Introduction

In 1993 the Disability Services Commission established a set of Disability Services Standards which apply to all agencies and services that it funds or provides. The Disability Services Standards are based on the federal Disability Services Act (1986) and similar Disability Services Acts that were subsequently passed in each State and Territory of Australia as a pre-condition of the Commonwealth State Disability Agreement. The draft standards were developed in 1992 by a working party made up of Commonwealth and State Government representatives. The draft standards were then further refined though a series of national consultations with stakeholders.

The primary intent of the standards is to ensure that services that are provided to consumers are consistent with the Principles and Objectives enshrined in Commonwealth and State disability services legislation, which is the basis on which disability services are funded and provided.

Governments, as both funders and providers of disability services, see the role of service standards as:

• empowering consumers by clearly defining what standards of service they should expect when accessing disability services,
• providing a basis for service providers and consumers to jointly improve service quality,
• assisting service providers to meet the Principles and Objectives of Commonwealth and State Disability Services Acts by clearly defining what is expected of them in terms of minimum service quality,
• assisting prospective service providers by defining what is expected of services to be eligible for funding, and
• providing a means of satisfying government accountability requirements.

Services that are funded by the Disability Services Commission are required to negotiate a Performance Agreement with the funder. Services that are provided by the Disability Services Commission are required to negotiate an Annual Service Plan.  The Disability Services Standards are a central plank in those negotiations and provide a means of assessing whether the service provider is meeting its service obligations and responsibilities under the Disability Services Act. 

There are eight specific service standards that service providers are required to meet as a condition of their funding.

• STANDARD 1 SERVICE ACCESS
  Each consumer seeking a service has access to a service on the basis of relative need and available resources.

• STANDARD 2 INDIVIDUAL NEEDS
  Each person with a disability receives a service which is designed to meet, in the least restrictive way, his or her individual needs and personal goals.
• STANDARD 3 DECISION MAKING AND CHOICE
  Each person with a disability has the opportunity to participate as fully as possible in making decisions about the events and activities of his or her daily life in relation to services he or she receives.
• STANDARD 4 PRIVACY, DIGNITY AND CONFIDENTIALITY
  Each consumer's right to privacy, dignity and confidentiality in all aspects of his or her life is recognised and respected.
• STANDARD 5 PARTICIPATION AND INTEGRATION
  Each person with a disability is supported and encouraged to participate and be involved in the life of the community.

• STANDARD 6 VALUED STATUS
  Each person with a disability has the opportunity to develop and maintain skills and to participate in activities that enable him or her to achieve valued roles in the community.

• STANDARD 7 COMPLAINTS AND DISPUTES
  Each consumer is free to raise, and have resolved, any complaints or disputes he or she may have regarding the agency or service.
• STANDARD 8 SERVICE MANAGEMENT
  Each agency adopts sound management practices which maximise outcomes for consumers.

In order for service providers to meet the eight standards they are required to have in place written policies and procedures that address each of the standards.

As stated earlier in this manual, policies are intended to help, not hinder, organisations. Some of the benefits that properly developed policies bring to an organisation are:

• written policies are an objective way of establishing that an organisation is attempting to comply with the standards or principles that apply to the delivery of services,
• management and staff are provided with a clear framework within which to carry out their duties,
• the process of developing draft policies puts the management committee in touch with its staff, consumers, members, other stakeholders and the wider community,
• written policies signal that the management committee is acting in a professional, business-like manner and is willing to be publicly accountable for its decisions,
• an organisation that is governed by well written policies will be a more attractive proposition for prospective management committee members,
• the management committee will need to make fewer decisions on the run (with its attendant risks of inconsistency in decisions made across different events and different management committees),
• written policies build efficiency and consistency into the management committee's deliberative processes because decisions can be made quickly and confidently within an endorsed policy framework,
• incoming management committees do not have to continuously 're-invent the wheel' and run the risk of making decisions that are inconsistent with previous decisions,
• written policies provide the mechanism for the management committee to delegate authority to management whilst retaining overall control,
• written policies provide an excellent orientation to incoming management committee members and staff of the organisation.

Policy does not need to be confusing, concerning or complicated. Donovan and Jackson (1991) define policy simply as,

"Any generalised decision that serves as a guide to action for organisation members."

This definition tells us that policies are not restricted to a single event, but apply to all similar events. It tells us that policies influence the way that the organisation, its staff and members, behave and the way that its services are delivered.

An even more pragmatic definition has been developed by Roberts (1996), who defines policy as,

"A statement of principles or standards of conduct which guide any decision making in relation to processes, activities and initiatives which happen, or are expected to happen, frequently."

This definition tells us that organisations only need to develop policies for activities that occur with sufficient frequency as to warrant the time and effort expended in developing a formal written policy.

The point at which policies are 'operationalised' (i.e., converted into specific actions) is often referred to as 'procedures'.  Thus, policies and procedures might be viewed as the thoughts and actions of an organisation.  Dyson (1994) says of procedures:

"Where policies provide the signposts or guidance, the procedures tell people how things will be done.  A procedure specifies what will be done, when and by whom."

Dyson, M. (1994)   How and When to Write Policies and Procedures. ACROD, Queensland,.

Donovan, F. & Jackson, A. (1991)   Managing Human Service Organisations. New York:                  Prentice-Hall

Roberts, J. (1996)   The Craft of Managing.  Council of Intellectual Disability Agencies, Victoria.

This Policy and Procedures Resource Manual is intended primarily as a resource to assist agencies funded by the Disability Services Commission to align their policies and procedures with the Disability Services Standards.  However, policies can only be effective if they are 'owned' by the organisation. This manual should not be used as a policy 'gap filler' for the organisation.  Policies need to be coherent with the organisation's mission, values and objectives.  Off-the-shelf policies carry the risk of impeding the organisation in achieving its stated objectives and delivering appropriate services. Indeed, it might be better to have no policy at all than a policy that does not fit the organisation's mission and values.

Policy development also requires proper consultation with stakeholders.  Major stakeholders include members of the organisation, users of the organisation's services and their families or carers, staff of the organisation and the funder of the organisation's services.

The Policy and Procedures Manual has been designed to cover the policies that most of the funded agencies are most likely to need. Every effort has been made to keep the manual as compact and as relevant as possible to the common policy needs of funded agencies.  For this reason, the manual does not claim to be exhaustive. Agencies may need to develop other policies that are specific to their own client group or the particular services that they operate. The manual does, however, provide a simple and easy to follow framework on floppy disk within which to develop other policies.  Additional policies can simply be added to the Service Management section of the manual.

The policy content of this manual was established through a process of consultation. The consultation was undertaken in two stages. The first stage, the 'consultation group', involved 16 funded agencies jointly selected by the authors and the funding body.  Each agency was sent a copy of a draft consultation manual which contained an extensive list of topics for inclusion in the manual.  Agencies were asked to rate each of the topics from the perspective of usefulness to their own agency and to suggest other topics that might be considered for inclusion.

Once the actual content of the Policy and Procedures Resource Manual had been finalised, the second stage of the consultation, the 'user group', was implemented. This stage involved a sub-set of five agencies drawn from the original consultative group of 16 agencies plus the Disability Services Commission's Standards Monitoring Unit. As draft policies and procedures were developed by the authors, they were sent out to members of the user group for comment and suggested modification.

Each of the first six standards were dealt with by means of a single policy and procedures statement. Standard 7, Complaints and Disputes, has already been the subject of extensive consultation with the industry and a Complaints Management Resource File has already been developed and distributed to agencies.  Consequently, no policy and procedures statement for Standard 7 has been included in this manual. Rather, agencies should insert the existing Complaints Management resource documentation in the appropriate section of this manual for easy access when needed. Standard 8, Service Management, is an all encompassing standard that covers the broad scope of management practices that are required to effectively operationalise the first seven standards.  Thus, there are a series of policies and procedures under Standard 8.

At the end of the introductory section there is list of the Commonwealth and State Acts that are referred to in the various policies, along with details of where copies can be procured.  It is important that agencies maintain a legislation resource file which contains copies of the relevant Acts under which the agency is required to operate.

The policy and procedures section of the Policy and Procedures Resource Manual is divided into eight sections, following the structure and sequence of the Disability Services Standards. The structure and content is as follows:

Standard 1 Policy on Service Access
Standard 2 Policy on Individual Needs
Standard 3 Policy on Decision Making and Choice
Standard 4 Policy on Privacy, Dignity and Confidentiality
Standard 5 Policy on Participation and Integration
Standard 6 Policy on Valued Status
Standard 7 Policy on Complaints and Disputes
Standard 8 Policies on Service Management

Policy on Management Committee Members Code of Conduct
Policy on Expenditure Delegations
Policy on Insurance and Indemnity Arrangements
Policy on Equal Employment Opportunity
Policy on Employee Recruitment and Selection
Policy on Police Clearances for Employees and Volunteers
Policy on Employee Training and Development
Policy on Employee Supervision and Appraisal
Policy on Managing Sub-Standard Employee Performance
Policy on Occupational Health and Safety
Policy on Employee Grievances
Policy on Use of Volunteers
Policy on Employee and Volunteer Code of Conduct
Policy on Manual Handling Procedures
Policy on Managing Challenging Behaviours
Policy on Maintaining a Safe Living Environment
Policy on Private Use of Agency Vehicles
Policy on Agency Use of Private Vehicles

The task of developing and writing policies is far less daunting and far more effective if the agency has a consistent structure and format to follow.  This Policy and Procedures Resource Manual has adopted a standard structure which has been adhered to as far as possible throughout the manual.

The structure that is used is based on contemporary quality service and quality management principles. Many agencies are currently, or will in the future, consider becoming endorsed under the ISO 9000 series quality standards. A key requirement in meeting the quality standards for ISO 9000 endorsement is having written policy and procedures documents that are properly developed, widely distributed and regularly updated. The policy structure followed in this manual is designed to meet ISO 9000 series standards.  The policy structure appears below:

• Title
• Background
• Purpose and Scope
• Policy Statement
• Procedures
• Performance Standards
• Review

Title
The title of the policy should appear on a separate cover page along with the name of the agency and its effective date of implementation.  The title should commence with the "Policy on..." followed by a brief description of the issue or activity the policy is addressing.

Background
Each policy should appear with a background statement on the agency.  The background statement should include the name of the organisation, its legal status, its mission and objectives, its management structure, its mode(s) of service delivery, and its source(s) of funding.  Having the background statement on every policy, whilst ostensibly repetitious, ensures that, when individual policies are separated from the agency's policy manual for whatever reason, the important background information on the agency is still available to the reader.

Purpose and Scope
The policy should include a statement of the purpose for which the policy was written.  This section should also identify government legislation or policies that impact on the policy. As well as providing a context for the reader, this also alerts the organisation as to its legal or funding obligations.  Scope refers to the programs within the agency to which the policy is intended to apply. For example, a policy may apply only to one program within the agency or only to the areas of activity that are funded by a particular funding body.

Policy Statement
The policy should include a brief statement outlining the general position of the agency with respect to the issue or activity identified in the policy title.

Procedures
The policy should describe a series of steps designed to convert the policy statement into action.  The procedures should specify what will be done by the agency.

Performance Standards
The policy should include a series of operating standards to enable the agency, and the reader, to ascertain in an objective manner whether the procedures outlined in the previous section have been effectively implemented.

Review
The policy should include a latest date by when the policy should be reviewed or future circumstances that may lead to an earlier review of the policy.  Current practice would suggest that all policies be reviewed at least every two years.

A major consideration in constructing a Policy and Procedures Resource Manual is how to make the content as understandable, accessible and applicable as possible - bearing in mind the diversity of organisations that the Disability Services Commission funds. In coming to a decision about content, several assumptions have been made by the authors based on their own experiences and advice from the Disability Services Commission.  First, smaller and/or more recently established agencies are likely to have fewer written policies in place. Second, smaller and/or more recently established agencies are less likely to have the time or resources to either develop needed policies internally or contract external help.  Third, and as a consequence of the first two assumptions, smaller and/or more recently established agencies are likely to benefit most from a Policy and Procedures Resources Manual.

Given that the primary target audience is smaller and/or more recently established agencies, consideration was then given to how best to present the content. In discussion with the consultation group it was felt that the content might be rendered most understandable, accessible and applicable if it were presented in the form of model policies and procedures.

In order that model policies and procedures can be written, it is necessary to invent a model agency to provide an organisational context within which to frame policies and procedures. It was felt that the subsequent policies and procedures would have the greatest relevance and ease of applicability to most agencies if the model organisation had a structure and service delivery mechanism that was most akin to funded agencies.

The model agency that evolved from all of the above considerations is Community Enterprise Inc. Community Enterprise is incorporated under the Associations Incorporation Act of Western Australia. It is governed by a management committee of eight people who are elected annually by the membership.  The constitution requires that three of the management committee members must be people with a disability or close relatives.

Community Enterprise offers services to people with disabilities who live in the Shire of Hidden Valley, an urban and rural community of approximately 15,000 people. The services offered by Community Enterprise include:

• a three person group home which is staffed evenings, overnight and week-ends,
• a two person wheelchair accessible respite house which is staffed by a live-in carer couple and is available on week-ends and school holidays only,
• an in-home support service where caregiving families are provided with cash assistance up to a maximum of $200 a month to purchase their own in-home respite or home help,
• a volunteer support service where people with disabilities are linked with a community volunteer who accompanies the person on regular community outings.

Community Enterprise employs three paid staff plus five paid carers who are based at the group home or respite house, both of which are owned by Community Enterprise. The group home is covered by one live-in and two part time visiting staff and the respite house is covered by a married couple in return for rent free accommodation and an hourly wage based on actual usage. The respite service is used by 10 local families.  The in-home support service is managed by a full-time service co-ordinator and is used by 20 local families who, between them, have access to a pool of discretionary funds totalling $20,000 per year.  The service co-ordinator is also responsible for the community volunteer program. Community Enterprise has a full time executive officer and a part time administrative assistant.

As mentioned at the outset, it is important that agencies do not merely adopt these policies 'off the shelf'. Policies need to be coherent with the organisation's mission, values and objectives. A process for customising needed policies is outlined below.

• Appoint a policy sub-committee made up of two management committee members, a senior staff member and a service user.
• Identify the policies in the Policy and Procedures Resource Manual that the agency does not currently possess.
• Construct a background statement to insert into the policies in place of the Community Enterprise background statement.
• Review the policy statement, procedures and performance indicators sections to more closely reflect the agency's own priorities and operations.
• Assemble a small focus group of interested consumers, provide them with copies of the draft policy and seek feedback.
• Re-convene the policy committee and incorporate suggested changes where considered appropriate.
• Present the modified draft policies to the full management committee for discussion, amendment and formal endorsement.
• Add the endorsed policy to the Policy and Procedures Manual.
• Advise service users of the new policies and make copies available on request.
• Provide a copy of the policy to the funding body.

The agency should also seek expert advice when customising possibly contentious issues such as the Policy on Challenging Behaviours. The Disability Services Commission is currently revising its policy on challenging behaviours and will provide further guidance in this area at a later date. Similarly, policies on Human Relations and Sexuality or Allegations of Client Abuse should be subjected to expert scrutiny.

The following Commonwealth Acts are referred to in one or more of the draft policies in this manual. Copies of these Acts can be obtained from the (Commonwealth) Government Info Shop, 469 Wellington Street, Perth (phone 08 9322 4737, fax 08 9481 4412).

• Equal Opportunity Act (1984)
• Disability Discrimination Act (1992)
• Sex Discrimination Act (1984)
• Racial Discrimination Act (1975)
• Human Rights and Equal Opportunity Commission Act (1986)
• Workplace Relations Act (1997)
• Privacy Act (1988)
• Income Tax Assessment Act (1936) and amendments
• Sales Tax Exemption and Classifications Act (1992)

The following State Acts are referred to in one of more of the draft policies in this manual. Copies of these Acts can be obtained from the State Law Publisher, 10 William Street, Perth (phone 08 9321 7688, fax 08 9321 7536).

• Disability Services Act (1993)
• Associations Incorporation Act (1987)
• Occupational Health, Safety and Welfare Act (1984)
• Workers' Compensation and Rehabilitation Act (1994)
• Minimum Conditions of Employment Act (1993)