Creating capacity by reducing red tape. Strategies for reducing government red tape for not-for-profit community service organisations.

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1 Page 1 Creating capacity by reducing red tape Strategies for reducing government red tape for not-for-profit community service organisations August 2012 Page 1

2 Creating capacity by reducing red tape: strategies for reducing government red tape for not-for-profit community service organisations The Queensland Council of Social Service (QCOSS) works towards a fair, inclusive and sustainable Queensland. A key part of achieving this is by leading on issues of significance to the Queensland notfor-profit social, health and community industry. This industry is a part of the broader Health and Community Services Industry, which contributed $16.2 billion to the Queensland economy in i. Not-for-profit organisations in this industry provide vital frontline services to vulnerable Queenslanders, with significant positive flow on impacts for the broader community. They are in the business of achieving positive outcomes for vulnerable people. Currently the red tape generated from government contracting and compliance places significant pressure on these organisations, taking them away from frontline service delivery. In 2008, the Australian Centre for Philanthropy and Nonprofit Studies reported that dealing with government generated paperwork cost organisations, on average, 1.7per cent of their total revenue ii. By reducing this red tape, the government has the opportunity to increase the services provided without having to increase spending. This will happen by creating greater flexibility and autonomy for contracted services. This flexibility and autonomy will free organisational resources to enhance frontline services. This will be done by increasing organisational capacity for innovation, collaboration, evaluation, and research. QCOSS sees the recommendations made in this paper as presenting many opportunities for government to work cooperatively with the community services industry. While some of this work will take time and may involve transitional costs, working collaboratively with industry will ensure outcomes that save time and money, and create greater capacity for organisations to respond to vulnerable Queenslanders. Table of contents: Adopting one criminal history screening system 3 A fair and transparent risk assessment framework to determine compliance and accountability requirements for contracted services 4 A whole of government data dictionary to standardise financial, client and performance reporting 5 Contracts and contract management practices that focus on outcomes and partnerships 7 Streamlining grant and tender application processes 8 Simplifying and harmonising quality standards across all government departments 9 Page 2

3 Adopt one criminal history screening system, with one card for working with vulnerable people. Currently there are multiple and duplicative criminal history screening requirements for funded services. People working or volunteering with children and young people are required to obtain a Blue Card, which is administered by the Commission for Children and Young People and Child Guardian. This card screens and monitors all applicants for particular criminal offences associated with abuse and exploitation of children. People working or volunteering with people with a disability at organisations funded by Disability Services are required to obtain a Yellow Card. This card is administered by the Department of Communities and screens and monitors all applicants for particular criminal offences associated with abuse and exploitation of children and adults, including fraud. People who work with children and adults with a disability in an organisation funded by Disability Services are currently screened twice and monitored through both systems. Employers must complete paperwork for both systems, every time they recruit a new employee and volunteer. Previously, Disability Services gave funded organisations a contribution towards the cost of criminal history screening for yellow cards. This has recently ceased, placing the cost of this compliance back onto the organisation or employee. Implementing one criminal checking system for all individuals working with vulnerable people would eliminate costs to Government, organisations and employees. Some organisations also require employees to undergo a full criminal history check on top of the Blue or Yellow Card requirements. A single, broader criminal checking system could also eliminate the cost of this. Case example These cards are required by a volunteer board member for an organisation that works with people with a disability, children and young people. Each card requires a separate form to be completed by the organisation, as well as an individual payment. QCOSS Recommends: The Queensland Government adopts one criminal history screening system for individuals working or volunteering with vulnerable people by 1 January A single criminal history screening system could be modeled on the United Kingdom s screening process that has one process for all individuals working with vulnerable people. Page 3

4 Working with the industry to develop a fair and transparent risk assessment framework to determine compliance and accountability requirements for contracted services The current compliance and accountability requirements for not-for-profit organisations delivering contracted services are disproportionate to the financial risk they pose. While government departments are required to use the National Standard Chart of Accounts for financial acquittals, organisations continue to be asked to report on financial information outside of these standards. This means that organisations regularly convert what is in their accounts to match multiple and inconsistent reporting frameworks. Case example A medium organisation (40 to 50 employees) with multiple programs requires 12 different financial databases to fulfill their financial contractual arrangements. They collect and report on different financial data for different contracts. The organisation has estimated that one full-time administrator is required to fulfill these contractual requirements, all of which occur quarterly. This level of administrative burden is seen as unnecessary, and detracts resources away from frontline work and service innovation. Developing a fair and transparent risk assessment framework in partnership with industry will ensure the frequency of reporting required from organizations is proportional to the level of risk associated with program delivery. Ensure government departments use of the National Standard Chart of Accounts for financial acquittals will ensure less time is spent by organisations converting their accounts to multiple financial reporting frameworks. QCOSS Recommends: Developing a fair and transparent risk assessment framework in partnership with industry. Attaching the risk assessment framework to approved service provider or quality system processes. Providing options for reporting to include progressive, monthly or quarterly, depending on the nature of the program being delivered. Whenever possible, the reporting procedure used by Disability Services should be adopted. This involves providing the Department with a: 12 monthly audited financial statement quarterly directors certification quarterly reporting against service outputs Ensuring government departments use of the National Standard Chart of Accounts for financial acquittals. Page 4

5 Developing a whole of government data dictionary to standardise financial, performance and client data collection Methods for program performance and outcome reporting, and the collection of client data are disjointed and do not provide data that is useful for government or organisations. Performance data is generally entered by frontline workers into databases maintained by funding bodies. Once submitted, it is extremely difficult for organisations to access this data to use for service planning and evaluation purposes. While some data systems generate reports, they are not in a format that is useful for services. Other data systems do not generate immediate reports, and organisations receive reports from the funding body anywhere between one and six months after the data has been submitted. Different programs require different performance and outcome information, which makes comparison of outcome data across whole organizations and regions extremely difficult. Organizations that regularly collect and use outcome data have to use database systems separate to those provided by funding bodies. This kind of database software is expensive and requires frontline workers to enter information into two systems. Developing a data dictionary to standardise the collection of financial, client, and performance data across the whole of government would reduce the cost and time spent converting data and doing special collections to comply with multiple reporting frameworks iii. The Australian Charities and Not-for-profit Commission (ACNC) is developing a report once, use often reporting framework for financial and governance information. This work will occur in partnership with State and Territory Governments. Therefore any data dictionary developed in Queensland should align with this work to avoid organisations having to provide information across multiple frameworks. Developing a single, centralised database for collecting information as defined in the dictionary would reduce time frontline and administrative workers spend collating and submitting data. It would also provide a large, coherent data set to analyse the impact of community service organisations and specific service delivery models. This data can be made available to service providers, researchers and government to inform the identification of need, opportunities for service improvement, and identifying best practice in service delivery. Page 5

6 QCOSS Recommends: Working in partnership with industry, universities and the ACNC to develop a whole of government data dictionary to standardise financial, client, and performance data, which also allows for the recording of qualitative case studies. Developing a single, centralised database for data collection, based on the data dictionary. This could be modeled on the Standard Business Reporting database iv, and could leverage off work being done by the ACNC to create a central database for financial and governance information. v De-identified data relating to client need and service outcomes be freely available to organisations, government and research institutions to support service development based on an understanding of client and community need, and best practice. Page 6

7 Develop contracts and contract management practices that are outcomes focused and encourage partnerships. Historically, government contracts with not-for-profit organisations and their contract management processes have not respected the independence and autonomy of organistions, and add additional administrative burden. Currently, contract compliance makes up to 60 per cent of an organisation s total compliance costs. vi In 2011 QCOSS surveyed the community services industry to identify opportunities for improving contract management processes with the (then) Department of Communities. This report was submitted to the Department to inform an internal review of their contract management processes. This review defined contract management as: The factors impacting on an organisation s relationship with the Department once their service agreement has been negotiated and signed. This includes issues around acquittal, assessments and the relationship with departmental officers, such as Community Resource Officers and/or Community Support Officers. vii This report found that strong, positive working relationships, which respect organisation s independence and autonomy, and the sharing of timely, consistent and reliable information, are vital to an efficient and effective contracting relationship. A number of the elements associated with contract compliance have already been addressed in this paper. When the proposed funding bill is passed there will be an opportunity to re-examine current contracts, such as the Common Service Agreement, to ensure they comply with the principles of the Act, and create a framework for a true partnership with government in delivering outcomes. Currently, service contracts are shifting from input-based to output-based. Input based contracts are based on the number of staff organizations are funded to employ, and other financial inputs. The shift to outputs, such as hours of service delivery, has been a significant step forward towards achieving outcome-based service agreements. As the new government moves towards outcome-based contracting, it is vital to work with the industry to establish the outcome indicators and measures that will form the base of investment in community services. QCOSS Recommends: Once the proposed funding bill is passed, government work with the industry to review government contracts and contract management processes to ensure they are consistent with the principles of the act. During the review process, consider contracts and contract management processes based on joint ventures, and true partnership arrangements between organisations and funders that focus on an issue or an outcome. Government works with industry to develop outcome indicators and measures that will form the basis of outcome-based contracts. Page 7

8 Streamline grant and tender application processes across the whole of government so they are proportionate to risk Government tender and grant application processes can sometimes be time consuming, have unclear eligibility and unreasonably short timeframes for submission. Community service organisations operate with scarce resources. In 2010, the Productivity Commission found that organisations are generally funded at around 70 per cent of the full cost of delivering services viii. In real terms, this funding gap means that organisations are constantly applying for government and philanthropic grants to respond effectively to their clients and community. Applying for these funds takes time and resources away from frontline service delivery, and service innovation. Organisations spend a significant amount of time applying for government grants and are unsuccessful. This is often due to unclear eligibility criteria, poor instructions and unreasonably short timeframes. QCOSS Recommends: Tender and grant specifications are made more specific so organisations are not applying for grants they are not eligible for. Grants have different processes depending on the size of the grant, with larger grants adopting an initial Expression of Interest that can provide organisations with prompt feedback regarding eligibility. All tenders have a contact person in the program area to ask questions regarding service eligibility. Government implements consistent timeframes for grant applications - minimum six weeks with eight weeks being preferable. Feedback on applications provided in all notification letters. Organisations that have existing service contracts with government do not need to resubmit basic information about their service. Government work with QCOSS and other industry representatives to ensure that changes to the tender processes are robust and mitigate risk without placing unnecessary administrative burdens on organisations. Page 8

9 Simplifying and harmonising quality standards across all government funded services Complying with multiple sets of quality standards for government funded services places a significant time and money cost onto organisations. The industry has led, and worked with government to create and trial a common set of standards across the community services, disability, and child safety program areas. The Human Services Quality Framework has now entered the implementation phase. Work to obtain mutual recognition with this quality framework and other national standards must continue to create a real reduction in compliance burden on organizations. QCOSS recommends: Work is continued to seek mutual recognition between the Human Services Quality Framework and national standards. QCOSS would like to acknowledge and thank the community service organisations and the Australian Centre for Philanthropic and Not-for-profit Studies for providing vital information and advice during the preparation of this paper. This paper was prepared by Anne Curson, Sector Strategy and Service Development Team, at the Queensland Council of Social Service. i Department of Communities 2012 The Health and Community Services Industry Building a stronger economy and a fairer Queensland. Queensland Government: Brisbane ii Ryan C., Newton C. & Lowndes 2008 How long is a piece of red tape? The paperwork reporting cost of government grants..australian Centre for Philanthropy and Nonprofit Studies, Queensland University of Technology: Brisbane iii Ryan et al 2008 p iii iv For more information on the Standard Business Reporting Database, visit: v For more information on the Australian Charities and Not-for-profit Commission s work on a centralised reporting framework, visit: ml/acnc_ir_07.htm vi vii Carlyon T Working Together Green Paper, Community Services Futures Forum: Brisbane Queensland Council of Social Service 2011, Community Contract Management Review: Report for Department of Communities, QCOSS: Brisbane, p 3, Available at: %20Contract%20Management%20Mar% pdf viii Productivity Commission 2010, Contribution of the Not-for-Profit Sector, Research Report, Canberra Page 9

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