Community Sector Red-tape
Reduction Forum –Report
Community Sector Reform Program
Red-tape Reduction Project
Contents
Community Sector Red-tape Reduction Forum – Report
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1.1
Executive Summary
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1.1.1 Introduction
1.1.2 Principle findings
1.1.3 Recommendation
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1.2
Purpose of this Report
1.2.1 Document Audience
1.3
1.4
1.5
1.6
1.7
Red-tape Reduction Forum - Background
Forum Objectives
Forum Methodology
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1.5.1 Overview
1.5.2 Forum Design
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Forum Analysis Design
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1.6.1 Conducting an affinity process
1.6.2 Conducting cause and effect analysis
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Principle Findings
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1.7.1
1.7.2
1.7.3
1.7.4
1.7.5
1.7.6
1.7.7
1.7.8
1.7.9
1.8
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Error! Bookmark not defined.
Out of scope issues
Strategic issues
ACT Government procurement process
Reporting requirements – both regulatory and funding agency
Contract management and contract compliance
Relationship management
Regulation by governments
Financial management/Auditing and funding issues
Any other issues
Recommendations
Appendix A. Community Sector Red-tape Forum –
Participating Community Sector Organisations
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Community Sector Red-tape
Reduction Forum – Report
1.1
Executive Summary
1.1.1
Introduction
A red-tape reduction forum for 65 of the ACT community sector leaders was
conducted on 20 February 2013. The forum applied a ‘world cafe’ approach and
collected 346 issues raised by the participants under six table topics that summarise
the relationship between the sector and government:
a. ACT Government procurement processes;
b. Reporting requirements – both regulatory and funding agency;
c. Regulation by government regulators;
d. Contract management and contract compliance;
e. Relationship management; and
f. Financial management and funding processes.
The attached report describes the design of the forum and the design of the analysis
applied to the forum results and provides a précis of the issues raised by the
participants, grouped into fifty four ‘affinity’ groups and analysed further through a
cause and effect analysis.
1.1.2
Principle findings
The report extracts eight strategic issues that are embedded throughout the fifty four
affinity groupings of issues raised. These strategic issues were:
a. Overcome the silos;
b. Understanding of risk;
c. Differences between directorates;
d. Outcomes over outputs;
e. Whole of Government Approach;
f. Change fatigue;
g. Dealing with scale; and
h. Inflexibility of funding arrangements.
Following the conduct of the cause and effect analysis, three priority areas were
identified for more concentrated attention. These three areas are:
a) Procurement;
b) Contract management; and
c) Reporting.
A fourth issue, relationship management, was also identified as ‘wrapping around’
the three priority areas above. As there is a significant structural component to
relationship management this issue will be managed separately.
1.1.3
Recommendation
The CSRAG have recommended the development of an options paper to address the
options and issues around procurement, contract management and reporting. The
development of an options paper would provide an opportunity for the sector to
participate in the development of options and would be expected to form the basis of
consideration by the Government into the most effective approach to resolving
issues around procurement, contract management and reporting.
1.2
Purpose of this Report
The community sector reform program conducted a red-tape reduction forum for
members of the ACT community sector on 20 February 2013. This paper provides a
report on the scope and methodology of the forum and the principle findings of the
forum.
1.3
Red-tape Reduction Forum Background
Red-tape reduction is one of the core components of the overall community sector
reform program.
The Red-tape Reduction Forum was conducted to collect as much information as
possible on the red-tape issues that impact upon the community sector in the ACT.
The forum was agreed in conjunction with the Community Sector Reform Advisory
Group in late 2012 for conduct in early 2012.
1.4
Forum Objectives
The objective of the community sector red-tape forum was to collect sufficient
feedback from the community sector to inform a structured approach to reducing
unnecessary red-tape from the relationship between the sector and the ACT
Government. The information collected needed to be sufficiently precise and
detailed to enable it to be considered against the relevant element of the business
process that it pertains to.
Additional objectives of the forum were to confirm, or to create an expectation
within the community sector around the intent of the Government with regard to redtape reduction.
1.5
Forum Methodology
1.5.1
Overview
The forum was designed as an element in a structured, process improvement,
approach to the overall red-tape reduction program. Under this methodology, the
key processes that characterise the relationship between the community sector and
the ACT Government are identified.
Once identified, each of the key processes is assessed for process objectives, the
extent to which the process outputs meet that objective and the potential to modify
the process to either improve alignment between process outcomes and objectives,
or to improve the efficiency of the process, or both.
Understanding the extent to which a process is delivering on its objectives and
understanding its relative efficiency are both enhanced by the views participants in
those processes and of the clients of those processes.
1.5.2
Forum Design
The success of the forum design is key to achieving results that will flow through to
well structured initiatives that are likely to reduce red-tape. Forum design is, in turn,
largely dictated by numbers of participants and the available time.
Design criteria were that the forum must be available to all ACT Government
funded community sector entities, should they wish to participate; that it provide an
open opportunity to address concerns about red-tape; that there be no public servants
(other than the two facilitators) present; that it would be advantageous for the
members of the Community Sector Reform Advisory Group (CSRAG) to play a
role; and that it be completed in a single afternoon.
There are approximately 150 ACT Government funded community sector
organisations, of which approximately 30 might be considered to be large entities,
another 30 might be considered medium sized, with the remaining 90 organisations
ranging from small to smallish. The organisations represented at the red-tape forum
are listed at Appendix A.
As this was the initial contact with the sector on red-tape, the decision was to seek
breadth of feedback from the participants, rather than depth. This decision was
taken on the basis that depth could be added through follow up work in smaller
groups, but that issues not picked in the forum ran the risk of being overlooked later.
With acceptances to the forum from approximately 70 organisations, mostly, but not
all, in the medium to large category, it was not possible to conduct the forum as a
single group, particularly if it was to be completed in a single afternoon.
Alternatives considered were to either conduct the forum as a series of parallel
brainstorming exercises, where groups were free to explore red-tape reduction and
with each group facilitated by a member of the CSRAG, or to conduct it using the
world cafe model, where groups rotate through a series of issues.
The world cafe model was chosen on the basis that it had a lower requirement for
group facilitation, and that it provided a starting structure that allowed each sector
representative the opportunity to address any aspect of red-tape that concerned them.
The alternative model had significantly higher facilitation requirements and ran the
risk of either not matching the skills and interests of participants to the issues that
concerned them, or of not addressing some areas of concern.
A variation was added to the world cafe model to ensure that, instead of fixed
groups rotating past a fixed group of table issues, each table rotation was designed to
ensure that participants formed a different group each time, while also never
addressing the same table issue twice. This variation maintained a continual
turnover of the table participants to encourage new combinations of ideas to emerge
for each table.
Under a world cafe model, determining the table issues for each rotation is vital.
This was addressed by a discussion among stakeholders to explore the key processes
that represent the relationship between the community sector and the government, as
described above. The results of this exercise were matched with the results of a
separate red-tape reduction brainstorm that was held in 2012 with ACT Government
representatives from the Community Services and Health Directorates. Six table
issues were selected as representing the span of the relationship, with a seventh, any
other issues, being included to provide an opportunity to address any issue that had
not been included:
a. ACT Government procurement processes (participants were asked to focus
on the current procurement process on the basis that significantly different
approaches were explored through a separate process);
b. Reporting requirements – both regulatory and funding agency;
c. Regulation by government regulators, including both the ACT and the
Australian Governments;
d. Contract management and contract compliance;
e. Relationship management;
f. Financial management and funding processes; and
g. Any other issue.
There were no limits to the scope of the discussion within these broad areas.
It can be immediately seen that these issues are heavily focused around the more
formal and structured aspects of the relationship between the sector and the
Government. This reflects both the impact of these processes on the community
sector and also their inherent potential for process improvement. There is of course
red-tape reduction potential around less structured and less formal aspects of the
relationship and this potential has been reflected in many of the comments and
issues raised during the forum.
Following an introduction by the Minister for Community Services and an
introduction to the task and the methodology, each rotation was allocated 20
minutes, with five minutes allowed for groups to reform for each rotation. The
schedule for rotations provided that a member of the CSRAG would be at each table
for each rotation and it was the role of the CSRAG member to ensure a steady flow
of content from the participants.
Each table had the benefit of seeing the material collected by their predecessors and
could add to it. Items were collected on butcher’s paper for later collation and
assessment.
1.6
Forum Analysis Design
The methodology described above delivered 346 separate items related to red-tape
issues. As might be anticipated, these items align well with the key processes that
form the relationship between the ACT Government and the ACT community
sector.
1.6.1
Conducting an affinity process
These 346 items were grouped through an affinity process and it is the results of that
affinity process that are described below in the report. In this process all of the 346
issues were transferred to separate pieces of paper and then analysed by a small
group according to the ‘affinity’ that each of the issues raised had for any other
issue. This process resulted in fifty four affinity groups. While the fifty four groups
were constructed from the all of the responses to allow for relationships between
table topics to be collected, the fifty four groups are structured in this report under
the table topic that best reflects the issues involved.
It should also be noted that, under an affinity process, issues may be represented by
multiple items from the brainstorm process, or may be represented by a single item,
with the number of items forming a category not necessarily indicating the
importance of the issue.
1.6.2
Conducting cause and effect analysis
In order to determine the cause and effect relationships between the issues
aggregated through the affinity process, an interrelationship analysis process was
conducted. This process is designed to determine whether or not cause and effect
relationships existed, and the direction of that causality.
The results of the cause and effect analysis will be provided separately.
1.7
Principle Findings
The principle findings from the forum are outlined below under a set of strategic
issues and under the table issues against which they were collected. Where a
particular group crossed the boundary of a table issue and addressed other issues, the
points made have been addressed under the relevant heading.
1.7.1
Out of scope issues
A small number of issues were raised that pertained to government policy issues or
to the delivery of specific services, rather than red-tape. Where the policy issue had
a red-tape element it was included. However, where this was not the case these
issues were extracted from the total and will be provided separately to the relevant
policy or line area.
1.7.2
Strategic issues
A considerable number of issues raised related to red-tape reduction but also had
connections broader policies or strategies. Most of these issues are embedded within
the responses discussed in more detail below, but have been separately drawn out
here.
a. Overcome the silos – comments here spread through many separate topics and
related to the multiple and overlapping relationships that are necessary for the
sector to manage their relationship with the ACT Government. Specific
suggestions were to rationalise program silos and to rationalise the multiple
strategies which operate to perpetuate the silos;
b. Understanding of risk - A recurring theme, linked with many aspects of the
relationship from procurement to reporting and contract/relationship
management, was the determination of and response to risk. The specific issues
will be addressed below. In summary, the commentary was a call for a more
developed approach to risk that limits increasing regulation/reporting/compliance
as a reaction. Risk management should be made with reference to the specific
underlying risk, with proportional measures to reduce the risk or ameliorate its
potential impact;
c. Differences between directorates - One issue that was raised a number of times
was that some directorates were ‘better’ at maintaining/managing a relationship
with the community sector than others. In particular, that the processes used by
some directorates were simpler, faster, and more effective than those used by
others;
d. Outcomes over outputs – A number of suggestions that continuing a shift to
measuring outcomes over outputs was necessary;
e. Whole of Government Approach – A related issue raised was the adoption of a
whole of Government approach. This was often expressed as ‘implement the
Hawke Review’;
f. Change fatigue – The issue of change fatigue was also raised, from a number of
perspectives. These included transparency around upcoming changes; a single
calendar/reporting tool around change; better co-ordination of change by
directorates; and a suggestion for better assessment of the impact of change
initiatives on the sector;
g. Dealing with scale – there were many points in the forum where the issue of
scale arose, along with the disadvantage that small organisations faced when
dealing with systems designed for larger organisations;
h. Inflexibility of funding arrangements – there were suggestions that funding
was too inflexible and that an inability to move resources between programs that
may be related was too restrictive;
1.7.3
ACT Government procurement process
Under this section, the results of the forum will be grouped roughly according to
stages in the procurement process. It should be noted that there are overlaps
between many of these issues. Issues raised were:
a. Strategic procurement conversations – there were suggestions around better
co-production of services and better conversations and communications between
policy makers and procurement processes and a better understanding of the costs
involved in doing business in order to develop more realistic proposals and better
cost services before tendering, thus avoiding inaccurate or deliberately under
bidding;
b. Prequalification – many comments were received in relation to prequalification.
Comments included increasing the validity period to beyond three years; the use
of public and ACNC records where possible; the elimination of tender
requirements where they have been addressed in the prequalification process;
overcoming the duplication between prequalification processes and other
accreditation requirements; extending prequalification to other Directorates.
There was call for a post-implementation review of prequalification that
addresses the assessment process, changes to processes as a result of
prequalification, consistency of process over the implementation and ways of
better managing the impact on the sector;
c. Choose the most appropriate procurement process – Issues here ranged from
determining when to go to market and when not to; whether procurement should
be through a grant or a service funding agreement (SFA) to a better balance
between the decision around procurement approach and the inherent risk
involved in the procurement/service;
d. Collaborate on the procurement process – Here, the issue is that CSD needs to
match talk about collaboration/co-production with appropriate processes, with
commentary that the NSW Government has been able to achieve this through
community sector participation on assessment panels;
e. Match funding terms to desired outcomes – This issue has connections to
others in this section, particularly collaboration, and seeks to ensure that the
delivery mechanism aligns with the desired outcome;
f. Ensure tendering times are appropriate – A number of comments went to
different aspects of this issue. These included avoiding Christmas tenders,
providing sufficient time to prepare the tender and ensuring that the decision be
arrived at promptly, with a suggestion that it match the time given to preparing
the tender;
g. Reduce the burden of tender writing – This issue related to both scale of entity
and to the scale of funding;
h. Better links between policy makers and procurement decision making – This
was a suggestion to strengthen these links to better align decisions with policies
and to overcome one cause of gaps between service delivery and contract
requirements;
i. Problems with communication between program and administrative units –
This issue was tangentially commented on in a number of ways, as well as being
directly addressed.
j. Address the transition timing of procurement decisions – Procurement
decisions need to be made known with sufficient time to enable transition out or
start up of new provider;
k. Conflict of interest – there was a perception that the ACT Government had a
conflict of interest in being both a provider and a purchaser of services.
1.7.4
Reporting requirements – both regulatory and funding
agency
Reporting by the community sector is for a number of purposes. In particular,
regulatory reporting to either ORS or to the ACNC, national reporting, to AIHW or
the ABS or to meet national objectives, and regular funding agency reporting. This
section was designed to gain views on all of these reporting elements.
a. Reporting timeframes – Move all reporting to financial year and limit all
reporting to 12 months, rather than six months;
b. Consistent templates – There were many suggestions that the ACT apply whole
of Government, and consistent, reporting templates and processes;
c. Consistent reporting across jurisdictions – This issue is an extension of the
one above and relates to an objective of consistent reporting across jurisdictions;
d. Reduce duplicate and unnecessary reports – as might be anticipated, there
were many requests for duplicated requirements, both within single reports,
within CSD, across the ACT and between jurisdictions. Other requests were for
the elimination of unnecessary reporting, particularly information sought but not
used;
e. Validate reporting requirements and processes – separate from requests to
eliminate duplicated and unnecessary reports, there were many suggestions
around the validation with the sector of reporting requirements – why
information was collected and how it was to be used. These suggestions
extended to not just the data, but also to the processes, procedures and the
expectations;
f. Financial and Annual Reports – there was a suggestion that financial and
annual reports should be the same thing, along with warnings not to use annual
reporting requirements to address reductions in reporting elsewhere;
g. Align performance reporting with tender terms – There were suggestions that
the terms for performance reporting should match the terms of the funding
agreement;
h. Scaled and risk based reporting – This issue addressed the question of scale in
reporting, both scale of reporting entity and scale of funding reported on, with
the suggestion that all reporting requirements should take scale and risk into
account;
i. Penalties for late reporting – Suggestion that there should be exception
reporting for established organisations;
j. Use of reporting technology – there were several suggestions that reporting
could be supported through better use of technology, with a number of examples
from the Commonwealth and other jurisdictions of better approaches than used
by the ACT.
1.7.5
Contract management and contract compliance
The contract management relationship forms a significant proportion of the formal
contact between the Government and the community sector. (something on the role
and on numbers and levels of contract managers?)
a. No feedback - Lack of feedback on contract management was strongly
commented on, with concern that reports disappeared into a ‘black hole’ that
there was no return of information in such a way that it could help improve
service delivery, a desire for analysis and a fear that reports were not even read.
b. Lack of respect by contract managers - a considerable number of the
comments made during the forum related to perceptions by the sector that
contract managers did respect the relationship between themselves and the
sector. Examples given included a lack of notice of meetings, time wasting
chatting without substance, tick box processes and meetings held just for the
sake of having a meeting;
c. Lack of equivalence in contracting roles - Other comments in relation to
contract management included observations that contract managersdid not have
the necessary seniority, or understanding of the business of the sector to be
undertaking their role;
d. Excessive turnover of contract managers – an issue broadly commented on
was what was considered to be excessive turnover of contract managers.
Examples of five managers in eighteen months were given. Examples were
given of the destabilising impact on organisations, including wasted time, loss of
knowledge, loss of trust and a loss of consistency and of continuity;
e. Unclear role of contract managers - Related comments went to an apparent
lack of clarity around the role of contract managers;
f. Standard contract clauses – There were suggestions that these were out of date
and needed to be updated;
g. Contract managers exceeding their role – There were many comments on the
role confusion between contract managers and relationship managers and in
general, managers did not appear to liaise with the business areas, have clear
direction and imposed administration procedures such as output delivery
processes on organisations; inconsistent and idiosyncratic interpretations of
contracts between contract managers; and changes to the size of contracts
without consultation.
h. Indexation payment timing – Concerns were raised that indexation payments
were late and suggestions that they should be made automatically and only
changed by exception;
i. Roles of Contract managers and Relationship managers - There is also a
question around the relationship between the roles of the contract mangers and
relationship managers, with the suggestion that both roles may not be needed
(see 1.6.5);
j. Conflict resolution – there were suggestions that there were no conflict
resolution processes in place in regard to contract management;
k. Process confusion regarding changes to agreements, and outputs– some
participants suggested that procedures for changes to outputs were inconsistent
and sometimes occurred without proper consultation. Further, notice of
contractual changes could be lost or not well communicated between program
and administrative functions;
l. Process errors – there were a number of comments around the contract
management process, including that quality control was not strong; that
organisations for example could receive other organisation’s contracts in the
mail; that contracts contained errors; that the process of contracts being prepared
and signed was onerous and should be able to be managed electronically; that the
late completion of contracts threatened service delivery and created rollover
issues;
1.7.6
Relationship management
In this process, relationship management includes the role of relationship managers
as well as the more ad hoc elements of relationship management, both strategic and
operational. It was generally noted that Health maintained better relationships than
CSD.
a. Social Compact – There were perceptions that the social compact was honoured
more in the breach than in fact, and that it should be honoured in both principle
and practice and form the basis of the relationship;
b. Reciprocal time requirements – There were multiple suggestions that the ACT
Government meet the same time requirements over business processes that it
imposes on the sector and that there should be penalties for failure to do so;
c. The Club – A comment made a number of times was that there was a ‘club’ of
community sector leaders who had access to the government, there was no clear
rationale for this club, with a negative impact on the role of the peaks;
d. Role of relationship managers - There was a suggestion that both relationship
managers and contract manager are not needed.
e. Number of relationship managers – there needs to be a single relationship
manager for each government agency, regardless of the number of contracts
involved, and that this person manage the internal relationships within
government that relate to the different contract outcomes;
f. Annual contract meetings – This was suggested as a whole of government
approach to avoid repetitive meetings;
g. Sector/Government secondments – These were proposed as a mechanism to
improve understanding and relationships.
1.7.7
Regulation by governments
The red-tape reduction project seeks the removal of unnecessary red-tape. This
section addresses commentary on red-tape that is due to regulation by any tier of
government, but separate from the red-tape imposed through the funding
relationship.
a. Elimination of duplicated red-tape due to ACNC - All of the rotations raised
the issue of the regulatory duplication created by the establishment of the
Australian Charities and Not-for-profit Commission and called for the
duplication to be eliminated.
b. The ACNC as a data clearing house - Some groups proposed that the ACNC
be a clearing house for reporting, including reporting to the ACT.
c. Use of compliance standards – A number of comments were received around
the requirement by Government for compliance with industry, or other related
standards. In particular the cost of maintaining compliance with multiple, often
overlapping, standards along with the cost of tracking the multiple and
overlapping requirements;
1.7.8
Financial management/Auditing and funding issues
Many of these issues are related to other categories considered in the forum.
a. Better balance administrative and delivery costs – this issue related to
comments around an overly prescriptive approach to what portion of funding
comprised administrative costs, with specific comments relating to the
inadequacy of applying 10% and the intrusion of stipulating any figure. It was
also noted that administrative costs were rising faster than other costs;
b. Compliance burden on small organisations is unrealistic – comments in this
area were heavily influenced by scale issues, with much of the commentary
around the disadvantage that smaller organisations face when meeting
compliance needs. There were also comments around the scale of the funding,
where small funding amounts had significant compliance requirements that
threatened the viability of the grant;
c. Audit costs – a related scale issue is around the cost of audits for small
organisations;
d. Aggregate auditing – issues raised in this area related to conducting single
audits of an organisation, not multiple audits based on separate programs;
participants advised that this is now the Commonwealth approach;
e. Build financial knowledge – There were suggestions that knowledge of
accounting standards should be increased across the sector;
f. Awareness of external issues – consideration in developing funding programs
for external issues, such as award requirements for minimum employment
periods of three hours – so don’t require one hour services;
g. Separate bank accounts – don’t require separate bank accounts to be
established for separate programs. There were also comments that this was
required under the Charitable Collections Act 2002;
h. Funding in arrears – funding in arrears can be a practical issue;
i. Inconsistent processes – some programs require invoices to trigger payments,
while others do not. This is inconsistent.
1.7.9
Any other issues
a. Working with vulnerable people – There were a number of comments about
the cost and complexity of this process. Specific comments were that there were
additional requirements outside the process, such as OCYFS driving record
check, the timeliness of the results and overlaps with the CHIPS checks.
b. Equal Remuneration Case Process – There were comments that this had been
a time consuming process.
1.8
Recommendations
The recommendations from the conduct of the red-tape forum relate to both the
proposed actions to address the red-tape issues identified and also to how to provide
feedback to the community sector participants in the process.
The primary finding of this process has been that procurement, contracting and
reporting are the key areas of activity with the potential to reduce red-tape for the
community sector and for the ACT Government. Resolution of the red-tape issues
will require the examination of existing ACT Government legislation, whole of
Government policies and practices. Resolution should also take account of the
rapidly changing environment in which community services are delivered and
explore new approaches to procurement, contracting and reporting, where these have
the potential to deliver benefits to all parties, as well as to improved outcomes for
clients.
All Australian jurisdictions are currently dealing with similar issues and a number
have already, or are undertaking, similar review processes for similar purposes, and
it is likely that valuable lessons can be learned from their experiences and processes.
The CSRAG has offered to work with the Community Sector Reform Program and
relevant others to contribute to the development of an options paper that explores the
question of procurement, contracting and reporting in the community sector in the
ACT and explores different ways of addressing this question for consideration by
the Government.
The material on which this analysis is based was provided by 65 community sector
leaders. These leaders have a reasonable expectation that the outcome of the process
be reported back to them, preferably with sufficient feedback of the collected
content to keep faith with their contribution. The most effective way of achieving
this outcome would be to would be through a letter to the sector outlining the
proposed next steps by the Government, supported by a list with a reasonable level
of detail of the issues raised, extracted from this report.
Appendix A. Community Sector Red-tape Forum –
Participating Community Sector Organisations
Organisation
People with Disabilities ACT
SHFPACT
Austism Asperger ACT
Mental Illness Education ACT
Carers ACT
Health Care Consumers Network
ACT Playgroups Association Inc
Parentline ACT
Winnunga Nimmityjah
Belconnen Community Service
Red Cross
Beryl Women
COTA
Northcott
NDS
Care Financial Counselling
Karinya House
Communities@Work
Koomari
Havelock House
Women's Centre for Health Matters
Koomari
ACT Deafness Resource Centre
The Smith Family
Sharing Places
ACTCOSS
ADACAS
Barnardos Canberra Childrens Family Centre
Anglicare
Capital Community Housing
Aids Action Council
Gunghalin Regional Community Service
Families ACT
Salvation Army
Girl Guides ACT and SE NSW Region
Relationships Australia
SHOUT Inc
Catholiccare
Tandem
Inanna
Woden Community Services
Mental Health Community Coalition
UnitingCare Kippax
Youth Coalition of the ACT
Northside Community Service
Karralika
Doris Womens' Refuge
Focus ACT
Prisoners Aid
Conflict Resolution Service
Canberra Rape Crisis Centre
Sharing Places
Community Options
St Vincent de Paul Society - Canberra/Goulburn
Ozhelp Foundation
Hartley Lifecare
ACT ME & CFS
Connections ACT