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What this report is about

Extreme rainfall across eastern Australia in 2021 and 2022 led to a series of major flood events in New South Wales.

This audit assessed how effectively the NSW Government provided emergency accommodation and temporary housing in response to the early 2022 Northern Rivers and late 2022 Central West flood events.

Responsible agencies included in this audit were the Department of Communities and Justice, NSW Reconstruction Authority, the former Department of Planning and Environment, the Department of Regional NSW and the Premier’s Department.

Findings

The Department of Communities and Justice rapidly provided emergency accommodation to displaced persons immediately following these flood events.

There was no plan in place to guide a temporary housing response and agencies did not have agency-level plans for implementing their responsibilities.

The NSW Government rapidly procured and constructed temporary housing villages. However, the amount of temporary housing provided did not meet the demand.

There is an extensive waitlist for temporary housing and the remaining demand in the Northern Rivers is unlikely to be met. The NSW Reconstruction Authority has not reviewed this list to confirm its accuracy.

Demobilisation plans for the temporary housing villages have been developed, but there are no long-term plans in place for the transition of tenants out of the temporary housing.

Agencies are in the process of evaluating the provision of emergency accommodation and temporary housing.

The findings from the 2022 State-wide lessons process largely relate to response activities.

Audit recommendations

The NSW Reconstruction Authority should:

  • Develop a plan for the provision of temporary housing.
  • Review the temporary housing waitlist.
  • Determine a timeline for demobilising the temporary housing villages.
  • Develop a strategy to manage the transition of people into long-term accommodation.
  • Develop a process for state-wide recovery lessons learned.

All audited agencies should:

  • Finalise evaluations of their role in the provision of emergency accommodation and temporary housing.
  • Develop internal plans for implementing their roles under state-wide plans.

Extreme rainfall across eastern Australia in 2021 and 2022 led to a series of major flood events in New South Wales. In response, the NSW Government declared each of these events a natural disaster and made available a wide range of support for affected individuals and businesses. The flooding experienced by the State was widespread and its severity caused significant destruction in communities across the State. Some of the most significant damage occurred in the Northern Rivers and Central West regions of New South Wales.

Whilst areas of the Northern Rivers are prone to regular flooding, the scale of flooding in 2022 had not been experienced in the region before. On 28 February 2022, the Wilsons River in Lismore reached a height of 14.4 metres, approximately 2.3 metres higher than the previous record. A second flood occurred on 30 March 2022, with the river reaching 11.4 metres. The flooding in the region was extensive, affecting towns including Lismore, Coraki, Woodburn and Ballina. Between late February and early April 2022, 13 lives were lost in the Northern Rivers floods. In addition, 4,055 properties were deemed uninhabitable, and a further 10,849 properties were assessed as damaged. Approximately 4,000 people had to be evacuated from Lismore alone during this period, with thousands displaced from their homes across the region.

In the Central West, on 14 November 2022, the Lachlan River at Forbes peaked at 10.6 metres and was categorised as major flooding due to the inundation of extensive rural areas with properties, villages and towns isolated. On the same day in Eugowra, the Mandagery Creek peaked at 9.8 metres, passing the previous record of 9.6 metres in 1950. Flooding occurred in other areas of the Central West including Parkes, Molong, Cowra and Canowindra. Two lives were lost in the town of Eugowra with 80% of homes and businesses in the town damaged.

This audit assessed the following two areas of NSW Government support provided in response to these flood events:

  • Provision of emergency accommodation: short-term accommodation provided to displaced persons unable to return to their own home in an emergency situation.
  • Provision of temporary housing provided in the form of temporary pods and caravans.

The Department of Communities and Justice (DCJ) is responsible for the provision of emergency accommodation and other welfare services in response to a disaster event. With regards to temporary housing, the following agencies were involved in this audit:

  • Resilience NSW was the lead agency responsible for recovery and led the implementation of the temporary housing program under the oversight of the Chair, Housing Taskforce (HTF) from July 2022. On 16 December 2022, Resilience NSW was abolished, with some staff transferred to the NSW Police Force, Department of Premier and Cabinet (DPC) and DCJ. The remaining staff were transitioned to the newly established NSW Reconstruction Authority.
  • The Department of Planning and Environment (DPE) chaired the HTF until July 2022 and led the process for the identification and evaluation of temporary housing village sites. On 1 January 2024, DPE was abolished and the DPE functions discussed in this report now form part of the Department of Planning, Housing and Infrastructure.
  • NSW Public Works (NSWPW), a branch of the Department of Regional NSW (DRNSW) procured and managed the construction of the pods used in this program, and procured the caravans used as part of the temporary housing response.

The then DPC (now Premier’s Department (PD)) was responsible for whole-of-government policy advice, convening the Crisis Policy Committee of Cabinet, and whole-of-government communications.

This audit assessed how effectively the NSW Government provided emergency and temporary housing in response to the early 2022 Northern Rivers and late 2022 Central West flood events. We addressed this objective by examining whether the audited agencies:

  • effectively planned for the provision of emergency accommodation and temporary housing prior to the flood events
  • provided emergency accommodation and temporary housing to meet the needs of affected communities in response to the flood events
  • are effectively capturing lessons learned in relation to their provision of emergency accommodation and temporary housing as part of the flood response.

There is a State-level plan in place to guide the approach to emergency accommodation

The Welfare Services Functional Area Supporting Plan (WSFASP, the plan) is a supporting plan to the New South Wales Emergency Management Plan (EMPLAN). The plan outlines the responsibilities of the Department of Communities and Justice (DCJ) for the coordination and delivery of disaster welfare services in New South Wales. This includes the provision of emergency accommodation services. The plan in place during the flood events outlined the responsibilities of DCJ and the former Office of Emergency Management (OEM), some responsibilities of which have since transitioned to the NSW Reconstruction Authority (the Reconstruction Authority). The plan sets out a framework for government and non-government organisations to coordinate to provide key welfare services during an emergency, and outlines agreed roles and responsibilities. The plan outlines preparedness measures and arrangements for the provision of key welfare services during the response to and recovery from emergencies in New South Wales.

The plan details the organisations and key positions involved in welfare services, including their overall roles and responsibilities, and a basic structure for the delivery of disaster welfare services. For example, the plan states that both the former Department of Families and Communities Services and the not-for-profit Adventist Development and Relief Agency (ADRA) are responsible for emergency accommodation but does not clarify the detailed responsibilities associated with this role. These provide a State-wide, though not detailed, approach to emergency accommodation and welfare services in a disaster recovery context.

There was no plan in place to guide the temporary housing response, despite the NSW Government utilising this type of response in a previous emergency event

The State-level emergency planning documents do not contemplate the need for temporary housing as a government disaster response. Although there was a temporary housing response to the Black Summer bushfires in 2019–20, albeit on a smaller scale, no specific plans were in place to guide this response or the flood events in 2021–22. The NSW Government therefore had to develop its approach to addressing demand for temporary housing whilst responding to the flood emergency as it was occurring.

A partnership was established between the NSW Government and the Minderoo Foundation in 2020 to provide 100 pods to people whose homes were destroyed in the Black Summer bushfires. The initial rollout consisted of four-person pods, however the need for greater capacity was identified, with larger, family-sized pods developed for up to six people. The implementation of this program did not include formalising the work completed in documented plans for future use in response to other emergency events.

A plan that sets out how temporary housing should be used is in place in Queensland. The Queensland Government released a Temporary Emergency Accommodation (TEA) plan in 2021 which describes the arrangements, roles and responsibilities of key organisations critical to supporting displaced community members after the closure of an evacuation centre. The TEA plan outlines the five phases in the provision of accommodation support which includes temporary housing recovery. This demonstrates that a plan for the use of temporary accommodation would not be unprecedented.

Without plans in place to respond to all aspects of an emergency, decision makers are forced to be reactive in their decision making or to develop these plans while also responding to the events. In this specific instance, the government was forced to develop governance structures and perform tasks such as options analysis and site selection for temporary housing during the immediate aftermath of the flood events.

The Reconstruction Authority has acknowledged the need for a formalised plan for temporary housing responses and has started work to develop this in preparation for future flood events. It advised that the Housing Taskforce (HTF) has begun this work by performing assessments and reviews of high-risk areas and engaging with local councils and community groups. The Reconstruction Authority is also developing a Recovery Readiness Checklist, which will include preparedness for the provision of temporary housing in an emergency. Pre-event recovery planning specific to Local Government Areas (LGAs) is also underway, with the Reconstruction Authority developing tailored checklists which cover the provision of temporary housing. These tools will form part of the State's recovery response under the NSW Recovery Plan, which the Reconstruction Authority is currently in the process of updating. The Reconstruction Authority advises that this update will include identifying responsibilities in relation to the temporary housing response and recovery more broadly.

The WSFASP in place during the flood events had not been reviewed and updated in line with its planning requirements

Plans which outline the coordination and delivery of services in response to an emergency are imperative to ensure all required activities are completed, and the needs of affected communities are met. Plans also serve as a common reference point for decision making. Out of date plans can result in unclear roles and responsibilities, requiring agencies to make improvised decisions due to the urgent nature of emergency response. This creates a risk of key activities not being fulfilled and community needs going unmet.

The WSFASP in place during the flood response was last updated and endorsed by the State Emergency Management Committee (SEMC) in June 2018. As part of the planning requirements outlined in the plan, the State Welfare Services Functional Area Coordinator (WelFAC) is required to ensure the plan is reviewed every five years, or when relevant aspects require review following emergency operations or changes to legislation. The State WelFAC is an officer from DCJ responsible for the monitoring, support and coordination of disaster welfare services in New South Wales.

In 2020, a machinery of government change was implemented which established Resilience NSW as a public service executive agency and transferred persons employed in OEM to Resilience NSW. Despite these legislative changes, the plan had not been updated in line with its requirements to reflect these and subsequent changes, as OEM was still listed as one of the two agencies responsible for the coordination and delivery of disaster welfare services. Similarly, the plan had not been updated to reflect emergency operations changes with ADRA listed as the responsible coordinator for the provision of emergency accommodation services, despite no longer being responsible for this service.

The WSFASP has since been updated to reflect these changes and was endorsed by the SEMC in September 2023. The current WSFASP aligns with the welfare services responsibilities following the transfer of the welfare services functional area to DCJ in 2023. This includes the role of DCJ as the lead agency for the WSFASP, and DCJ and the Housing Contact Centre (HCC) within DCJ as the coordinator of emergency accommodation. The updated plan also provides an outline of the key welfare services that are delivered by the functional area, including emergency accommodation, personal support, essential food and grocery items, and transition from emergency accommodation. The outline provides a description of each service and the agency, team or non-government organisation responsible for coordinating the service.

Agencies did not have agency-level plans in place for implementing their responsibilities under State-level emergency accommodation and temporary housing plans

The State EMPLAN establishes a framework for sub plans, supporting plans and related policy instruments and guidelines. It states that a supporting plan should describe the support which is to be provided to the controlling or coordinating authority during emergency operations and be an action plan which describes how an agency or functional area is to be coordinated in order to fulfill the roles and responsibilities allocated. Without this more detailed guidance being in place, there is no common reference point for individuals within an agency to refer to when implementing the broader State-level plans, such as the WSFASP.

The WSFASP defines emergency accommodation and outlines the government and non-government organisations responsible for its provision. It does not provide a detailed description of the specific roles and responsibilities related to its provision. DCJ does not have an agency-level plan in place that specifies these in more detail, and did not have any standard operating procedures (SOPs) in place to guide the process of housing displaced persons in emergency accommodation.

The absence of SOPs to guide this process can increase the chance of inconsistent implementation of the WSFASP, with a reliance on the experience of staff to complete tasks to house people in emergency accommodation. For example, at the onset of an emergency, staff in the HCC contact local accommodation venues such as hotels and motels to determine availability in the area. They may also book blocks of rooms in preparation for housing displaced persons. At the time of the flood events, there was no documentation which detailed the process for DCJ staff to follow and these tasks were not recorded anywhere as requiring completion before a disaster occurred.

DCJ has advised that they have since developed internal processes which form part of the training program for Disaster Welfare staff. In addition to this, the HCC has developed a guide which steps out the various processes relating to the provision of emergency accommodation, as well as outlining the different roles and responsibilities within the HCC in relation to these processes.

As noted, there is no State-level plan in place to guide the temporary housing response. As a result, there is no framework to guide this process at an agency level for the Reconstruction Authority. The absence of both State and agency-level plans guiding the provision of temporary housing at the time of the flood events meant that agencies were required to develop a process to follow at the same time as responding to the flood events.

Appropriate governance structures were established quickly and changed as needed to reflect recovery needs

The State Recovery Committee (SRC) was activated following the 2019–20 bushfires and was still operating at the time of the 2022 floods. As part of this, the SRC had a terms of reference which included responsibilities of the SRC and a membership list. The responsibilities of the SRC in the terms of reference are to:

  • provide strategic direction in relation to disaster recovery
  • oversee reconstruction and recovery efforts in disaster impacted areas
  • provide senior leadership to facilitate whole-of-government coordination
  • monitor and report to the Premier, Deputy Premier and Cabinet on the progress of recovery efforts in disaster impacted areas.

Once the flood events commenced on 28 February 2022, the SRC increased its meeting frequency to every two days initially, for a total of 13 meetings in March. The SRC continued to meet at least twice a week from mid-April until the end of May, at which point it reduced gradually in frequency to weekly and then fortnightly. The SRC continued to meet throughout all of 2022 and 2023.

The SRC established a range of subcommittees to assist with recovery efforts. These subcommittees were operational from March 2022 onwards. Subcommittees had terms of reference setting out their role and were chaired by appropriate agencies with operational responsibilities that aligned with those roles. The Health and Wellbeing subcommittee was established as part of this and initially had responsibility for the provision of both emergency accommodation and temporary housing. This subcommittee was chaired by a relevant Senior Executive in DCJ.

As noted above, none of the whole-of-government plans prior to the flood events allocated responsibility to an agency or subcommittee for constructing and managing temporary housing. Although temporary housing had been utilised by the government previously in response to the 2019–20 bushfires, its provision had never been implemented on the scale required in response to the flood events.

In early March, the SRC created a new subcommittee: the Housing Taskforce (HTF). The HTF contained key staff from a wide variety of agencies, as well as other key stakeholders like local councils where appropriate, and was chaired by a Senior Executive from the Planning Branch of the Department of Planning and Environment (DPE). A terms of reference was quickly developed for the subcommittee. The HTF’s initial purpose included developing a strategy for identifying locations and pathways for temporary housing. This allowed the Health and Wellbeing subcommittee and the HTF to provide more focus on their particular areas of responsibility.

The SRC helped to manage issues but did not provide strategic risk management

Subcommittees regularly reported to the SRC throughout the flood response period. The SRC was able to manage issues with these programs as they arose, often by connecting relevant staff and providing a forum for these issues to be resolved across agencies. In this way, the SRC was able to manage issues, which aligns with its role in facilitating whole-of-government coordination.

Given that all relevant agencies were represented on the SRC, it was uniquely placed to provide strategic risk management across all aspects of the recovery effort including provision of accommodation and housing following the floods. This would fall within the SRC’s role of providing strategic direction in relation to disaster recovery. Strategic risk management involves addressing external risks, including those which may impact the government’s ability to achieve its objectives. The SRC did not undertake strategic risk management to proactively identify issues that could hinder the recovery effort, such as through developing risk registers and assigning mitigation strategies to agencies or specific individuals.

In regards to the flood temporary housing response, this may have included identifying and mitigating risks that could impact on the quantity of housing provided, risks to the overall flood recovery budget, and risks related to further flood events occurring that might hinder flood recovery. While the SRC did not consider this work during the flood response, Resilience NSW and the Reconstruction Authority both documented some whole-of-government risks to the delivery of the response to natural disasters as part of their enterprise risk management processes, including throughout 2022. However, this work was not undertaken specifically in relation to the unfolding flood events, but was instead done as part of the agency's regular review of its enterprise risks. Given that only one agency was involved in this risk identification, it was not a substitute for whole-of-government risk identification through the SRC.

The HTF did undertake some separate risk identification for the temporary housing response in the Northern Rivers, but not until October 2022. The HTF had been in operation since March 2022 without undertaking formal risk assessments to determine key risks to the provision of temporary housing that required mitigation. Some of the risks identified included expenditure on temporary housing exceeding its allocated budget, temporary housing sites failing to deliver agreed outcomes, and that there would be inappropriate or ineffective engagement with Aboriginal communities. This risk identification from the HTF was also reflected in Resilience NSW's and the Reconstruction Authority’s enterprise risk registers, where it is identified that there is a risk that the agencies do not effectively deliver on short and medium term housing.

The SRC provided oversight of the work of subcommittees

As noted above, one of the roles of the SRC is to oversee reconstruction and recovery efforts in disaster impacted areas. To fulfil this role of providing oversight, the SRC received updates on the activities of each subcommittee at each meeting.

In March 2022, each subcommittee developed a 100-Day Flood Action Plan that set out actions that would be completed in the first 30, 60 and 100 days. Each subcommittee was required to update its Flood Action Plan and report progress on implementation to the SRC every two weeks. The SRC received this regular reporting from each subcommittee, which included the status of each item, actions undertaken to date, and the next steps that each subcommittee was undertaking. This served to provide the SRC with oversight of the actions of each group to supplement the subcommittee updates with greater detail.

The quality of reporting from the HTF to the SRC reduced throughout August and September 2022. At this time the updates from the subcommittee included either only a verbal update or only statistical updates on the temporary housing response. This means that throughout this period, the SRC was providing only limited oversight of the temporary housing response. From October 2022, the HTF provided more detailed updates to the SRC, providing data on the temporary housing villages including the number of dwellings, estimated capacity and the status of each of the village sites (whether operational or estimated date of construction completion).

DCJ adapted its usual procedures to house a large number of people in emergency accommodation following the Northern Rivers flood event

The HCC, a branch within DCJ, is responsible for arranging emergency accommodation during a disaster, although this responsibility was not outlined in a specific emergency accommodation plan or procedure at the time of the flood events. Once a disaster is declared, the HCC is activated for a disaster welfare response. The team is required to estimate the number of people who will be displaced by the disaster and may seek emergency accommodation. The team is also required to contact local accommodation providers such as hotels, motels and caravan parks to determine vacancy information, as well as obtain information about the facilities such as wheelchair accessibility and pet-friendly rooms. The HCC team will then make direct contact with staff at evacuation centres and facilitate bookings based on the demand. A central internal database is utilised by the HCC, which enables them to see providers and book within the system.

In following these procedures, DCJ housed 788 people in the two weeks following the initial flood event by utilising the standard local accommodation providers. On 27 April 2022, 1,440 people were reported as staying at local accommodation providers as part of the emergency accommodation response. Exhibit 5 shows the number of people housed in emergency accommodation across the North Coast from March 2022 to early April 2023.

Governance structures continued to operate as previously established in response to the Central West flood event

The governance structures established in response to the 2019–20 bushfires and the flood event in the Northern Rivers mostly operated in the same capacity for the management of the Central West flood event. In October 2022, the meeting frequency for the SRC reduced to fortnightly, following the same structure with subcommittee updates discussed as part of the agenda. There was no increase in meeting frequency during or in the immediate aftermath of the response to the Central West flood event.

Resilience NSW continued to document whole-of-government risks to the delivery of the response to natural disasters during the response to the Central West flood event, and this work was continued by the Reconstruction Authority once established. Resilience NSW also continued to develop risk dashboard heatmaps each quarter, monitoring any changes in the residual risk rating of these risks, as well as outlining issues identified, and any new and emerging risks.

DCJ housed displaced persons in the Central West quickly, considering additional needs during the process

DCJ, through the HCC, advised that it followed its standard process outlined above for the provision of emergency accommodation during the Central West flood event. The evacuation order for Eugowra was made on 15 November 2022, and by 8 December 2022, DCJ had housed 93 people from the community in emergency accommodation. The HCC was able to utilise alternative accommodation such as rooms at Charles Sturt University to meet the increasing demand for emergency accommodation in the Central West.

Through the initial consultation process conducted with displaced persons at evacuation centres, the HCC was also able to consider their additional needs and meet these where possible. For example, companion animals were supported by Local Land Services and the Royal Society for the Prevention of Cruelty to Animals through the provision of boarding services. DCJ advised that local needs were also considered as part of the intake process. For example, displaced persons were accommodated as close to their hometown as possible. Those evacuated from Forbes were given priority for emergency accommodation in Forbes. This did impact evacuees from other towns. Ordinarily, those displaced in Eugowra would also be housed in Forbes, but due to limited accommodation options, they were evacuated to Orange instead. Other considerations made for displaced persons included level access and accessible rooms for those with disabilities, and baby care items, such as cots, where required.

The At-home Caravans program was implemented as immediate shelter for displaced persons awaiting pods on their property in the Central West

By 28 November 2022, Resilience NSW made the decision to activate the At-home Caravans program in the Central West, with applications from displaced persons being taken within a week after the flood event in Eugowra. Caravans were temporarily set up on private properties in Eugowra. Displaced persons are able to live in these caravans while waiting for a pod to be installed on their property. By 10 January 2023, 102 caravans had been delivered to the Central West and started to be located on private properties. At 30 May 2023, Resilience NSW had delivered 124 out of the 129 required caravans to properties. A plan was implemented to provide immediate shelter in the community through the caravans, organise medium-term housing in the form of pods, and support displaced persons to repair or rebuild their homes. Caravans were provided to households where properties required demolition, those that were damaged but reparable, and rental properties with owner’s consent.

Other options for immediate shelter were considered but not progressed. Placing caravans on site at showgrounds or caravan parks was considered, however a NSWPW assessment found that 95% of impacted homes could accommodate caravans on property. Caravans on property require less ongoing case management, site works and utilities. Private farm house rental accommodation was also considered, however extremely low availability of these in the area resulted in the decision to not progress this option.

Resilience NSW was able to meet the demand for housing in the Central West by placing temporary housing on people’s property

Resilience NSW conducted early analysis of potential temporary housing village sites in the aftermath of the floods in the Central West. However, after reviewing the situation in Eugowra and the relatively larger blocks, it was decided a more appropriate solution would be to place temporary pods on private property. Part of this decision was the impact a centralised village located in Eugowra would have on displaced persons from other affected towns. At 30 May 2023, 59 out of 100 pods had been installed on private properties. These pods replaced caravans initially installed on private properties, although at the time of the audit some disaster-affected persons were still living in caravans while they wait for pod installation on their property.

Resilience NSW was able to utilise the excess pods from the Northern Rivers to reduce the wait time for displaced persons to move into the pod from the caravan located on their property. Once their eligibility had been confirmed, the resident met with NSWPW and the builders contracted to install the pods. The resident confirmed where they would like the pod placed and the size needed. Applicants were then prioritised by Resilience NSW and pods installed in order of this prioritisation. NSWPW engaged the same third-party contractor used in the Northern Rivers construction to expedite the installation process.

Resilience NSW used measures to adapt the pods for suitable use in the Central West, as well as configuring them to meet mobility needs of residents. Cabonne Shire and Forbes Shire Councils required pods to be built at a height of 1.5 metres. The pods were therefore installed on scaffolding to raise their height. As the pods were designed and constructed for the Northern Rivers climate, insulation was installed on the base of the pods to ensure the inside temperature was appropriate for residents in the Central West. The raised height of the pods also impacted their accessibility, so the contractor was also engaged to install ramps instead of stairs where needed.

The first demobilisation of a pod occurred on 7 August 2023, after the resident’s home had been repaired and it was suitable for them to move back home. The Reconstruction Authority advised that as pods continue to be demobilised, they will be cleaned, any required repairs completed, and then moved onto the next property as needed. There was no long-term plan initially developed for the transition of tenants out of temporary housing, although the Reconstruction Authority has advised that the newly developed Temporary Housing Plan will include these considerations to inform processes at the end of the lease period. There has been consideration for returning the pods to the Northern Rivers once the work in the Central West is complete.

The Reconstruction Authority advised that due to the delays residents are facing in accessing trades and payment of insurance claims, the HTF is currently seeking the support of councils to extend the placement of pods beyond the two years that were initially planned.

There was no clear process in place to support displaced persons in emergency accommodation who were ineligible for temporary housing in the Central West

The WSFASP in place during the flood events did not outline a transition plan for displaced persons staying in emergency accommodation. Resilience NSW took over responsibility for the transition of displaced persons from emergency accommodation to temporary housing. It was not always possible to house rental tenants by placing a pod on the property they were occupying because they were unable to obtain landowner permission. It was necessary to find an alternative property to install these pods, usually on property owned by a family member. This was able to address most tenants’ issues.

It was unclear which agency was responsible for the support of renting households in the medium to long-term. The lack of a documented process for the provision of emergency accommodation created a gap in relation to the support for displaced persons. The WSFASP has since been updated to include provision for coordinated case management support to assist people in emergency accommodation with longer-term housing needs.

DCJ maintained a list of displaced persons who had been staying in emergency accommodation and were unable to exit without assistance. This list was provided to Resilience NSW weekly. Resilience NSW provided updates to DCJ on the status of those who were being transitioned into temporary housing, but no assistance was provided by Resilience NSW to those who were ineligible for temporary housing. DCJ was therefore required to provide case management to these people to assist in their transition to more stable housing.

Agencies learned and applied lessons from the Northern Rivers floods to the Central West flood event, but most have not formalised these for future consideration

Agencies involved in the provision of emergency accommodation and temporary housing learned key lessons from the Northern Rivers floods that could be applied in the Central West response. These lessons included the Reconstruction Authority rapidly standing up the At-home Caravans Program to provide immediate accommodation to displaced persons, and instigating a community reference group to provide feedback on the proposed housing response plan. These lessons learned were largely undocumented, with many staff being involved across both the Northern Rivers and Central West flood response, and able to directly apply lessons learned from their experience in the earlier response. It is good practice to formalise lessons learned to ensure that future responses may have access to contemporary information to learn from both positive and negative experiences in previous situations.

DCJ and Premier’s Department (PD) have not yet documented any lessons learned from their roles in the flood events. Some lessons were documented by Resilience NSW in April 2022 as part of a process to identify emerging insights. These lessons covered a broad range of activities, including findings relevant to the provision of temporary housing.

In June 2023, the Reconstruction Authority formally documented its own lessons learned from the provision of temporary housing. This includes identifying actions to avoid repeating some of the negative experiences, such as Aboriginal communities not being consulted at the appropriate time, and not having adequate program design processes in place for the temporary housing program. In addition, NSWPW has commissioned an evaluation of its work in the construction and provision of temporary housing, which includes a formal lessons learned component.

External reviews have also been conducted and have captured interim lessons learned, including the 2022 NSW Flood Inquiry and the ‘Response to major flooding across New South Wales in 2022’ Parliamentary Inquiry.

Agencies are in the process of evaluating the provision of emergency accommodation and temporary housing

Agencies have commenced the process of evaluating their role in the provision of emergency accommodation and temporary housing. DCJ advised that an external evaluation would commence shortly and that it was in the process of engaging a consultancy firm to conduct this. NSWPW has also commenced an external review of its provision of temporary housing. DPE and PD have not commenced a review, although PD has established a new unit for strategic communications during disasters in response to the agency's involvement in crisis communications during the flood events. This unit has been developed to deliver overarching whole-of-government messaging during disaster events.

Similarly, the Reconstruction Authority advised that an evaluation was planned for the provision of temporary housing. In addition, Resilience NSW commissioned an evaluation of the use of the Minderoo Foundation pods in response to the 2019–20 bushfires. This review reported in November 2022, though it had limited consideration of the role of the Minderoo Foundation pods as a source of temporary housing in the Northern Rivers. This report made 19 recommendations to the Reconstruction Authority and the Minderoo Foundation, and found that the Minderoo pods had largely been delivered in line with the original intended objectives.

There is no State-wide process in place to capture lessons learned from all agencies involved in recovery

Each year, the SEMC conducts a State-wide lessons learned exercise, incorporating learnings from all of the emergency events in the previous year. This exercise has commenced for the 2022 emergency events, however at the time of the audit it was in draft and not yet formally endorsed by the SEMC.

The agencies involved in the State lessons learned process are agencies with emergency response responsibilities. The findings largely relate to these response activities, with very few lessons learned relating to recovery. Only a limited number of agencies are involved in this activity, and the 2022 review did not incorporate the views of a number of agencies that were involved in the recovery phase of the Northern Rivers and Central West flood events.

While it is important that lessons are learned from the response phase of an emergency, it is equally important that State-wide lessons are learned from the recovery phase to ensure that appropriate State-wide changes can be made, or positive experiences can be continued. There is currently no process in place to capture these lessons learned from the recovery phase from all agencies involved in the recovery phase.

Appendix one – Responses from entities

Appendix two – About the audit

Appendix three – Performance auditing

 

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Parliamentary reference - Report number #389 - released 22 February 2024

Published

Actions for Natural disasters

Natural disasters

Community Services
Environment
Finance
Local Government
Planning
Transport
Treasury
Whole of Government
Asset valuation
Compliance
Financial reporting
Infrastructure
Regulation
Risk
Service delivery

What this report is about

This report draws together the financial impact of natural disasters on agencies integral to the response and impact of natural disasters during 2021–22.

What we found

Over the 2021–22 financial year $1.4 billion from a budget of $1.9 billion was spent by the NSW Government in response to natural disasters.

Total expenses were less than the budget due to underspend in the following areas:

  • clean-up assistance, including council grants
  • anticipated temporary accommodation support
  • payments relating to the Northern Rivers Business Support scheme for small businesses.

Natural disaster events damaged council assets such as roads, bridges, waste collection centres and other facilities used to provide essential services. Additional staff, contractors and experts were engaged to restore and repair damaged assets and minimise disruption to service delivery.

At 30 June 2022, the estimated damage to council infrastructure assets totalled $349 million.

Over the first half of the 2022–23 financial year, councils experienced further damage to infrastructure assets due to natural disasters. NSW Government spending on natural disasters continued with a further $1.1 billion spent over this period.

Thirty-six councils did not identify climate change or natural disaster as a strategic risk despite 22 of these having at least one natural disaster during 2021–22.

Section highlights

  • $1.4 billion from a budget of $1.9 billion was spent by the NSW Government in response to natural disasters during 2021–22.
  • Budget underspent for temporary housing and small business support as lower than expected need.

Section highlights

  • 83 local council areas were impacted by natural disasters during 2021–22, with 58 being impacted by more than one type of natural disaster.
  • $349 million damage to council infrastructure assets at 30 June 2022.

 

Published

Actions for Managing the affairs of people under financial management and/or guardianship orders

Managing the affairs of people under financial management and/or guardianship orders

Justice
Community Services
Management and administration
Project management
Regulation
Risk
Service delivery
Workforce and capability

Click here for the Easy English version of the report highlights

The Easy English version of the report highlights is intended to meet the needs of some people with lower literacy skills, some people with an intellectual disability, and some people from different cultural backgrounds.

The Easy English document is not the final audit report that has been prepared and tabled in NSW Parliament under s.38EB and s.38EC of the Government Sector Audit Act 1983. It should not be relied on or quoted from as the final audit report.


What this report is about

This audit assessed whether NSW Trustee and Guardian is effectively delivering public guardianship and financial management services in line with legislative requirements and standards.

What we found

NSW Trustee and Guardian is delivering guardianship and financial management services in line with its broad legal authority.

However, NSW Trustee and Guardian does not have sufficient oversight to ensure that its services are consistent with legislative principles which aim to promote positive client outcomes.

The agency's governance and practices could be better supported by relevant training and guidance to account for the diversity of its clients.

It does not track the actual costs of service delivery, the quality of services or client experiences and key findings from previous reviews remain unresolved.

Government funding for public guardianship services and direct financial management services for low-wealth clients has not kept pace with the growth in clients.

There is a risk that some fee-paying clients are unknowingly subsidising others.

NSW Trustee and Guardian has applied additional funding to increase frontline staff, but gaps in monitoring and IT system constraints create a risk that it will not address service quality issues, nor be able to demonstrate the impact of this new funding.

What we recommended

We recommended that NSW Trustee and Guardian:

  • Broaden governance arrangements to enable input to key decisions from people with lived experience, relevant peak bodies and representatives of diverse communities.
  • Implement mechanisms to seek feedback on the effectiveness and quality of services from clients under orders.
  • Assess staff competency and implement regular training in effectively serving clients with disability, dementia, mental illness, cognitive impairments and other factors relevant to decision-making incapacity.
  • Implement a risk-based quality framework to assess whether public guardian and financial management decisions are in line with policy and the legislative principles.
  • Improve data collection and monitoring to track performance, the costs to serve, and client outcomes and report on these publicly.

NSW Trustee and Guardian is a NSW Government agency in the Stronger Communities cluster. It supports the NSW Trustee and the Public Guardian in the exercise of their statutory functions. It is accountable to the relevant Minister, the Attorney General.

The legislative responsibilities for the Public Guardian and the NSW Trustee are provided in separate statutes (NSW Trustee and Guardian Act 2009 and Guardianship Act 1987). Together, these establish a number of functions and services that NSW Trustee and Guardian as an agency is expected to deliver, including:

  • acting as executor and administrator of deceased estates
  • acting as a trustee responsible for managing trust property on behalf of another person or organisation in line with the trust terms
  • drafting Will, Power of Attorney and Enduring Guardianship instruments, and educating the community about the importance of having these documents in place
  • making decisions on behalf of people under guardianship or financial management orders as a guardian or a financial manager 'of last resort', or overseeing and assisting private financial managers.

This audit focuses on the last of these - NSW Trustee and Guardian's financial management and guardianship services.

The NSW Trustee and the Public Guardian are appointed to provide direct financial management and/or guardianship services (respectively) to over 13,300 people (as at 30 June 2022) who are deemed by a court or tribunal unable to manage their own affairs. This involves making decisions for people under a relevant court or tribunal order, within the terms of the order. The court or tribunal order enables the appointed guardian or financial manager to make decisions on behalf of the person for whom the order is made. The legislation allows the financial manager or guardian to exercise all the functions of the person under management has or would have were they not incapable of managing for themselves. From a legal perspective, these 'substitute decisions' have the same effect as if the person had made the decision themselves. While the legal presumption is that a person has capacity to care for themselves and manage their own affairs, a financial manager or guardian can be appointed without the person's consent if the court or tribunal finds the person does not have relevant decision-making capacity.

There can be a range of factors that impact on a person's decision-making capacity, including cognitive impairment, intellectual disability, dementia, mental illness and addiction. Guardianship (of both the person and their estate) developed as a response, through European and English law over hundreds of years. In Australia, it was a function of the Supreme Court of NSW before the establishment of government agencies. What is now known as substitute decision-making can sometimes be referred to as a 'protective' function because:

  • it relates to decisions or actions that need to be taken, which the person under an order cannot take because they are incapable of managing their own affairs
  • due to this lack of competence, the person may be disadvantaged in the conduct of their affairs (for example, their money or property may be dissipated or lost, they may enter agreements unwisely or they may be at risk of abuse or exploitation)
  • substitute decisions must be made in the best interests of the person on whose behalf they are made.

An alternative model is 'supported decision-making'. This refers to processes and approaches that assist people with impaired decision-making capacity to exercise their autonomy and legal capacity by supporting them to make decisions. This approach seeks to give effect to the will and preferences of the person requiring decision-making support wherever possible, including decisions involving risk. There has been a longstanding legal and community push for Australian guardianship and administration systems to move from substituted to supported decision-making. However, the legislation in New South Wales provides for 'best interests' substitute decision-making and this is the framework against which we have audited NSW Trustee and Guardian.

The Public Guardian and the NSW Trustee may be appointed as substitute decision makers by the NSW Civil and Administrative Tribunal (NCAT) and the Supreme Court. The NSW Trustee may also be appointed by the Mental Health Review Tribunal for financial management orders only.1 They are intended to be appointed as a 'last resort' when there is no one willing or suitable to fill the role, or there is significant family conflict regarding decision-making for the person. The Public Guardian and the NSW Trustee cannot refuse to accept a court or tribunal appointment to administer an order for guardianship or financial management.

Public Guardian decisions cover healthcare, lifestyle, accommodation and/or medical decisions such as where a person should live (for example: at home, in an aged care facility or disability group home), what disability or other support services they receive, who can have access to them (for example: through establishing visiting schedules between conflicting family members) and consent to the use of restrictive practices on the advice of independent experts (for example: seclusion, chemical restraint such as anti-psychotic medication, environmental restraints such as limiting access to knives).

Under a financial management order where the NSW Trustee is appointed as financial manager, the NSW Trustee carries out such functions as securing and collecting assets, income and entitlements, paying expenses, debts and designing budgets, investing financial assets, lodging tax returns and paying maintenance for dependents, taking or defending legal proceedings and managing other financial and legal affairs for the person. This is referred to as direct financial management.

A court or tribunal may appoint a private financial manager, such as a family member, friend, private trustee company or other commercial provider. Where a private manager is appointed, the NSW Trustee provides authorisation and directions to the private manager and oversees their performance. As at 30 June 2022, over 6,200 people had private managers.

As an agency, the majority of NSW Trustee and Guardian's overall revenue is from fees (including for services outside the scope of the audit, such as will preparation) and investments. The remainder is from the NSW Government as funding for non-commercial services including guardianship services and subsidised financial management services for low-wealth clients. Public guardian clients do not pay fees. Financial management clients pay fees, but these are subsidised where the client does not have capacity to pay full fees. NSW Trustee and Guardian is considered a self-funded agency by NSW Treasury definitions.

Demand for financial management and guardianship services, and the complexity of clients' circumstances for these services, has grown over the last decade. In November 2020, NSW Trustee and Guardian advised the Attorney General that it had run an operating deficit in 2019–20 driven by an increase in non/low fee paying customers and an increase in the complexity of matters. NSW Trustee and Guardian advised the Attorney General that government funding was no longer meeting the full cost of guardianship services, and of direct financial management services for people with low balances. NSW Trustee and Guardian's analysis had identified a shortfall in government funding of $8.4 million in 2019–20 that was expected to increase over the forward estimates. A working group was established with officers from NSW Trustee and Guardian, NSW Treasury and the Department of Communities and Justice to advise the government on options for improving the financial sustainability of NSW Trustee and Guardian overall.

NSW Trustee and Guardian subsequently received a funding boost of $41.5 million across four years in the 2021–22 State Budget. NSW Trustee and Guardian applied the majority of the budget enhancement to recruit approximately 120 new roles mostly in financial management and guardianship services.

The objective of this audit was to assess whether NSW Trustee and Guardian is effectively delivering guardianship and financial management services in line with legislative requirements and relevant non-legislative standards. These include a legislative duty to observe certain principles when exercising the relevant legislative functions, including to: give primary consideration to clients’ welfare and interests, restrict their freedom of decision and action as little as possible, take account of their views, and encourage their self-reliance.

The audit was guided by three questions:

  • Does NSW Trustee and Guardian align its service delivery with its legislative functions and principles, and relevant standards?
  • Does NSW Trustee and Guardian drive and monitor performance to give effect to its legislative functions and principles, and relevant standards?
  • Has NSW Trustee and Guardian effectively planned the use of additional funding to improve service delivery and adherence to its legislative functions and principles, and relevant standards?

The audit review period was the five years between 1 July 2017 - 30 June 2022.

Throughout this report:

  • 'client' refers to a person who is under a guardianship order and/or whose estate is under financial management, for whom the Public Guardian and/or the NSW Trustee is appointed to act or responsible to oversee their private financial manager
  • 'financial management' refers to clients under financial management orders (direct and private financial management) and/or the services provided by NSW Trustee and Guardian to these clients or their private managers
  • 'guardianship' refers to clients under guardianship orders where the Public Guardian is appointed, and/or the services provided by the Public Guardian to these clients
  • 'frontline staff' refers to the staff responsible for engagement with, and decision-making for, clients and private managers (titled client service officers, senior client service officers and principal client service officers in NSW Trustee and Guardian)
  • Aboriginal refers to the First Nations peoples of the land and waters now called Australia and includes Aboriginal and Torres Strait Islander peoples.

Conclusion

NSW Trustee and Guardian is delivering guardianship and financial management services in line with its legal authority. However, it does not have sufficient oversight to ensure that its services are consistent with legislative principles which aim to promote positive client outcomes

NSW Trustee and Guardian's guardianship and direct financial management services rightly emphasise the legal requirement to give paramount consideration to the welfare and interests of its clients when making decisions for them. However, NSW Trustee and Guardian does not consistently obtain and record relevant client information to determine which of the other legislative principles should be applied to individual decisions. It also does not test that staff decision-making aligns with the legislative principles in practice.

Staff caseloads for financial management and guardianship services have limited the amount of time that staff can spend in building a relationship with each client or working on each client matter. This constrains the extent to which they can get to know a client and understand their circumstances - both of which are central to applying the legislative principles. Poor client information sharing in legacy IT systems, insufficient quality monitoring, and limited staff training and staff supports exacerbate this further.

NSW Trustee and Guardian governance and practices for financial management and guardianship do not reflect the nature and diversity of its client base

Despite direct financial management and public guardian clients having, by definition, impaired decision-making capacity often related to traumatic brain injury, dementia, intellectual disability and mental illness, an understanding of the sometimes-complex conditions that affect its clients has only been expected of all frontline staff since late 2021, and relevant training has been insufficient.

NSW Trustee and Guardian also does not have a consumer advisory entity to provide it with advice on financial management and guardianship services from the perspective of clients with lived experience.

Despite a significant over-representation amongst its client group, NSW Trustee and Guardian does not have specific governance, consultation, staff roles or practice guidance for its engagement with Aboriginal clients and their representatives.

NSW Trustee and Guardian does not know how well it delivers financial management and guardianship services

NSW Trustee and Guardian does not routinely track its performance with respect to service quality or how well it gives effect to the legislative functions, principles and standards for direct financial management and guardianship services. It has not been effectively monitoring whether these services are improving over time. Nor does it measure its performance with respect to the experiences and outcomes of clients of these services.

Key findings and recommendations from previous reviews remain unresolved. This includes a repeated finding by the Independent Pricing and Regulatory Tribunal (IPART) that direct financial management services should be subject to transparent fee-for-service charges rather than fees calculated as a proportion of client estate value.

NSW Trustee and Guardian does not have effective monitoring in place to know the actual costs of service delivery

Direct financial management services are resourced predominantly by client fees, comprising 81% of revenue between FY2018-FY2022. Government funding makes up the balance and is directed to fee subsidies and waivers for low-wealth clients (those with assets apart from their principal place of residence, motor vehicle and furniture valued under $75,000). Sixty-eight per cent of direct financial management clients at 30 June 2022 were low-wealth and eligible for fee subsidies. Private financial management services are resourced predominantly by client fees; government funding is not provided. Fees for both direct financial management and private management are capped by regulation.

On the other hand, guardianship services are funded entirely by government funding as an annual grant, with the objective of providing these services for free to the client.

NSW Trustee and Guardian has taken steps to try to capture data on the actual cost of providing guardianship and subsidised financial management services, and to estimate these costs in the absence of such data collection. However, system limitations have frustrated attempts to fully identify and quantify the costs of service provision, including the varying complexity of client needs and related staff effort. Without data on actual costs to serve, NSW Trustee and Guardian cannot confidently demonstrate that its guardianship and financial management expenses are efficient, or determine whether revenue - either from government funding or client fees - is sufficient to meet these costs. This is hampering its efforts to address a gap between the rate of growth in client numbers and complexity, and government funding for guardianship and subsidised direct financial management services.

Government funding for guardianship services and direct financial management services for low-wealth clients has not kept pace with the growth in clients. There is a risk that some fee-paying clients are unknowingly subsidising others

Under its enabling legislation, NSW Trustee and Guardian cannot decline to receive a guardianship or direct financial management client once the court or tribunal make relevant orders. It is intended to be a provider of 'last resort' where no other suitable person is willing or able to be the guardian or financial manager for a client. It also cannot decline to oversee a private financial manager.

Demand for guardianship and direct financial management services is growing. Over the five- year audit review period (FY2018-FY2022), there has been an eight per cent increase in the number of people who have the NSW Trustee as their financial manager, a 32% increase in the number of people who have private managers and a 46% increase in the number of people who have the Public Guardian as their guardian. NSW Trustee and Guardian data suggests the complexity of client circumstances has also grown over time, increasing the staff effort required on client matters.

The risk of cross-subsidisation arises when the revenue or income for a service (whether from fees, government funding or other sources) is less than the cost to provide the service. IPART found in a 2014 review that NSW Trustee and Guardian's fee structure across all its charged services at that time was resulting in significant cross-subsidies between services and between clients within each service. Such a gap remains evident with respect to NSW Trustee and Guardian's private management, direct financial management and guardianship services.

However, NSW Trustee and Guardian cannot determine whether high-wealth direct financial management clients are subsidising services for guardianship and low-wealth direct financial management clients or private management clients without data on the actual costs to serve each client. There is a risk that some clients of these or other NSW Trustee and Guardian services are unknowingly subsidising financial management or guardianship clients.

Cross-subsidisation is inequitable, inefficient and not aligned with NSW Treasury policy on government funding for non-commercial activities. NSW Trustee and Guardian has recognised this and repeatedly sought increased government funding for guardianship services, and subsidised direct financial management services, over the five-year audit review period.

NSW Trustee and Guardian has applied additional funding received in the 2021–22 Budget to increase frontline service delivery staff, but gaps in monitoring and continuing IT system constraints create a risk that it will not address service quality issues, nor be able to demonstrate the impact of this new funding

NSW Trustee and Guardian received a funding boost of $41.5 million across four years in the 2021–22 State Budget. The budget enhancement represented a significant increase in government funding for NSW Trustee and Guardian to provide free guardianship services and subsidised direct financial management services. Nevertheless, NSW Trustee and Guardian expects the budget enhancement will address immediate funding shortfalls for these services, but not those forecast to occur in the future on existing client growth and fee revenue trends.

NSW Trustee and Guardian has targeted the additional funding received in 2021–22 to improve adherence to its legislation through new operating models and a significant uplift in frontline staff numbers for guardianship and financial management services. Capital funding for IT system enhancements was not included in the additional funding allocated.

However, there is a risk that existing gaps in monitoring service quality, performance and consumer experiences - and continuing IT system constraints - could lead to increasing frontline staff numbers without also addressing key issues in service quality, or in being able to demonstrate impact from the budget enhancement in seeking future funding.


1 Some direct financial management clients are not subject to court or tribunal order, but are voluntary patients admitted to a mental health facility in accordance with the Mental Health Act 2007. NSW Trustee and Guardian may assume a financial management role if requested by the patient or, if the patient is under 18 years, a person with parental responsibility: NSW Trustee and Guardian Act 2009, s 53.

NSW Trustee and Guardian has only recently identified measures to track the performance of its financial management and guardianship services

Between 2021 and 2022, NSW Trustee and Guardian developed new divisional key performance indicators which aim to track the quality of services delivered to people under financial management and guardianship orders. These measures are reported quarterly to the organisation's executive leadership team. The divisions have started measuring some of these new performance indicators, but many will require changes to consumer engagement processes and IT legacy systems to collect additional data. At this stage it is unclear when these necessary changes will occur, and when relevant data will begin to be collected and analysed.

Before 2021, NSW Trustee and Guardian measured the performance of some of its financial management and guardianship operational processes. While these operational measures identify whether it is fulfilling some of its legislative functions, they are predominantly activity measures and do not inform on the quality of decision-making for direct financial management or guardianship clients, or on client experiences and outcomes.

Operational performance targets and measures have only recently been developed and used to centrally track the time elapsed between requests for certain decisions and the decisions made or relevant actions taken by relevant frontline staff. Baseline data for these measures show that target timeframes are not close to being met for minor medical decisions for people under guardianship orders, or for first customer payment, and redirection of income for people who are directly financially managed.

NSW Trustee and Guardian has proactively developed a benefits realisation framework to monitor the expected benefits from the additional funding received in 2021–22

NSW Trustee and Guardian has developed a benefits realisation framework to monitor the expected benefits from the additional funding (and other elements of the budget bid including increased fees and business improvements for efficiencies). This is not a requirement imposed by NSW Treasury, but a proactive step taken by NSW Trustee and Guardian to account for the use of the additional funding and to attempt to identify its impacts.

The benefits realisation framework includes interim and preferred measures, which reflect the things that can be tracked with existing data, and those that require new data collection, respectively. The measures are underpinned by separate program logics for direct and private financial management, and guardianship, and an overall investment logic. 'Logics' articulate the inputs, outputs and short/medium/long term outcomes expected from a project, program or investment, as well as the underpinning assumptions about how desired changes will occur (the 'mechanism' or 'theory' of change).

The targets and measures for NSW Trustee and Guardian's benefits realisation framework are the responsibility of the organisational divisions delivering guardianship and financial management services. The baseline data against which change will be measured is 30 June 2021, as the budget enhancement funds were allocated from 1 July 2021. The audit has been provided with baseline data, but not first year results (covering 2021–22) and as such, cannot assess whether any progress has been made towards the targets.

The benefits realisation framework may not provide the information needed to demonstrate the effectiveness of the budget enhancement

A lack of available data and limited measures in the benefits realisation framework may mean NSW Trustee and Guardian will not be able to meaningfully assess the impact of the additional funding.

The 22 measures in the benefits realisation framework across guardianship and financial management functions are predominantly monitoring activity and outputs which seek to track staff caseloads, the number of decisions made, the timeliness of key actions/tasks, and annual consumer engagements.

There is one service quality outcome measure: that customers, family and carers report an improved experience. The metrics for this measure will initially be monitored using the whole-of-government customer satisfaction measurement survey administered by the Department of Customer Service, until such time as other additional sources are developed. The whole-of-government survey is built around six core customer commitments relating to respondents' experiences with government services and staff - that they are: 'easy to access, act with empathy, respect my time, explain what to expect, resolve the situation and engage the community'. It is not clear whether or how the whole-of-government survey targets and engages people with impaired decision-making capacity or accessible communication needs.

Some measures in the NSW Trustee and Guardian benefits realisation framework do not yet have targets set, such as the ratio of the number of clients to the number of guardians or financial managers. Many relate to compliance with internal operational policies.

One interim measure for a direct financial management service indicator is 'increased personalised face-to-face consultations by phone or virtually'. It is intended to be replaced with the preferred measure 'ensure the client’s story is understood by staff and systems by consulting stakeholders and adding to the client’s story in the IT system'. However, the interim measure would better align with the national standards regarding regular and accessible engagement (discussed above).

A lack of availability of key data to track the preferred measures was identified by NSW Trustee and Guardian as an enterprise risk, and issues with existing data collected were identified early on, including that:

  • data can be entered into systems inconsistently by staff
  • current systems mask some issues – for example, a task can be completed within internal timeframes but not reflect the actual waiting time of consumers
  • current systems cater to measuring outputs rather than service quality.

IT system improvements are slated in order to allow data to be collected to inform on preferred measures, but these depend on capital funding that has not yet been secured. At the time of writing, data sources were yet to be identified for three of the 22 measures, and NSW Trustee and Guardian did not have staff trained and available to run and analyse data for the benefits realisation framework.

The mechanisms of change and the underlying assumptions in the program and investment logics are also not clearly articulated in the benefits realisation framework, and nor is the underpinning evidence (such as from earlier reviews, research or pilots, or experiences elsewhere). Identifying and evidencing these would give some confidence that the assumptions are sound and that the mechanisms of change will operate as expected (for example, that a decline in frontline staff caseloads will translate into more time spent on individual matters, and improved service quality).

Given these limitations in measures, data collection and logics, there is a risk that the benefits realisation framework may not provide the performance and impact evidence necessary to assess the effectiveness of the budget enhancement, or to justify further additional funding in the future.

NSW Trustee and Guardian cannot track its financial management and guardianship service performance over time

NSW Trustee and Guardian's operational performance activity measures have changed over the audit review period, which limits NSW Trustee and Guardian’s ability to identify whether it has sustained or improved performance in its guardianship and financial management services over time.

NSW Trustee and Guardian has consistently tracked the number and themes of complaints about financial management and guardianship services, which do provide some insight into service quality and experiences. However, this is an incomplete measure as people under financial management and guardianship orders are a more vulnerable cohort than other NSW Trustee and Guardian customers and may require support to make a complaint. There is also a structural power imbalance between clients and their guardian or financial manager which may dissuade clients and their stakeholders from raising concerns. Therefore, it is not clear whether the numbers and themes in complaints received are representative of broader experiences.

Appendix one – Response

Appendix two – Client characteristics

Appendix three – Easy English, Easy Read and Plain English formats

Appendix four – Financial management fees

Appendix five – NSW Trustee and Guardian Common Funds

Appendix six – About the audit

Appendix seven – Performance auditing

 

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

 

Parliamentary reference - Report number #379 - released 18 May 2023

Published

Actions for Coordination of the response to COVID-19 (June to November 2021)

Coordination of the response to COVID-19 (June to November 2021)

Premier and Cabinet
Community Services
Health
Justice
Whole of Government
Internal controls and governance
Risk
Service delivery
Shared services and collaboration

What the report is about

This audit assessed the effectiveness of NSW Government agencies’ coordination of the response to COVID-19, with a focus on the Delta variant outbreak in the Dubbo and Fairfield Local Government Areas (LGA) between June and November 2021. We audited five agencies - the Department of Premier and Cabinet, NSW Health, the NSW Police Force, Resilience NSW and the Department of Customer Service.

The audit also considered relevant planning and preparation activities that occurred prior to June 2021 to examine how emergency management and public health responses learned from previous events.

What we found

Prior to Delta, agencies developed capability to respond to COVID-19 related challenges.

However, lessons learned from prior reviews of emergency management arrangements, and from other jurisdictions, had not been implemented when Delta emerged in June 2021. As a result, agencies were not as fully prepared as they could have been to respond to the additional challenges presented by Delta.

Gaps in emergency management plans affected agencies' ability to support individuals, families and businesses impacted by restrictions to movement and gathering such as stay-at-home orders. In LGAs of concern, modest delays of a few days had a significant impact on people, especially those most vulnerable.

On 23 July 2021, the NSW Government established a cross-government coordinating approach, the Delta Microstrategy, which complemented existing emergency management arrangements, improved coordination between NSW Government agencies and led to more effective local responses.

Where possible, advice provided to government was supported by cross-government consultation, up-to-date evidence and insights. Public Health Orders were updated as the response to Delta intensified or to address unintended consequences of previous orders. The frequency of changes hampered agencies' ability to effectively communicate changes to frontline staff and the community in a rapidly evolving situation.

The NSW Government could provide greater transparency and accountability over decisions to apply Public Health Orders during a pandemic.

What we recommended

The audit made seven recommendations intended to improve transparency, accountability and preparedness for future emergency events.

This audit assessed the effectiveness of NSW Government agencies’ coordination (focused on the Department of Premier and Cabinet, NSW Health, the NSW Police Force, Resilience NSW and the Department of Customer Service) of the COVID-19 response in selected Local Government Areas (Fairfield City Council and Dubbo Regional Council) between June and November 2021.

As noted in this report, Resilience NSW was responsible for the coordination of welfare services as part of the emergency management arrangements. On 16 December 2022, the NSW Government abolished Resilience NSW.

During the audited period, Resilience NSW was tasked with supporting the needs of communities subject to stay-at-home orders or stricter restrictions and it provided secretariat support to the State Emergency Management Committee (SEMC). The SEMC was, and remains, responsible for the coordination and oversight of emergency management policy and preparedness.

Our work for this performance audit was completed on 15 November 2022, when we issued the final report to the five audited agencies. While the audit report does not make specific recommendations to Resilience NSW, it does include five recommendations to the State Emergency Management Committee. On 8 December 2022, the then Commissioner of Resilience NSW provided a response to the final report, which we include as it is the formal response from the audited entity at the time the audit was conducted.

The community of New South Wales has experienced significant emergency events during the past three years. COVID-19 first emerged in New South Wales after bushfire and flooding emergencies in 2019–20. The pandemic is now into its third year, and there have been further extreme weather and flooding events during 2021 and 2022.

Lessons taken from the experience of these events are important to informing future responses and reducing future risks to the community from emergencies.

This audit focuses on the NSW Government's response to the COVID-19 pandemic, and in particular, the Delta variant (Delta) that occurred between June and November 2021. The response to the Delta represents six months of heightened challenges for the NSW Government.

Government responses to emergencies are guided by legislation. The State Emergency and Rescue Management Act 1989 (SERM Act) establishes emergency management arrangements in New South Wales and covers:

  • coordination at state, regional and local levels through emergency management committees
  • emergency management plans, supporting plans and functional areas including the State Emergency Management Plan (EMPLAN)
  • operations centres and controllers at state, regional and local levels.

This audit focuses on the activities of five agencies during the audit period:

  • The NSW Police Force led the emergency management response and was responsible for coordinating agencies across government in providing the tactical and operational elements that supported and enhanced the health response to the pandemic. The NSW Police Force also led the compliance response which enforced Public Health Orders and included household checks on those required to isolate at home after testing positive to COVID-19. In some parts of NSW, they were supported by the Australian Defence Force in this role.
  • NSW Health was responsible for leading the health response which coordinated all parts of the health system, initially to prevent, and then to manage, the pandemic.
  • Resilience NSW coordinated welfare services as part of the emergency management arrangements and provided secretariat support to the State Emergency Management Committee (SEMC). The SEMC is responsible for the coordination and oversight of emergency management policy and preparedness. Resilience NSW was also tasked with supporting the needs of communities subject to stay-at-home orders or stricter restrictions.
  • The Department of Customer Service (DCS) was responsible for the statewide strategic communications response.
  • The Department of Premier and Cabinet (DPC) held a key role in providing policy and legal services, as well as supporting the coordination of activity across a range of functional areas and decision-making by our State’s leaders.

This audit assessed the effectiveness of NSW Government agencies’ coordination (focused on the Department of Premier and Cabinet, NSW Health, the NSW Police Force, Resilience NSW and the Department of Customer Service) of the COVID-19 response in selected Local Government Areas (LGA) (Fairfield City Council and Dubbo Regional Council) after June 2021.

The audit investigated whether:

  • government decisions to apply LGA-specific Public Health Orders were supported by effective crisis management governance and planning frameworks
  • agencies effectively coordinated in the communication (and enforcement) of Public Health Orders.

While focusing on the coordination of NSW Government agencies’ response to the Delta variant in June through to November 2021, the audit also considered relevant planning and preparation activities that occurred prior to June 2021 to examine how emergency management and public health responses learned from previous events.

This audit does not assess the effectiveness of other specific COVID-19 responses such as business support. It refers to the preparedness, planning and delivery of these activities in the context of supporting communities in selected LGAs. NSW Health's contribution to the Australian COVID-19 vaccine rollout was also subject to a separate audit titled 'New South Wales COVID-19 vaccine rollout' tabled in NSW Parliament on 7 December 2022. 

This audit is part of a series of audits which have been completed, or are in progress, regarding the New South Wales COVID-19 emergency response. The Audit Office of New South Wales '2022–2025 Annual Work Program' details the ongoing focus our audits will have on providing assurance on the effectiveness of emergency responses.

In this document Aboriginal refers to the First Nations peoples of the land and waters now called Australia, and includes Aboriginal and Torres Strait Islander peoples.

Conclusion

Prior to June 2021, agencies worked effectively together to adapt and refine pre-existing emergency management arrangements to respond to COVID-19. However, lessons learned from prior reviews of emergency management arrangements, and from other jurisdictions, had not been implemented when Delta emerged in June 2021. As a result, agencies were not as fully prepared as they could have been to respond to the additional challenges presented by Delta.

In the period March 2020 to June 2021, the State's Emergency Management (EM) arrangements coordinated the New South Wales emergency response to COVID-19 with support from the Department of Premier and Cabinet (DPC) which led the cross-government COVID-19 Taskforce. NSW Government agencies enhanced the EM arrangements, which until then had typically been activated in response to natural disasters, to meet the specific circumstances of the pandemic.

However, the State Emergency Management Committee (SEMC), supported by Resilience NSW, did not address relevant recommendations arising from the 2020 Bushfires Inquiry before June 2021 and agencies did not always integrate lessons learned from other jurisdictions or scenario training exercises into emergency management plans or strategies before Delta. As a result, deficiencies in the EM arrangements, including representation of vulnerable communities on EM bodies, well-being support for multicultural communities in locked down environments and cross-agency information sharing, persisted when Delta emerged in June 2021.

It should be noted that for the purposes of this audit there is no benchmark, informed by precedent, that articulates what level of preparation would have been sufficient or proportionate. However, the steps required to address these gaps were reasonable and achievable, and the failure to do so meant that agencies were not as fully prepared as they could have been for the scale and escalation of Delta’s spread across the State.

The Delta Microstrategy complemented the EM arrangements to support greater coordination and agencies are working to improve their capability for future events

The Delta Microstrategy (the Microstrategy) led to innovations in information sharing and collaboration across the public service. Agencies involved in the response have completed, or are completing, reviews of their contribution to the response. That said, none of these reviews includes a focus on whole-of-government coordination.

On 23 July 2021, the NSW Government approved the establishment of the Microstrategy to respond to the additional challenges presented by Delta including the need to support communities most impacted by restrictions to movement and gathering in the LGAs of concern. An extensive range of government agencies were represented across eight Microstrategy workstreams, which coordinated with the existing EM arrangements to deliver targeted strategies to communities in high-risk locations and improve data and information sharing across government. This enhanced the public health, compliance, income and food support, communications and community engagement aspects of the response.

Agencies also leveraged learnings from early weeks of the Delta wave and were able to replicate those lessons in other locations. The use of pre-staging hubs in Fairfield to support food and personal hamper distribution was used a month later in Dubbo which acted as a central hub for more remote parts of the State.

Emergency management plans did not enable government to respond immediately to support vulnerable communities in high-risk LGAs or regional NSW

There are gaps in the emergency management plans relating to the support for individuals, families and businesses impacted by the stay-at-home orders and other restrictions to movement and gathering. These gaps affected agencies' ability to respond immediately when the need arose during Delta.

Emergency management plans and supporting instruments did not include provision for immediate relief for households, which meant arrangements for isolation income support and food security measures had to be designed in the early stages of Delta before it could be approved and deployed.

There were delays – sometimes only days, on occasion, weeks - in providing support to affected communities. In particular, there were delays to the provision of income support and in scaling up efforts to coordinate food and grocery hampers to households in isolation. In LGAs of concern, modest delays of a few days had a significant impact on people, especially those most vulnerable.

Although government issued stricter restrictions for workers in the Fairfield LGA on 14 July 2021, it only approved targeted income support for people in LGAs of concern on 16 August 2021.

Overall, agencies coordinated effectively to provide advice to government but there are opportunities to learn lessons to improve preparedness for future events

Agencies coordinated in providing advice to government. The advice was supported by timely public health information, although this was in the context of a pandemic, where data and information about the virus and its variants was changing regularly. However, agencies did not always consider the impact on key industries or supply chains when they provided advice to government, which meant that Public Health Orders would sometimes need to be corrected.

Public Health Orders were also updated as the response to Delta intensified or to address unintended consequences of previous orders. The frequency of changes hampered agencies' ability to effectively communicate changes to frontline staff and the community in a rapidly evolving situation.

The audit identified several occasions where there were delays, ranging from three to 21 days, between the provision of advice to government and subsequent decision-making (which we have not detailed due to the confidentiality of Cabinet deliberations). Agency officers advised of instances where they were not provided sufficient notice of changes to Public Health Orders to organise local infrastructure (such as traffic support for testing clinics) to support compliance with new requirements.

The COVID-19 pandemic arrived in Australia in late January 2020 as the bushfire and localised flooding emergencies were in their final stages. Between 2020 and mid-2021, agencies responded to the initial variants of COVID-19, managed a border closure with Victoria that lasted nearly four months and dealt with localised ‘flare-ups’ that required postcode-based restrictions on mobility in northern parts of Sydney and regional New South Wales. During this period, New South Wales had the opportunity to learn from events in Victoria which imposed strict restrictions on mobility across the State and the growing emergence of the Delta variant (Delta) across the Asia Pacific.

This section of the report assesses how emergency management and public health responses adapted to these lessons and determined preparedness for, and responses to, widespread community transmission of Delta in New South Wales.

The previous chapter discusses how agencies had refined the existing emergency management arrangements to suit the needs of a pandemic and describes some gaps that were not addressed. This chapter explores the first month of Delta (mid-June to mid-July 2021). It explores the areas where agencies were prepared and responses in place for the outbreak. It also discusses the impact of the gaps that were not addressed in the period prior to Delta and other issues that emerged.

NSW Health provided advice on the removal of restrictions based on up-to-date advice

The NSW Government discussed the gradual process for removing restrictions using the Doherty Institute modelling provided to National Cabinet on 10 August 2021. NSW Health highlighted the importance of maintaining a level of public health and safety measure bundles to further suppress case numbers. This was based on additional modelling from the Doherty Institute.

The Department of Regional NSW led discussion and planning around reopening with a range of proposal through August and September 2021. The Department of Premier and Cabinet and NSW Health jointly developed a paper to provide options on the restrictions when the State reached a level of 70% double dose vaccinations.

The roadmap to reopening was originally published on 9 September 2021. However, by 11 October 2021, the restrictions were relaxed when the 70% double dose threshold was reached to allow:

  • up to ten fully vaccinated visitors to a home (increased from five)
  • up to 30 fully vaccinated people attending outdoor gatherings (increased from 20)
  • weddings and funerals limits increased to 100 people (from 50)
  • the reopening of indoor pools for training, exercise and learning purposes only.

On the same day, the NSW Government announced further relaxation of restrictions once the 80% double dose threshold was reached. These restrictions were further relaxed on 8 November 2021. This included the removal of capacity restrictions to the number of visitors to a private residence, indoor pools to reopen for all purposes and density limits of one person for every two square metres, dancing allowed in nightclubs and 100% capacity in major stadia.

The NSW Government allowed workers in regional areas who received one vaccination dose to return to their workplace from 11 October 2021.

The Premier extended the date of easing of restrictions for unvaccinated people aged over 16 from 1 December to 15 December 2021.

Many agencies have undertaken reviews of their response to the Delta outbreak but a whole-of-government review has yet to be conducted

Various agencies and entities associated with the response to the Delta outbreak conducted after-action review processes. These processes assessed the achievements delivered, lessons learned and opportunities for improvement. However, a whole-of-government level review has not been conducted. This limits the New South Wales public service's ability to improve how it coordinates responses in future emergencies.

The agencies/entities that conducted reviews included:

  • South West Metropolitan region, Western NSW region, Fairfield Local Emergency Management Committee (LEMC), Dubbo Local Emergency Operations Controller (LEOCON), which were collated centrally by the State Emergency Operations Centre (SEOC)
  • Aboriginal Affairs NSW assessed representation and relevance of the emergency management arrangements for Aboriginal communities following the 2019 bushfires
  • Resilience NSW developed case studies to capture improved practice with regard to food security and supply chains
  • a community support and empowerment-focused after-action review undertaken by the Pillar 5 workstream of the Microstrategy.

Key lessons collated from the after-action reviews include:

  • the impact of variation in capability across agencies on the management of key aspects of the response including welfare support and logistics
  • issues with boundary differences between NSW Police Force regions, local government areas (LGA and local health districts (LHD) caused issues in delivering and coordinating services in an emergency situation 
  • the need to improve relationships between state and local Government outside of acute emergency responses to improve service delivery 
  • issues arising from impediments to information sharing between agencies and jurisdictions, such as:
    • timeliness and accuracy of data used to direct compliance activities
    • the impact of insufficient advance notice on changes to Public Health Orders
    • timely access to data across public sector agencies and other jurisdictions to inform decision-making, analysis and communications
    • gaps in data around ethnicity, geolocation of recent positive cases and infection/vaccination rates in Aboriginal communities.
  • the lack of Aboriginal community representation on many LEMCs
  • compared with the response to COVID-19 in 2020, improved coordination of communications with Culturally and Linguistically Diverse (CALD) populations with a reduction in overlapping messages and over-communication
  • improved attendance from agency representatives in LEMCs, and regional emergency operations centres (REOC) to improve interagency communications, planning, capability development and community engagement issues
  • deficiencies in succession planning and fatigue management practices
  • the potential for REOC Welfare/Well-being subgroups to be included as part of the wider efforts to community needs during emergencies.

NSW Health commenced a whole of system review of its COVID-19 response in May 2022. At the time of writing, the completion due date for the debrief is 7 November 2022. This debrief is expected to explore:

  • governance
  • engagement 
  • innovation and technology 
  • community impact 
  • workforce impact
  • system impact and performance.

NSW Health is also undertaking a parallel Intra-Action Review that is focused on the public health aspects of the response with finalisation estimated for the end of November 2022. At the time of completing this performance audit report, NSW Health had not finalised these reviews and, as a result, we cannot validate their findings against our own observations.

Recent inquiries are likely to impact the governance of emergency management in New South Wales

In March 2022, the NSW Government established an independent inquiry to examine and report on the causes of, preparedness for, response to and recovery from the 2022 floods. The Flood Inquiry report made 28 recommendations, which the NSW Government supported in full or in principle. Some of the recommendations relate directly to the governance and leadership of emergency management arrangements in New South Wales. 

The State Emergency Management Committee (SEMC) will likely be involved in, and impacted by, the recommendations arising from the Flood Inquiry with potential changes to its membership and reshaping of functional areas and agencies. At the same time, the SEMC may have a role in overseeing the changes that emerge from the SEOC consolidated after-action reviews. This can also extend to ensuring local and regional bodies have incorporated the required actions. There is a risk that the recommendations from the pandemic-based after-action reviews may not be considered due to the priority of action resulting from the Flood Inquiry.

Furthermore, there is potential for the SEMC to work with NSW Health during its system-wide review. Such an approach is likely to improve preparedness for future events.

Appendix one – Response from agencies

Appendix two – Chronology 2020–2021

Appendix three – About the audit

Appendix four – Performance auditing

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

 

Parliamentary reference - Report number #371 - released 20 December 2022

Published

Actions for Audit Insights 2018-2022

Audit Insights 2018-2022

Community Services
Education
Environment
Finance
Health
Industry
Justice
Local Government
Premier and Cabinet
Planning
Transport
Treasury
Universities
Whole of Government
Asset valuation
Cross-agency collaboration
Compliance
Cyber security
Financial reporting
Fraud
Information technology
Infrastructure
Internal controls and governance
Management and administration
Procurement
Project management
Regulation
Risk
Service delivery
Shared services and collaboration
Workforce and capability

What the report is about

In this report, we have analysed the key findings and recommendations from our audit reports over the past four years.

This analysis includes financial audits, performance audits, and compliance audits of state and local government entities that were tabled in NSW Parliament between July 2018 and February 2022.

The report is framed by recognition that the past four years have seen significant challenges and emergency events.

The scale of government responses to these events has been wide-ranging, involving emergency response coordination, service delivery, governance and policy.

The report is a resource to support public sector agencies and local government to improve future programs and activities.

What we found

Our analysis of findings and recommendations is structured around six key themes:

  • Integrity and transparency
  • Performance and monitoring
  • Governance and oversight
  • Cyber security and data
  • System planning for disruption
  • Resource management.

The report draws from this analysis to present recommendations for elements of good practice that government agencies should consider in relation to these themes. It also includes relevant examples from recent audit reports.

In this report we particularly call out threats to the integrity of government systems, processes and governance arrangements.

The report highlights the need for balanced advice to government on options and risks, for transparent documentation and reporting of directions and decisions, and for early and open sharing of information with integrity bodies and audit.

A number of the matters highlighted in this report are similar to those described in our previous Insights Report, (Performance Audit Insights: key findings from 2014–2018) specifically in relation to cyber and information security, to performance measurement, reporting and evaluation, and system and workforce planning and capability.

Fast facts

  • 72 audits included in the Audit Insights 2018–2022 analysis
  • 4 years of audits tabled by the Auditor-General for New South Wales
  • 6 key themes for Audit Insights 2018–2022.

picture of Margaret Crawford Auditor-General for New South Wales in black dress with city skyline as backgroundI am pleased to present the Audit Insights 2018–2022 report. This report describes key findings, trends and lessons learned from the last four years of audit. It seeks to inform the New South Wales Parliament of key risks identified and to provide insights and suggestions to the agencies we audit to improve performance across the public sector.

The report is framed by a very clear recognition that governments have been responding to significant events, in number, character and scale, over recent years. Further, it acknowledges that public servants at both state and council levels generally bring their best selves to work and diligently strive to deliver great outcomes for citizens and communities. The role of audit in this context is to provide necessary assurance over government spending, programs and services, and make suggestions for continuous improvement.

A number of the matters highlighted in this report are similar to those described in our previous Insights Report, (Performance Audit Insights: key findings from 2014–2018) specifically in relation to cyber and information security, to performance measurement, reporting and evaluation, and system and workforce planning and capability.

However, in this report we particularly call out threats to the integrity of government systems, processes and governance arrangements. We highlight the need for balanced advice to government on options and risks, for transparent documentation and reporting of directions and decisions, and for early and open sharing of information with integrity bodies and audit. Arguably, these considerations are never more important than in an increasingly complex environment and in the face of significant emergency events and they will be key areas of focus in our future audit program.

While we have acknowledged the challenges of the last few years have required rapid responses to address the short-term impacts of emergency events, there is much to be learned to improve future programs. I trust that the insights developed in this report provide a helpful resource to public sector agencies and local government across New South Wales. I would be pleased to receive any feedback you may wish to offer.

Margaret Crawford
Auditor-General for New South Wales

Integrity and transparency Performance and monitoring Governance and oversight Cyber security and data System planning Resource management
Insufficient documentation of decisions reduces the ability to identify, or rule out, misconduct or corruption. Failure to apply lessons learned risks mistakes being repeated and undermines future decisions on the use of public funds. The control environment should be risk-based and keep pace with changes in the quantum and diversity of agency work. Building effective cyber resilience requires leadership and committed executive management, along with dedicated resourcing to build improvements in cyber security and culture. Priorities to meet forecast demand should incorporate regular assessment of need and any emerging risks or trends. Absence of an overarching strategy to guide decision-making results in project-by-project decisions lacking coordination. Governments must weigh up the cost of reliance on consultants at the expense of internal capability, and actively manage contracts and conflicts of interest.
Government entities should report to the public at both system and project level for transparency and accountability. Government activities benefit from a clear statement of objectives and associated performance measures to support systematic monitoring and reporting on outcomes and impact. Management of risk should include mechanisms to escalate risks, and action plans to mitigate risks with effective controls. In implementing strategies to mitigate cyber risk, agencies must set target cyber maturity levels, and document their acceptance of cyber risks consistent with their risk appetite. Service planning should establish future service offerings and service levels relative to current capacity, address risks to avoid or mitigate disruption of business and service delivery, and coordinate across other relevant plans and stakeholders. Negotiations on outsourced services and major transactions must maintain focus on integrity and seeking value for public funds.
Entities must provide balanced advice to decision-makers on the benefits and risks of investments. Benefits realisation should identify responsibility for benefits management, set baselines and targets for benefits, review during delivery, and evaluate costs and benefits post-delivery. Active review of policies and procedures in line with current business activities supports more effective risk management. Governments hold repositories of valuable data and data capabilities that should be leveraged and shared across government and non-government entities to improve strategic planning and forecasting. Formal structures and systems to facilitate coordination between agencies is critical to more efficient allocation of resources and to facilitate a timely response to unexpected events. Transformation programs can be improved by resourcing a program management office.
Clear guidelines and transparency of decisions are critical in distributing grant funding. Quality assurance should underpin key inputs that support performance monitoring and accounting judgements. Governance arrangements can enable input into key decisions from both government and non-government partners, and those with direct experience of complex issues.     Workforce planning should consider service continuity and ensure that specialist and targeted roles can be resourced and allocated to meet community need.
Governments must ensure timely and complete provision of information to support governance, integrity and audit processes.          
Read more Read more Read more Read more Read more Read more

 

This report brings together a summary of key findings arising from NSW Audit Office reports tabled in the New South Wales Parliament between July 2018 and February 2022. This includes analysis of financial audits, performance audits, and compliance audits tabled over this period.

  • Financial audits provide an independent opinion on the financial statements of NSW Government entities, universities and councils and identify whether they comply with accounting standards, relevant laws, regulations, and government directions.
  • Performance audits determine whether government entities carry out their activities effectively, are doing so economically and efficiently, and in accordance with relevant laws. The activities examined by a performance audit may include a selected program or service, all or part of an entity, or more than one government entity. Performance audits can consider issues which affect the whole state and/or the local government sectors.
  • Compliance audits and other assurance reviews are audits that assess whether specific legislation, directions, and regulations have been adhered to.

This report follows our earlier edition titled 'Performance Audit Insights: key findings from 2014–2018'. That report sought to highlight issues and themes emerging from performance audit findings, and to share lessons common across government. In this report, we have analysed the key findings and recommendations from our reports over the past four years. The full list of reports is included in Appendix 1. The analysis included findings and recommendations from 58 performance audits, as well as selected financial and compliance reports tabled between July 2018 and February 2022. The number of recommendations and key findings made across different areas of activity and the top issues are summarised at Exhibit 1.

The past four years have seen unprecedented challenges and several emergency events, and the scale of government responses to these events has been wide-ranging involving emergency response coordination, service delivery, governance and policy. While these emergencies are having a significant impact today, they are also likely to continue to have an impact into the future. There is much to learn from the response to those events that will help the government sector to prepare for and respond to future disruption. The following chapters bring together our recommendations for core elements of good practice across a number of areas of government activity, along with relevant examples from recent audit reports.

This 'Audit Insights 2018–2022' report does not make comparative analysis of trends in public sector performance since our 2018 Insights report, but instead highlights areas where government continues to face challenges, as well as new issues that our audits have identified since our 2018 report. We will continue to use the findings of our Insights analysis to shape our future audit priorities, in line with our purpose to help Parliament hold government accountable for its use of public resources in New South Wales.

Appendix one – Included reports, 2018–2022

Appendix two – About this report

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

Published

Actions for COVID-19: response, recovery and impact

COVID-19: response, recovery and impact

Community Services
Education
Health
Justice
Premier and Cabinet
Transport
Treasury
Whole of Government
Cross-agency collaboration
Financial reporting
Management and administration
Service delivery
Shared services and collaboration

What the report is about

This report draws together the financial impact of COVID-19 on the agencies integral to responses across the state government sector of New South Wales.

What we found

Since the COVID-19 pandemic hit NSW in January 2020, and until 30 June 2021, $7.5 billion was spent by state government agencies for health and economic stimulus. The response was largely funded by borrowings.

The key areas of spending since the start of COVID-19 in NSW to 30 June 2021 were:

  • direct health response measures – $2.2 billion
  • personal protective equipment – $1.4 billion
  • small business grants – $795 million
  • quarantine costs – $613 million
  • increases in employee expenses and cleaning costs across most agencies
  • vaccine distribution, including vaccination hubs – $71 million.

The COVID-19 pandemic significantly impacted the financial performance and position of state government agencies.

Decreases in revenue from providing goods and services were offset by increases in appropriations, grants and contributions, for health and economic stimulus funding in response to the pandemic.

Most agencies had expense growth, due to additional operating requirements to manage and respond to the pandemic along with implementing new or expanded stimulus programs and initiatives.

Response measures for COVID-19 have meant the NSW Government is unlikely to meet targets in the Fiscal Responsibility Act 2012 being:

  • annual expense growth kept below long-term average revenue growth
  • elimination of State’s unfunded superannuation liability by 2030.

 Fast facts

  • First COVID-19 case in NSW on 25 January 2020
  • COVID-19 vaccinations commenced on 21 February 2021
  • By 31 December 2021, 25.2 million PCR tests had been performed in NSW and 13.6 million vaccines administered, with 93.6% of the 16 and over population receiving two doses
  • During 2020–21, NSW Health employed an extra 4,893 full-time staff and incurred $28 million in overtime mainly in response to COVID-19
  • During 2020–21, $1.2 billion was spent on direct health COVID-19 response measures and $532 million was spent on quarantine for incoming international travellers

Section highlights

  • Up to 30 June 2021, $7.5 billion has been spent by state government agencies for health and economic stimulus.
  • Revenue increased for most agencies as falling revenue from providing goods and services was offset by additional funding from appropriations, grants and contributions.
  • Expenses increased as most agencies incurred additional costs to manage and respond to the pandemic along with delivering stimulus and support programs.
  • Borrowings of $7.5 billion over the last two years helped to fund the response to COVID-19.

Section highlights

  • NSW Government unlikely to meet targets in Fiscal Responsibility Act 2012.

Published

Actions for Police responses to domestic and family violence

Police responses to domestic and family violence

Community Services
Justice
Service delivery

What the report is about

This audit assessed whether the NSW Police Force has effective systems, processes, resources, and capability to respond to domestic and family violence events in New South Wales.

What we found

The NSW Police Force has almost doubled its domestic violence specialist workforce in the past five years and is conducting higher levels of risk monitoring to check that frontline police comply with domestic and family violence policing procedures.

However, a lack of workload monitoring at a whole of agency level is limiting the ability of the NSW Police Force to assess whether specialist and frontline police are sufficient to manage domestic and family violence demands across all 57 local commands.

Rates of compliance checking of domestic violence events vary across local commands, and there is a lack of system level policy or oversight to guide this activity.

While the NSW Police Force has structured training for probationary constables on domestic and family violence policing practices, it does not monitor training or skill levels of the broader workforce to understand levels of expertise in domestic violence policing.

The NSW Police Force does not have regular or consistent methods for seeking feedback and it has a limited understanding of its service quality from the perspective of victim survivors of domestic and family violence.

Performance reporting on domestic and family violence is limited, with most measures focused on activity counts rather than service quality or outcomes.

What we recommended

Improve workforce and workload data collections, analysis and reporting on domestic and family violence workload volumes and allocations of specialist and frontline police to meet demands.

Structure and resource the domestic and family violence strategic policy function to a level commensurate with workload volumes and risks associated with domestic violence policing.

Review debriefing protocols, procedures, and resources for police after domestic and family violence incidents.

Improve databases and information systems for recording domestic violence events so that related events and individuals are automatically connected.

Design a procedure to collect, collate, and analyse service user and stakeholder feedback about police responses to domestic and family violence.

Review existing activity measures and targets for domestic and family violence and expand to include performance measures, service quality measures and outcomes reporting.

Review the process for investigating allegations of domestic and family violence against current and former serving police personnel and implement procedures to ensure processes are independent of interested parties and mitigate conflicts of interest.

Fast facts

  • 140,000 calls to police each year for assistance in relation to domestic and family violence
  • 280 domestic violence specialist police in NSW
  • A 145% increase in police compliance checks of Apprehended Domestic Violence Orders from 2018 to 2020.

The NSW Police Force describes domestic and family violence as a significantly under-reported and complex crime that is mainly perpetrated by men in intimate partner relationships. It is a crime that can include one or more of the following behaviours: emotional and psychological abuse, intimidation, harassment, stalking, physical and sexual assault.

The NSW Police Force responds to over 140,000 domestic and family violence calls for assistance every year. This equates to one call every four minutes. According to NSW Bureau of Crime Statistics and Research statistics, the number and volume of domestic and family violence crime types have increased from October 2016 to September 2021.

The NSW Police Force's responses to domestic and family violence are prescribed in legislation and its own procedural guidance. Principally, the NSW Police Force is required to:

  • investigate incidents of domestic and family violence
  • take out Apprehended Domestic Violence Orders on behalf of victims and children
  • provide safety and support to victims, including taking offenders away from victims
  • place alleged perpetrators before the courts
  • investigate breaches of Apprehended Domestic Violence Orders and target repeat offenders
  • work with local service providers to reduce incidents of domestic and family violence.

Domestic and family violence incident dispatches are attended by general duties police – also described in this report as frontline police.

The objective of this audit was to assess the effectiveness of the NSW Police Force in responding to domestic and family violence. To do this, we assessed whether the NSW Police Force:

  • conducts capability planning to ensure its workforce can effectively respond to domestic and family violence incidents and support victim-survivors
  • resources its workforce with the required systems, skills, knowledge, and administrative support to monitor, record and respond to domestic and family violence events
  • assesses the effectiveness of police responses to domestic and family violence events and the effectiveness of support for victim-survivors.
Where to get help

If you or someone you know is experiencing violence or abuse, you can contact 1800 RESPECT (1800respect.org.au or 1800 737 732).

Conclusion

The NSW Police Force has almost doubled its domestic violence specialist workforce in the past five years. This has enabled higher levels of risk monitoring, and increased levels of support for general duties frontline police. However, a lack of workforce and workload monitoring at the system level, has limited the ability of the NSW Police Force to assess whether specialist and frontline police are sufficient in numbers to manage workload demands in all local commands.

The NSW Police Force does not measure the types or categories of police work that constitute the workload profiles of general duties frontline police. This limits the ability of the NSW Police Force to understand the proportion of police time that is spent managing domestic and family violence incidents and allocate resources accordingly.

While the NSW Police Force has increased the numbers of specialist domestic violence personnel, it lacks accurate data to assess whether the distribution of specialist personnel is adequate in number to support workload volumes across the different local commands. The NSW Police Force is currently expanding its use of a workforce modelling tool - Capacity Planning for Policing. This tool has the functionality to assess the distribution of the police workforce against incident dispatches by crime type, and other workload metrics.

There is potential for the NSW Police Force to use this tool to take a more proactive approach to domestic and family violence workforce planning. This could include enhanced monitoring and reporting of the domestic and family violence incident dispatches in each local command, and the levels of domestic violence specialist staff in these commands. Enhanced data reporting will assist local commanders to assess their staffing levels against crime statistics, compare to commands with similar activity levels, and ensure that staffing allocations are appropriate for workload demands.

The NSW Police Force has dedicated additional resources to improve the levels of monitoring of police compliance with domestic and family violence policing procedures. However, rates of compliance checking of domestic violence events vary across local commands, and there is a lack of system level policy or oversight to guide this activity.

The NSW Police Force has enhanced its quality control measures to improve domestic violence policing through a range of checking mechanisms to monitor compliance with standard operating procedures. However, there is significant variability in the levels of compliance checking across local commands and no system level data about the levels of quality assurance across commands. Some commands attempt to check 100% of domestic violence events, while others check far fewer, depending on their local workload requirements. The NSW Police Force does not provide advice about what constitutes minimum or optimal levels of compliance checking, and there is no centralised reporting on this activity.

The NSW Police Force provides a structured training program for probationary constables on domestic and family violence policing but does not monitor the training or skill levels of the broader workforce. This limits the ability of NSW Police Force managers to understand whether the workforce has the required skills and knowledge in this area.

During pre-service training probationary constables are provided with procedural knowledge and a structured skill development program in preparation for domestic and family violence policing. They develop further proficiency and skills through mentoring and on the job experience.

The NSW Police Force has processes to ensure that probationary police officers are monitored and mentored in domestic violence procedures and practices. However, it is unable to ensure that the broader workforce is completing targeted professional development to improve and update skills and knowledge levels over time. The NSW Police Force does not consistently assess workforce capabilities or gaps in workforce skills and knowledge about domestic violence policing. 

The NSW Police Force does not have regular or consistent methods for seeking feedback from service users. As a result, it has a limited understanding of its service quality from the perspective of victim-survivors of domestic and family violence.

The NSW Police Force is guided by its Domestic and Family Violence Code of Practice and Customer Service Guidelines to provide 'timely and appropriate victim support and referral'. These guidelines require victim follow-up within seven days of an incident where an offence is detected. The NSW Police Force has limited information to understand whether it is complying with these requirements for domestic violence incidents.

The NSW Police Force is not able to separate complaints about domestic and family violence service quality from other complaints. While the NSW Police Force participates in forums where it can receive feedback from stakeholder groups, there remains the risk that processes are not systematised, and are dependent on the commitment of local commands.

Police participation in Aboriginal and Torres Strait Islander feedback forums show significant variability in the levels of engagement across police regions. Through its Multicultural Plan, the NSW Police Force collects information about culturally and linguistically diverse communities. However, reporting is not specific to domestic violence, and only occurs every four years.

Performance reporting on domestic and family violence is limited, with most measures focused on activity counts rather than service quality or outcomes. Six of the seven NSW Police Force indicators for domestic and family violence are counts of incident types, rather than measures of police performance or outcomes.

Appendix one – Response from agency 

Appendix two – Workload and workforce numbers in 2020–21 supporting Exhibits 4, 6 and 7 

Appendix three – Key NSW Police Force initiatives, July 2016–present 

Appendix four – About the audit 

Appendix five – Performance auditing 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

 

Parliamentary reference - Report number #363 - released 4 April 2022.

Published

Actions for Responses to homelessness

Responses to homelessness

Community Services
Justice
Management and administration
Project management
Service delivery

What the report is about

The report assessed how effectively the Department of Communities and Justice is responding to homelessness through the NSW Government’s Homelessness Strategy.

It also assessed the effectiveness of the department’s efforts to address street homelessness in its COVID-19 response.

What we found

The strategy was designed to build evidence to inform future state-wide action rather than to end homelessness.

The department received significantly less funding than it sought for the strategy.

Actions delivered under the strategy have a narrow reach in terms of locations and number of people targeted for assistance.

The strategy will have limited short-term impact on homelessness across NSW, but it is building evidence on what works to prevent and reduce homelessness.

The department effectively implemented a crisis response to assist over 4,350 people sleeping rough into temporary accommodation during the pandemic.

While there was an effective crisis response to assist people sleeping rough during the pandemic, more will need to be done to ensure a sustainable response which prevents people returning to homelessness.

What we recommend

The department should:

  • provide advice to the NSW Government on sustainably addressing demand and unmet need for homelessness supports
  • commence development of a comprehensive strategy to address homelessness, linked to the government’s 10-year plan for social housing and 20-year housing strategy
  • enable input to key decisions on homelessness policy from partner agencies, the specialist homelessness services sector, the community housing sector, Aboriginal people, and people with lived experience of homelessness
  • partner with Aboriginal stakeholders and communities to design and implement a strategy for early identification and responses to the needs of Aboriginal people vulnerable to homelessness; and build the capacity and resourcing of the Aboriginal Community Controlled Sector to deliver homelessness services
  • evaluate the homelessness response to COVID-19, integrate the lessons learned into future practice, and develop protocols to inform actions in future emergencies or disasters
  • regularly collect client outcomes data and feedback and use this to drive improvements to responses to homelessness.

Fast facts

Homelessness Strategy
  • $169m total additional and existing funding allocated to the strategy.
  • 22% of the number of people in NSW experiencing homelessness in 2016 may be supported by strategy actions.
COVID-19 response 1 April 2020 to 31 January 2021
  • 400 people sleeping rough in temporary accommodation were assisted with two year rentals and wrap around support packages.
  • 72% of people sleeping rough provided with temporary accommodation were estimated to have left with unknown housing outcomes.

Further information

Please contact Ian Goodwin, Deputy Auditor-General on 9275 7347 or by email.

Homelessness exists when a person does not have suitable accommodation alternatives. A person is considered to be experiencing homelessness if their current living arrangement:

  • is in a dwelling that is inadequate; or
  • has no tenure, or if their initial tenure is short and not extendable; or
  • does not allow them to have control of, and access to space for social relations.

The number of people experiencing homelessness in New South Wales increased by 37 per cent between the last two censuses, from 27,479 in 2011, to 37,715 in 2016. New South Wales recorded the largest increase of all the states and territories in both the number of people experiencing homelessness and in the homeless rate (from 40.8 to 50.4 persons per 10,000).

The NSW Government's primary service response to homelessness is crisis, temporary and transitional accommodation, and support services, funded at more than $1.0 billion over four years from 2018–19. These are ‘commissioned services’ delivered by non‑government organisations under contracts with the Department of Communities and Justice (the Department) and out of scope for this audit. We assessed how the Department manages contracts for specialist homelessness services in our 2019 audit 'Contracting non‑government organisations'.

The policy framework for the NSW Government's response to homelessness is the NSW Homelessness Strategy 2018–23 (the Strategy), which is examined in this audit. The Department is responsible for the development, implementation, monitoring and evaluation of the Strategy. The Strategy comprises 21 actions, ten of which directly target people at risk of, or already experiencing, homelessness through measures such as:

  • screening high school students for the risk of homelessness and providing supports
  • assisting vulnerable people to maintain their tenancies in social housing or the private rental market
  • providing purpose‑built social housing.

These ten actions comprise $160 million of the Strategy's $169 million funding.

In December 2019, the first evidence of the COVID‑19 virus emerged. People sleeping without shelter or in public places (sleeping rough) typically live in communal arrangements, with some having limited access to basic hygiene supplies or showering facilities. These factors may increase the risk of transmission of COVID‑19 amongst this population.

In response to the pandemic, the NSW Government provided additional funding for the Department to institute a range of actions aimed at preventing vulnerable people from becoming homeless, and people sleeping rough from contracting or transmitting the virus. These were informed by, but separate to, actions under the Homelessness Strategy.

This audit focused on the temporary accommodation provided to individuals experiencing street homelessness during the pandemic, and the new 'Together Home' program established in 2020 to transition people with experience or history sleeping rough from temporary accommodation into more sustainable longer‑term housing.

This audit assessed how effectively the Department is implementing the Homelessness Strategy and addressing street homelessness in its COVID‑19 response. In making this assessment, the audit examined whether the Department:

  • has effectively developed an evidence‑based Strategy and established supporting arrangements to implement it
  • is ensuring the Strategy is achieving its objectives and outcomes
  • is effectively supporting people sleeping rough into temporary accommodation during COVID‑19 and to transition into more sustainable longer‑term housing.

Conclusion

The $169 million Homelessness Strategy will have a limited short‑term impact on homelessness across New South Wales.

The Department designed the Strategy to build evidence to inform future state‑wide action rather than to end homelessness. The Department also received significantly less funding than it sought, and as a result, the Strategy's actions have a narrow reach in terms of the locations and the number of people targeted for assistance.

The Department has clearly communicated its aims to intervene early to prevent people from experiencing homelessness; to provide effective supports to people experiencing homelessness; and to create an integrated person‑centred system. While these objectives are clear, they are not being pursued state‑wide.

The Department recognised in its advice to government on Strategy resourcing that growing demand could not be met within current funding and housing supply, and that there was limited proof on effective preventative and early interventions in the available evidence base. Given the evidence threshold for new funding, the Department designed the Strategy to pilot approaches which help to identify the best prevention and early intervention measures for state‑wide roll out after the Strategy's five‑year term, subject to budget approval.

The Department received significantly less funding than it sought for the Strategy. It repurposed existing resources, dropped some proposed actions and scaled others down to fit within the final funding envelope. While seeking to demonstrate what works to prevent homelessness or intervene earlier, the Department directed 95 per cent of the final Strategy funding to concrete actions supporting people at risk of, or experiencing, homelessness.

The Department has put in place governance and operational arrangements which are supporting the implementation and evaluation of the Strategy, and it is broadly on track with reaching the target number of clients expected. The Department’s data shows that more than 4,100 people have received direct supports under Strategy actions. However, the reach of the Strategy remains constrained. Once fully implemented, most Strategy actions will be available in only a quarter of the state's local government areas, supporting around 8,200 people ‑ what equates to around 22 per cent of the number of people experiencing homelessness in New South Wales at the last census in 2016.

There is a risk that future funding will not be secured – and Strategy actions not continued or scaled up – if the evidence on effectiveness is incomplete, mixed or unclear when the Strategy concludes. This sits against a backdrop of increasing need for housing and homelessness supports in the state that may become more acute once the full economic impacts of the COVID‑19 pandemic are felt.

The Department effectively planned and implemented a crisis response to assist people sleeping on the streets during the COVID‑19 pandemic. The Department will need to do more to ensure a sustainable longer‑term response which prevents people returning to street homelessness.

The Department's crisis response focused on people sleeping rough due to the public health risk of COVID‑19 transmission amongst this group. Of the approximately 32,500 people provided with temporary accommodation between 1 April 2020 and 31 January 2021, 4,355 were sleeping rough. As at 13 May 2021, only one case of COVID‑19 had been detected to date among the individuals who received assistance. The Department advises that around one‑quarter of all those placed in temporary accommodation were assisted into social housing or private rental accommodation.

Within metropolitan Sydney, the Department established a dedicated team and contracted provider to connect people sleeping rough placed in hotels with support services, and to assist and monitor their transition to longer‑term housing. The Department’s data suggests that almost 38 per cent of the approximately 1,800 people who received this support were able to move to social housing or private rental accommodation. However, the Department did not track the housing outcomes for clients who were not provided with this support, or who were not engaged with housing or funded support services.

The Department offers supports to people in temporary accommodation to assist them in finding longer term housing, and it has a policy to not knowingly exit someone from temporary accommodation into homelessness. However, it does not track housing outcomes for every client if they do not engage with the Department's housing or funded support services.

The Department cannot precisely identify how many people sleeping rough assisted during COVID‑19 have returned to rough sleeping or other forms of homelessness. The Department’s data suggests that 72 per cent of the approximately 4,000 people sleeping rough assisted with temporary accommodation between April 2020 and April 2021 who exited left with an unknown housing outcome. The Department intends to conduct research in the future to better understand what happens to people who leave temporary accommodation without seeking further assistance.

The Department also has limited data to understand whether the enhanced temporary accommodation program was more effective in helping to connect participants with services and support them into stable accommodation, than previous approaches.

The Department extended an existing initiative for community housing providers to head lease properties in the private rental market and ensure support services for people who were sleeping rough before being assisted into enhanced temporary accommodation. As at April 2021, the Together Home program has assisted 400 people to obtain accommodation and supports for two years. However, the number of Together Home places is significantly less than what is required to provide housing for the more than 4,350 individuals who were sleeping rough prior to entering enhanced temporary accommodation.

The Department advises it is using a combination of ‘business‑as‑usual’ options to assist other people sleeping rough into stable accommodation where Together Home places are not available, including social and affordable housing and supported transitional accommodation. It also intends to secure longer‑term housing options for Together Home clients after the two‑year support ends. But it is not clear how it will overcome longstanding housing challenges to do so, given the complexity of needs amongst this client group, the limited availability of affordable rental properties and the existing scale of unmet need for social housing in New South Wales.

1. Key findings: the Homelessness Strategy

The Strategy's geographical and client reach is limited because it is building the evidence base on what works

The Department's objectives to intervene early, provide effective supports and create an integrated person‑centred system to address homelessness are clear, but are not being pursued state‑wide.

There were existing gaps in the available evidence which made it difficult for the Department to develop a holistic, state‑wide, long‑term solution to homelessness. Some of the actions under the Strategy have a degree of supporting evidence. Other actions are intended to generate evidence through pilots and by evaluating existing programs more robustly.

At least one Strategy action is available in each of the Department's 16 districts, and there are examples of the Department rolling out practice changes from Strategy pilots across the state. However, progress towards the Strategy aims is confined to pockets where actions are being trialled.

Once fully implemented, Strategy actions will be available in only a quarter of the state's 128 local government areas and will support approximately 8,200 people ‑ which equates to around 22 per cent of the number of people who were experiencing homelessness at the time of the last census in New South Wales in 2016 more than 37,000 people. This does not include the number of people at risk of homelessness.

A key gap in Strategy actions is addressing Aboriginal homelessness.

The Department received significantly less funding than sought and designed the Strategy to build the evidence base rather than eliminate homelessness

The Department could not meet the evidence threshold for a cost benefit analysis required by a Treasury business case, given the limited evidence available locally and internationally on what works to prevent homelessness or intervene earlier. The Department sought new, targeted investment to extend a small number of initiatives with proven effect, and to build the evidence base about other measures that work, rather than the quantum of funding required to end homelessness in New South Wales.

Even so, approved funding was significantly less than that sought by the Department. It repurposed existing resources, dropped some proposed actions and scaled others down to fit within the final funding envelope. It directed 95 per cent of the total Strategy funding to supports and accommodation for people at risk of or experiencing homelessness.

The Department intends to use the gathered data from implementation of the Strategy to expand effective prevention and early intervention measures after it concludes, subject to budget approval. It expects that, over time, these initiatives will reduce the demand for crisis services.

Actions may not be scaled up at the end of the Strategy's term, perpetuating the Strategy's limited reach and narrow impact on homelessness

The Department's approach of testing interventions and building the evidence base through the Strategy was well described and provided a clear rationale in its original advice to government. An evaluation framework has been designed to generate sufficient evidence on the overall Strategy and its individual actions for a cost benefit analysis to support a future budget bid.

The Department intends to use the findings from interim evaluation reports, due by September 2021, to determine the programs and pilots with promising evidence that should continue to the end of the Strategy term. It expects this to enable more qualitative and quantitative data to be available to the evaluations, as well as to support service continuity.

However, delays in delivery of some actions under the Strategy, and the time taken for outcomes to be achieved and show up in the data, will impact on the strength of the evidence available at the mid‑term and final Strategy evaluation points. This raises a risk that future funding for a comprehensive Strategy will not be secured ‑ and prevention and early intervention activities not continued or scaled up beyond pilot sites ‑ if the evidence on effectiveness is incomplete, mixed or unclear when the Strategy concludes.

Given its limited reach, even if the existing Strategy actions were retained, and no expansion occurred, it would continue to have a narrow impact on homelessness in New South Wales. This sits against a backdrop of increasing need for housing and homelessness supports in the state that may become more acute once the full economic impacts of the COVID‑19 pandemic are felt.

2. Key findings: the COVID‑19 response to homelessness

The Department effectively planned and implemented its homelessness response to the pandemic and reduced the risk of transmission of COVID‑19 for people sleeping rough

The Department's crisis response focused on people sleeping rough due to the public health risk of COVID‑19 transmission amongst this group.

The Department engaged with the specialist homelessness services sector from mid‑March 2020 to modify service delivery, advise on infection control and plan extra supports. It explored options with temporary accommodation providers to support self‑isolation for clients, and scaled up its assertive outreach patrols by staff, specialist caseworkers and health professionals to support people sleeping rough into crisis or temporary accommodation for safety.

The Minister directed the Department to address street homelessness in the COVID‑19 response using the Government’s second stage of stimulus funding. The Department procured hotel, motel or serviced apartment accommodation for 400 people who were sleeping rough, or unable to physically distance in large crisis accommodation centres, within a week of the ministerial direction, building on existing programs. The Department provided advice to the Minister on the need to adjust existing policy settings to meet the forecast demand for temporary accommodation services.

The Department secured additional temporary accommodation when and where it was required, to accommodate the number of people sleeping rough who wanted support. Between 1 April 2020 and 31 January 2021, the Department provided temporary accommodation to 32,158 individuals, of which 4,355 people were sleeping rough, totalling more than 70,000 nights of temporary accommodation and services.

The Department met regularly with NSW homelessness peak organisations and established a Taskforce involving other government agencies, peak organisations, and service providers, to assist in quickly executing the measure and resolving issues arising. The Taskforce built on existing collaborative arrangements in place to support cross‑sectoral coordination, enabling it to respond quickly to COVID‑19.

The Department worked with NSW Health and health providers to ensure its COVID‑19 response to homelessness was in line with health guidelines. As of May 2021, just one participant in the Department's enhanced temporary accommodation program had contracted COVID‑19.

The Department does not know how many people sleeping rough who were assisted with enhanced temporary accommodation have returned to homelessness

Within metropolitan Sydney, the Department established a specialist housing team, and contracted a non‑government provider, to connect people placed in hotels with support services, provide tailored support, and to assist and monitor their transition to longer‑term housing.

The Department’s data indicates that between May 2020 and 31 January 2021, over 1,800 people who had previously been sleeping rough had been engaged in this program, more than four times the expected client numbers. Almost half moved into further accommodation when they left the program, including people supported with longer‑term housing such as social housing, community leasing under the Together Home program, and private rental arrangements.

However, the Department did not track the housing outcomes for clients who were not provided with this support, or who disengaged from services. The Department advises that this would have required additional resourcing to do so.

The Department offers assistance to people in temporary accommodation to find longer term options, and has a policy to not knowingly exit someone from temporary accommodation into homelessness. However, it does not track housing outcomes for every client if they do not engage with the Department's housing or funded support services. It intends to conduct research in the future to better understand what happens to people who leave temporary accommodation without seeking further assistance from the Department.

The Department cannot identify precisely how many people sleeping rough who were assisted during COVID‑19 have returned to rough sleeping or other forms of homelessness. The Department’s data suggests that 72 per cent of the approximately 4,000 people formerly sleeping rough who left temporary accommodation between April 2020 and April 2021 left with an unknown housing outcome. This includes people who were not eligible for social housing, were stranded due to border closures, or who disengaged from the Department or funded support services.

The Department also has limited data to understand whether the enhanced temporary accommodation program was more effective in helping to connect participants with services and support them into stable accommodation, than previous approaches.

The Together Home program was established quickly to assist people into more permanent accommodation but will not meet demand as a standalone response

The Department established the Together Home program in September 2020 to provide longer‑term accommodation to people who were sleeping rough during the pandemic. Community housing providers head‑lease properties in the private rental market for two years and sub‑lease these to clients, while ensuring they receive additional support, such as health services, to help them maintain the lease.

Under the initial tranche of funding, the Together Home program aimed to support 400 people sleeping rough. This target was met by April 2021. Due to increased rental demand in many areas of the state, there were some delays in securing properties in certain areas. In addition, people on temporary visas, or with existing public housing debt, are ineligible for this program.

A further $29.0 million was provided to this program through the 2020–21 NSW Budget, creating 400 additional program places. However, the total number of 800 Together Home places will not be sufficient to provide housing for the more than 4,000 individuals who were sleeping rough prior to entering enhanced temporary accommodation.

The Department advises it is using a range of ‘business‑as‑usual’ options to assist other people sleeping rough into stable accommodation outside of the Together Home program. These options include social housing, supported transitional accommodation, subsidised private rental, boarding houses, and referral to mental health and substance addiction rehabilitation facilities.

The Department’s latest annual state‑wide street count suggested that the number of people sleeping rough across New South Wales decreased by 13 per cent between February 2020 and February 2021. The Department has acknowledged that it could do more to monitor and support the housing outcomes for people in temporary accommodation after they exit.

The Department has plans to secure longer‑term housing options for Together Home clients after the two‑year program, through commissioned community housing and private rental assistance. However, it is not clear how this will overcome existing housing challenges given the complexity of needs amongst this client group, the limited availability of affordable rental properties and the existing scale of unmet need for social housing.

3. Recommendations

By July 2022, the Department of Communities and Justice should:

  1. use data and analysis identified through the Homelessness Strategy 2018–2023 and provide advice to the NSW Government on sustainably addressing demand and unmet need for homelessness supports

  2. use the evidence obtained through the Homelessness Strategy 2018–2023 to commence development of a comprehensive strategy to address homelessness, linked to the government’s ten‑year plan for social housing and 20‑year housing strategy

  3. establish and sustain governance arrangements that enable input to key decisions on homelessness policy from partner agencies, the specialist homelessness services sector, the community housing sector, Aboriginal people and people with lived experience of homelessness

  4. in partnership with Aboriginal stakeholders and communities, design and implement a strategy for early identification and responses to the needs of Aboriginal people vulnerable to homelessness; and build the capacity and resourcing of the Aboriginal Community Controlled Sector to deliver homelessness services

  5. evaluate the homelessness response to COVID‑19 and integrate the lessons learned into future practice; and develop protocols to inform actions in future emergencies/disasters

  6. establish and sustain a means to regularly collect client outcomes data and feedback; and use this to drive improvements to responses to homelessness.

This chapter considers how effectively the NSW Homelessness Strategy was developed and is currently being implemented by the Department of Communities and Justice.

This chapter examines how effectively the Department of Communities and Justice addressed homelessness in its response to the COVID‑19 pandemic, and how well it is applying lessons learned from the pandemic to future policy and service development.

Appendix one – Response from agency

Appendix two – Actions within the NSW Homelessness Strategy 2018–23

Appendix three – Reported progress on Homelessness Strategy actions to date (unaudited)

Appendix four – Key homelessness data collections

Appendix five – Temporary accommodation for people sleeping rough standard practice vs COVID 19 response

Appendix six – Key measures in the COVID 19 response to homelessness

Appendix seven – About the audit

Appendix eight – Performance auditing

 

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

Parliamentary reference - Report number #350 - released (4 June 2021).

Published

Actions for Stronger Communities 2020

Stronger Communities 2020

Justice
Community Services
Asset valuation
Compliance
Financial reporting
Information technology
Internal controls and governance
Management and administration
Service delivery

This report analyses the results of our audits of financial statements of the agencies comprising the Stronger Communities cluster for the year ended 30 June 2020. The table below summarises our key observations.

1. Financial reporting

Quality of financial reporting Unqualified audit opinions were issued for all agencies' 30 June 2020 financial statements.
Compliance with financial reporting requirements

The Treasury extended the statutory deadline for the submission of the 2019–20 financial statements. For agencies subject to Treasurer's Directions, Treasury required agencies to submit their 30 June 2020 financial statements by 5 August 2020. For other agencies, the deadline was extended to 31 October 2020. All agencies in the cluster met the revised statutory deadlines.

Cluster agencies substantially completed the mandatory early close procedures set by NSW Treasury. However, nine agencies including the Department of Communities and Justice (the department) did not complete one or more mandatory requirements, such as assessing the impact of new and updated accounting standards.

Financial implications of recent emergencies

Emergency events significantly impacted cluster agencies in 2019–20. Our review of seven cluster agencies most affected highlighted some had incurred additional expenditure because of the bushfires and floods. Others lost revenue due to the COVID-19 pandemic.

During the year these agencies collectively received additional funding of $1.1 billion from the State to respond to:

  • increased demand for homeless people seeking temporary accommodation
  • additional cleaning requirements
  • bushfire recovery efforts
  • emergency support for eligible small businesses.

The Sydney Cricket Ground Trust, Venues NSW and Office of Sport lodged insurance claims of $51.3 million with the Treasury Managed Fund with respect to lost revenues from the pandemic. The losses were mainly due to event cancellations and covered various periods ranging from mid-March to 31 December 2020.

The change in economic conditions caused by the COVID-19 pandemic resulted in the NSW Government cancelling the refurbishment of Stadium Australia it had previously approved in August 2019. Venues NSW wrote off $16.8 million of redevelopment costs during 2019–20.

Restatement of the Sydney Cricket Ground valuation The valuation of the Sydney Cricket Ground (the Stadium) included costs of $28.6 million which were not eligible for capitalisation. The financial statements were restated to reflect the reduction in the value of the Stadium and the asset revaluation reserve.
Unresolved data quality issues in the VS Connect system

The department continues to address significant data quality issues resulting from its implementation of the VS Connect system (the System) in 2019. The issues relate to the completeness and accuracy of the data transferred from the legacy system. The System is used by the department to manage its Victims Support Services (VSS) and for financial reporting purposes.

An independent actuary helps the department estimate its liability for VSS claims. The actuary's valuation at 30 June 2020 was again impacted by the data quality issues. Consequently, the actuary adopted a revised valuation methodology compared to previous years.

Recommendation (repeat issue):

The department should resolve the data quality issues in the VS Connect System before 31 March 2021.

AASB 16 'Leases' resulted in significant changes to agencies' financial position

Cluster agencies implemented three new accounting standards for the first time in 2019–20. Adoption of AASB 16 'Leases' resulted in cluster agencies collectively recognising right-of-use assets and lease liabilities of $1.7 billion and $1.1 billion respectively on 1 July 2019.

Significant misstatements in how lease related balances had been calculated were found in 17 of the 29 cluster agencies. The cluster outsources the management of most of its owned and leased property portfolio to Property NSW, but cluster agencies remain responsible for any deliverables under that arrangement. The misstatements were mainly caused by late revisions of key assumptions and issues with the accuracy and completeness of Property NSW's lease information.

2. Audit observations

Internal control deficiencies

Our 2019–20 financial audits identified 191 internal control issues. Of these, two were high risk and almost one-third were repeat findings from previous audits. While repeat findings reduced by 5.7 percentage points in 2019–20, the number remains high.

Recommendation (repeat issue):

Cluster agencies should action recommendations to address internal control weaknesses promptly. Focus should be given to addressing high risk and repeat issues.

Agencies response to recent emergencies

The severity of the recent bushfires and floods meant natural disaster expenses incurred by emergency services agencies rose from $67.4 million in 2018–19 to $497 million in 2019–20.

The COVID-19 pandemic presented unprecedented challenges for the cluster. Social distancing and other infection control measures disrupted the traditional means of delivering services. Agencies established committees or response teams to respond to these challenges.

The department introduced measures to minimise the risk of the spread of COVID-19 amongst inmates in custodial settings.

Managing excess annual leave

Managing excess annual leave was a challenge for cluster agencies directly involved in the government's response to the emergency events. Employees in frontline cluster agencies deferred leave plans and many have taken little or no annual leave during the reporting period.

Annual leave liabilities rose at the department, NSW Police Force, Fire and Rescue NSW, Office of the NSW Rural Fire Service, the Legal Aid Commission of New South Wales and the Office of the Director of Public Prosecutions. The combined liabilities increased from $620 million to $692 million or 11.6 per cent between 30 June 2019 and 30 June 2020.

Implementation of Machinery of Government (MoG) changes

Administrative Arrangement Orders effective from 1 July 2019, created the department of Communities and Justice and transferred functions and staff, together with associated assets and liabilities into the department from the former departments of Justice and Family and Community Services.

The department continues to establish its governance arrangements following the MoG changes.

Recommendation:

The department should finalise appropriate governance arrangements for its new organisational structure as soon as possible. This includes:

  • harmonising policies and procedures to ensure a unified approach across the department
  • finalising risk management and monitoring processes across the department
  • updating its delegation instruments to reflect the current organisational structure, delegation limits and roles and responsibilities.
Delivery of the Prison Bed Capacity Program

The department continued to expand prison system capacity through the NSW Government's $3.8 billion Prison Bed Capacity Program. The department reported it spent $480 million on the Program in 2019–20. Six prison expansion projects were completed during the year, which added 1,660 new and 395 refurbished beds to the NSW prison system.

Data from the department shows the number of adult inmates in the NSW prison system reached a maximum of 14,165 during the year. Operational capacity was 16,096 beds on 19 August 2020.

 

This report provides parliament and other users of the financial statements of agencies in the Stronger Communities cluster with the results of our audits, our observations, analysis, conclusions and recommendations.

Agencies in the Stronger Communities cluster were significantly impacted by the bushfires, floods and the COVID-19 pandemic in 2019–20. Our 2019–20 financial audits of the seven cluster agencies most significantly impacted by the recent emergency events considered:

  • the financial implications of the emergency events
  • changes to agencies' operating models and control environments
  • delivery of new or expanded projects, programs or services at short notice.

Our findings on these seven agencies' responses to the recent emergencies are included throughout this report. These agencies are:

  • Department of Communities and Justice
  • Fire and Rescue NSW
  • NSW Police Force
  • Office of the NSW Rural Fire Service
  • Office of the NSW State Emergency Service
  • Sydney Cricket and Sports Ground Trust
  • Venues NSW.

The Department of Communities and Justice is the principal agency of the cluster. The names of all agencies in the Stronger Communities cluster are included in Appendix one.

Financial reporting is an important element of good governance. Confidence and transparency in public sector decision making are enhanced when financial reporting is accurate and timely.

This chapter outlines our audit observations related to the financial reporting of agencies in the Stronger Communities cluster for 2020, including any financial implications from the recent emergency events.

Section highlights

  • Unqualified audit opinions were issued for all agencies' 30 June 2020 financial statements. All agencies met the revised statutory deadlines for completing early close procedures and submitting their financial statements.
  • Emergency events significantly impacted cluster agencies in 2019–20. Agencies received additional funding of $1.1 billion to respond to the emergencies.
  • Cluster agencies implemented three new accounting standards in 2019–20. Adoption of AASB 16 'Leases' resulted in significant changes to agencies' financial statements.

Appropriate financial controls help ensure the efficient and effective use of resources and administration of agency policies. They are essential for quality and timely decision making.

This chapter outlines our:

  • observations and insights from our financial statement audits of agencies in the Stronger Communities cluster
  • assessment of how well cluster agencies adapted their systems, policies and procedures, and governance arrangements in response to recent emergencies
  • review of how the cluster agencies managed the increased risks associated with new programs aimed at stemming the spread of COVID-19 and stimulating the economy.

Section highlights

  • Almost one-third of internal control issues reported were repeat findings. Cluster agencies should address these issues more promptly.
  • The severity of the recent bushfires and floods meant natural disaster expenses incurred by emergency services agencies increased by $430 million in 2019–20.
  • The department continues to establish its governance arrangements following Machinery of Government changes effective 1 July 2019.

 

Appendix one – Timeliness of financial reporting by agency

Appendix two – Management letter findings by agency

Appendix three – List of 2020 recommendations 

Appendix four – Status of 2019 recommendations 

Appendix five – Selected agencies for review of response to emergency events 

Appendix six – Financial data 

 

Copyright notice

© Copyright reserved by the Audit Office of New South Wales. All rights reserved. No part of this publication may be reproduced without prior consent of the Audit Office of New South Wales. The Audit Office does not accept responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any of this material.

Published

Actions for Stronger Communities 2019

Stronger Communities 2019

Justice
Community Services
Compliance
Financial reporting
Internal controls and governance
Management and administration
Project management
Service delivery
Shared services and collaboration
Workforce and capability

A report has been released on the NSW Stronger Communities cluster.

From 1 July 2019, the functions of the former Department of Justice, the former Department of Family and Community Services and many of the cluster agencies moved to the new Stronger Communities cluster. The Department of Communities and Justice is the principal agency in the new Stronger Communities cluster.

The report focuses on key observations and findings from the most recent financial audits of agencies in the Stronger Communities cluster.

Unqualified audit opinions were issued on the financial statements for all agencies in the cluster.  

There were 157 audit findings on internal controls. Two of these were high risk and 59 were repeat findings from previous financial audits. ‘Cluster agencies should prioritise actions to address internal control weaknesses promptly with particular focus given to issues that are assessed as high risk’, the Auditor-General said.

The report notes that the NSW Government’s new workers' compensation legislation, which gave eligible firefighters presumptive rights to workers' compensation, cost emergency services agencies $180 million in 2018–19, mostly in increased premiums.

Download the PDF version of report

This report analyses the results of our audits of financial statements of the agencies comprising the Stronger Communities cluster for the year ended 30 June 2019. The table below summarises our key observations.

This report provides parliament and other users of the financial statements of agencies in the Stronger Communities cluster with the results of our audits, our observations, analyses, conclusions and recommendations in the following areas:

  • financial reporting
  • audit observations.

This cluster was significantly impacted by the Machinery of Government (MoG) changes on 1 July 2019. This report focuses on the agencies that from 1 July 2019, comprised the Stronger Communities cluster. The MoG changes moved some agencies from the clusters to which they belonged in 2018–19 to the Stronger Communities cluster. Conversely, the MoG also moved some agencies formerly in the Family and Community Services cluster and Justice cluster elsewhere. Please refer to the section on Machinery of Government changes for more details.

The Department of Communities and Justice is the principal agency of the cluster. The newly created department combines functions of the former Department of Justice and the Department of Family and Community Services.

Machinery of Government (MoG) refers to how the government organises the structures and functions of the public service. MoG changes occur when the government reorganises these structures and functions and those changes are given effect by Administrative Orders.

The MoG changes announced following the NSW State election on 23 March 2019 significantly impacted the Stronger Communities cluster through Administrative Changes Orders issued on 2 April 2019 and 1 May 2019. These orders took effect on 1 July 2019.

Section highlights

The 2019 MoG changes significantly impacted the former Justice and Family and Community Services (FACS) departments and clusters.

  • The Stronger Communities cluster combines most of the functions and agencies of the former Justice and FACS clusters from 1 July 2019.
  • The Department of Communities and Justice is now the principal agency in the new cluster.
  • The MoG changes bring new responsibilities, risks and challenges to the cluster.
  • A temporary office has been established by the Department of Communities and Justice to support the cluster in the planning, delivery and reporting associated with implementing the changes.

Financial reporting is an important element of good governance. Confidence and transparency in public sector decision making are enhanced when financial reporting is accurate and timely.

This chapter outlines our audit observations relating to the financial reporting of agencies in the Stronger Communities cluster for 2019.

Section highlights
  • Unqualified audit opinions were issued for all agencies' 30 June 2019 financial statements. However, further actions can be taken by some cluster agencies to enhance the quality of their financial reporting.
  • In November 2018, the Department of Justice implemented a new Victims Support Services system called VS Connect. Significant data quality issues arising from the VS Connect system implementation impacted the Department's ability to reliably estimate its Victims Support Scheme claims liabilities at 30 June 2019.
    We recommend the Department of Communities and Justice resolves the data quality issues in the new VS Connect System before 30 June 2020 and capture and apply lessons learned from recent project implementations, including LifeLink, Justice SAP and VS Connect, in any relevant future implementations.
  • Our audits found some cluster agencies needed to do more work on their impact assessments and preparedness to implement the new accounting standards, to minimise the risk of errors in their 2019–20 financial statements.
  • Cluster agencies with annual leave balances exceeding the State's target should further review their approach to managing leave balances.

Appropriate financial controls help ensure the efficient and effective use of resources and administration of agency policies. They are essential for quality and timely decision making.

This chapter outlines our observations and insights from our financial statement audits of agencies in the Stronger Communities cluster.

Section highlights

  • Cluster agencies should action recommendations to address internal control weaknesses promptly. Particular focus should be given to prioritising high risk issues. The 2018–19 financial audits of cluster agencies identified 157 internal control issues. Of these, two were high risk and 37.6 per cent were repeat findings from previous audits.
  • Data from the Department of Justice shows the inmate population reached a maximum of 13,798, compared to an operational capacity of 14,626 beds on 31 August 2019. This equates to an operational vacancy rate of 5.7 per cent, which is more than the recommended 5.0 per cent buffer. This is the first time the vacancy rate has exceeded the target over the last five years. Growth in the NSW prison population is being managed through the NSW Government's $3.8 billion Prison Bed Capacity Program.
  • In September 2018, the NSW Government introduced new workers' compensation legislation, which gives eligible firefighters presumptive rights to workers' compensation when diagnosed with one of 12 prescribed cancers. The new legislation cost emergency services agencies $180 million in 2018–19, mainly through additional workers' compensation premiums.

Appendix one – Timeliness of financial reporting by agency

Appendix two – Management letter findings by agency

Appendix three – List of 2019 recommendations 

Appendix four – Status of 2018 recommendations 

Appendix five – Cluster agencies 

Appendix six – Financial data 

 

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