ࡱ> 5@ Bbjbj22 CXX B,,,jL" " " $F OOOPO$OF 2QQ(6Q6Q6Qp q quwwwwww$(RzB" uifpuu6Q6QWx|x|x|u6Q" 6Qux|uux|x|z}fp 0" ٚ6QQ J}ʯO{dQD|Ɲ0D:|(ٚF F " ٚ 'qqx|rtr)'q'q'qF F DBOb|F F ODiscussion paper 1 Development of a Charter of Rights for people experiencing homelessness or at risk of homelessness 2 Development of a strengthened complaints mechanism for the homelessness and related service systems 20 October 2024 Prepared by: Thomson Goodall Associates Pty Ltd 260 Dendy Street East Brighton Victoria 3187 Tel: (03) 9592 5868 Fax: (03) 9553 8736 email: thomgood@ozemail.com.au Table of Contents Page number 1 Introduction 1 2 The need for a Charter of Rights 4 3 Background to a Charter of Rights 7 4 Features of Charters of Rights 11 5 A Charter of Rights framework 13 6 Implementation issues 17 7 Protecting peoples rights 20 1 Introduction The Victorian Department of Human Services is seeking to develop a Charter of Rights, and an enhanced complaints mechanism for people experiencing and at risk of homelessness. Thomson Goodall Associates (independent consultants) have been commissioned to undertake this Project, and will work closely with a Steering Committee, the homelessness sector, and people experiencing homelessness, to develop the Charter. The Project commenced in August 2003, and is scheduled for completion in April 2004. The methodology includes a literature review, interviews with key informants, the development of a Discussion Paper, workshops with service providers, and obtaining service user feedback. The development of a Charter of Rights, supported by strengthened complaints mechanisms, is a priority of the Victorian Homelessness Strategy. In particular, the Victorian Government is committed to creating service environments which uniformly recognise and respect the right of people who are homeless to a quality response. A Charter of Rights and robust complaints mechanisms will provide a clearer focus on rights and responsibilities, which will seek to empower people experiencing and at risk of homelessness. The Charter will also underpin and be directly linked to the development of new service standards for the homelessness services system. A separate project has been commissioned to revise and develop service standards in homelessness services in Victoria. Currently in Victoria, the two main components of the Homelessness Service System (HSS) are Transitional Housing Management Services (THMs) and Supported Accommodation Assistance Program (SAAP) agencies, both funded by DHS. The Charter will apply to these services as a minimum, and will also be relevant to services outside the Homelessness Service System, who are working with people who are experiencing and at risk of homelessness. Its application in these service areas will be the subject of further discussion and negotiation. Anticipated benefits of the Charter of Rights, and a strengthened complaints mechanism, include: the placing of an obligation on governments and service providers to meet peoples minimum needs when they are experiencing and at risk of homelessness the provision of a right of access to adequate assistance by people experiencing and at risk of homelessness service environments which encourage increased participation and empowerment of people using homelessness services the development and implementation of clear standards of service quality for people who are experiencing and at risk of homelessness consistency in a rights approach within and across all homelessness service sectors and cultures, and a common basis for assessing and resolving complaints increased accountability by homelessness services to their client group, based on a strengthened rights focus improved outcomes for people who are experiencing and at risk of homelessness, through enhanced rights based practices and assertive advocacy the provision of a rights and responsibilities framework for services outside the HSS, to consider when developing targeted responses to people who are experiencing and at risk of homelessness Purpose of the Discussion Paper This Discussion Paper has been developed following preliminary discussions with key stakeholders, government representatives, members of the Steering Committee, and a review of relevant literature. The Discussion Paper covers a range of topics. All homelessness services will have the opportunity to comment on the Discussion Paper, and also to provide further feedback once a draft Charter of Rights has been developed, later in the project. The purpose of this Discussion Paper is: To provide clear information about the Project To progress thinking in the development of a rights framework for people who are experiencing and at risk of homelessness To provide homelessness services and other organisations and individuals with the opportunity for input into the development of a Charter of Rights and strengthened complaints mechanisms To provide the basis for discussion at Workshops planned for late 2003 All homelessness services are invited to consider the Discussion Paper and provide a response (phone, mail, email, or fax) by contacting Julie Goodall, Diz McKinnon or John Thomson of Thomson Goodall Associates Pty Ltd. Contact details are on the front cover of this paper. The main questions posed by this Discussion Paper are: 1.1 What rights do people who are experiencing, and at risk of homelessness have? 1.2 How should those rights be promoted, protected and upheld? The Discussion Paper presents a number of other questions, inviting comments on specific issues. Comments on any aspect of the Project are welcome, and do not need to be confined to the questions listed for consideration in the Discussion Paper. In summary, the purpose of the Discussion Paper is to act as a starting point for discussing the issues that might be covered by a Charter of Rights, and which would be recognised as part of a strengthened complaints mechanism. Thomson Goodall Associates Pty Ltd, independent consultants, prepared the Discussion Paper and is responsible for the information and views contained in the Paper. As such, the Discussion Paper does not constitute a Victorian Government policy position. 2 The need for a Charter of Rights Feedback from people who have used homelessness services indicates the need for an enhanced rights culture within the HSS. A Charter of Rights will be an important part of working towards this. The Support and Accommodation Rights Service (SARS) has advocated for people over many years in relation to breaches of rights and incidents of poor practice in homelessness services. Preliminary consultations undertaken for this Project also identified a number of areas where rights have been abused. The Victorian Homelessness Strategy reports important criticisms and concerns by some people about their negative experiences of seeking to access a service, or while they were a client of a service. Some of these negative experiences are related to how the service system is structured, and some concerns are the result of practices within services. Service System issues A range of factors are relevant to the development and implementation of a Charter of Rights, and strengthening a rights culture within the Homelessness Services System. The policy, legislative and funding contexts all impact the service system, and its capacity to ensure all people who are experiencing, and at risk of homelessness, can realise the right to access the assistance they need. Once people are accepted into, or are being assisted by the service system, a range of contextual factors impact the quality and consistency of assistance, and the extent to which service users rights are upheld. Service Practice Issues Working within a challenging context, and high levels of demand for housing and support, many services demonstrate a genuine and positive commitment to upholding the rights of people who seek their assistance. The Charter of Rights will build on, and formalise, these good practices. Many individual service providers have their own code of rights and provide clients with opportunities for participation and feedback, including through internal grievance mechanisms. Many providers also acknowledge that upholding rights is about more than providing a complaints mechanism. A rights based approach influences all aspects of service culture and practice. Examples of a commitment to rights in practical terms, provided to the consultants during preliminary consultations, include: Services accept responsibility to ensure that all people who approach the service for assistance receive some form of tangible outcome. This involves a process of practical assistance, supported referral and/or any other appropriate action, where the service provides interim support while actively seeking the most appropriate option for the client. Service users are empowered to contribute to the development of a set of user rights and responsibilities, to apply to both workers and service users. These rights are prominently displayed in the service. Service collects comprehensive data on all service user feedback (including complaints). Data is audited every 6 months, and considered a central component of ongoing quality review and service development within the agency. Service works to a commitment to never ban anyone from receiving assistance or support. Flexible approaches include working within a team approach; developing management plans with the service user; assisting the person to locate alternate accommodation; other. This does not exclude involving police when a criminal act has been committed, but the service will continue to provide some form of support to the person regardless. Services develop or are based on an assertive outreach component, that actively seeks out people who are homeless and at risk of homelessness; seeks to make the service environment culturally appropriate, accessible and user friendly; and provides flexible, ongoing support on the basis of client-identified need. It is important to remember that while a rights focus and good practice may exist in many, if not most homelessness services, any breaches are unacceptable. The Table below provides examples provided to the consultants, where peoples rights have been violated or breached. These examples are listed in order to shed light on some of the areas which might be covered by a Charter of Rights. Examples of abuses of service users rights 1 Right to accommodation (universal right) Person is issued with a notice to vacate at the same time they are provided with transitional accommodation Person is forced to leave crisis/ transitional accommodation without having safe and secure accommodation to go to 2 Right to access a service Person denied access without any form of assessment, and provided with no assistance to find a service that can provide appropriate support Person denied access on the basis of high and complex needs Person banned from a service based on assumed behaviours Person in crisis is vouchered to a substandard, unsafe, poor quality hotel without support Children excluded from a service response because they are not viewed as a client in their own right, and their needs are not considered in the parents case management plan Person receives no support to find permanent accommodation, after being allocated a transitional property Woman from a non English speaking background with a young child accused of breaching service rules, denied access to an interpreter, unable to explain the circumstances, and evicted with no assistance to find alternative accommodation. 3 Service user rights A worker speaks to another worker about a client in a derogatory manner The terms of accommodation allow a worker to enter a residence without permission if unable to make prior contact Personal information is passed to another person or agency without a clients permission A person is evicted without a proper grievance process A person in a crisis accommodation service becomes ill after eating food that had been prepared and stored in unhygienic conditions. A family spends a week without hot water, due to maintenance delays A referral was made based on worker assumptions without first discussing needs with the person concerned Workers failed to protect a client who was threatened by a co-tenants behaviour and drug taking As indicated, the extent to which peoples rights are abused or upheld within the Homelessness Service System varies across services, sectors and workers. The Support and Accommodation Rights service currently provides advocacy and support for people involved in grievance procedures, and has played a significant role in advancing service users rights through promoting a service user rights culture. It is clear however, that mechanisms for protecting the rights of homeless people, and facilitating a user rights culture could be significantly strengthened. What is required is a consistent rights framework across the Homelessness Services System, at a minimum, which will result in the development of a rights based service culture, and enhanced outcomes for people who are experiencing and at risk of homelessness. 3 Background to a Charter or Rights - legislative and service system context 3.1 Introduction The development of a Charter of Rights cannot be undertaken in isolation, and needs to consider the existing legislative and service system context. The most relevant legislation specific to people experiencing and at risk of homelessness is the SAAP Act 1994; the Housing Assistance Act 1996; and the Residential Tenancies Act 2002. In addition there is other legislation relevant to upholding peoples rights, and legislation that includes rights provisions. The Australian Governments primary responses to people experiencing and at risk of homelessness are covered under two Commonwealth Acts - The SAAP Act 1994 and the Housing Assistance Act 1996. Both these Acts make clear reference to peoples rights. In Victoria, tenancy issues are covered by the Residential Tenancies Act. 3.2 The SAAP Act 1994 The SAAP Act 1994, explicitly recognises the need for the rights of people who are experiencing and at risk of homelessness to be protected. Understanding the SAAP Act is fundamental to the development of a Charter of Rights for people experiencing and at risk of homelessness. The Preamble to the Act sets out the way in which services to homeless people are to be provided: Homeless people form one of the most powerless and marginalised groups in Society. Responses to their needs should aim to empower them and to maximise their independence. These responses should be provided in a way that respects their dignity as individuals, enhances their self-esteem, is sensitive to their social and economic circumstances, and respects their cultural backgrounds and their beliefs. (SAAP Act 1994, Preamble) The Act notes that citizens rights are protected through Australias recognition of international standards for the protection of universal human rights and fundamental freedoms, and through specific Australian legislation. The Parliament intends to ensure that people who are homeless or at risk of homelessness are given opportunities to redress their circumstances and that their universal human rights are not prejudiced by the manner in which services are provided to them. Importantly, the Act stipulates that protection of rights should be operationalised through Commonwealth State Agreements. Agreements must deal with: establishing the means by which the civil, political, economic and social rights of people who are homeless may be preserved and protected by service providers (SAAP Act, 1994, Article 8b) Government and non government organisations (ie service providers) together share responsibility for ensuring quality services are provided, as well as preserving and protecting the civil, political, economic and social rights of people who are homeless, through advocacy and other means. Of particular relevance, the Act stipulates that: SAAP is to safeguard clients rights and deal with clients responsibilities through measures including, but not limited to: (i) the development of grievance and appeals procedures; and (ii) the development of charters of rights and responsibilities (SAAP Act, 5.4(f) ) The Act also offers a number of important perspectives on the ways in which services to people experiencing and at risk of homelessness should be provided. These may be interpreted as: encouraging self-reliance and independence focussing on individual needs ensuring access (as a right) to an equitable share of the communitys resources redressing social inequalities and achieving a reduction in poverty providing a safety net or a place of last resort ensuring a responsive service system emphasising human dignity ensuring opportunities to enable people to participate in the community upholding and protecting clients rights Implementation of the SAAP Act in Victoria In accordance with the SAAP Act, a bilateral agreement between the Commonwealth and the States/Territories prescribes the provision of SAAP funded services. The Victorian Supported Accommodation Assistance Program has operated for many years within a set of standards which refer to autonomous decision making; assessment and referral; provision of service information; privacy and confidentiality; a non threatening environment; provision of support and advocacy; and opportunities for participating in service management in the context of User Rights. As a result, many SAAP funded services within the Homelessness Service System have developed a range of approaches to protecting the rights of people using their services. These include: Grievance resolution processes  Adherence to Homelessness Standards/ quality improvement processes Worker codes of conduct, and staff recruitment and training practices that emphasise the importance of client rights, and robust, supportive supervision processes Client participation and feedback Supportive referral processes, referral feedback, peer review. These agency based approaches are supported by the Support and Accommodation Rights Service (SARS), which offers and provides advocacy support for people wishing to raise a formal grievance with a homelessness service provider, as well as advocacy support for people who are involved in an existing grievance process with a service provider. 3.3 Housing Assistance Act 1996 The Commonwealth Housing Assistance Act (HAA) (1996) also recognizes that vulnerable groups in society may need special measures to assist them to access appropriate and affordable housing. The Preamble to the HAA (1996) states that: people who are economically or socially disadvantaged may be less likely to obtain affordable, secure and appropriate housing. They may also be more likely to suffer discrimination in their efforts to obtain adequate housing and may be at a greater risk of homelessness. The HAA 1996 is implemented through Commonwealth State Housing Agreements. These Agreements include (among other things) the provision of funding for crisis and transitional housing, and for community housing programs. Section 5(3g) of the Act stipulates that Agreements must include provisions to safeguard: the rights and obligations of the people to whom the assistance is to be provided. Implementation of the HAA in Victoria In Victoria, crisis and transitional properties are administered through the Transitional Housing Management Program (THMP). THM Guidelines (2002) outline key service delivery principles, which include privacy considerations, and a requirement that services are delivered in a respectful manner consistent with user rights principles. User rights are defined as: Ensuring that clients are active participants in any actions/decisions affecting their lives Ensuring that clients are fully informed of options available to them Provision of accurate information on THM service policy and services offered Making client files available to the client concerned Implementing client feedback and consumer satisfaction systems Provision of services and accommodation that are responsive to individual client need ie security needs considered; appropriate facilities available, etc. Section 13 of the Guidelines requires that all THM agencies develop, document, and publicise a grievance/dispute resolution process. The core aim of these processes is to secure the best possible outcome for their client. Information about such processes must be made available to people in an accessible form. Section 7 of this Discussion Paper notes some of the other relevant legislation and mechanisms which might be relevant to people experiencing and at risk of homelessness. 3.4 The Residential Tenancies Act 2002 The terms and conditions under which people are accommodated in a wide range of public and private housing are covered by the Victorian Residential Tenancies Act 2002. There are specific provisions relating to people in transitional housing. Some provisions of the Act relating to transitional accommodation are regarded as inappropriate, in that tenants are often required to vacate within 3 months. Crisis accommodation is exempt from the provisions of the RTA. Breaches of the terms and conditions of the RTA 2002 are heard by the Residential Tenancies Tribunal. Either tenants or landlords (ie THMs) may take a case to the Tribunal. 3.5 Other implications A Charter of Rights for homeless people, could have implications where people experience discrimination on the basis of, or as a result of their homelessness. This would depend on the strength of the Charter and whether it is enshrined in legislation. Thus, homeless people who are currently excluded from accessing temporary accommodation (eg. hotels, motels), or who are charged with offences that are a direct result of their homeless state (eg. vagrancy, begging) may have recourse to protection of their rights through a Charter. 3.1 What changes in the law would be needed to implement a Charter of Rights? 3.2 What changes to how services are provided would be needed to implement a Charter of Rights? 4 Features of Charters of Rights 4.1 What is a Charter? A charter is a document explicitly identifying and conferring rights or privileges on an individual or group of people. Some countries, such as Canada, have a Charter of Rights and Freedoms, which describe the fundamental rights for all its citizens. This is similar to the USA Bill of Rights. Australia does not have a Bill of Rights, although this has been proposed, and some States/Territories in Australia are considering establishing a Bill of Rights. 4.2 Why have a Charter? Charters of Rights are sometimes developed for groups of people in society who are disempowered or vulnerable, and are usually written to protect their rights as service users or consumers. That is, while a person still has universal rights, it is recognised that in accessing and receiving services she/he is potentially subject to exclusion, abuse, marginalisation and discrimination. While there may be legislation and laws which cover some aspects of this, a Charter of Rights is more like a contract between an individual and an organisation or service system. In terms of service provision, a Charter of Rights would describe what people can and should expect from service providers, particularly the way in which services are accessed and provided. Charters of Rights clearly identify the rights of a specific group of people, and may be complemented by a set of service user responsibilities, or service rules. 4.3 How do Charters work? A Charter of Rights provides a framework which sets out the basis for enhancing the way services are accessed, and delivered. It can provide the foundation for service development through service standards, a quality improvement framework, and accreditation. A Charter also provides the basis for grievance procedures where people consider their rights have been abused. In short, a Charter of Rights can provide a basis for change in terms of peoples ability to access an adequate standard of living; access to services; and the way in which services are provided. Some Charters of Rights are attached to legislation, and this can add weight to the enforcement of rights. However, there is no readily apparent Victorian legislation covering services to homeless people, to which a Charter of Rights could be attached. Legislation which covers service provision in a range of disciplines or program areas often refers to the way in which services should be provided. This can be in the form of principles for service delivery, or in some cases, as an attached Charter of Rights. Some people would argue that there should be a Charter of Rights attached to the SAAP Act 1994, especially as the Act provides for such a Charter. As indicated, some legislation is designed to protect the rights of particular groups, and a Charter of Rights may be separately documented to reflect the expectations of the legislators and the community. For example, the Victorian Health Services (Conciliation and Review) Act 1987 is specifically designed to protect the rights of people receiving treatment and assistance from health services. Guiding principles (for service providers) in the Preamble to the Act are used by Complaints Liaison Officers and the Health Services Commissioner to evaluate complaints. In addition, a Victorian Public Hospital Patient Charter  has been developed which clearly sets out the quality of service that patients should expect from public hospitals. A literature review for this Project is underway, which will identify various examples of legislation, in a range of disciplines and program areas, in protecting and furthering peoples rights. 5 A Charter of Rights framework for people experiencing and at risk of homelessness The rights of people experiencing and at risk of homelessness can be considered at three levels universal (human) rights; the right to access services; and rights as a consumer of services (ie service user rights). Chart 5.1 below shows the different levels. Chart 5.1: Rights of people experiencing and at risk of homelessness            5.1 Universal rights As indicated in the SAAP Act, a range of International Covenants exist which are designed to protect peoples universal rights. Of particular interest is the International Covenant on Economic, Social and Cultural Rights (ICESCR), under which the Australian government has an obligation to respect, protect, promote and ensure each individuals right to adequate housing. If people have a right to safe and secure housing, then that fundamental right is violated if a person/ household is involuntarily experiencing homelessness. The ability to access and maintain safe and secure housing depends on a range of factors including affordability and housing market conditions, adequate income, and in many cases, a level of on-going support. Without access to income support, and/or other on-going support, many people may have their right to safe and secure housing compromised. Clearly, universal rights should apply within the homelessness service system. The Homelessness Service System is designed as a safety net, when the right to housing has not been upheld. In its report "Our Homeless Children", the Human Rights and Equal Opportunity Commission identified a number of violations of rights of young people who were experiencing and at risk of homelessness. A key aim of the Homelessness Service System is to help ensure that people gain access to safe and secure housing. However the universal right to adequate housing cannot be guaranteed by the Homelessness Service System alone. Universal rights, drawn from a variety of sources, might form an introduction or preamble to a Charter of Rights. Examples of universal rights include the right to housing, health, education, work and employment. 5.1 Is it a good approach to include reference to Universal Rights in the Charter of Rights? If so, what is the best way to do this, for example in a Preamble? 5.2 Rights to access services Homelessness services are responsible for providing a safety net response to one of the most powerless and marginalised groups in society. This response includes the provision of information, assessment and referral, advocacy to assist people to access other services, and preserving and protecting the civil, political, economic and social rights of people who are homeless. Many people who are experiencing homelessness, report that gaining access to services (ie getting past first base) can be confusing and frustrating. Some services are unable to respond and refer people elsewhere, without undertaking an assessment. Most homelessness services operate during business hours, and many require that people travel to their office. In reality, not all people can access the homelessness service system, and may be subject to eligibility criteria which are difficult to meet. People seeking assistance often have to contact several services, repeating their story many times. There is sometimes poor co-operation between agencies. Access to homelessness services is determined by different eligibility criteria and service models, and the availability (or not) of accommodation and support. People can be excluded due to family circumstances, level of need, cultural factors, and other factors such as behaviours. Ideally there needs to be an adequate range of service models to meet the needs of all homeless people in Victoria. A key component of the Victorian Homelessness Strategy is an enhanced access and entry system for people experiencing and at risk of homelessness. This is based on the right of homeless people to receive assisted access to the most appropriate service as soon as possible. Within this approach, the service first approached by a person/family accepts responsibility to negotiate a tangible outcome for that client. Examples of rights to access a service might include a right to: a constructive, empowering and individual response at initial contact convenient access arrangements (physically accessible, assertive outreach, responsive, convenient hours of operating, culturally appropriate) safety, choice and opportunities be treated with dignity and respect 5.2 What rights in relation to access need to be included in a Charter of Rights? 5.3 Service user rights Once a person/ family has accessed a homelessness service, they have the right to receive services consistent with the principles and provisions of legislation pertaining to universal rights; the SAAP Act; the Housing Assistance Act, and various other relevant legislation. Some of the rights which have been identified by homelessness services in Victoria include a right to: an individual response, based on assessed needs, and case management culturally appropriate responses safety and security; freedom from abuse, and a non threatening environment respect and fairness; being fully informed, and given the opportunity to make decisions; privacy and confidentiality professional assistance - skilful, appropriate, sensitive, timely, aware, non-judgemental housing and support provision normal and independent living opportunities to undertake activities of daily living in a home like environment have the individual needs of all family members considered, including children participate and contribute to service provision through involvement in the service, via feedback, suggestions, house meetings, etc. access to appropriate resources assistance with redressing social inequalities and achieving a reduction in poverty assistance accessing a range of services opportunities to participate in the community be assisted out of crisis and transitional accommodation into permanent accommodation grievance procedures 5.3 Do you endorse the above? What other rights need to be included? 6 Implementation issues 6.1 To whom would the Charter of Rights apply? A Charter of Rights would outline what all people who are experiencing and at risk of homelessness can expect of the service system. Defining homelessness, and who might be considered homeless has implications for operationalising a Charter of Rights. Assuming a Charter covers the rights of all homeless people to access services, as well as their subsequent rights once they have become a service user, it might apply to people living in: housing or circumstances which are not safe, secure or adequate housing or circumstances which lack personal amenities and the economic and social support that a home normally affords housing which is likely to damage health or threaten their safety crisis and transitional supported accommodation. Homelessness is further described by Chamberlain and McKenzie as comprising three levels: - primary (on the streets, sleeping in parks, squatting in derelict buildings, using cars or railway carriages for temporary shelter, etc.) - secondary (frequently moving from one form of temporary accommodation to another, eg. staying with friends, relatives, or in hotels/ motels, or in crisis accommodation) - tertiary (sub standard accommodation - boarding houses and caravan parks, with no security of tenure provided by a lease) The Charter of Rights could theoretically apply to all homeless people in these housing situations. 6.1 What definition of homelessness should the Charter be based on? 6.2 Does the Charter of Rights need to specify or take account of the needs of different sub groups within the homelessness population, eg. children accompanying adults, Indigenous people, other? If so, how should it do this? 6.2 Which services would be covered by the Charter of Rights, and how? Clearly, the Victorian Homelessness Services System (comprising SAAP and THMs) would be covered by the Charter of Rights, with mechanisms in place to ensure rights are upheld by these services. In addition there are a range of other services which people who are experiencing and at risk of homelessness may use. This is illustrated in Figure 6.1 on the following page, with the Homelessness Services System shown at the centre of these services. Beyond the Homelessness Service System, there are a number of other Victorian programs which specifically target people who are experiencing and at risk of homelessness, including programs outside the dedicated homelessness area. Examples include the Community Connection Program (CCP), and the Mental Health Homeless Outreach Psychiatric Services (HOPS). There are also Commonwealth programs which target, or are directly relevant to, people who are experiencing and at risk of homelessness such as Job Placement Employment and Training Program (JPET), Reconnect, and ACHA (Assistance with Care and Housing for the Aged). While the Charter might apply to these programs, the mechanisms used to enforce the Charter may be different from those developed specifically for the DHS funded Homelessness Service System. Moving beyond targeted homelessness services, there is a wide range of services which homeless people might use, including accommodation and support services. How the Charter of Rights might be applied outside the Homelessness Service System could vary. The Charter of Rights could apply in principle to all people experiencing and at risk of homelessness irrespective of which part of the service system they approach, or are in. While a Charter of Rights may not be directly enforceable in all circumstances, it could provide for the development of protocols and referral arrangements to homelessness services, where those rights are enforceable. 6.3 If a Charter of Rights is to apply to all people experiencing and at risk of homelessness, how can it be applied most effectively in terms of: a) universal rights b) right to access support, and accommodation c) rights within Homelessness Service System services d) rights within other services (outside of the Homelessness Service System)? Figure 6.1: Victorian Homelessness Service System and broader service system context              SRSSupported residential ServiceHACCHome and Community CareCCPCommunity Connection ProgramHOPSHomeless Outreach Psychiatric ServicePHAPPublic Housing Advocacy ProgramACHAAssistance with Care and Housing for the AgedJPETJob Placement and SupportIHSYInnovative Health Services for Young People7 Protecting, promoting and upholding peoples rights mechanisms to implement the Charter of Rights 7.1 Upholding rights a spectrum of approaches There are a range of mechanisms to assist services to uphold peoples rights. Chart 7.1 on the following page suggests four key areas. Organisational factors At an organisational level, client rights may be reflected in mission or values statements, and/or within the organisations policies and code of ethics. A commitment to upholding peoples rights will be reflected in quality improvement, training and service development. Accountability and reporting Accountability and reporting mechanisms incorporating service standards, accreditation, and compliance with Funding and Service Agreements will also seek to facilitate and support a user rights culture. Consumer participation Importantly, consumers can also assist services to implement a Charter of Rights, and more broadly influence service system culture, by participating in a range of service activities, and/or by providing feedback through surveys, meetings, and other approaches. Complaints mechanisms Where peoples rights are breached, there are currently limited complaints mechanisms available, including local resolution with the service provider involved, and/or possible legal action, which is often not an option for people who are homeless. Chart 7.1 on the following page indicates four possible approaches which might be taken where rights are breached. A person with a complaint has a right to receive advocacy support. This aims to address the power imbalance commonly experienced when a service user makes a complaint. An advocate may assist a person with resolution of a complaint directly with a service provider, or might provide assistance in taking the complaint to an external organisation, such as the Equal Opportunity Commission. Many funded agencies have grievance processes to facilitate resolution of complaints (see Section 7.2 below). Apart from seeking resolution directly with a service provider, and depending on the nature of the complaint, a person may contact the Department of Human Services, Housing Appeals Office, the Equal Opportunity Commission, the Ombudsman or take action through VCAT. Chart 7.1: Mechanisms to assist services to implement the Charter of Rights         Consumer participationWhere rights are breachedConsumer participation in service planning, in working groups, research, community development, leadershipConsumer feedback (written and verbal), eg. surveys; meetings, suggestion boxes; otherAdvocacy People have a right to advocacy support  Grievance processes  DHS, Housing Appeals, Equal Opportunity Commission, Ombudsman, VCAT Legal action7.2 What is a complaints mechanism and grievance process? Complaints mechanisms and grievance processes are recognised processes which people can use when rights have been breached. The complaint may relate to accessing services; the way in which services are provided (usually relating to a specific incident or inappropriate behaviour of another person); or the physical conditions of a service (eg. food, security). Complaints mechanisms and grievance processes describe various actions which a person can take if they have a complaint or grievance. For the purposes of discussion, complaints mechanisms include a wide range of actions which a person with a complaint may take. Some complaints may be addressed through direct feedback to staff; responding to in-house surveys, or in other ways. For other complaints, a formal grievance process may be used. A grievance process describes a number of steps which can be taken by both the person making the complaint and the service provider, in order to resolve the problem. This requires that both parties are willing to engage in the process. Other mechanisms include taking the complaint to the Department of Human Services, the Equal Opportunity Commission or the Ombudsman, or seeking legal advice. 7.3 Why have complaints mechanisms and grievance processes? Complaints mechanisms and grievance processes are essential for groups of people in society who are disempowered or vulnerable. They are necessary to ensure that complaints are dealt with fairly, and that rights are upheld. Complaints mechanisms are an important way for services to be accountable to the people they serve. Grievance processes are generally used to resolve complaints internally, that is, between the person making the complaint, and the service provider. Resolution of problems at the service provider level, if done properly, can provide a timely and constructive outcome for service users, and may also lead to improved service provider practices. 7.4 What are some examples of complaints mechanisms and grievance processes? Current Mechanisms within the Homelessness Service System In addition to developing a Charter of Rights, this Project seeks to identify ways of strengthening the complaints mechanisms available to people who are experiencing and at risk of homelessness. Examples of current mechanisms are outlined below. Homelessness service providers may operate internal grievance procedures and provide other opportunities for consumer feedback The Support Accommodation Rights Service (SARS) offers and provides advocacy support to people wishing to raise a formal grievance with a homelessness service provider as well as advocacy support for people who are involved in an existing grievance process with a service provider. The SARS model does not include mediation, undertake investigations or make determinations. . People experiencing homelessness may seek legal advice on any matter, by contacting the Homeless Persons Legal Clinic (PILCH), which provides pro-bono legal representation for people experiencing and at risk of homelessness. PILCH operates at various outreach locations in Melbourne. PILCH will not represent a client who wishes to take legal action against a homelessness service provider, but refer the person to another legal aid agency. THM clients are covered by the Residential Tenancies Act 2002. Tenancy disputes are resolved by the Victorian Administrative Appeals Tribunal (VCAT). People who apply for priority rental housing (eg. Segment 1 and 3), assistance to meet bond costs, or other types of rental housing assistance provided by the Office of Housing, and are unhappy with the result, can lodge an appeal with the Housing Appeals Office within the Department of Human Services. If not satisfied, people can further appeal to the Ombudsman or the Equal Opportunity Commission. The Victorian Ombudsman investigates complaints about the administrative actions taken by any government department, or statutory authority. The Equal Opportunity Commission investigates cases of discrimination on the basis of age, race, religion, marital status, gender, disability, political or religious beliefs. The Tenants Union of Victoria provides information and advice to tenants, particularly in relation to their rights, and the actions which they might take in making a complaint. Other complaints mechanisms There are other services which may be available to people experiencing and at risk of homelessness, whose rights have been abused. Examples of Victorian complaints mechanisms are shown in Appendix 1, and provide additional insight about types of complaints mechanisms which might be appropriate for people experiencing and at risk of homelessness. There are also community based groups which provide information, advice and advocacy. For example, in the Loddon Mallee and Goulburn Valley regions, the Regional Information and Advocacy Council provides both individual and systemic advocacy for people with disabilities and their carers and families Questions for discussion 7.1 What sort of mechanism(s) would be the most appropriate way to promote, uphold, and enforce a Charter of Rights for homeless people? 7.2 What mechanisms to promote, uphold and enforce rights might be applied to each of the bands shown in Figure 6.1? 7.3 What existing mechanisms could also apply to people experiencing homelessness? What could be done to make these mechanisms more accessible Appendix 1: Examples of other Victorian mechanisms MechanismJurisdictionKey ElementsPowersRemedies & EnforcementEqual Opportunity Commission (under the Equal Opportunity Act 1995). Includes discrimination on the basis of age, race, religion, marital status, gender, disability, political or religious beliefs.All Victorians who consider they have experienced discrimination. Includes accommodation, education, employment, goods and services, sport. Covers all forms of rental accommodation Information, education and consultancy services. Free and impartial complaint resolution services, investigation and reporting.Complaint resolution includes investigation, determination of compliance with the Act.Resolved or referred for Conciliation at VCAT (Anti-Discrimination List)Health Services CommissionAll health services in Victoria, including hospitals, GPs, drug and alcohol treatment services, mental health services, pharmacies, counsellorsComplaints Liaison Officers (patients advocates) in public hospitals seek to resolve complaints, otherwise refer complaints to the Commissioner.Investigate and resolve complaints, promote standards of service provision, and undertake community education Restitution possibly including compensation. Formal reporting of outcomes. Commitment by health services to service improvementVictorian Dispute Settlement Centre Auspiced by the Victorian Attorney Generals DepartmentAll citizens, groups and organisations in Victoria who wish to resolve a dispute using mediation. Access to interpreters, and individuals may be accompanied by an advocate if they wish. Dispute Advisory and Referral service. Mediation provided by a team of trained mediators. Community education. Service is free, and there is no requirement to put complaints in writing. Participation in mediation is voluntary, and the VDSC does not have the power to compel people to participate.Mediation, involving identifying disputed issues; considering options Mediation is a voluntary activity, so there is no enforcement mechanism.OmbudsmanInvestigates complaints concerning the administrative actions taken by a government DepartmentInvestigation and reportingProduces reports, recommends actionInvestigative only, recommendations and report have coercive powerOffice of the Public Advocate legislated in the Victorian Disability Services Act (1991),The Office of the Public Advocate is empowered to make investigations into alleged breaches of the rights of individuals with disabilitiesAdvice, Advocacy, Investigation, Community Programs to monitor service quality (eg. community visitors).Investigatory and reporting, with recommendationsResolved or referred to VCAT (Guardianship List)  The consultants work with a Reference Group comprising senior staff from the Community Programs Group, citizen representatives (5), a representative of the Support and Accommodation Rights Service, a representative of the Public Interest Law Clearing House Homeless Persons Legal Clinic and a representative of the Homlessness Practice Development Advisory Group.  Victorian Department of Human Services (2002) Victorian Homelessness Strategy, Melbourne.  Criticisms included a perceived lack of understanding within the service system about homelessness and instances of discrimination, stigmatisation and stereotyping (VHS, p28)  Such as Commonwealth and State Equal Opportunity legislation, Health Services and Disability Discrimination Acts.  Such as the Victorian Intellectually Disabled Persons Act 1986, Mental Health Act 1986, and Commonwealth Aged Care and Disability Services Act.  All SAAP and THM agencies are currently required to establish, document and publicise internal grievance processes  Discussed further in Section 7 of this Discussion Paper.  The Magna Carta was a Bill of Rights.  The ACT has developed a draft Bill of Rights  There are legislative provisions which protect people from discrimination. This includes people with disabilities, and people from different racial backgrounds. The Equal Opportunity Act protects people from discrimination on the basis of religion, etc. It does not include social status (which is part of Equal Opportunity legislation in other jurisdictions), which could provide a stronger basis for claims made by homeless people.  See for example, the Aged and Disability Services Act (Commonwealth). A Charter of Rights attached under Schedule 1.  www.health.vic.gov.au/hsc  The SAAP Act 1984 says that a person is homeless if he/she has inadequate access to safe and secure housing (Art. 4.1).  Department of Human Services (2002) Victorian Homelessness Strategy, p 24. The VHS includes the strategic objective to develop a common assessment and referral approach to address these issues.  The Assessment and Referral in Homelessness Services Project, proposed that all people receive an initial assessment, referral (where appropriate), and tangible outcome, and that designated front door services be established in each DHS Region.  Other related functions of SARS include the provision of secondary consultation to agencies and individuals seeking information on practice and policy related matters, training and development, systemic advocacy, as well as research and broader policy development.  Importantly the Equal Opportunity Commission cannot deal with discrimination on the basis of social status (ie poverty, level/type of income, employment status, or homelessness) PAGE 1 PAGE 25 Charter of Rights Discussion Paper Accountability and reporting Service standards Accreditation FASAs Complaints mechanisms Organisational mission, values, quality improvement, training, policies, code of ethics You have the right to make a complaint Good No Yes You have the right to be treated with dignity and respect, and have other rights respected by the service Are these rights respected? Rights as a service user Accommodation providers, incl. SRS, rooming houses, public housing, caravan parks, motels, real estate agents DHS non SAAP programs targeting homelessness. Eg. HACC, CCP, HOPS, public housing Seg.1 and 3, PHAP Homelessness Services System Other non government organisations Commonwealth programs targeting homeless people. Eg. Reconnect, ACHA, IHSY, JPET DHS Joined Up Initiatives Local government Unfunded organisations, eg. church based, other Generalist and specialist services used by homeless people Charter of Rights No Yes Good Rights to access services You have the right to access the Homelessness Service System Can you access the Homelessness Service System? No Yes You have the right to an adequate standard of living, including adequate housing Do you have an adequate standard of living? Do you have adequate housing? 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