Key Concerns

When Rape & Domestic Violence Services Australia made the decision to withdraw from the 1800RESPECT Trauma Counselling Service, it was not a decision that was made easily or lightly.

Rape & Domestic Violence Services Australia withdrew from the 1800RESPECT contract with Medibank Health Solutions due to several key concerns.


Privacy and confidentiality concerns

  • The handover of existing client file notes

The new 1800RESPECT contract written by Medibank required Rape & Domestic Violence Services Australia to handover all client file notes resulting from the past six years of counselling for the 1800RESPECT service. We firmly believe that this would breach client confidentiality and contradict Australian privacy legislation.

This requirement causes even greater concern due to Medibank’s position that they will not evoke communications privilege to protect client confidence. Medibank have also provided limited guarantees for the protection of counselling notes if Medibank were to be sold. It is the view of Rape & Domestic Violence Services Australia that this requirement of the contract cannot be met legally or ethically.

  • The recording of client file notes on the Medibank system

The new 1800RESPECT contract requires that counsellors do not keep client file notes. This directly conflicts with the practice requirements of the professional associations with whom counsellors hold membership. These professional associations require counsellors to be personally responsible for how their client file notes are stored and protected.

The new 1800RESPECT contract also requires that all new client file notes are recorded on the Medibank IT system, called Aladdin. However, in 2010 when Rape & Domestic Violence Services Australia first joined the 1800RESPECT service, Medibank and Rape & Domestic Violence Services Australia each conducted reviews of Aladdin and concluded that this technology would NOT suit the needs of a specialist trauma counselling service.

The technology selected by Medibank (Aladdin) is unsuitable for the requirements of a specialist trauma counselling service as it does not provide for the attachment of file notes, reports, notifications, therapeutic plans, and clinical care networks to a client intake sheet.

  • Recording of phone calls

Rape & Domestic Violence Services Australia is deeply concerned that the new contract would require counsellors to sign an agreement directly with Medibank for their counselling calls to be recordedCallers to 1800RESPECT may now experience not only the written documentation being provided to the Courts but they may also experience release of the voice recording.

Sexual assault and domestic violence services have worked over many years with government to establish communications privilege to protect client’s therapeutic records from being misused in legal proceedings. Medibank holds a position that it will not engage in communications privilege actions when client files are subpoenaed.

Working under the Medibank Counselling model

  • Counselling manual

The 1800RESPECT Trauma Counselling Service sub contract required Rape & Domestic Violence Services Australia to agree that staff will provide the trauma specialist counselling service within the Medibank counselling manual. A copy of this manual for review was requested, but was never provided. On separate occasions, Medibank has claimed that the manual would be provided once the contract was signed, or that the manual would be developed by the service providers.

If Rape & Domestic Violence Services Australia had agreed to the contract, we would have been committing our counsellors to work within a counselling model that we did not know the details of and could not ensure was best practice in advance of signing the contract.

Rape & Domestic Violence Services Australia has an evidence-based and best practice counselling manual. The first edition was prepared over a two-year period and included national and international reviews of evidence in relation to sexual assault domestic and family violence trauma, consultation with Australian practitioners, and stakeholder reviews. The two subsequent reviews of the manual were completed over two 12-month periods in 2009 and 2014.

It is the view of Rape & Domestic Violence Services Australia that a counselling manual that reflects evidence and best practice cannot be developed in the time frame described by Medibank, or if it has been developed has not undergone the rigorous practitioner and stakeholder review required of such an important document.

  • Supervision, coaching, and orientation

The1800RESPECT Specialist Trauma Counselling sub contract states that Medibank will provide staff coaching. Coaching is not a recommended clinical practice for counsellors. The professional associations that our counsellors are registered with (APS, AASWA, CAPA) all require clinical supervision.

Clinical supervision is currently provided by Rape & Domestic Violence Services Australia in house by qualified supervisors for all of our counsellors. It is of considerable concern that any downgrading and outsourcing of this practice, which is critical to quality service provision, might considerably reduce the current excellence in the service provided.

  • New service delivery model

The 1800RESPECT Specialist Trauma Counselling contract directs that there will be up to four trauma counselling service providers. Medibank has stated that calls will be referred to the trauma counselling service based on counsellor availability.

Rape & Domestic Violence Services Australia holds considerable respect for the service providers nominated and the work that they undertake. There will however be significant difficulties in maintaining any form of consistent counselling service delivery under this model.

The current two service system of 1800RESPECT has resulted in substantial challenges in meeting client needs in a respectful and coordinated way with many of those challenges continuing 12 months past the introduction of the model.

Rape & Domestic Violence Services Australia holds significant concerns for the capacity of five providers to ensure consistency, quality and continuity of counselling service to clients.

It is the view of Rape & Domestic Violence Services Australia that the five service model proposed creates a substantial risk that the 1800RESPECT Trauma Counselling service will become a one off information and referral intervention. For clients who ring multiple times there is a considerable risk that consistency in service provision may be adversely impacted.

  • Elimination of the Recontacts service

As with all trauma counselling services that work with those who have experienced sexual assault, domestic or family violence, there are clients who are experiencing trauma impacts and those who are experiencing complex trauma. Many from both groups will also present with co-morbidities, which means that our clients are often struggling with other impacts such as mental health, drug and alcohol addiction, homelessness, and isolation, related to the trauma caused by sexual assault or domestic violence.

Clients who are suffering from complex trauma have often experienced sexual assault in childhood and then experienced further violence, both sexual and domestic, in adolescence and adulthood. For these clients their stage of recovery at the time of contact means that accessing face-to-face counselling services is not currently within their capacity. Rape & Domestic Violence Services Australia, in recognition of the specific needs of this client group, established the Recontacts line.

Where a client is assessed to be experiencing complex trauma they are referred to the Recontacts service. As a Recontact client, the counselling service is further tailored to their specific needs. It is noted that many of these clients often hold active suicidal ideation, and have regular engagement with mental health services and emergency services. Currently there are 600 clients engaged in the Recontacts service with approximately 200 of those being current regular callers.

The new contract eliminates the Recontacts service, a vital support for some of Australia’s most violently treated and vulnerable citizens.

Workplace Arrangements

  • Counsellor management

The requirement that orientation and coaching will be outsourced is also concerning in many respects, including from a WH&S perspective.

The required outsourcing of coaching, orientation and professional development would lead to a two-tiered counselling service at Rape & Domestic Violence Services Australia and dramatically impact on the employer-employee relationship between Rape & Domestic Violence Services Australia and the 1800RESPECT counsellors.

  • Shift arrangements

The 1800RESPECT Trauma Counselling contact states that on a three monthly basis Medibank will provide Rape & Domestic Violence Services Australia, along with the other providers, the roster they will be required to fill for the coming three months.

This means that staff cannot be offered permanent shifts or in fact any guarantee of regular work.

It is noted that Rape & Domestic Violence Services Australia employs in its clinical service people who hold a four year Social Work or Psychology degree or equivalent, who have considerable counselling experience, and have participated in further professional development beyond their degrees. Most have family and financial responsibilities.

The casualisation of their employment through lack of predictability of work times and hours as proposed in the contract will make continuing employment and recruitment difficult. The contract proposes a disrespectful way to treat highly skilled and committed staff.

It is well recognised that in all areas of endeavour, skilled and committed staff are critical to quality outcomes and the success of the entity. It is the view of Rape & Domestic Violence Services Australia that the proposed treatment of staff is not a precursor to a respectful employer employee relationship or to the achievement of quality in service provision.

  • Cash flow

In 2012, Medibank worked with Rape & Domestic Violence Services Australia to establish the service cost per counsellor FTE. With pay equity and CPI accruals since that time the cost in the 2016/17 year is $250,000 per FTE.

The new 1800RESPECT Trauma Counselling Service contract offers $160,000 per FTE.

The contract is unclear on payment of invoices and can be read as payment being from 30 to 60 days post provision of the service.

Rape & Domestic Violence Services Australia does not hold the cash reserves required cover payments in arrears of up to $320,000.

Additionally, to accept the 1800RESPECT Trauma Counselling Service contract Rape & Domestic Violence Services Australia would need to undertake considerable fund raising to subsidise participation in the national service.

Alignment of Values

  • Alignment of Values with the National Plan to Reduce Violence against Women and their Children, the findings of Our Watch, the values of sexual assault and domestic violence services in Australia, and the international evidenced position of organisations such as the United Nations and the World Health Organisation.

The 1800RESPECT Specialist Trauma Counselling sub contract and engagement with Medibank over recent years has repeatedly highlighted a de-gendered analysis of the crimes of sexual assault and domestic and family violence. This reduction in analysis has also resulted in a loss of the response to the power and control dynamics of the crimes, the importance of understanding and working with clients to recover from the impact of those dynamics, and the necessity of empowerment in the recovery process.

As Rape & Domestic Violence Services Australia was able to provide the trauma counselling services within its evidence based counselling practices, which fully incorporates such concepts, the impact of the increasing de-gendering of the service by the lead agency has been somewhat contained.

Rape & Domestic Violence Services Australia seeks to state that it recognises and affirms that the other provider services adhere to and will seek to provide the trauma counselling service within a gendered, evidence based, power and control framework.

The concern held by Rape & Domestic Violence Services Australia is that the lead agency does not hold or operate with reference to these fundamental concepts. This lack of commitment to a gendered analysis and the national and international position in relation to violence against women will impact on the service.

Additionally, in public communications and the contract negotiation, Medibank has clearly indicated that their primary concern is the number of calls being answered – with no reference to the quality of therapeutic interventions for clients.

  • Systems Advocacy

As the new contract is limited to funding counselling positions only, the loss of systems advocacy is a considerable concern.

NGOs have many roles and responsibilities, one being to represent the voices of those made vulnerable by their circumstances in the democratic process. If NGO voices are silenced through privatisation or contracts that ‘gag’ systems advocacy, the only voice that will be heard will be those of the powerful.

Such an imbalance will undermine many of the values we know are critical to a thriving democracy such as human rights, social justice, equity, and the elimination of violence against women.

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