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Information, Linkages and Capacity Building (ILC) Commissioning Framework – Consultation Draft VCOSS Submission to the NDIAApril 2016

VCOSS Submission to the ILC Commissioning Framework – Consultation Draft 1

About VCOSSThe Victorian Council of Social Service (VCOSS) is the peak body of the social and community sector in Victoria. VCOSS members reflect the diversity of the sector and include large charities, peak organisations, small community services, advocacy groups, and individuals interested in social policy. In addition to supporting the sector, VCOSS represents the interests of vulnerable and disadvantaged Victorians in policy debates and advocates for the development of a sustainable, fair and equitable society.

This submission was prepared by VCOSS Policy Advisor Carly Nowell with input from VCOSS members.

Authorised by:Emma King, Chief Executive Officer© Copyright 2015 Victorian Council of Social Service

Victorian Council of Social ServiceLevel 8, 128 Exhibition StreetMelbourne, Victoria, 3000+61 3 9235 1000

For enquiries:Llewellyn Reynders, Policy and Programs [email protected]


Contents

Executive Summary...........................................................................................................................4

Summary of recommendations..........................................................................................................6

Deliver an NDIS that meet the needs of all people with disability......................................................8

Provide continuity of support for people with disability, their families and carers..........................8

Engage people with disability in all aspects of the ILC commissioning process............................9

Ensure ILC activities reach the most vulnerable............................................................................9

Support ILC delivery in rural areas...............................................................................................10

A meaningful outcomes framework..................................................................................................11

Provide a clear outcomes framework...........................................................................................11

Amend the outcomes to make them clear, achievable and measurable.....................................11

Improve the data collection strategy to better capture outcomes................................................15

Support organisations to move to an outcomes based framework..........................................16

Provide a fair and robust grants process.........................................................................................17

Recognise and support the unique value of the community sector.............................................17

Develop a fair and robust grants process that supports collaboration.........................................18

Support social capital and social inclusion.......................................................................................20


Executive Summary

VCOSS welcomes the opportunity to comment on the Information Linkages and Capacity Building Commissioning Framework –Consultation Draft (the ILC Commissioning Framework). People with disability have the right to full and equal participation in their community, yet many still experience systemic disadvantage. The disadvantage and discrimination people with disability experience is not created by their impairments, but by the physical and social environment in which they live.

The ILC component of the National Disability Insurance Scheme (NDIS) aims to assist people with disability regardless of whether they have an individually funded package (IFP). It will build the capacity of individuals and mainstream services to increase access and inclusion of people with disability, their families and carers, and help people access timely information and support. The ILC Commissioning Framework outlines how the National Disability Insurance Agency (NDIA) will fund and manage ILC activities and proposes expected outcomes.

This submission outlines VCOSS’ recommendations for the ILC Commissioning Framework to ensure it:

delivers ILC activities for all people with disability, including those most vulnerable and people living in rural and regional areas;

provides a fair and robust grants process which supports local partnerships and collaboration;

recognises the unique value of the community sector in supporting people with disability, their families and carers;

develops clear, measureable outcomes reflecting the interests of people with disability, their families and carers;

uses multiple data collection methods to accurately capture ILC activities’ impact; supports organisations transition to competitive grants and outcomes based performance

measurement, by providing timely information and advice, training and adequate resources;

supports and adequately resource organisations working with volunteers and people with disability to grow social capital.

Achieving the objectives of the ILC will require long-term commitment and investment from Government.

VCOSS strongly supports the ILC objectives, but the lack of detail on many elements of the ILC Commissioning Framework makes it difficult to provide meaningful feedback. In particular, the framework doesn’t detail how ILC grants will be distributed and assessed, the types of ILC activities eligible for funding, how the outcomes framework will be used, or how the NDIA will


provide adequate coverage of activities across cohorts and all parts of Australia. Several VCOSS members also expressed concerns that the level of ILC funding is too low, spreading services too thinly.

The NDIA has not yet articulated how the ILC policy framework will interact with other elements of the NDIS and mainstream services including, the Early Childhood Early Intervention (ECEI) approach, Local Area Coordinators (LACs), mental health services, aged care, primary health networks and Victoria’s Primary Care Partnerships (PCP). The NDIA should provide details about these are coordinated to seamlessly work together and prevent people falling through the cracks.


Summary of recommendations

Deliver ILC activities that meet the needs of all people with disability

Engage people with disability in all aspects of the ILC Commissioning Framework. Ensure ILC activities engage hard-to-reach groups and people who are most vulnerable. Recognise the additional costs and challenges of delivering ILC activities in rural and

regional areas. Provide adequate coverage of ILC activities in rural and regional areas.

A meaningful outcomes framework

Provide a program logic model that outlines how the outcomes framework will apply to individual organisations and the ILC framework as a whole.

Amend the proposed outcomes so they are clear, achievable, measureable and represent the interests of people with disability, their families and carers.

Use a range of qualitative and quantitative data collection methods to inform the ILC outcomes, with particular attention given to engaging vulnerable and hard-to-reach groups.

Support community sector organisations by providing clear and timely information about the outcomes framework, support to develop their practice to achieve outcomes, and training and guidance about how to capture and report on outcomes.

Consider tasking an independent or semi-independent organisation with responsibility for supporting organisations, developing reporting measures for ILC activities and collecting high-level data.

Provide a fair and robust grants process

Recognise and support the unique value of community sector organisations in supporting people with disability, their families and carers.

Provide training or workshops to support community sector organisations to apply for grants.

Provide clear and timely information about the ILC grants process to help organisations plan and prepare for the competitive grants process.

Support regional partnerships and community collaboration in the delivery of ILC activities. Develop robust funding criteria to ensure that the needs of all people with disability are met

and so that small, not-for-profit providers are not disadvantaged.

Support social capital

Adopt a broader view of social capital. Recognise the untapped potential of people with disability in building social capital.


Support volunteers by resourcing community service organisations to recruit, manage, train and develop volunteers.


Deliver an NDIS that meet the needs of all people with disability

Provide continuity of support for people with disability, their families and carersPeople with disability, their families and carers1 should continue receiving ILC-type services during the NDIS transition. The NDIS will shift state and federal responsibilities, creating uncertainty for the future of many existing ILC-type initiatives. For instance, the Victorian Department of Health and Human Services currently fund RuralAccess, MetroAccess and Deafaccess workers as part of the Disability Services Community Building Program. This program supports communities develop new ways of including people with a disability in local community life.2 State and federal governments should clarify how the ILC framework will affect current ILC-type initiatives, including whether services will continue to be funded separately or rolled into the ILC. Effective initiatives should not be lost.

Victoria has a strong community mental health community sector. Many of these services align with the goals of the ILC and it is unclear if these initiatives will be eligible for ILC funding, and if not, whether they will continue to be funded by other means. Unlike in other states, all of Victoria’s mental health community support funds have been committed to the NDIS. This creates further uncertainly about the continuity of current services and activities, which provide essential support for people with mental illness.

VCOSS members advise funding for some carer supports are planned for transfer to the NDIS including the Mental Health Respite: Carer Support programme (MHR:CS) and the Young Carer Respite and Information Service Activity (YCRIS). It is uncertain whether similar carer supports will be available under the NDIS, either through the ILC or through IFPs. The scope of carer specific supports in the draft commissioning framework appears narrow in scope and potentially reduced from what is currently offered. To support carers’ wellbeing and allow them to continue in their caring role, all carers must have access to carer specific supports and services that meet their needs, regardless of the age or condition of the person they care for.

The National Disability Advocacy Program (NDAP) is currently under review, with current grant agreements in place until 30 June 2017. Independent advocacy is not available under the ILC

1 The term ‘carers’ includes the diverse range of people in care relationships, including carers and people receiving care in same-sex families, ‘families of choice', friends and others who provide unpaid care.2 Victorian Government Department of Health and Human Services, Community Involvement - RuralAccess, MetroAccess, DeafAccess, http://www.dhs.vic.gov.au/for-individuals/disability/community-life-and-jobs/community-involvement/community-involvement-ruralaccess,-metroaccess,-deafaccess, accessed 4 April 2016.


http://www.dhs.vic.gov.au/for-individuals/disability/community-life-and-jobs/community-involvement/community-involvement-ruralaccess,-metroaccess,-deafaccess

http://www.dhs.vic.gov.au/for-individuals/disability/community-life-and-jobs/community-involvement/community-involvement-ruralaccess,-metroaccess,-deafaccess

framework, only funding to build the capacity of individuals, their families and carers to self-advocate. Continued funding for individual and systemic independent advocacy is needed to empower and protect the rights of people with disability.

Engage people with disability in all aspects of the ILC commissioning process

Recommendation Engage people with disability in all aspects of the ILC Commissioning Framework.

The ILC commissioning process should reflect the lived experience and voices of people with disability, their families are carers. The NDIA should actively involve people with disability in the full design of commissioning framework, including the outcomes and measurement; ongoing ILC evaluation; and assessment of grants. This should be representative of diverse groups of people with disability, their families and carers, including Aboriginal3 people, people from culturally and linguistically diverse (CALD) backgrounds, people from metropolitan, regional, rural and remote areas, and people with a diversity of disabilities.

Ensure ILC activities reach the most vulnerableRecommendation Ensure ILC activities engage hard-to-reach groups and people who are most

vulnerable.

Moving to a competitive grants process creates a risk that ILC services will not adequately engage with hard-to-reach groups and people who are most vulnerable. The NDIA should ensure the scope of ILC activities will meet the needs of all people with disability, their families and carers. Particular attention should be given to engaging people who are most likely to be underserviced such as Aboriginal people and people from CALD backgrounds. This includes funding ILC activities and interventions tailored for certain cohorts, as well as building the capacity of mainstream services to be inclusive, culturally safe and accessible to all people with disability.

3 The term ‘Aboriginal’ is used in this submission to refer to both Aboriginal and Torres Strait Islander peoples.


Support ILC delivery in rural areasRecommendations Recognise the additional costs and challenges of delivering ILC activities in rural and

regional areas. Provide adequate coverage of ILC activities in rural and regional areas.

In rural and remote areas ILC activities often cost more to deliver as they lack economies of scale and incur higher travel expenses. Travel costs may involve staff time and resources, on top of the direct costs of travel. Rural areas may also lack specialist expertise to deliver certain activities, creating additional costs in sourcing people with the right skills and experience. To help address this, the commissioning framework and grants process should recognise and accommodate these additional costs.

There is a risk ILC activities and supports will lack a physical presence in rural areas, using a fly-in-fly-out or drive-in-drive-out practice, or relying on remote delivery, such as teleconferencing. To maximise ILC community development and partnerships, the NDIA should require a physical rural presence.

Many rural areas experience higher levels of disadvantage than average. At the same time they have limited access to mainstream services, specialist health and disability services. To help overcome this ‘double disadvantage’, the NDIA could provide greater flexibility in the types of ILC activities delivered in rural and remote areas, and recognise outcomes may be more difficult to achieve when assessing performance.

VCOSS members advise that some rural areas are already underserviced, and shifting from block funding to competitive grants could make this worse. In some rural areas, no organisations may apply to deliver ILC activities. To provide adequate coverage of ILC activities in rural Australia, the NDIA may need to ‘develop the market’ in some areas prior to the grants process opening and build local expertise. This would have the added benefit of providing regional employment opportunities.


A meaningful outcomes framework

Provide a clear outcomes frameworkRecommendations Provide a program logic model that outlines how the outcomes framework will apply

to individual organisations and the ILC framework as a whole.

Many of the outcomes and associated measures are high-level and it is unclear how these will relate to a particular ILC grant, particularly smaller scale activities. The NDIA should develop a program logic model which outlines the overall objectives of the ILC and how these high-level population outcomes link to individual ILC activities. The high-level outcomes and measures will need to be modified for use at the local level, so they are meaningful and useful in assessing the effectiveness of particular ILC activities. For example, if the outcome ‘independence and social and economic participation of all is promoted’ is successfully achieved at the national level improvements could be expected in the workforce participation rates for people with disability, educational attainment and proportion of people with disability entering further education and training, and reduced rates of people with disability accessing emergency services. An individual ILC activity delivered by a small organisation may contribute to this outcomes but the measures would need to substantially different to reflect changes that the ILC activity could realistically influence.

Ideally, the outcomes framework would be used to assess the performance of individual grants through short-term outcomes and the broader impact of ILC investment through longitudinal outcomes. This is particularly relevant for outcomes related to building the capacity of communities and mainstream services where attitudinal changes may only be realised over the medium and long-term. Timeframes for the achievement of the program-level outcomes should be identified in the program logic model.

Amend the outcomes to make them clear, achievable and measurable

Recommendations Amend the proposed outcomes so they are clear, achievable, measureable and

represent the interests of people with disability, their families and carers.

The NDIA should refine the proposed outcomes and measures so they are clear, achievable, measurable and represent the interests of people with disability, their families and carers. The language in some outcomes is ambiguous and should be reworded or accompanied by definitions.


For example, the terms ‘unfunded supports’, ‘informal support’, ‘individual funding’ ‘participant’ and ‘non participant’ could be interpreted in multiple ways. In several outcomes it is unclear which group of people are the focus, for example people with disability in receipt of an NDIS package, people accessing short-term interventions under the ILC, all people with disability regardless of eligibility for an NDIS package, families and carers, or people with disability, their families and carers. In some cases, the language used in the ‘outcome’, ‘outputs’, ‘measures of quality and effectiveness’ and ‘measures of outcomes’ shifted between these different groups. Reframing the outcomes to capture positive changes rather than focusing on deficits would support a strengths-based approach to supporting people with disability. Many outcomes are likely to be affected by the efficacy of programs not funded by the NDIS, such as the National Disability Advocacy Program, disability employment programs, and the availability and adequacy of income support for people with disability.

VCOSS members identified inconsistencies between some outcomes and their associated measures. For example, while some of the outcomes related to community-based changes, the measures related to the individual. In other cases the measures appeared unrelated to the outcome. Specific feedback on each of the outcomes are provided below.

Table 1: Detailed feedback on the proposed outcomes

Outcome Feedback on outcomes Feedback on measures

1. People with disability have capacity to exercise choice and control in pursuit of goals.

Clarify whether ‘choice and control’ relates to the delivery of ILC funded activities for an individual or whether it relates to people’s choice and control more generally in the community, such accessing mainstream services, or both of these.

To support people with disability to exercise choice and control, the NDIA should invest in building the capacity of families, carers and other services providers, to provide decision making support to people with disability.

There are no measures capturing the level of choice and control in accessing services in the community.

Measures could include, capturing whether people with disability have access to a range of services and/or whether services are responsive to people with disability.

2. Independence and social and economic participation of all is promoted.

Clarify who ‘all’ is referring to. Ideally, this should include all people with disability (regardless of their eligibility for an NDIS package) as well as their families and carers. To help carers to sustain their caring role, they need support to improve their social and economic participation.

The ‘measures of quality and effectiveness’ refers to non-participants, yet the ‘measure of outcomes’ refers only to ‘assisted individuals’. This language is confusing and should be clarified.

Suggest the ‘measure of quality and effectiveness’ be reworded to be framed positively.

Suggest developing measures to



capture outcomes for carers and families.

3. Informal support and care arrangements are upheld and nurtured.

Suggest this outcome is reworded to recognise the needs of carers so that care arrangements are sustainable. For example ‘people with disability have informal support and care arrangements and those providing informal support and care arrangements (e.g. carers) are well supported in their roles.’

Clarify whether this outcomes extends to informal supports, such as peer networks.

Information is required about how carers will be supported in their role under the ILC.

While the outputs directly relate to carers, the measures of outcomes relates to people with disability. Suggest this is modified to include measures for people with disability and their carers.

4. Participants can access unfunded supports and individual funding is provided at the optimal time.

Unclear if ‘unfunded supports’ refers to mainstream services or supports for people with disability provided under the ILC.

This outcome assumes that the same level of supports will continue to be offered by state governments, but it is not clear how these will be funded in the transition to the NDIS.

It is unclear whether ‘individual funding’, refers to short-term interventions under the ILC or NDIS packages.

The outcome measure refers to accessing support in the early stages of their condition. This appears to align more closely to outcome 6.

5. High-quality, effective and efficient disability support, is available including ILC activities.

All services should be available to people with disability not just disability services. Suggest removing the word ‘disability’.

There is a lack of clarity about whether the measures are inclusive of the LAC.

Members questioned the appropriateness of the outcome measure for potential ILC providers, such as neighbourhood houses, or peer support groups.

6. People with disability have appropriate support during

Suggest this outcomes includes a focus on helping people to navigate the service system.

The outcome measure captures whether people have a better understanding of their diagnosis/condition. Members questioned how this fits with the ILC



their lifetime, including early intervention.

and the health system.

7. People with disability, their families and carers shape supports and services.

Suggest there should be a stronger emphasis on working in partnership with people with disability.

There is inconsistency between the measure, which focuses on accessing services, and the outcome, which is focused on shaping services to meet their needs.

8. Increased community/mainstream awareness of how to support people with disability.

Suggest this outcome is strengthened to go beyond awareness and focus on improving access and inclusion of people with disability.

9. Interests of people with disability are faithfully represented in policy/infrastructure design.

Unclear if this is this outcomes is referring to the ILC framework in general, the ILC activities or both.

Stronger emphasis on working in partnership with people with disability.

The outcome measure ‘individuals were prevented from doing a course they wanted to do’ doesn’t appear to relate to the outcome.

Suggests measures are framed positively.

VCOSS members provided feedback that the outcomes framework would be enhanced by having a greater emphasis on measuring community-wide outcomes, including community awareness and inclusion of people with disability. There appeared to be a lack of community-based outcomes and measures, particularly given the goals of the ILC to build the capacity of the community and to increase collaboration with local communities and mainstream services. Other gaps identified in the outcomes framework, include outcomes to capture the health and wellbeing of people with disability and a lack of outcomes for families and carers.

Improve the data collection strategy to better capture outcomes

Recommendations


Use a range of qualitative and quantitative data collection methods to inform the ILC outcomes, with particular attention given to engaging vulnerable and hard-to-reach groups.

The ILC Commissioning Framework indicates that outcome data will be collected through individual outcome surveys. Surveys present a number of challenges. There is a risk they will fail to adequately capture outcomes for some sub-populations and hard-to-reach groups including Aboriginal people, people from CALD communities, people with mental illness and people with more complex or severe disability. This is likely to skew the data and provide an inaccurate picture of the impact of ILC activities.

People may also need to identify themselves to receive and complete the survey. Experience from VCOSS members indicates that a substantial proportion of people accessing ILC activities will desire to remain anonymous, particularly people with mental illness and people living in rural and remote areas who are more easily identifiable. This survey format may also not lend itself to certain forms of ILC activities such as anonymous helplines providing advice and support to people with a certain type of disability.

To help address this, the NDIA could use a use mixed-method design that incorporate several qualitative and quantitative methods to inform the outcomes, rather than relying solely, or primarily, on surveys. Extensive research has been conducted on how to engage hard-to-reach groups and the measurement framework should draw on this evidence.4 For example, VCOSS members suggest incorporating a range of qualitative measures including in-depth interviews, focus groups and participatory action research. Outcome measurements could also be informed by data from systemic disability advocacy and from other datasets such as ABS data on workforce participation and education.

All tools developed should be inclusive and accessible to all people with disability, such as using easy English, translating tools into multiple languages and working with communities to make sure they are culturally safe and relevant.

Baseline data are required to be able to measure and track the impact of the ILC activities. To be meaningful, these data should capture and reflect the differences that exist in rural, regional, growth corridors and metro regions, and the differences that exist between cohorts.

Support organisations to move to an outcomes based framework

Recommendations Support community sector organisations by providing clear and timely information

about the outcomes framework, support to develop their practice to achieve outcomes, and training and guidance about how to capture and report on outcomes.

4 For example, B Bonevski, M Randell, C Paul, K Chapman, LTwyman, J Bryant, I Brozek and C Hughes, Reaching the hard-to-reach: a systematic review of strategies for improving health and medical research with socially disadvantaged groups, BMC Medical Research Methodology, 2014, volume 42.


Consider tasking an independent or semi-independent organisation with responsibility for supporting organisations, developing reporting measures for ILC activities and collecting high-level data.

The community sector, particularly small organisations, require support from the NDIA to move towards outcomes based performance measurement. This includes providing clear information and training about how outcomes will be measured and reported well in advance of the grant rounds opening. This should be accompanied by guidance, helping organisations capture and report outcomes once they are delivering ILC activities. Measuring outcomes effectively is resource intensive and may require redirecting frontline service staff to complete outcomes reporting. This will disadvantage smaller organisations if they are not appropriately supported and resourced through the ILC grants to complete this work. It is also unclear whether ILC activities delivered to carers and families will need to capture outcomes for both carers and the people with disability they are supporting. If outcomes for both cohorts need to be captured, this will likely result in additional resourcing requirements which will need to be reflected in the grants.

Several VCOSS members suggest that an independent agency be available to assist organisations develop their practice to achieve outcomes. This organisation could be tasked with collecting and reporting on high level ILC program outcomes at the regional, state and national level and be responsible for developing the tools/mechanisms for capturing and reporting outcomes for individual ILC activities. This would help to improve consistency and avoid individual organisations duplicating effort by developing their own tools.

Consideration should be given to using and building on existing measures where possible. The tools should also incorporate sufficient flexibility so that reporting can be tailored to meet the needs of particular cohorts and reflect the context in which ILC activities are being delivered. For example, outcomes may take longer to be delivered in regional areas or with vulnerable cohorts and organisations should not be unfairly penalised for taking on this work.


Provide a fair and robust grants process

A series of recommendations to the design and structure of the grants process are outlined below to help provide good coverage of ILC activities, support collaboration, and not place small, locally based community sector organisations at a disadvantage in the competitive process. In particular, VCOSS members recommend learning from the 2014 Department of Social Services (DSS) tendering process. In its final report on the service quality, efficiency and sustainability of the 2014 Commonwealth community service tendering processes by DSS, the Committee identified a number of issues including: a lack of planning and analysis and insufficient timeframes; emergence of service gaps; lack of sector diversity, including the loss of smaller organisations; lack of transparency and equity in the decision making process; and negative impact on service users and providers.5

Recognise and support the unique value of the community sector

Recommendations Recognise and support the unique value of not-for-profit community sector

organisations in supporting people with disability, their families and carers. Provide training or workshops to support community sector organisations to apply for

grants.

The not-for-profit community sector is a significant contributor to society’s wellbeing and plays a unique role in supporting people with disability to overcome disadvantage. Operating with direct-on-the ground experience of the communities, families and individuals with whom they work, they are able to be flexible in their approach to supporting people to overcome disadvantage, while also helping develop long-term social policy solutions.

Smaller organisations have considerable local knowledge and expertise but need support to be successful in a competitive grants process. Larger organisations are often more experienced in tender processes and hold greater capacity to prepare sophisticated tender applications, giving them a competitive advantage. There is a risk that small community based organisations, who would deliver high quality services, will miss out on funding. Not-for-profit providers often face additional challenges, such as greater compliance burdens, which make it harder to be nimble and compete with for-profit providers. For example, providers that hold contracts with the state or federal government often have extensive red tape compliance requirements around reporting and insurance. 5 The Senate, Community Affairs References Committee, Impact on service quality, efficiency and sustainability of recent Commonwealth community service tendering processes by the Department of Social Services Final report, September 2015, p.48-49.


The NDIA could provide workshops or training for the community sector to help organisations understand the ILC application process, including how the outcomes-based performance measurement will operate. This would be complemented by recognising the value of diversity in not-for-profit providers and small community sector organisations in the ILC Commissioning Framework. The grants process could include a positive weighting scale for small community sector organisations to help level out the playing field, or consider having a separate funding stream for small organisations. The grant process could also include selection criteria, or a priority investment area, which requires organisations to demonstrate local knowledge and relationships with the community. This is particularly important for activities aimed at supporting Aboriginal or CALD communities. Consideration should be given to how to support Aboriginal Community Controlled Organisations and CALD based organisations to successfully apply for and deliver ILC activities, to help engage with these communities.

Develop a fair and robust grants process that supports collaboration

Recommendations Provide clear and timely information about the ILC grants process to help

organisations plan and prepare for the competitive grants process. Support regional partnerships and community collaboration in the delivery of ILC

activities. Develop robust funding criteria to ensure that the needs of all people with disability

are met and so that small, not-for-profit providers are not disadvantaged.

To support organisations plan and prepare for the ILC competitive grants process, timely and clear (jargon free) information needs to be provided to the sector. This should include the nature and scale of ILC activities that will be funded and the criteria used to make assessments. Four weeks is inadequate to prepare a tender, particularly for small organisations which often have limited capacity to release staff to develop the tender application. Longer lead times also allow organisations to consider consortia arrangements. Adequate promotion of the grants process is required so that small and locally based organisations are notified and have a chance to apply.

The application process should be commensurate with the size of the grants so that small grants do not have heavy administrative burdens. Lengthy grant application processes, particularly for small grants, can place smaller community organisations at a disadvantage.

VCOSS members suggest that multi-year grants should be made available to provide stability to the community as well as the sector. Without continuity of funding, it is hard for organisations to plan and deliver sustainable services and organisations risk losing qualified and experienced workers. The timing of grant rounds could also be structured so that they overlap, to avoid gaps in service delivery. Ideally these grants should not coincide with tender arrangements for other similar services, including LACs and other DSS contracts.


VCOSS members raise concerns about the reference to ‘annual grant rounds’. If there is only one opportunity per year for organisations to apply for funding, small organisations who miss out in the first year may struggle to remain viable and may not be able to compete in the second year.

To help achieve the goals of the ILC, the grants process should be designed to support partnerships and community collaboration. VCOSS members questioned whether the competitive nature of the grants process may impede collaboration. There is also a risk that a piecemeal approach to capacity building will occur, for example an ILC activity is funded which supports one particular CALD group in a region, but people from other CALD groups within the same area are not supported. To help address this, the NDIA could encourage organisations within a region to work together, for example through prioritising consortium applications or by incorporating more outcomes which focus on genuine collaboration.

Developing robust funding criteria would help to ensure that the needs of all people with disability are met and small, not-for-profit providers are not disadvantaged. Suggestions of funding criteria include, that organisations demonstrate:

their experience or ability to support and empower people with disability that the ILC activity will meet the local needs of people with disability, families and/or carers robust internal policies and procedures that promote the inclusion of people with disability local knowledge of the communities in which the ILC activities will be delivered relationships with other local services and/or strategic partnerships with specialist disability

services.

To ensure the most suitable grant applications are successful, grant assessors should have local knowledge of the regions in which grants are being delivered. They should also have a relevant mix of skills and expertise related to supporting people with disability, their families and carers.


Support social capital and social inclusion

Recommendations Adopt a broader view of social capital. Recognise the untapped potential of people with disability in building social capital. Support volunteers by resourcing community service organisations to recruit,

manage, train and develop volunteers.

Social capital is defined as the ‘networks, together with shared norms, values and understandings which facilitate cooperation within or among groups.6 It relates to the resources available within communities and relies upon trust, mutual support and reciprocity between people.7 Social capital helps strengthen communities and increases the participation and social inclusion of people with disability.

The ILC Commissioning Framework takes a relatively narrow view of social capital, focusing predominately on the role of volunteers. Supporting a broader range of actions that build social capital will deliver better outcomes for people with disability. For example, VCOSS members highlight the value that ILC recipients and people with disability could bring to building social capital. The NDIA could explore this further to capitalise on the untapped potential of people with disability.

The community sector also works on a daily basis to build social capital, connect people to their community, and break down social isolation. While these benefit the community at large, it is people facing disadvantage and vulnerability, including people with disability, that benefit most from this work.8 The NDIA could recognise and support the community sector’s role in sustaining and growing social capital.

VCOSS recognise that volunteers play a crucial role in supporting people with disability to fully participate socially and economically in their communities and reducing barriers for in participation in community life. To be effective volunteers need to be adequately supported and linked to opportunities that align with their skills. There are substantial costs involved in doing this and community service organisations that work with volunteers need to be resourced to recruit,

6 Organisation for Economic Co-operation and Development, The Well-Being of Nations: The Role of Human and Social Capital, OECD, Paris, 2001.7 Australian Bureau of Statistics, Measuring Social Capital: An Australian Framework and Indicators, ABS, 2004.8 Victorian Council of Social Service, Building on the value of Victoria’s community sector, VCOSS 2015.


http://www.ausstats.abs.gov.au/Ausstats/free.nsf/Lookup/13C0688F6B98DD45CA256E360077D526/$File/13780_2004.pdf

manage, train and develop volunteers, as well as to support the organisations that receive volunteers. This will be particularly important as demand for volunteers grows in other areas such as aged care, which may limit the available pool of volunteers available to support the disability sector. Many small community services organisations already do this work and need to be recognised and resourced to continue.

Volunteers should not be viewed as ‘free labour’ or used to replace professional service delivery. Instead, volunteers should be used to enhance the ILC work being undertaken by paid, trained workers. There is a risk of overreliance on volunteers and greater clarity is required about their role in the ILC.


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