VAADA: Response to the National Drug Strategy 2010-2015

8/8/2019 VAADA: Response to the National Drug Strategy 2010-2015

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The Victorian Alcohol and Drug AssociationThe Victorian Alcohol and Drug Association (VAADA) is the peak body for alcohol and other drug(AOD) services in Victoria. We provide advocacy, leadership, information and representation on AODissues both within and beyond the AOD sector.

As a state wide peak organisation, VAADA has a broad constituency. Our membership andstakeholders include drug specific organisations, consumer advocacy organisations, hospitals,community health centres, primary health organisations, disability services, religious services,general youth services, local government and others, as well as interested individuals.

VAADA sBoard is elected from the membership and comprises a range of expertise in the provisionand management of alcohol and other drug services and related services.

As a peak organisation, VAADA spurpose is to ensure that the issues for both people experiencingthe harms associated with alcohol and other drug use, and the organisations that support them, are

well represented in policy, program development, and public discussion.

VAADAs consultation processAs the peak body on alcohol and other drug issues in Victoria, VAADAhas referred to consultationswhich were undertaken in late 2009 and early 2010 in response to the earlier National Drug StrategyConsultation Paper. We conducted both general and targeted consultation with member servicesacross the Victorian AOD sector to determine their views on emerging trends and issues, keydirections and priorities, and workforce needs under the new National Drug Strategy 2010 2015.

Diversity is among the strengths and defining features of the Victorian, and indeed, Australian, AODsector. This response is based on a diverse range of opinions from across our membership, and somecomments may not reflect the individual views of all those who have provided input. While therewas powerful consensus on many of the key issues and priorities outlined in this document, the finalanalysis represents the views of VAADA.

We again extend our thanks to those VAADAmembers who have generously given of their time andprofessional insight to contribute to the development of this response.


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Contents

Introduction 4

Summary of Recommendations 6

Recommendations in response to the current NDS 9

A better balance 11

The investment mix 11

A national prevention agenda 12

Key issues and priorities 13

A growing population 13

An aging population 14

Prescription and over the counter medicines 14

Addressing the social and structural determinants of drug use 16

Enhancing community awareness and understanding of AOD issues 18

Knowledge gaps 18

Improved data collection 19

Supporting the workforce 20

Funding and funding models 20

Professionalism, pay and conditions 21

Coordination and governance 21

Policy coordination 22

Transparency 23

Consumer and service provider participation 23

Performance measures and reporting 24

Findings from state/territory jurisdictions 24

References 26


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Introduction

We welcome the opportunity to respond to the National Drug Strategy 2010 2015 ConsultationDraft (hereafter the NDS). We believe that the NDS is critical in further developing a holisticresponse to AOD issues involving all stakeholders. We also believe that it plays a crucial role in

providing a foundation for policy and public discourse on AOD issues and is a core policy documentoutlining the government s stance, strategies and responses to these issues over the next five years.

As peak body for Victorian AOD treatment providers, our response illustrates the underpinning rolesof our membership and their capacity to maintain a high level of quality in the delivery of theirservices to the community within the framework of the NDS.

We have carefully considered the NDS and identified some core strengths as well as significant gapswhich we will address in this submission. We support the four commitments outlined in the NDS:

building workforce capacity; evidence based and evidence informed practice, innovation and evaluation performance measuring; and Building partnerships across sectors.

We do, however seek further detail on how those commitments will be applied to the NDS.

We would like to reaffirm the four thematic tenets which underpinned our previous submission toAustralia s National Drug Strategy in February 2010, which were:

1. The need for a better balance in investment across the three pillars of supply, demand andharm reduction;

2. Key issues and priorities3. The need to build workforce capacity; and4. NDS coordination and governance.

As in our earlier submission, these tenets will provide the framework for our recommendations.

We note that the NDS has addressed some of the recommendations contained in our previoussubmission. However, it is evident that some of our recommendations have not been adapted andwould urge the Ministerial Council on Drug Strategy (MCDS) to revisit them. This submission willdetail those recommendations which have been omitted.


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We believe that the NDS should provide a blueprint for action on contemporary AOD issues as wellas enable a level of flexibility to secure positive action to developing trends and patterns in harmfulsubstance use. We are conscious that policy development is a fluid process and that the currentstatus of AOD issues is a precursor to future AOD policy direction. We are therefore mindful thatAOD issues are highly political and social in nature and influenced by a raft of factors.


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Summary of recommendations

The recommendations contained below draw on some of VAADA searlier thoughts in our previous

submission which we believe are absent in the NDS. We have omitted relisting thoserecommendations which have been taken up by the MCDS in the preparation of the draft NDS.

It is crucial that these recommendations are considered as they are the result of strategic and carefulconsultation with experts from the Victorian AOD sector. These recommendations represent aculmination of the vast experience and expertise of these stakeholders and provide sensible,strategic, long term solutions to the challenges facing service users of the AOD sector.

A better balance

Review the balance of expenditure across the three pillars of supply, demand and harmreduction

Ensure that all investment decisions and policy initiatives across supply, demand and harmreduction are informed by, and equally subject to, independent evidence and critique

Ensure all investment decisions and policy initiatives across supply, demand and harmreduction are based on evidence of measurable outcomes and cost effectiveness

Make funding allocations and information on proportional investment across the threepillars transparent and compile and publish the information annually

Develop indicators for the effectiveness of law enforcement, and for how law enforcementand supply reduction interventions interact with and impact on harm reduction efforts

Invest in the development and expansion of treatment and harm reduction services andactions

A growing population

Undertake forecasting and planning for short, medium and long term AOD treatment needsbased on Australia s growing population

Enhance links and engagement with local government as well as local and state planningauthorities to advise on population shifts, local profiles and community and service systemneeds

An aging population

Support research on alcohol and other drug use and harms among older adults, includingo Risk and protective factorso Best practice treatment options


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o Interactions of prescription medications with alcohol and other drugs Strengthen partnerships between AOD, mental health, aged care and primary services and

sectors

Prescription and over the counter medicines

Work with relevant bodies to incorporate AOD training components in under to postgraduate nursing and medical curricula, vocational education and continuous professionaldevelopment levels and to enhance recognition of addiction as a specialist field

Support and extend research to build the evidence base around prescription drugs. Thiscould include research into: long term effects of various medications on cognitivefunctioning; long term efficacy and therapeutic value of a range of prescription drugs andcurrent and emerging treatment modalities for benzodiazepines and other pharmaceutical

drugs Increase the scope and effectiveness of national mechanisms to monitor and assess

consumption and misuse to minimise the harms derived from prescribed medications,including doctor/pharmacy shopping

Increase access to and availability of pharmacotherapy and opiate substitution therapyoptions, including addressing the impact of dispensing fees for both clients and serviceproviders, the need for alternative models of pharmacotherapy, and the need for greaternumbers of prescribers.

Addressing the social and structural determinants of drug use

Promote a definition of prevention that focuses on the social and structural determinants of drug use

Invest in mechanisms to ensure cross sectoral collaboration and linkages between AOD,mental health, indigenous, family and community health, housing, employment andcommunity legal services

Ensure drug policy is coordinated with social and welfare policies addressing disadvantage,poverty, homelessness, marginalisation and social exclusion; and actively develop and direct

resources to initiatives that strengthen community capacity

Enhancing community awareness and understanding of drug issues

Develop a communication strategy which provides clear, consistent messages to politiciansabout the work of the NDS and the AOD sector more broadly

Encourage informed community debate about drug issues and approaches for responding todrug related harm

Ensure all NDS funded health promotion and education campaigns are developed in

consultation with AOD expert input (including service provider input) and provide nuanced,well evidenced messages to drug related harms


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Knowledge gaps

Build the evidence base for prevention and law enforcement initiatives and strategies Build the knowledge base for addressing alcohol and drug use among refugees and newly

arrived communities, including specifically how treatment and other drug services can better

engage with these groups Increase the knowledge base and wider awareness of the social and structural determinants

of drug use Implement strategies to mitigate the compounded harm associated with serving a prison

sentence with substance use issues Allocate more energy and resources to diversion from the criminal justice system and

support in the community

Improved data collection

Identify measures to better assess outcomes and effects of treatment and otherinterventions. Any outcome measures must be developed in consultation with serviceproviders and any expansion of data collection processes must be appropriately resourced

It is crucial to improve methods for national and State data collection and expand the scopeand capacity of national data collection systems to produce accurate trend and outcomedata and report back to agencies on local level trends and outcomes

Improve access to law enforcement data for the purposes of evaluation, review and planningof services

Funding and funding models

Develop and implement alternative and best practice models for funding community basedAOD services

Professionalisation, pay and conditions

Support the development of an industry plan for the community AOD sector that will ensurethe workforce is able to continue to provide quality, effective services and sets the agendafor addressing issues of workforce pay, employment conditions and parity with relatedsectors.

Facilitate rural and regional treatment staff to access technologies which will assist traininguptake, knowledge acquisition, and better integration of service delivery


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Policy coordination

Ensure coordination and integration of the NDS with NDS sub strategies including theNational Alcohol Strategy. Consider developing the National Alcohol Strategy concurrentlywith the overarching NDS

Identify and prioritise the national social and health polices of relevance to the AOD sectorand the development of the next NDS

Ensure the NDS is aligned with identified social and health policies Provide a rational, coordinated framework or action plan for the integration of identified

policies into service practice Ensure the new NDS complements and builds on, rather than replicates, alcohol related

policy directions and initiatives proposed by the National Preventative Health Taskforce

Transparency

Clearly articulate the various roles, responsibilities and aims of NDS bodies and make thisinformation publically available via the NDS website and other means

Publish documents on governance of the NDS and its advisory bodies to enhance the AODsector and wider community understanding of how the structures supporting the NDSoperate

Improve documentation of policy discussions, processes and decision making by the NDSbodies

Consumer and service provider participation

Enhance engagement and direct dialogue with the AOD NGO sector Develop formal mechanisms to gather views of service providers and incorporate these into

the development and implementation of the new NDS. This could be done throughstate/territory and national peak bodies

Incorporate consumer representation and views into the NDS, potentially through national,state and territory consumer organisations

Performance measures and reporting

Define responsibility for the further development and implementation of NDS performancemeasures, monitoring and evaluation with the NDS structures

Recommendations in response to the current NDS

Further to the recommendations listed above which were included in our previous submission,VAADAproposes further recommendations in response to the NDS.


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Findings from state/territory Coronial Jurisdictions

Develop a process in which NDS monitoring and governance bodies can access any coronial

findings from all state/territory jurisdictions which have relevance to the AOD sector Review and strongly consider relevant coronial findings in implementing and executing

related policies Lead a public discourse promoting coronial findings which aim to reduce the harm

associated with alcohol and drug use Use this evidence to pursue systemic and policy changes with a view to reducing morbidity


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A better balance

VAADA is supportive of the NDS s intention to retain harm minimisation as the overarchingprinciple. We are also supportive of the retention of the three pillars of supply, demand and harmreduction, which is in line with the views of the majority of the member organisations we consulted.

As discussed in our previous submission, VAADA acknowledges that there is a level of communitymisunderstanding regarding the principle of harm minimisation but also accepts that harmminimisation is now entrenched in AOD discourses and provides a basis for organisational practiceand direction for the sector. This should be protected and maintained.

The investment mix

VAADAbelieves that the NDS does not strike the right balance in investment and resource allocationacross licit and illicit drugs and the three pillars of supply, demand and harm reduction. Demand andharm reduction continue to be eclipsed by supply reduction, which attracts the most resources(Siggins Miller 2009: viii). Our previous submission noted that demand and harm reduction haveendured long term chronic underfunding, as opposed to law enforcement and interdiction, whichcontinues to be well resourced. As it is not possible to develop a balance of expenditure betweenthe three pillars which will remain static thereafter, it is necessary to engage in a continuous processof review and evaluation, and moreover, ensure that this process is transparent and accessible to allstakeholders (VAADA2010:10).

As we asserted in our earlier submission, given the significant expenditure, there is a need toundertake further evidence based research on the efficacy of supply reduction, and further, inparticular on the assumptions which inform the success of this approach.

We note with some concern the penultimate action listed under Objective 1 (NDS 2010: 17)research, investigate and gather information on all aspects of drug supply markets to properly

inform law enforcement responses . This action is premised on the assumption that lawenforcement responses are appropriate and research should be conducted only to ensure that theycan capture drug supply markets. Indicators of success in law enforcement are often informed by a

number of assumptions which are not often evaluated. The supply reductive practices (in boardersecurity and law and order) resulting from those assumptions are reviewed with an implied standardand view that they are the most cost and health effective means of preventing the importation of illegal drugs.

VAADAdoes not necessarily disagree with the efficacy of supply reduction practices such as bordersecurity and law and order responses. We do, however, assert that these strategies need to bereviewed with the same level of vigour as demand and harm reduction strategies. For instance,

needle and syringe programs have been regularly reviewed, as noted in our previous submission and


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iterated in the NDS, and the results of the evaluation processes indicate that they should continue tobe expanded due to ongoing efficacy, cost effectiveness and public health value (NDS 2010:31).

Resourcing issues are particularly poignant in the AOD sector, as the review of the cost of Counselling, Consultancy and Continuing Care (CCCC)services within the Victorian Drug and Alcohol

Sector (2010a:5), as commissioned by VAADA,illustrated that many services suffer a shortfall of upto 18% in base funding in this program area alone. Many CCCC providers are required to accessreserves to maintain consistent levels of service provision. We would recommend that the findingsof this review be considered in light of the disparity in funding allocation between the pillars andthat the first step towards achieving a balance is to apply rigorous evidence based evaluationprocesses equally between the pillars.

A national prevention agenda

Our previous submission provided a comprehensive discussion on the need to promote a moreaccurate and meaningful understanding of prevention (VAADA 2010: 11). We discussed theoverarching notion that contemporary prevention strategies are centred on prohibition and that thisis a limited and narrow approach which does not encapsulate a full understanding of the termprevention.

We reaffirm that preventative action should embed contemporary understandings of the structuraldeterminants of harmful drug use (VAADA 2010: 11). In order to develop these understandings,

there is a need for further research into what works with preventative strategies. Moreover, thisresearch should be centred on the social and structural determinants of drug use rather than strictadherence to a prohibitionist framework.

Recommendations

Review the balance of expenditure across the three pillars of supply, demand and harmreduction

Ensure that all investment decisions and policy initiatives across supply, demand and harmreduction are informed by, and equally subject to, independent evidence and critique

Ensure all investment decisions and policy initiatives across supply, demand and harmreduction are based on evidence of measurable outcomes and cost effectiveness

Make funding allocations and information on proportional investment across the threepillars transparent and compile and publish the information annually

Develop indicators for the effectiveness of law enforcement, and for how law enforcementand supply reduction interventions interact with and impact on harm reduction efforts

Invest in the development and expansion of treatment and harm reduction services andactions


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Key issues and priorities

We reaffirm our concerns outlined in our previous submission regarding some of the key issues andpriorities which are not contained in the NDS.

A growing population

As population growth is predicted to reach almost 30 million over the next 15 years (ABS 2008),there is likely to be considerable strain on the AOD sector as growth corridors emerge to soak upvast swathes of population ahead of the necessary infrastructure required to service growingcommunities. There are a number of regions which are growing at rapid rates in the variousAustralian States, for example the City of Casey in Victoria is growing at the rate of 146 people perweek and is predicted to increase from 240,000 in 2009 to 375,000 people by 2026 (City of Casey

2010). There must be provision in the NDS for the identification and scoping of accelerated growthcorridors such as this region and the subsequent needs of these expanding community groups.Failure to respond to these issues will result in communities enduring significant disadvantagecompared to their established counterparts, creating a greater chasm of access and equity in welfareservices. This will impact on the development of harmful (and in part preventable) substance usetrends and other adverse structural determinants which result in harm in the community.

Further, due to cheaper housing, newly arrived and culturally and linguistically diverse (CALD)community groups are more likely to reside in these areas. These groups are more likely to requireassistance from community services and will therefore fare poorly in the absence of comprehensiveand responsive service provision.

Therefore, VAADAreaffirms the need for the NDS to outline processes for engaging with state andlocal government planning authorities who can advise on population shifts, local profiles andconcurrent needs. This will enable the AOD sector to proactively gauge future service need andtherefore adopt a preventative approach and minimise harm to these communities.

Recommendations

Undertake forecasting and planning for short, medium, and long term AOD treatment needsbased on Australia s growing population.

Enhance links and engagement with local government and local and state planningauthorities to advise on population shifts, local profiles and concurrent needs.


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An aging population

VAADAcommends the NDS on the recognition that there are certain times in peoples lives wherethey are at greater risk of harm from drugs and alcohol and moreover, some of the specific harmswhich are emerging as the demographics shift to an older population. We further commend the NDS

for promoting a collaborative approach to holistic service delivery including the promotion of strongpartnerships and integrated service approaches with social welfare, income support and jobservices, homeless services, mental health care providers and correctional services (NDS 2010 :11).However, further specificity is required outlining how these partnerships and integrated serviceapproaches will work on the ground and whether those sectors also include aged care serviceprovision for example.

It is important to reiterate that Australia has a growing population of older people and therefore araft of new challenges facing the AOD sector will emerge. These include various social phenomenasuch as increased isolation, periods of transition (from fulltime employment to retirement) and a

lack of awareness of substance use issues. These are further exacerbated by limited social support,the manifestation of age related physiological and psychological disorders and an increase in the useof prescription medicine which when mixed with alcohol and other drugs may cause harm.

We reiterate the recommendations listed in our previous submission. The latter recommendationshould be considered in light of providing clarity on the particular roles of the various sectors andstrategies employed to strengthen partnerships.

Recommendations

Support research on alcohol and other drug use and harms among older adults, including

risk and protective factors

best practice treatment options

the interaction of prescription medications with alcohol and other drugs.

Strengthen partnerships between AOD, mental health, aged care and primary health services and

sectors.

Prescription and over the counter medicines

We noted in our earlier submission that the misuse of prescription drugs including benzodiazepines,opioids, anti depressants and other pharmaceuticals is an emerging challenge in contemporaryAustralian society. We also asserted that misuse of prescription drugs is in many cases replacing theuse of illegal opiates, with many opiate dependent people now using prescribed opiates bothlegally and illegally rather than chasing street heroin (Service provider, VAADAconsultation 2010).AOD treatment providers have also noted that some medical practitioners are engaging in


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inappropriate prescribing practices, which has been echoed by the Drugs and Crime PreventionCommittee (DCPC)2007: 273).

A number of issues were raised in the previous submission which is still highly pertinent to the NDS:

o The need for better information, including independent, research based evidence on therelative benefits and harms of prescribed medication, on drug interactions and iatrogenicillness

o Limited training and knowledge within the primary and allied health workforce onaddiction and misuse of prescription medicines

o Substitution of illicit for licit substances

o Limited availability and access to pharmacotherapy and opiate substitution therapy options

o Chronic pain management

o The need for better monitoring and assessment of consumption and usage of prescribedmedications, including doctor/pharmacy shopping

o Over prescription of pharmaceutical drugs by GPs

The NDS does not provide strong coverage of these challenges or those recommendations listed inour previous submission; misuse of prescription drugs is in part subsumed into discussions onreducing supply of other licit drugs with minimal attention given to the process of procurement.VAADA reaffirms our assertion from our previous submission that this is an issue which spans

multiple contexts with those misusing prescription drugs originating from a wide variety of socialgroups. Further, Turning Point (2008:7) highlighted significant challenges in this area, indicating that

we are only seeing the tip of the iceberg of pharmaceutical misuse and called for research toascertain the extent of pharmaceutical misuse in the community, the range of pharmaceuticalrelated problems and how to develop appropriate interventions to increase awareness andtreatment uptake (Turning Point 2008:7).

VAADA has previously recommended the development of further AOD training components under

and post graduate nursing and medical curricula, vocational education and continuous professionaldevelopment to assist primary health professionals to better respond to AOD issues. We commendthe NDS for responding to the training needs of workers and specialist skills required to work in theAOD sector through proposing to accredit AOD services and set a minimum set of qualifications (wenote that this has already occurred in Victoria). We believe that more work needs to be undertakenin the area of workforce development and minimum standards.

We note that the NDS proposes the development of a Pharmaceutical Drugs Misuse Strategy. Wewould be keen to ascertain further information regarding this strategy, including the consultationprocesses which will be undertaken, terms of reference governing the development of this strategy

and its relationship with the NDS and other relevant sectors.


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Recommendations

Work with relevant bodies to incorporate AOD training component in under to post graduatenursing and medical curricula, vocational education and continuous professional developmentlevels and to enhance recognition of addiction as a special field

Support and extend research to build the evidence base around prescription drugs. This couldinclude research into: long term effects of various medications on cognitive functioning; longterm efficacy and therapeutic value of a range of prescription drugs and current and emergingtreatment modalities for benzodiazepines and other pharmaceutical drugs

Increase the scope and effectiveness of national mechanisms to monitor and assessconsumption and misuse of prescribed medications, including doctor/pharmacy shopping

Increase access to and availability of pharmacotherapy and opiate substitution therapy options,including addressing the impact of dispensing fees for both clients and service providers, the

need for alternative models of pharmacotherapy, and the need for greater numbers of prescribers.

Addressing the social and structural determinants of drug use

Our previous submission outlined our recommendations regarding the social and structuraldeterminants of drug use. We reaffirm our position as outlined in our previous submission.

People who experience the most serious harms associated with drug use are often among the most

marginalised and socially disadvantaged populations. Social cohesion, access to services, income andemployment are structural and social determinants of health. These have been clearly identified bythe Preventative Health Taskforce (National Preventative Health Taskforce 2008) and inform thenational social inclusion agenda. Important work has been done in enhancing understanding of themultiple and causal factors that drive harmful alcohol and drug use, however VAADAbelieves thisknowledge must be more meaningfully embedded in effective policy.

The particular needs and challenges within Aboriginal and Torres Strait Islander communities are anexample of the ways substance use and harms, but also protective factors, are shaped by social andhistorical processes. Disparities in health and life expectancy between Aboriginal and Torres StraitIslander communities and the broader population, on which substance use is a significant influence,are a case in point of the critical need to integrate drug policy with broader social policy efforts.VAADArecognises that the specific and particular needs and issues within Indigenous communitiesrequire tailored policies, and supports the continuation of a separate Complementary Action Plan.However, we also contend that the broader NDS should ensure cultural relevance and validity, andbelieve this would be achieved through greater attention to the structural determinants of health, of which belonging to a minority group is one.

VAADAbelieves the next phase of the NDS should be heavily informed by an understanding of the

complex interactions between social disadvantage and harm from drug use. This will require that theNDS and governance bodies better coordinate drug policy with social and welfare policies addressing


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disadvantage, poverty, homelessness, marginalisation and social exclusion; actively develop anddirect resources to initiatives that strengthen community capacity; and ensure transparency andparticipation in its processes, as discussed below.

The NDS must also recognise that at practice level, addressing alcohol or drug use cannot be doneeffectively without also addressing financial, legal, housing and other support needs. Currentlyhowever, treatment services are obliged to deal with these issues, in addition to clients drug use,without additional funding. As one service provider observed, social isolation, marginalisation,disadvantage, poverty [and] homelessness all impact negatively on individuals who are experiencingproblems associated with their use of drugs (Service provider, VAADAconsultation 2009 10).

Along with greater funding to recognise work already being done, collaboration and linkagesbetween services that span the AOD, mental health, Indigenous, family and community health,housing, employment and community legal systems are key to ensuring that individual and family

needs can be addressed meaningfully. Better collaboration and service networks could be achieved,for example, through encouraging funding applications based on working partnerships andconsortia, and by mandating MOUs and partnerships for cross sector projects and programs.Investment in a connected network of quality services will result in better, more sustainableoutcomes.

Further, VAADAstrongly believes, as discussed above, that the next phase of the NDS should engagegovernment, policy makers and the public in informed debate that generates better understandingsof the real drivers of significant harms to drug users and the wider community. This would includeacknowledgement that the criminalisation of some drugs directly contributes to negative health,

social and legal consequences, and to the social exclusion of users of illicit drugs (VAADA2010: 1415).

The NDS (2010: 11) does provide commentary on partnerships and collaboration between varioussectors with references to reduce potential harms , recover from drug and alcohol problemsand recognise and manage the impacts of drug misuse on families and children . These generalstatements are positive in nature but further elaboration is required on the content and substanceof the partnerships which will result in these positive outcomes. Comprehensive partnershipsbetween sectors need to be established to break down the minutiae of social and structuraldeterminants which contribute to disadvantage in our communities. These partnerships need to bedeveloped with long term goals in mind, and need to operate beyond the political cycle.

Recommendations

Promote a definition of prevention that focuses on the social and structural determinants of druguse

Invest in mechanisms to ensure cross sectoral collaboration and linkages between AOD, mentalhealth, Indigenous, family and community health, housing, employment and community legal

services.


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Ensure drug policy is coordinated with social and welfare policies addressing disadvantage,poverty, homelessness, marginalisation and social exclusion; and actively develop and directresources to initiatives that strengthen community capacity.

Enhancing community awareness and understanding of AOD issues

Community understanding of AOD issues is crucial as inflamed public opinion can rapidlydeconstruct and sabotage sound AOD policy responses. Our previous submission noted the views of our members citing community understanding of AOD issues as impoverished . We reiterate ourargument for the urgent need for nuanced, well evidenced health promotion and educationaddressing drug related harms, rather than drugs per se (VAADA2010:16) and the subsequent needfor an informed and supportive community. VAADAbelieves that AOD education must be conveyedin simple and plain terms, with a consistent and evidence based foundation.

Further, as noted in our previous submission, the media strongly influences public opinion.Therefore, in order to ensure a high level of consistent and effective drug policy, there is a need todevelop strategies to engage with the media with the aim of encouraging them to commit toaccurate and responsible reporting of AOD issues. The NDS has actioned this point. We would,however, urge the Ministerial Council on Drug Strategy to include strategies outlining a process tocommunicate sound evidence based policy and advice to politicians.

Recommendations

Develop a communication strategy which provides clear, consistent messages to politicians aboutthe work of the NDS and the AOD sector more broadly.

Encourage and lead informed community debate about drug issues and approaches forresponding to drug related harm.

Ensure all NDS funded health promotion and education campaigns are developed in consultationwith AOD expert input (including service provider input) and provide nuanced, well evidencedmessages to address drug related harms.

Knowledge gaps

We reaffirm the recommendations contained in our previous submission to the NDS regarding gapsin knowledge.

VAADAbelieves that there is a need to undertake a comprehensive analysis of the harms associatedwith incarceration of people who have experienced harm through substance abuse. The NDS


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acknowledges that these people have endured significant harm. However, it does not outline aprocess to mitigate those harms or the compounded harms associated with having served a prisonsentence. We recommend that strategies to mitigate the compounded harm associated with servinga prison sentence be outlined in the NDS.

Recommendations

Build the evidence bases for prevention and law enforcement initiatives and strategies.

Build the knowledge base for addressing alcohol and drug use among refugees and newly arrivedcommunities, including specifically how treatment and other services can better engage withthese groups.

Enhance the NDS focus on particular groups including: people transitioning back into thecommunity from correctional facilities; people transitioning back into the community fromresidential facilities; and rural and remote communities.

Increase the knowledge base for and wider awareness of the social and structural determinantsof drug use.

Implement strategies to mitigate the compounded harm associated with serving a prisonsentence with substance use issues

Allocate more energy and resources to diversion from the criminal justice system and support in

the community

Improved data collection

Our previous submission highlighted the limitations in data collection identified by our membership:

o Timeliness (reports on trends that have often passed)

o Level of detail (global data rather than local)

o Lack of useful return and feedback on local level data

o Need for a balance in the kind of data a better balance between statistical data;effectiveness and efficiency data and other outcomes measures

o Lack of consistency across jurisdictions

o Lack of availability of law enforcement data


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Recommendations

Identify measures to better assess outcomes and effects of treatment and other interventions.Any outcome measures must be developed in consultation with service providers and anyexpansion of data collection processes must be appropriately resourced.

Improve methods for national and State data collection and expand the scope and capacity of national data collections systems to produce accurate trend and outcome data and report backto agencies on local level trends and outcomes.

Improve access to law enforcement data for the purposes of evaluation and review.

Supporting the workforce

VAADAmembership is unanimously of the view that workforce development and capacity issues areparamount if the sector is to retain experienced staff and continue to be able to respond to theneeds of service users.

The NDS strongly commits to building workforce capacity and cites that an appropriate skilled andqualified workforce is critical to achieving and sustaining effective responses to drug misuse (NDS2010:29).

We note that a working group will be convened to develop a workforce strategy. We wouldrecommend that the working group is drawn from a wide range of organisations from the AOD

sector to ensure that the strategy is well informed and responsive to the sector s needs.

Funding and funding models

We reaffirm the discussion outlined in our previous submission regarding the funding models, whichhighlights the multiple treatment needs of service users presenting to AOD agencies. We note thatcurrent reporting models do not allow for agencies to adequately represent the work which they areundertaking in response to the diverse treatment and welfare needs of service users.

Our previous submission noted that there is a significant amount of administrative requirementswhich are not reported on, but consume resources, including quality accreditation processes,professional training and development, supervision, data collection and reporting, fundingapplications and administration, human resource management, and OH&S requirements. VAADAbelieves one way in which we can improve responses to clients is to develop flexible funding modelsthat allow services to manage complexity and emerging needs and trends, and that capture thescope of work undertaken (VAADA2010:19 20).


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Recommendations

Develop and implement alternative and best practice models for funding community based AOD services

Professionalisation, pay and conditions

VAADAcommends the NDS on the prioritisation of a set of minimum qualifications of workers andaccreditation of services. We further commend the NDS on the commitment to provide support forthe workforce and establishing and maintaining worker wellbeing. We anticipate that the nationalworkforce strategy will provide a comprehensive discussion and outline on the establishment andmaintenance of worker wellbeing and support.

We reaffirm comments regarding our proposal for the development of a national industry plan forconsideration in developing the national workforce strategy noted in the NDS.

Inconsultation with peak bodies, an industry plan would provide a framework for ensuring the AODworkforce is able to provide quality, effective treatment and harm reduction services into the future.It could support system and organisational change, serve to set a benchmark for quality andprofessionalism, and contribute to enhancing the profile of AOD professionals and work. An industryplan would enable identification of workforce capacity issues of cross jurisdictional significance, andcould be supported by strategies to address the need for specialisation, for greater diversity of skilled professionals, and to increase career pathways through the sector (VAADA2010:20).

VAADA is aware of the challenges facing regional AOD workers regarding accessing training and

remaining abreast of contemporary practice and knowledge. We therefore recommend that the NDSmake provision for the development of technology which will provide regional workers access toappropriate avenues of training and knowledge acquisition.

Recommendations

Support the development of an industry plan for the community AOD sector that will ensure theworkforce is able to continue to provide quality, effective services and sets the agenda foraddressing issues of workforce pay, employment conditions and parity with related sectors.

Facilitate rural and regional treatment staff access to technologies which will assist traininguptake, knowledge acquisition, and better integration of service delivery

Coordination and governance

As stated in our previous submission, VAADAbelieves the overall coordination and governance of the NDS could be improved by enhancing transparency and accountability within NDS structures andby increasing broader stakeholder participation and representation in NDS policy and decisionmaking processes. In particular, we believe there is a need for further engagement with AOD service


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providers and service users, and for stronger links between the AOD NGO sector and the NDS. Thereis also a need to build capacity to monitor outcomes of the NDS (VAADA2010: 21 22).

Policy coordination

As asserted in our previous submission, the coordination and oversight of national drug policy ishighly complex with a broad spectrum of stakeholder views, variance in practice between jurisdictions as well as changing political priorities.

We note that some of the sub strategies in the NDS have expired or are due to expire in the nearfuture. As we asserted previously, there is a need to ensure that all sub strategies are current andthat they are structured in a collaborative and strategic manner which minimises duplication of

scarce resources. Building on the need for collaboration, we reiterate our previous commentsregarding the need to align the NDS with a broader range of strategies which contend with relatedsocial and structural determinants of disadvantage, such as the Social Inclusion Agenda; nationalhomelessness strategies; taxation reform; education initiatives and health care reform (VAADA2010:22) . Meaningful collaboration equates to collaboration across sectors at all levels of government as well as the community services sector. As service users of the AOD sector do notpresent exclusively with AOD issues, strategies aiming to promote safe and healthy communitiesneed to acquire acumen from other related areas such as those suggested above.

VAADAreaffirms its views on the need for the NDS to include the significant work undertaken by theNational Preventative Health Taskforce. As stated in our previous submission, the NDS (and the nextNational Alcohol Strategy) should complement, not replicate, the work of the taskforce. We are of the view that there should continue to be a separate National Alcohol Strategy, as there are toomany challenges with alcohol use which deserve primacy.

Recommendations

Ensure coordination and integration of the NDS with NDS sub strategies including the NationalAlcohol Strategy. Consider developing the National Alcohol Strategy concurrently with theoverarching NDS.

Identify and prioritise the national social and health policies of relevance to the AOD sector andthe development of the next NDS.

Ensure the NDS is aligned with identified social and health policies.

Provide a rational, coordinated framework or action plan for the integration of identified policies

into service practice.


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Ensure the new NDS complements and builds on, rather than replicates, alcohol related policydirections and initiatives proposed by the National Preventative Health Taskforce.

Transparency

The NDS has not provided further discussion or an outlay of the processes for enabling public accessto policy decisions. The various governance structures and a synopsis of their roles andresponsibilities are included but the NDS provides limited commentary their decision makingprocesses and communication strategies.

Recommendations

Clearly articulate the various roles, responsibilities and aims of NDS bodies and make thisinformation publicly available via the NDS website.

Provide information on the various working groups of the IGCDand ANCDand make this publiclyavailable via the NDS website.

Publish documents on the governance of the NDS and its advisory bodies to enhance AOD sectorand wider community understanding of how the structures supporting the NDS operate.

Improve documentation of policy discussions, processes and decision making by the NDS bodies.

Consumer and service provider participation

The coverage of the IGCD and ANCD in the NDS provides scope for selective consumer and serviceprovider input and flexibility in the development of responsive working groups. However, thedevelopment of further formal mechanisms for consumer and service provider engagement islacking (beyond annual jurisdictional meetings facilitated by the ANCD). Our previous submissiondiscussed the need for greater consumer participation to be included in the NDS and we reaffirmthat view. Following from this, as discussed in our earlier submission, there is a need to ensure that

mechanisms are developed to provide feedback to all stakeholders, including AOD service providersand consumers (VAADA2010: 24).

Recommendations

Enhance engagement and direct dialogue with the AOD NGO sector.

Incorporate consumer representation and views into the NDS, potentially through national, stateand territory consumer organisations.

Provide regular updates on the implementation of NDS initiatives to all stakeholders.


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Performance measures and reporting

VAADAreaffirms its views outlined in the previous submission; major components of the NDS have

been developed with limited monitoring and evaluation, making it difficult to assess theeffectiveness and efficiency of various programs and initiatives (VAADA2010: 24).

There is a need for clear lines of responsibility with regard to reporting and evaluation measures forincumbent and developing sub strategies so responsibility for actioning policies is clearlydemarcated. Furthermore, there is a need to ensure that this information is transparent.

Recommendations

Define responsibility for the further development and implementation of NDS performancemeasures, monitoring and evaluation within the NDS structures.

Build monitoring and evaluation processes into the new NDS and sub strategies from the outsetas recommended in the Siggins Miller evaluation.

Findings from state/territory coronial jurisdictions

Coronial systems are part of the legal and justice landscape within each state and territory jurisdiction. Coroners are responsible for the investigation of unexpected deaths, or those whichhave occurred within certain institutions, such as hospitals and prisons. The role of the coroner is toidentify the deceased and ascertain the cause of death.

The coroner also has a public safety mandate, executed through the power to proposerecommendations with a view to death prevention. The power of these recommendations variesbetween state and territory jurisdictions.

VAADAbelieves that the Coroners Court has a significant community safety and preventative role.We believe that the health and safety benefits of the Coroners Court, with particular reference torecommendations, is not being utilised to full capacity in the AOD sector as well as within all levels of governmental policy development. We believe that there is a lack of awareness of the communitysafety and harm minimisation roles of coroners in the AOD sector, as well as a lack of understandingregarding the value which inquest findings and recommendations can make to positive policydevelopment.


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Accessing and utilising coronial findings aligns strongly with the principle of harm minimisation. Afurther benefit is that the findings are public, as is the process of inquiry and therefore has thecapacity to contribute a transparent and independent addition to AOD policy development.

VAADAbelieves that the NDS monitoring and governance bodies must access coronial findings andrecommendations which are relevant to the AOD sector. These findings and recommendationsshould inform the development of relevant policy.

The public generally has a limited understanding of the role of the coroner and generally are notaware of the death prevention aspects to the coroner s role. The NDS should develop strategies todisseminate those findings and recommendations which are relevant to the AOD sector into thewider community to derive public support for the development of effective AOD related policy.

Finally, the NDS should provide for the promotion of coronial findings to pursue systemic policyreform which will lead to a reduction in morbidity in the AOD sector. Coronial recommendationshave contributed strongly to death prevention in many areas of public life. Coronial findings andrecommendations have the potential to be a vital resource, given the high prevalence of morbidityamongst AOD service users.

Recommendations

Develop a process in which NDS monitoring and governance bodies can access any coronialfindings from all state/territory jurisdictions which have relevance to the AOD sector

Review and strongly consider relevant coronial findings in implementing and executing relatedpolicies

Lead a public discourse promoting coronial findings which aim to reduce the harm associatedwith alcohol and drug use

Use this evidence to pursue systemic and policy changes with a view to reducing morbidity


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Documents

VAADA: Response to the National Drug Strategy 2010-2015