and to offenders within prison settings. This has meant that the 37 members of the ATCA are now operating 67 therapeutic communities, which constitutes more than a 50% growth in service delivery over the past five years since funding was provided to the ATCA Secretariat by the Australian Government’s Department of Health and Ageing.
The ATCA, as the peak body, is therefore ideally placed to broker change and to work with Government to ensure quality services are established and maintained and looks forward to a continued and developing relationship with the Australian Government to address this task.
The ATCA provided a comprehensive submission in relation to the National Drug Strategy (NDS)Consultation Paper in March 2010, and at that time addressed the 13 key issues raised in the Consultation paper, providing 11 key recommendations, many of which have been addressed in the Draft National Drug Strategy 2010 – 2015.
The following response therefore addresses some outstandingissues of concern, many of which were raised and discussed at the forum in Canberra on Thursday 2 December 2010,and which we believe still need to be addressed in the continuation of the National Drug Strategy 2010 – 2015.
2. Emphasis in the NDS
The ATCA notes the Consultation Draft of the National DrugStrategy retains the emphasis on the three pillars, that the Health and Law partnership remains the central emphasis of the Strategy, and the continued emphasis on both licit and illicit drugs.
The ATCA believes there needs to be a more equitable emphasis on all pillars. Therefore funding support needs to be adequate to resource the strategies across all areas – and particularly those of prevention and treatment which are referred to under Harm Reduction. We are concerned that services across governments and sectors are better coordinated to provide the best opportunities for individuals and communities experiencing the harms related to substance use.
While the introductory section of the NDS outlines the three pillars of Supply, Demand and Harm Reduction, there needs to be recognition that strategies under “Supply” are much more than just law enforcement.
Objective 2 under the “Supply” Pillar refers to supply reduction for alcohol, tobacco, pharmaceutical and other legal drugs and involves activities targeted toward the regulation of legitimate supply and the detection and interruption of illegal markets. The debate relating to the supply of alcohol also needs to take into consideration the following:
1.Raising alcohol prices
2. Raising purchase age
3. Reducing accessibility
4. Reducing marketing and advertising
5. Increasing drink driving countermeasures
6. Boost treatment options
There needs to be an emphasis on the role and importance of diversion strategies, and their success in moving people out of the criminal justice system through the provision of a range of treatment interventions. Currently these are restricted to illicit drugs, however this needs to be extended to include diversion for alcohol-related issues.
In many jurisdictions, a young person (in particular) is more likely to become involved in the criminal justice system and to gain a prison sentence for drink driving related offences . Drink driving remains one of the biggest killers on Australian roads, with approximately a quarter of all fatal crashes involving a driver or rider with an illegal Blood Alcohol Concentration (BAC). Research has repeatedly demonstrated that between 20% and 30% of convicted drink drivers re-offend (Buchanan 1995; Henderson 1996; Langford, 1998; Popkin 1994; Ryan et al. 1996) and that this sub-group of drivers is disproportionately represented in crash statistics (Hedlund & Fell 1995; Marques et al. 1998).
Diversion, which is referred to under the “Demand” Reduction Pillar, therefore needs to be extended to incorporate a range of diversionary strategies for alcohol misuse and abuse – and particularly as a means of positively redirecting people from the criminal justice system. This is essential as an early strategy to prevent the subsequent carnage and fatalities resulting from the abuse of alcohol – both in terms of family and other violence and road accidents.
The non-government sector plays a particularly important role in the provision of diversion programs, and funding to maintain and extend these initiatives, with the inclusion of alcohol as well as illicit drug use, should remain a priority area for governments. In addition, the development and provision of diversionary programs for offenders with substance use problems provides an opportunity for partnership development between the criminal justice and drug treatment sectors, and should be supported and encouraged.
2.1. Mission statement
The Mission Statement, as outlined in the consultation draft, states: To build safe and healthy
communities by minimizing alcohol, tobacco, illegal and other drug related health, social and economic harms among individuals, families and communities.
It is noted that in the section following, definitions are provided for:Drug, Illegal drug, Pharmaceuticals, and Other drugs. While pharmaceuticals are mentioned separately to other drug category areas and should therefore be included in the Mission, it is recognised that the Mission Statement cannot include each drug type separately. We therefore recommend a simplification of the whole Mission Statement to provide the term of substance use to include all substances.
Therefore the Mission Statementcould read: To build safe and healthy communities by minimizing substance related health, social and economic harms among individuals, families and communities.
2.2. Overarching framework and priority areas
The National Drug Strategy 2010 - 2015 is the Government’s overarching framework and therefore needs to reflect the priority areas of concern. While the term “Drug” may be seen as inclusive of all substances, including alcohol, we believe the title of the Strategy needs to more clearly reflect the Government’s priority areas, and therefore should include the term “Alcohol” in the title.
Therefore we would recommend the title of the Strategy be changed to The National Alcohol and other Drug Strategy 2010 – 2015.
2.3. Sub-strategies
The sub-strategy of The National Alcohol Strategy is due to expire in 2011. It therefore needs to be reviewed and updated to reflect the considerable concerns that alcohol misuse has caused in the Australian community. If “Alcohol” was to be incorporated into the NDS, it is suggested the sub-strategy be known as an Action Plan.
Related to this, is the need to review the National Drug Strategy Aboriginal and Torres Strait Islander Peoples Complementary Action Plan 2003–2009, which is now more than a year past its expiry date. It is noted that many Aboriginal communities have taken the lead in addressing issues of substance abuse, and particularly volatile substances and alcohol, and alcohol’s relationship to the terrible cost of Fetal Alcohol Spectrum Disorder (FASD) within some Aboriginal communities. These initiatives need to be supported by increased funding to allow Aboriginal and Torres Strait Islander communities to initiate and manage innovative programs and strategies.
3. Presentation of the NDS and activities under each of the Pillars
Currently the NDS Consultation Draft is set out in the following order:
- About the National Drug Strategy
- The Pillars
- Pillar 1: Supply reduction
- Pillar 2: Demand reduction
- Pillar 3: Harm reduction
- Supporting Approaches
Listed in this section are Workforce, Evidence base, Performance measures and Governance.
We welcome the inclusion of a section on Workforce in the NDS and would like to recommend that the first reference in relation to Workforce (ie. Who is the Workforce?) be brought to the front of the document and expanded to include the variety and breadth of the AOD workforce – including Hospital Emergency Department staff, Needle and Syringe Program workers and those with lived experience.
People with lived experience comprise a vital and important part of the AOD workforce, and their contribution needs to be acknowledged. In particular, we are concerned that the value of workers with lived experience will be minimized by the concentration on minimal qualifications to the exclusion of these AOD workers. While ongoing professional development should be encouraged and supported through funding, it is important to recognize the unique benefits that peers and those in recovery provide to the sector.
There are many successes which need to be celebrated under the previous Strategy. While the Consultation Draft outlines some of these under each of the Pillars, the document is, nevertheless, framed in somewhat negative terms. The NDS 2010 – 2015 should be framed in waysthat builds on the strengths and achievements of the previous Strategy, expanding and developing the successes and at the same time providing opportunity for innovation. This should be supported under each of the pillars – and would encourage the development of evidence-informed treatment interventions, including the development of both psychosocial and pharmacological interventions as part of drug law reform.
By comparison to the NDS, the Fourth National Mental Health Plan 2009 – 2014is framed in positive, recovery-oriented language with five priority areas which include (1) Social inclusion and recovery; (2) Prevention and early intervention; (3) Service access, coordination and continuity of care; (4) Quality improvement and innovation; and (5) Accountability – measuring and reporting progress.
The Consultation Draft of the NDS highlights the concerns for disadvantaged populations, and in this context includes the strong evidence of association between the social determinants of unemployment, homelessness, poverty and family breakdown. While mentioned, there is a perceived lack of acknowledgement of the need to provide services in association with other sectors to address these social determinants as part of the recovery process.
For approximately 50% - 80% of people who are caught up in substance misuse and abuse, comorbidity with mental health problems, unresolved trauma and abuse are often underlying issues. The role of substances as a way of dealing with underlying issues needs to be acknowledged and a range of interventions provided in partnership across all areas of health and community services.
Therefore substance use may be seen as a way of managing pain and the positive symptoms of mental illness.
The related social problems of lack of housing and community services, education, training and employment has not received attention in the NDS and need to be included as a way of ensuring that those involved in substance use have access to a range of services and support to enable them to participate fully in the community.
Funding therefore needs to be made available and strategies supported under the NDS to address the social determinants of substance use.
3.1. Consumers
There are also some areas which are completely missing from the document – in particular any reference to the important role of consumers. This contrasts dramatically to the way in which mental health consumers are referred to and considered as active members in their own treatment under the Fourth National Mental Health Plan 2009 - 2014. There is an underlying assumption that substance users are a “problem” and even, that families are complicit in the maintenance of harms (supplying alcohol illegally to minors, smoking in cars and other intergenerational issues of substance abuse).
There needs to be a reframing within the document to recognise that whilst families may play a role in the architecture of substance use problems, they may also be the victims of intergenerational abuse and trauma and need to be supported in the recovery process.
Consumers and their families provide the best source of expert advice and should be supported in the treatment and recovery process. For many consumers and their families, trauma and other issues are the underlying cause of substance use and this needs to be addressed as part of a coordinated approach which includes housing, justice, community services, education and employment. Integration of services will facilitate access for people with a range of problems relating to their substance use.
3.2. Alcohol
Among the challenges for 2010 – 2015, risky drinking, alcohol-related violence and accidents are highlighted as continuing to cause significant harms. This needs to be extended to include the considerable concerns relating to Fetal Alcohol Spectrum Disorders (FASD), and the growing recognition of intergenerational issues in alcohol misuse. This poses some very real health concerns in the Australian community, and should also be seen in relation to prevention and early intervention strategies, particularly when we consider that FASD is often seen within families and amongst siblings, evident of the fact that education on the risks of alcohol use in pregnancy has often been lacking. It is an indictment on our health system that siblings within families suffer the life-limiting effects of FASD through a lack of early intervention and screening.
As noted, the misuse of alcohol continues to cause concern in Australian society and its use cannot be addressed without consideration of supply. Differences in legislation between States and Territories and the role of each of the three tiers of Government – Federal, State and Local – need to be considered in the development of strategies related to the availability of alcohol in the community. This includes the number of outlets, opening hours and restrictions on sale.
There needs to be more consideration of the unintended harm resulting from action in one area – such as increased pricing as a strategy to limit supply and availability – which may result in more dangerous use of other substances. Volumetric taxation, rather than an emphasis on types of alcoholic beverages, is considered an important part of a Strategy to address issues of Supply. This also recognises use and misuse across the lifespan, rather than focusing primarily on one group (e.g., young people).
3.3. Pharmaceutical drugs
The draft Strategy provides a new emphasis on the use of pharmaceutical drugs, and this is welcomed by the ATCA, whose members are noting an increase in the number of people contacting services with problems associated with the use of prescribed medications. In particular the increased use of pain medications, which are used both legally and illegally through blackmarket sales, has resulted in a new group of clients accessing services.