UnitingCare Australia is the national body for the UnitingCare network of community and social service providers and is an agency of the Uniting Church in Australia. The UnitingCare network provides services to children, young people and families, indigenous Australians, people living with disabilities, the poor and disadvantaged, people from culturally diverse backgrounds and older people, in urban, rural and remote communities.
This submission provides our assessment of the Public Governance, Performance and Accountability Bill 2013 (PGPA Bill) and builds on the comments we made in our submissions on the Commonwealth Financial Accountability Review: Is Less More discussion paper and Sharpening the Focus position paper. Additionally it also draws on our analysis of the Code of Best Practice for Engagement with the not-for-profit (NFP) sector developed under the National Compact.
UnitingCare Australia believes that the charitable community services sector is an important partner for government and other sectors in the delivery of services and support to some of the most vulnerable and disadvantaged members of our society. Many policy and legislative decisions, although not specifically targeted at our sector, impact on the Commonwealth’s relationship with us.
Accordingly, this submission provides comment only on those elements of the PGPA Bill that we believe will impact on the UnitingCare network and makes suggestions as to how we believe the Bill can be further strengthened in those areas:
- UnitingCare Australia welcomes the overall direction of the Bill recognising that it is a framework for the proper use of public resources;
- While we acknowledge that Commonwealth agencies will be required to develop new rules and practices to meet the requirements of the Bill, we believe that the implementation of this Bill should include the participation of key stakeholders;
- We support the positive obligation on Commonwealth agencies to both recognise the importance of collaborating and partnering with non-Commonwealth entities and the need to take account of the impact of reporting and control requirements on nonCommonwealth entities; and
- While we support the need for the Commonwealth to explicitly address the issue of risk and control in this Bill, we hope that further guidance on this matter can be developed so as to ensure clauses 17 and 18 (Duty to encourage cooperation with others and Duty in relation to requirements imposed on others) can be achieved.
We believe it would be prudent to better identify non-Commonwealth partners within the Bill to further signal the importance of partnership and collaboration for Commonwealth agencies.
Therefore, we recommend further consideration is given to amending the following Clauses:
- Clause 5 - Objects of this Act should include a note which clarifies the term ‘others’ in 5(c)(iv) to expressly acknowledge State and Territory government agencies and bodies, charity and not-for-profit entities as well as for-profit organisations; and
- Clause 17 – Duty to encourage cooperation with others as with Clause 5 it would be helpful to expressly acknowledge State and Territory government agencies and bodies, charity and not-for-profit entities as well as for-profit organisations.