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4. Enablers and barriers to implementation

Enablers and barriers to implementation in the Child Information Sharing Scheme Two-Year Review report.

This chapter considers the research question:

  • What are the key enablers and barriers to implementation of the CIS Scheme?

in the following contexts:

  • ISEs have the skills and knowledge to effectively implement the CIS Scheme
  • ISEs demonstrate increased participation in child information sharing
  • ISEs have delivered activities to enable practice change to appropriately share information under the CIS Scheme
  • ISEs’ implementation is true to the intent of the legislation and design of the CIS Scheme.

Box 4.1 Key findings – implementation enablers and barriers

  • Stakeholders have identified enablers and barriers to implementation of the CIS Scheme that relate to issues such as the anxiety of workers around privacy and confidentiality concerns, translation of policy into practice and understanding of child-focus practice.
  • Data on information sharing requests is thin and will need to improve for effective and ongoing monitoring of the child information reforms.
  • A number of strategies have been adopted by prescribed organisations and services to target culture change in support of effective implementation of the CIS Scheme. There is opportunity to better disseminate these innovative approaches to the potential advantage of Phase One and Phase Two prescribed workforces.
  • While there is a high level of understanding about the purpose of the CIS Scheme further work is required to embed practice.

Source: ACIL Allen Consulting 2020

4.1 Workforce skills and knowledge

Enablers

A wide range of enablers to effective implementation of the CIS Scheme through ensuring workforce skills and knowledge were cited by information sharing entities. These included:

  • Building workforce understanding of the legislative basis for information sharing to improve confidence in applying the CIS Scheme.
Legislation is the great enabler - the kind of thing that would give confidence to people to share; it needs to be emphasised more to cut through issues of privacy and consent to make things happen. Central experts to help but if you have quality managers to champion this change across the organisation it would be useful. Cultural shift to a default to share rather than think of privacy as the first concern. 'Can-do' approach - take the first step to share and work out what is necessary to be done. (Workshop participant)
Addressing existing ingrained attitudes to privacy and reassuring workers not only of their responsibilities but also their protection in relation to CIS Scheme. (Homelessness Services workforce survey respondent)
Learning to overcome the privacy and confidentiality principles. Trusting that all organisations are acting within the child’s best interests. (Homelessness Services workforce survey respondent)
Alignment of confidentiality policies to the CIS scheme and understanding when this applies. (Out-of-Home Care workforce survey respondent)
  • Having an identified person with responsibility for implementation of the Scheme (also see Box 3.2).
Allocated/dedicated person in charge of implementation - consistent information and useful to push the organisation. (Workshop participant)
  • Translation of policy into practice including alignment with other policies, frameworks and guiding principles.
Relationship between policy and practice areas within an organisation - ensuring that other relevant policies sit well with the CIS Scheme, e.g. Child safety policy. Translation of policy into practice manuals and documents that guide operations. (workshop participant)
  • Promotion of ongoing (experiential) learning through communities of practice.
Communities of practice for FVIS Scheme have been invaluable - how might this look for CIS Scheme or be used to promote ongoing education for CIS Scheme? (Workshop participant)

Barriers

Conversely, insights into barriers to effective implementation of the CIS Scheme because of a lack of workforce capability are provided by prescribed workforces responding to the follow up survey in 2020 about the main reason for not requesting information. This largely derives from insufficient knowledge of the CIS Scheme, and includes:

Unsure about the correct way to do so [apply the CIS Scheme]. (MCH workforce survey respondent)
Staff had still not participated in the training. (MCH workforce survey respondent)[21]
Agencies understanding of obligations. (Family Services workforce survey respondent)
Practice based skills development and confidence [needed]. Multiple workforces are still struggling to effectively implement CIS Scheme. (Alcohol and other Drugs (AOD) workforce survey respondent)
Please support and request that prescribed organisations develop their own practice-based workforce development strategy to promote embedding into practice; this is severely lacking across the board. (AOD workforce survey respondent)
Reminding other agencies that they can share. (MCH workforce survey respondent)

Other challenges experienced included:

  • lack of practice in applying a child-focus
The challenges include professional discomfort in information disclosure and the fear of legal repercussions for such newly required practice. The organisation, itself, has been challenged by the requirement to be involved in the scheme when its identity has historically been that of an adult patient facility. A very small number of families have been affronted by what they have seen as a betrayal of professional confidentiality. (Workforce survey respondent – ‘Other’-health related organisation)
There was a culture of protecting information, especially health information. Education was needed to change the culture from protecting the subject of the information to protecting the child by sharing information. (Workforce survey respondent – ‘Other’-justice related organisation)
  • lack of familiarity with the culture of other organisations
Understanding what to ask in a way the other organisation’s culture understands. (Workforce survey respondent - Family Violence Therapeutic Responses and Counselling)
  • privacy perceptions (also discussed under ‘Enablers’)
Literacy about the Scheme, and how it relates to other Schemes (FVIS Scheme) and Acts (Children Youth and Families Act 2005, Mental Health Act 2014, and privacy legislation). (Workforce survey respondent – Mental Health Services)
Needs work with AHPRA (psychologists and psychiatrists) regarding patient confidentiality legislation and policy. (Workshop participant)

Another limitation in supporting their workforce was the inability of organisations to track completion of the eLearning modules, only access to the external links as the information sharing eLearning was not embedded within the organisation’s own learning management system.

4.2 Increased participation in child information sharing

The extent to which prescribed organisations and services are actively participating in child information sharing is considered based on July 2020 reporting to the ISMARAM Steering Committee on monitoring of information sharing. The reporting is not consistent across departments but does provide some evidence of the implementation of the information sharing schemes by government services and funded organisations.

  • Department of Health and Human Services, Information Sharing Team (responsible for requests for information where there is no current Child Protection involvement)
    • A total of 603 information requests in 2019. This included 119 under the CIS Scheme, and 78 where requests were made under both the FVIS and CIS Schemes. This compares to 406 requests under the FVIS Scheme only for the same period.
    • A total of 516 requests in the first six months of 2020 with 119 requests under the CIS Scheme and 212 requests made under both the FVIS and CIS Schemes. This compares to 185 requests under the FVIS Scheme only.
    • The subject of most information requests related to a child victim survivor.
  • Victoria Police
    • Since implementation of the respective information sharing schemes, there has been 2,179 requests for information under the CIS Scheme and 4,372 under the FVIS Scheme.
    • Not all requests were shared. In some instances, voluntary shares were made in the context of an existing request.
  • Department of Justice and Community Safety, Justice Health
    • Where requests have been identified by information sharing scheme, numbers reported since implementation predominantly relate to sharing under the FVIS Scheme with a very small number of requests relating to the CIS Scheme. For example, for Justice Health, a total of 69 requests of which 6 related to the CIS Scheme and a further 15 related to requests under both the FVIS and CIS Schemes. Low numbers are not indicative of overall sharing activity and Justice Health continues to respond to requests for health information under a range of different legislative vehicles (including the Privacy and Data Protection Act 2014, the Health Records Act 2001 and the Children, Youth and Families Act 2005).

There is no benchmark for the expected use of the CIS Scheme, however, based on the relatively crude measure[22] of the information requests reported, with the exception of requests for Victoria Police to share, the volume of CIS Scheme requests suggest there is opportunity for improved application of the CIS Scheme in the interests of the wellbeing of the child. A ramping up of information sharing under the CIS Scheme may be evident in the information requests reported by DHHS IST for the first half of 2020, noting that this has predominantly been in a family violence context. Stakeholder feedback also suggests that there will be increased opportunity for sharing by Phase One prescribed workforces under the CIS Scheme with the prescription of Phase Two universal services (see section 5.1.3). It is expected that the Monitoring and Reporting Framework under development for the child information sharing reforms will enable better capture of information about implementation of the CIS Scheme and the extent to which the objectives of the CIS Scheme are being met.

This section supports the earlier recommendation for improved record keeping with the potential also to contribute to measurement of the achievements of the CIS Scheme (see section 3.4).

4.3 ISEs have delivered activities to enable practice change to appropriately share information under the CIS Scheme

A range of innovative approaches have been developed by prescribed organisations and services to support practice change among their workforces. This has involved embedding training in relevant existing training programs, making the language around the CIS Scheme more accessible, enabling awareness of children in their work, and identifying professionals/leaders available for secondary consultations.

We are integrating the information sharing schemes into the broader privacy and consent training for new staff. (Workshop participant)

We are supporting our workforce by deciphering the enormous amount of legislation and putting it into plain language for the staff to understand. Addressing staff attitudes and understanding of what exactly they can share, and ensuring they understand the legal obligations of sharing. Minimising the staff concerns around legal accountability for "oversharing". Managing the influx of information requests as external agencies realise what a resource our workforce is to them. (MCH workforce survey respondent)

Educating staff about CIS Scheme has enabled us to have conversations about the wellbeing of children and the need to keep them in focus. It has enabled us to update forms and incorporate the need to be aware of children in procedures. We have implemented a Dependent Care Plan for use for all clients who have dependent children. (Workforce survey respondent – Mental Health Services)

We have implemented training and set up key child safe officers across the organisation for secondary consults. (AOD workforce survey respondent)

Our organisation has clearly identified leadership team responsible for all related schemes, helpful for people in the organisation to have someone to go to. (Workshop participant)

There should be a process for capturing and disseminating examples of approaches to supporting workforce practice change, such as the potential for proactive sharing. At a minimum, this could be demonstrated through a series of case studies that have regard for the structure, size and location of organisations and services.

Recommendation 7         Disseminating approaches to practice change
That good practice case studies across a range of contexts be identified and shared through a variety of media, including through innovation workshops and published material.

4.3 ISE implementation is true to the intent of the legislation and design of the CIS Scheme

Sector understanding of the intent of the CIS Scheme legislation and how this should be reflected in implementation emphasises the importance of collaboration and expanded networks in the interests of the child. However, there is also a caution that implementation of information sharing schemes ensure that the needs of diverse and marginalised groups are addressed.

We need to shift from a risk averse info sharing culture to one that is more proactive, collaborative and appropriately balanced. (MCH workforce survey respondent)
[the legislation] supports the notion that ‘protecting children is everyone’s responsibility’; not just that of DHHS and police. It has led to more emphasis on early intervention and prevention through increased collaboration, and has removed information sharing obstacles, thereby reducing risk of harm to children. (MCH workforce survey respondent)
[the challenges of the CIS Scheme for my organisation are to] Ensure prescribed entities and workers know the scheme and their responsibilities. Improve processes for requesting and responding to request for information under the CIS Scheme and the FVIS Scheme. Improve methods to identify outcomes from sharing of information. Ensure best practice principles are enacted, children and young people are consulted re: sharing of sensitive and confidential information and people's legitimate rights to privacy are protected. Ensure the needs of diverse and marginalised communities i.e.CALD, LGBTIQ, disabled, rural, homeless, etc., are addressed and their increased vulnerability to violence, is addressed through the CIS Scheme and FVIS Scheme. (Workforce survey respondent - Specialist Victim Survivor Family Violence Service)

There would appear to be a high level of understanding amongst prescribed organisations and services about the purpose of the CIS Scheme. The challenge continues to embed the CIS Scheme in the tool kit for workforces to draw on where appropriate in ensuring that consideration is given to the wellbeing and safety of children based on the best available information and at the earliest opportunity.

[21] It is noted that as of 20 July 2020, 556 users had enrolled in the MCH tailored information sharing eLearn that covers the CIS and FVIS Schemes.

[22] Noting that the FVIS Scheme can be used where no children are present, Child Protection has other permissions to request information about child risk, and Justice Health is prescribed under the CIS Scheme only in relation to services to children in custody while the FVIS Scheme operates for their work in adult correctional facilities.

Reviewed 30 March 2021

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