report

Department of Communities’ Administration of Family and Domestic Violence Support Services

This audit assessed if the Department of Communities effectively administers contracts for the provision of support services for people experiencing family and domestic violence.

Auditor General’s overview

Family and domestic violence is a complex and pervasive issue that impacts people from all walks of life. Preventing and responding to family and domestic violence is a responsibility shared by the whole community. However, State government entities have the capacity, through their role and funding to provide specific services and responses.

The Department of Communities (the Department) invests significant funding every year in the community services sector to provide a range of family and domestic violence support services across the State. This report provides Parliament and the public with foundational transparency on how these services are structured, findings on how effectively the Department is administering contracted services and whether it knows if services are meeting demand.

It was pleasing to see that contracts were generally administered well, albeit with opportunities for improvement.

However, we found that the Department could do more to improve its understanding of the current demand and how long people are waiting to access those services. While I recognise that addressing a problem like family and domestic violence is never simple, without this information the Department will struggle to provide evidence-based information to Government to determine future funding and service needs.

I am pleased that the Department has already commenced steps to address the recommendations from this audit. I hope the release of Path to Safety: Western Australia’s Strategy to Reduce Family and Domestic Violence 2020-2030 will provide the Department with the impetus and structure to address the issues my Office has identified in this audit.

Executive summary

Introduction

The objective of the audit was to assess if the Department of Communities (the Department) effectively administers contracts for the provision of support services for people experiencing family and domestic violence (FDV).

We focused on the Department as a primary contractor of FDV support services in Western Australia (WA) and the service agreements it has with those providers. This audit did not examine the effectiveness of services and outcomes.

Background

In 2019-20, FDV response teams (consisting of staff from the Department, the WA Police Force and FDV service providers), recorded 49,198 FDV incidents in WA. COVID-19 further compounded risks around FDV. For example, between March and November 2020 the WA Women’s Helpline received on average a 22% increase in calls compared to the same period in 2019. FDV can impact people from all walks of life, but certain groups are more vulnerable, including but not limited to children, young and older women, Aboriginal and culturally and linguistically diverse people.

Despite the number of reported FDV incidents in Australia, it is also known that many people do not contact the police or seek support after an FDV incident.[1] FDV is a complex issue and its effects can impact all aspects of peoples’ lives. In turn, responses to FDV can also be complex, involving multiple entities and services.

Figure 1 shows key entry points into the State FDV service system. These services do not operate as a discrete response but interact with a wide range of other organisations and their activities.

Source: OAG using Department of Communities information
Figure 1: Key entry points into the FDV service system

In 2019-20, the Department spent $45.9 million on contracting FDV support services (see Appendix 1 for information on COVID-19 funding). In October 2020, the Department had 89 active service agreements (contracts) and 56 grant agreements (including 45 National Partnership Agreement COVID-19 Domestic and Family Violence Response grants). Contracted services include:

  • Accommodation and support – for women and children that experience FDV and for male perpetrators (18 and older) to address violence issues and help change behaviours.
  • Three lead 24/7 specialist emergency response services – these provide 24 hour, 7 days a week crisis response to women and children requiring immediate assistance. They provide coordination, facilitation and a referral point for WA Police Force and key emergency crisis care organisations.
  • Counselling and advocacy – to assist adults, young people and children to find solutions to problems resulting from FDV. They also include services for perpetrators or those at risk of perpetrating, to hold them accountable and assist them to accept responsibility for their behaviour.
  • Coordinated response services – jointly triage FDV incident reports, provide risk assessments and appropriate responses for families and individuals. They are part of a partnership between the Department, the WA Police Force and other non-government FDV service providers.
  • Domestic violence outreach – these provide early intervention and prevention strategies aimed at breaking the cycle of FDV and preventing women and children becoming homeless following FDV incidents.
  • Safe at Home – supports women and children experiencing FDV to stay in their housing, when it is safe to do so.

Total funding to the Department has remained relatively stable since 2017-18 (Figure 2) which includes income from State appropriated funds and Commonwealth agreements. State appropriation increased in 2017-18 to meet a drop in Commonwealth funding but decreased to prior levels in 2018-19 when Commonwealth funding was reintroduced.

Source: OAG using Department of Communities information
Figure 2: Income sources for Communities-funded prevention and reduction of FDV

The Government launched Path to Safety: Western Australia’s Strategy to Reduce Family and Domestic Violence 2020-2030 (the new Strategy) on 22 July 2020. The new Strategy continues with a whole-of-government approach and highlights the need for wider community commitment to addressing FDV. The Department is the lead entity for the coordination of the new Strategy and policy direction for the prevention of FDV in WA. The Department will continue to use contract services to provide FDV support under the new Strategy.

The new Strategy identified 4 key focus areas:

  • work with Aboriginal people to strengthen Aboriginal family safety
  • act now to keep people safe and hold perpetrators to account
  • grow primary prevention to stop FDV
  • reform systems to prioritise safety, accountability and collaboration.

The First Action Plan 2020-2022, released at the same time, has a specific focus on addressing the impact of COVID-19 on WA families, consolidating existing efforts and partnering for change.

Audit conclusion

The Department’s administration of the provision of FDV support services is not fully effective. While there was adequate day-to-day administration of current contracted services, with some areas for improvement, the Department lacks an overarching understanding of community demand and wait times. This limits its ability to assess if current services are sufficient, if gaps exist and to effectively plan for future requirements.

Current FDV contracts are appropriately authorised, include quality, compliance and reporting requirements and have set review processes to support ongoing provision of services. However, there are opportunities for the Department to strengthen aspects of its contract management including its timeliness of service reviews, verifying service providers’ compliance with legislation and how it uses information from service providers to inform its future planning of services.

The Department does not know if FDV support services are meeting needs, nor can it quantify if performance varies over time and in response to different factors. This is because it does not collect or monitor demand and waitlist data. In addition, it has extended contracts without reviewing the ongoing need or funding approach for services. To address priority actions in the new Strategy, including that victims have immediate, early and ongoing access to safety and are supported to recover, this information is key.  

Recommendations

To strengthen the administration of FDV support services the Department should:

  1. Improve the management of contracted services by:
    1. using provider feedback to better inform overarching planning for services
    2. completing service reviews within agreed set timeframes
    3. verifying compliance with contract requirements, including the Working with Children (Criminal Record Checking) Act 2004

The Department’s response:

  1. Communities agrees with this recommendation and internal reforms already underway are designed to address it.
    Our Finance division is implementing a more rigorous and comprehensive approach to service group level input into the issues and trends register. This improved systemic collation of service group level information will better inform overarching planning for services to implement the clear direction set by Path to Safety: Western Australia’s Strategy to Reduce Family and Domestic Violence 2020-2030.
    This process of improvement commenced in December 2020 for new service agreements over $5 million. Communities’ Finance division has trialled this on the one new service agreement established since then and will roll it out on each new or renewed service agreement from now.
  2. Communities supports this recommendation.
    Our Finance division has commenced work to inform a new contract management system that will support more efficient, integrated and consistent processes. A tracking system will be developed and implemented by July 2021 to monitor service reviews are undertaken by contract managers. Policies and procedures will be updated and completed by December 2021 to ensure a consistent approach to undertaking service reviews.
  3. Throughout service review processes contract managers ensure services providers are aware of and adhering to their compliance requirements, and this is documented.
    Exceptions occur occasionally for a range of reasons.
    Communities’ work already underway on more efficient, integrated and consistent ways of working will improve the verification of compliance with contractual obligations. In November 2020 Communities’ Finance division provided improved guidance to contract managers for processes and documentation of service reviews with a focus on compliance requirements. A follow up meeting to reinforce these changes is scheduled for March 2021. A forthcoming review of the Purchasing and Contracting Serviced Manual will further support this. This is expected to be completed by December 2021.

Implementation timeframe: August to December 2021

  1. Identify and collect relevant data on un-met demand and waitlist times, to inform performance, where services are needed and what types of services are required

The Department’s response:

Communities supports this recommendation. While this data is collected across some FDV service groups, this is not the case for FDV Counselling and Advocacy Support and FDV Coordinated Response services.
Communities’ Finance division contract managers will discuss the additional collection of un-met demand and waitlist data for the FDV Counselling and Advocacy Support service group and the FDV Coordinated Response with relevant service providers in the next service agreements negotiations ahead of the 30 June 2022 contract cessation dates. These discussions with providers are expected to commence from July 2021. Consideration will be given to how to support additional reporting while minimising the impact on services.
Communities will use this data to inform commissioning that supports the implementation of the key priorities outlined in Path to Safety: Western Australia’s Strategy to Reduce Family and Domestic Violence 2020-2030.

Implementation timeframe: August 2021

  1. Complete its procurement planning to meet the expectations of the new Strategy, including a review of current contracted services to determine if any changes are needed and to identify any service gaps

The Department’s response:

In December 2020, the Expenditure Review Committee (ERC) requested the development of a State-wide Commissioning Strategy for community services (the Strategy), incorporating agency-level commissioning plans. The Department of Finance (in consultation with the Departments of the Premier and Cabinet and Treasury) is due to report back to the ERC with the Strategy as part of the 2021-22 Budget process.
The Strategy will aim to capture commissioning needs and gaps across government funded services for the next 5 years and is intended to understand not only services contracted under the Delivering Community Services in Partnership Policy, but all community services delivered by or on behalf of agencies to provide Government with better insight into what, where and how it is investing in community services, and the intended outcomes of this investment.
To assist with this work, Communities will develop an Agency Commission Plan to inform the Strategy. The timeframe for this will be informed by the Department of Finance’s planning for the State-wide Commissioning Strategy.
In developing the Agency Commissioning Plan, the Department will consider and prioritise services in the context of WA Government policy priorities, including (but not limited to):

  • Government strategies, policies and reforms for key community supports, such as FDV, Homelessness, and Out-of-Home Care reforms;
  • 2021 election commitments; and
  • The Closing the Gap (CTG) Agreement commitment to implement measures to increase the proportion of services delivered by Aboriginal organisation, particularly Aboriginal Community-Controlled Organisations (ACCOs) (cl.55) and to support outcomes aligned with CTG targets.

Communities’ Finance division has approved the Department’s overarching Community Services procurement plan with the first stage commencing 1 July 2021. This will implement a phased approach to the contracting and procurement cycle to align with internal resources, sector capacity and alignment to strategies for specific services such as Path to Safety: Western Australia’s Strategy to Reduce Family and Domestic Violence 2020-2030.

Implementation timeframe: August 2021

  1. Publicly report on progress against the new Strategy and action plans at least annually

The Department’s response:

Path to Safety: Western Australia’s Strategy to Reduce Family and Domestic Violence 2020-2030. is a whole of government, whole of community approach. Reporting arrangements are outlined in the Strategy, and oversight and implementation of the Strategy is supported by the Path to Safety Steering Group, comprising members from relevant WA Government agencies, peak bodies and academia.
The Department of Communities will give consideration to the recommendation in this context of existing reporting arrangements, and as part of a broader approach to the governance and reporting of the implementation of the many strategies Communities has carriage of.

Implementation timeframe: August 2021

Findings

The Department has effective processes to administer its current contracts, but there are areas for improvement

The Department has effective processes in place to administer its current contracts to support ongoing provision of services. Contracts follow the State government’s Delivering Community Services in Partnership Policy (Partnership Policy) (Case study 1) and comply with the Department’s processes most of the time. We identified areas for improvement, including timeliness of service reviews, processes to capture and evaluate issues raised by providers and verification checks for some contract conditions.

Case study 1: Delivering Community Services in Partnership Policy

The Partnership Policy, originally implemented in 2011 and replaced with the current version in October 2018, is designed to build partnerships between the public sector and the not-for-profit sector through planning and delivering sustainable community services. The Partnership Policy applies to all WA public sector entities that procure community services. 

A key element of the Partnership Policy is to tender for outcomes, which are the changes, benefits, learnings or effects at a community or individual level as a result of the service. The policy supports public sector entities to develop transparent and consultative needs analysis, supported by appropriate data collection to demonstrate achievement of outcomes.

Under the Partnership Policy, contracts must meet several requirements, including:

  • expected community and service-level outcomes
  • avoid prescribing what resources will deliver a service, such as staff levels and salaries
  • clear performance and outcome measures
  • price review mechanisms
  • minimum 5-year initial contract terms (not including extension options).

The Partnership Policy also advocates for relationship-based contract management. This means public sector entities should develop a collaborative relationship with service providers to actively manage delivery of outcomes through the life of the contract.

Source: Department of Finance

We reviewed 5 contracts, worth $1.86 million in 2019-20, including a mix of metropolitan and regional providers for counselling and advocacy support and coordinated response services. All 5 contracts we reviewed:

  • specified relevant service outcomes and performance measures
  • had reporting requirements including 6 monthly progress reports and a minimum of 3 service reviews across the life of the contract
  • included price indexation in line with the Partnership Policy
  • listed quality standards, guidance and frameworks relevant to FDV, including a requirement for service providers to meet the Western Australian FDV Common Risk Assessment and Risk Management Framework.

Counselling and advocacy services had additional requirements to work towards best practice for victims of FDV and provision of perpetrator services in WA and implement the Practice Guidelines: Women and Children’s FDV Counselling and Support Programs.

Controls to review and approve payments to providers were in place and being followed by staff. We found there were appropriate segregation between the contract award process, management of the contract, and approval of payments to providers. The Department also checked providers’ compliance with reporting requirements prior to releasing payment, which includes the provision of 6 monthly progress reports, audited financial statements and a copy of their disability access and inclusion plans. Contract managers engage with providers on an ongoing basis and complete desktop reviews of progress reporting. Effective controls and segregation of duties reduce the risk of incorrect or fraudulent payments to providers.

Service reviews were not always conducted on time and documentation could be improved

The Department’s mid-contract service reviews were delayed. For 4 of the 5 contracts we reviewed, mid-contract reviews were delayed between 5 to 9 months. Start and end of contract service reviews were conducted on time for 4 of the 5. For 1 contract the Department was unable to provide documentation for either the start or mid-contract service review reports. Service reviews help to assess if a service is meeting needs, outcomes, quality standards and contract requirements as well as if it is operating efficiently and effectively. Ensuring service reviews happen on time and are well documented supports effective contract management.

There is no systematic process to capture issues raised by providers during service reviews to inform future service planning. The Department demonstrated that issues raised by providers were discussed, such as the need for support for male victims and competing priorities for child protection workers involved in coordinated response teams. However, it could not show how these issues were resolved or evaluated to inform future service design. Processes to record and collate knowledge collected from providers would support the Department’s overarching future service planning.

Processes for verifying that providers comply with contract requirements can be improved. The 5 contracts we reviewed included a requirement to comply with legislation including the Working with Children (Criminal Record Checking) Act 2004 and other conditions such as insurance and police clearances. The Department told us compliance requirements are discussed during service review meetings, but there was insufficient documented evidence to support this. Documented evidence of providers’ compliance and the Department’s verification is important to help ensure the safety of clients and quality of service delivery.

Improved information is needed to understand if services are meeting demand

The Department does not collect data on un-met demand or waitlist times for all services, nor does it set expected timeframes in which a person should receive a service. Performance data for State funded services is focused on the number of clients who receive the service (Case study 2). For some services groups, like counselling and advocacy support, it would be valuable to collect information on waitlist times. Providing the right services at the right time is key. To fully understand the capacity and demand for FDV support services the Department needs to know how many people request the service, how many are unable to access it, and why, and if any wait times exist and the reasons for these. Without this information the Department cannot know if its contracted services are meeting the needs of people experiencing FDV.

Case study 2: Reporting requirements for FDV service contracts – understanding demand

All providers must complete 6 monthly progress reports to the Department on outcome indicators relevant to the service group, see example below. These indicators provide the Department with the number of clients and type of services they accessed, but not the number who attempted and failed to access the service or wait times.

Service outcomeOutcome indicators/Measures of success
Clients exposed to FDV are assisted to enhance their safety
  • Number of clients provided with outreach services and brokerage funding

  • Number of clients assisted to access mainstream services to enhance their safety and wellbeing

  • Number of clients who have risk assessments and safety plans developed during period of service delivery

  • Number/percentage of clients who report increased knowledge and skills regarding their safety and future plans on exit from the service

  • Number of case management plans developed

  • The proportion of clients who achieved their case management goals on exit from the serviceNumber of clients who received accommodation

  • Number of nights an accommodation service was provided
  • Source: Department of Communities

    The Department demonstrated the need to understand waitlist times in November 2019, after identifying a drop in counselling services provided for children, in data reported by service providers. Further investigation by the Department’s contract management team, including a request for un-met demand information from the service provider demonstrated a 2 to 3-month waitlist. The Department used this data to develop a submission for additional funding, however, the request did not proceed. Without this demand data the Department will struggle to justify the need, type and location of new services.

    In the absence of collecting data about service demand in its own reporting, the Department can still access information on unassisted requests for some types of services (Figure 3). Services funded through the National Housing and Homelessness Agreement (NHHA), and some NHHA state matching funds require providers to complete additional reporting to the Australian Institute of Health and Welfare (AIHW) for the Specialist Homelessness Services Collection (SHSC). While the Department does verify this data, it was unclear how it was being used to inform future planning.

    Source: OAG based on Department of Communities information
    Figure 3: Reporting requirements based on funding source

    Under the First Action Plan 2020-2022, the Department is responsible for developing a data dashboard, intended to better inform the broader picture of FDV needs in WA. A cross entity steering group has been established and held its first meeting in November 2020. This group is responsible for establishing reporting mechanisms to track implementation of actions. Transparent, public reporting of progress for items in the first action plan will support accountability for delivery of this important groundwork.

    The Department has extended contracts without individual review and does not have a funding approach to address future needs of services

    Contracts have been extended multiple times without being reviewed to ensure they reflect current and future needs. Eighty-four of the 89 current contracts are substantially unchanged from when they were originally signed, some up to 10 years ago. Letters sent to 35 service providers in February 2019 indicated extensions were to allow for continuity of service, while the Department reviewed its service mix in light of the new Strategy. At December 2020, the Department had still not reviewed these services. Figure 4 shows a timeline of contract extensions for 1 of the contracts we reviewed. Extending contracts without review creates a risk that they may not reflect current and future needs.  

    Source: OAG using Department of Communities information
    Figure 4: Timeline of contract extensions from a sampled FDV service

    The Department has not developed a FDV funding approach to address future service needs. The amount committed to funding ongoing contracted services remains relatively consistent (Figure 5), with increases limited to indexation. Under this model, services like counselling and advocacy, must adapt delivery areas, operating hours and staff to maintain viability. The State COVID-19 Recovery Plan committed a total of $1.08 million in one-off funding to the 22 counselling and advocacy services, to meet anticipated increases in demand and where possible, restore reduced service levels. Once this funding ends, contracts will return to their original funding rates. The Department relies heavily on contracted services to provide frontline FDV support. It needs to develop an ongoing funding approach to reflect changes envisaged in the new Strategy and meet future needs.

    Source: OAG using Department of Communities information
    Figure 5: Allocation of Communities’ funding for preventing and responding to FDV

    Response from the Department of Communities

    Family and domestic violence is a far-reaching problem in Western Australia. To turn this around we must continue to improve our responses as individuals, agencies and as a community. Stopping family and domestic violence is everyone’s business.

    Through Path to Safety: Western Australia’s strategy to reduce family and domestic violence 2020-2030 we focus our efforts on some key priorities.

    The safety and wellbeing of victims is our first priority. At the same time, we need to hold perpetrators to account and support them to change their behaviour.

    We need to prevent violence before it starts. It is especially important that we increase our prevention efforts and change the social conditions and attitudes that enable violence against women to occur.

    It is imperative that we work together across government agencies and the community sector to create a safe, accountable and collaborative service system. We know that integrated responses are considered best practice in family and domestic violence.

    To make a difference, across government our support and prevention strategies need to respond to the unique needs and experiences of people and communities, rather than providing a one-size-fits-all approach.

    The department is firmly committed to continuing to review and improve how we serve the people of Western Australia. We are now exploring new ways to harness data and information to inform our planning and commissioning of services. We are actively looking at how we do business, identifying opportunities for changes to help us deliver the reforms needed to support the implementation of Path to Safety.

    There is nowhere this is more critical than when it comes to the experiences of Aboriginal people. As many as one in two Aboriginal women experience violence and abuse in intimate family relationships. Through our Agency Capability Program we are committed to finding new ways of working alongside Aboriginal people and communities, to support solutions based on strengths and culture that enable healing and safety.

    The department welcomes the Summary of Findings’ confirmation that we are on the right path.

    Audit focus and scope

    The audit objective was to assess if the Department of Communities effectively administers contracts for the provision of support services for people experiencing FDV.

    We based our audit on the following criteria:

    • Does the Department know if support services are meeting the needs of people experiencing FDV?
    • Does the Department effectively administer contracts for FDV support services?

    The narrow-scoped audit focused on FDV support services contracted by the Department and if it had effective processes in place to administer them. We also considered the potential challenges for the Department to transition their current contracting approach to meet the objectives of the new Strategy Path to Safety: Western Australia’s Strategy to Reduce Family and Domestic Violence 2020-2030.

    We reviewed 5 contracts for FDV support services with 3 metropolitan and 2 regional service providers.

    In undertaking the audit we:

    • reviewed contract documentation including agreements, service provider performance reporting, Department service reviews, and minutes of meeting with service providers
    • analysed service agreement data
    • reviewed the Department’s FDV strategies, plans, guidelines, budgets and financial statements
    • interviewed key staff from the Department.

    We also engaged with a number of key stakeholders to better understand the role of the Department in administering FDV support services. We met with representatives from:

    • Ombudsman of WA
    • Department of Justice
    • Mental Health Commission
    • WA Police Force
    • 2 service providers.

    We did not audit how effective the Department’s support services are in helping people experiencing FDV, or the FDV services provided by the WA Police Force and the Department of Justices’ Family Violence Service.

    This was an independent performance audit, conducted under Section 18 of the Auditor General Act 2006, in accordance with Australian Standard on Assurance Engagements ASAE 3500 Performance Engagements. We complied with the independence and other ethical requirements related to assurance engagements. Performance audits focus primarily on the effective management and operations of entity programs and activities. The approximate cost of undertaking the audit and reporting was $220,500.

    Appendix 1: COVID-19 funding

    To address the increased demand on FDV services as a result of COVID-19, both State and Commonwealth governments provided additional funding. The following table highlights the key funding announcements relating to FDV services.

    Amount announced Number of grants allocated Total value allocated by year Source Purpose
    $3.1m 45 2019-20
    $2.6m

    2020-21
    $140,000
    National Partnership on COVID-19 Response 45 service providers received funding for:
    • increased Safe at Home capacity
    • perpetrator case management and interventions
    • brokerage
    • accommodation
    • child advocates in emergency accommodation.

    Grant agreements ran from June 2020 to December 2020.

    $8.6m 22 $8.6m State Government COVID-19 Recovery Plan Provide funding to the Mobile Outreach Initiative to increase outreach workers in refuges across Perth and the regions to provide support for women and children experiencing FDV. Grants provide for the recruitment of 29 full time equivalent workers.
    Grant agreements are active from December 2020 to November 2022.
    $6.7m 9 $6.7m State Government COVID-19 Recovery Plan Expand FDV response teams with an additional FTE in all 17 district locations across the WA.
    Grant agreements are active from November 2020 to November 2022.
    $2.9m 2 $2.9m State Government COVID-19 Recovery Plan Addressing Family Violence in the Kimberley Grants Program 2020/2022 was a competitive grant process open from 18 September 2020 to 16 October 2020.
    Grant agreements are active from February 2021 to December 2022.
    $1.08m 22 $1.08m State Government COVID-19 Recovery Plan One-off funding to counselling and advocacy services through variations to current contracts. Variations to contracts were approved in October 2020.
    $123,000 1 $123,000 State Government COVID-19 Recovery Plan</td, rowspan2> Job retraining for women in metropolitan refuges to improve opportunities.
    Grant agreement is active from November 2020 to October 2021.
    Source: Department of Communities

    [1] Australian Institute of Health and Welfare, Family, domestic and sexual violence in Australia: continuing the national story 2019: In Brief. p11

    Page last updated: March 12, 2021

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