INCORPORATING
59 Power Crescent (PO Box 1729) Port Augusta, SA 5700
Telephone 08 8642 4477
Facsimile 08 8642 4446
Free Call 1800 631 301
Email admin@rice.org.au
www.rice.org.au
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Feedback on Regulation Impact Statement for proposed options for changes to the National Quality
Framework
Background
RICE is a not for profit organisation sponsored by the South Australian and
Commonwealth Governments with its primary aim to provide accessible health, welfare, preschool
education, childcare and toy/resource library service for the children and their families in the remote and
isolated areas of outback South Australia. RICE is the only organisation in Australia that provides such a
holistic service ( health, welfare, education and childcare ) to geographically remote and isolated children
and their families and have been performing this role since 1976. RICE operates via an interdisciplinary
team providing holistic services to the pastoral properties and small communities in outback South Australia
covering some 650 000 square kilometres. RICE practitioners travel from the base in Port Augusta in 4wd
vehicles to provide these services on the property and in various facilities in the small communities ( sheds,
hotels, community halls, etc ).
Proposal 3.1 Additional services to be included in the NQF
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The simple fact in our opinion is that innovative mobile services such as RICE cannot comply to the
existing 7 standards and associated elements as contained in the NQF. It is suggested that the
report authors has no real actual knowledge of the needs and difficulties in the provision of services
in the remote and very remote parts of Australia.
RICE supports regulation and audit ( Best Practice ) but it has to be relevant to the service not one
size fits all.
Comment p42 “ many out of scope services that are not regulated do not benefit from the
requirements of the NQF” is incorrect, at least in the case of RICE. RICE has undertaken to comply
where practical, economically viable and sensible to the standards set by the NQF. For example
RICE has implemented a policy that the minimum qualification requirement is Cert 111 in Children’s
Services and actively encourage all relevant staff to work towards the Diploma. This is done even as
it increases our costs but with no increase in grant funding
Comment p43 “compliance costs would be incurred, but that this cost would be lessened by preexisting regulatory compliance requirements”. Currently compliance costs are minimal. The
statement clearly shows a total lack of understanding of the financial vulnerability of BBF services
in Australia. Currently all three mobile BBF services in South Australia are underfunded and are
operating from previous surpluses, cutting services or in overdraft. I believe this trend is Australia
wide. This leaves the question where does the money come from for more compliance costs.
It should be noted that the Commonwealth Department of Education are by stealth via funding
agreements forcing BBF services to comply with the NQF or parts thereof; e.g.
- Reporting of staff qualifications and staff studying - Compliance & Operations Report
- Submission of a QIP by 31 August 2014
- Proof of Police criminal checks
If these are not submitted by the relevant due dates the milestone payments are withheld so we
have no choice.
Conclusion
Mobile BBF services cannot be included in NQF unless the standards and elements
are developed to address the needs of the innovative services ( not merely a rehash of the centre driven
standards ) and that appropriate funds are provided by the Commonwealth Government to fund increase
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Sponsored by the South Australian and Commonwealth Governments
Providing services to families in remote and isolated areas of South Australia
Health - Welfare - Childcare - Play Days - Early Childhood Education
operational and compliance costs. Current funding does not meet current operational costs. In the case of
RICE there is an increased demand for services that are not being addressed because of limited funds.
Proposal 3.2 Application of assessment and rating processes to additional services
This proposal is irrelevant until Out of Scope BBF services have standards and associated elements that
are relevant to this particular innovative and different form of delivering services.
If a standard was developed that was relevant there is not an issue for some form of assessment/ or
compliance monitoring. The Assessment process in the current NQF of Observe – Discuss – Sight can not
operate in RICE, the itinerant style of RICE’s operations will prevent this from occurring.
Conclusion
The preferred option would be compliance monitoring but based on Standards and
Elements that are specifically developed for non mainstream services.
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Sponsored by the South Australian and Commonwealth Governments
Providing services to families in remote and isolated areas of South Australia
Health - Welfare - Childcare - Play Days - Early Childhood Education