4.1
This chapter sets out the Committee’s findings in relation to the inquiry into Mental Health in the Australian Federal Police, based on Auditor‑General Report No. 31 (2017‑18), Managing Mental Health in the Australian Federal Police. It comprises the following sections:
Committee conclusions and recommendations
Committee conclusions and recommendations
4.2
As the Australian Government’s primary policing agency responsible for the enforcement of Commonwealth laws and the protection of Australian interests from criminal activities, the Australian Federal Police (AFP) delivers a diverse range of functions and operates in a high risk environment for employee mental health.
4.3
The AFP recognises that sixty‑six per cent of AFP employees will experience a potentially traumatic event at some stage during their career. According to Safe Work Australia, first responders such as police services, paramedics, and fire fighters, were the combined occupational group most likely to make a psychological injury workplace compensation claim.
4.4
The Australian National Audit Office (ANAO) undertook a performance audit to examine the effectiveness of the AFP in managing employee mental health. The selection of the audit reflected the increasing rates of AFP employee Comcare psychological claims, and the risks and costs involved in AFP’s management of employee mental health.
4.5
The audit criteria focused on AFP’s governance and risk management practices, monitoring and evaluation arrangements for mental health, and support services for AFP employees throughout their career lifecycle. The audit examined the AFP’s high level management and coordination of programs supporting mental health. The ANAO audit made six recommendations and the AFP agreed to all recommendations, stating that the AFP ‘recognised the need for enhanced mental health and support’.
4.6
The Committee commends the AFP for the work undertaken to date to improve its management of employee mental health, and acknowledges that the AFP began improvements prior to the ANAO audit. The Committee noted the strength of the AFP’s response to the ANAO recommendations, and acknowledges that the AFP is involved in broader organisational change, including challenges in relation to its budget and resource management, and is undertaking the implementation of recommendations from various internal and external reviews. In addition to the ANAO audit tabled on 7 March 2018, the AFP has undergone a number of reviews in recent years, as in Table 4.1 below.
Table 4.1: AFP reviews
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Culture Change: Gender Diversity and Inclusion in the Australian Federal Police
(the Culture Change Review)
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2016
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Functional and Efficiency Review of the Australian Federal Police
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2016
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Internal review of the Confidant Network
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2017
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AFP Structural Review, Reform and Policy Development on Mental Health Review
(the Phoenix Review)
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2017
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Draft 2017 AFP Mental Health Review
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2017
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KPMG review of the AFP governance framework
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2017
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Internal review of the AFP committee structure
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2017/18
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Source: ANAO Report No. 31 (2017-18)
4.7
The Committee notes that the AFP has developed the Health and Wellbeing Strategy 2018‑2023 in order to incorporate recommendations from two key assessments of the AFP’s management of employee mental health: the ANAO audit and the Phoenix Review. The Health and Wellbeing Strategy states that the AFP also developed an accompanying AFP Health and Wellbeing Implementation Plan which details specific ‘projects, timelines and responsibilities’.
4.8
The Committee considers that the implementation of recommendations from various reviews must be accompanied by an implementation plan with clearly defined lines of accountability, milestones, performance measures, and monitoring, reporting and evaluating arrangements. This will assist in ensuring a comprehensive organisational response to the consolidation of multiple review recommendations and outcomes at a time of organisational change.
4.9
The Committee recommends that the Australian Federal Police report back to the Committee to outline progress on the implementation of recommendations from all reviews undertaken since 2015 that are relevant to AFP’s management of employee mental health, including, but not limited to, ANAO Report No. 31 (2017‑18), the Phoenix Review, the Culture Change Review and the Draft 2017 AFP Mental Health Review.
4.10
The Committee notes that the Phoenix Review identified staff concerns about a reduction in resources for psychological support services. At the public hearing, the AFP stated that it was ‘seeing discussions around budget reduction and staffing number reduction having an impact on members’ morale’. The Committee notes evidence provided by the AFP Commissioner in Senate Estimates that staffing and resourcing at the AFP had fallen in recent years, however acknowledges that ongoing discussions between the AFP and the Government regarding lapsing funding may ameliorate the situation.
4.11
The Committee notes that the AFP has undertaken recruitment activities throughout 2017 and 2018 in order to employ more psychologists. The AFP is aiming to improve the staffing ratio of mental health professionals – such as psychologists and social workers – to one to 250 employees. Considering natural turnover and that the AFP is aiming to recruit personnel that have an understanding of law enforcement, the Committee is interested in the AFP’s progress in improving the staffing ratio.
4.12
The Committee recommends that the Australian Federal Police report back to the Committee in August 2019 on:
an update of the overall budget situation for the AFP taking account of the 2018-19 MYEFO and the 2019-20 Budget decisions and forward estimates;
the number of mental health professionals employed by the AFP as at 30 June, for each year from 2016 to 2019;
the staffing ratios of mental health professionals to AFP employees, against each of the years as above; and
the allocation of mental health resources to identified mental health needs.
4.13
The Committee notes that the Health and Wellbeing Strategy provides evidence that the AFP intends to improve internal governance frameworks. The AFP has established a dedicated People Committee focused on ‘strategic people issues, including health and wellbeing’. However, the ANAO outlined that the structure and co‑ordination of business areas could be strengthened and concluded that the AFP had not established ‘a clear governance structure for decision‑making, information sharing and oversight in relation to employee mental health arrangements’.
4.14
The Committee recommends that the Australian Federal Police report back to the Committee on its progress towards improving governance arrangements for employee mental health at the organisational level.
4.15
The Committee notes the ANAO concluded that ‘the AFP does not have arrangements to ensure resources and funding are aligned to key mental health risks’ and has recommended the AFP address this issue (Recommendation 2). The Committee has recommended (Recommendation 7) that the AFP report back on progress in implementing all of the ANAO’s recommendations.
4.16
The Committee further notes that the AFP had commenced activities in order to address the need for the improved identification of mental health and physical injury risks across the AFP. The Committee is interested in the AFP’s informal pilot project designed to ‘link disparate data sources to track employee exposure to critical or potentially traumatic incidents’. The Committee also notes that the AFP is aware that long‑term exposure to explicit material is associated with potential health risks for AFP employees.
4.17
The Committee recognises that prevention and early intervention is of vital importance to supporting mental health and wellbeing. In implementing the ANAO recommendations as part of the Health and Wellbeing Strategy, the Committee considers that the AFP has the opportunity to implement formal monitoring and reporting arrangements around employee exposure to traumatic incidents and exposure to explicit material.
4.18
The Committee recommends that the Australian Federal Police:
report back to the Committee on the outcomes of the informal pilot project on identifying the exposure of AFP employees to traumatic events;
in implementing Recommendation No. 4 of the ANAO audit:
consider developing formal processes to monitor and report on the AFP employee exposure to traumatic events and exposure to explicit material; and
strengthen formal processes to monitor and provide assurance that employees, before moving into specialist roles, have appropriate psychological clearances.
Review of evidence
4.19
This section sets out the Committee’s review of evidence in the following areas of interest:
Psychological injury: prevention, identification and return to work; and
Mental health support services.
Resourcing and Funding
4.20
In response to the ANAO audit report findings and recommendations, the AFP Commissioner explained that:
As an organisation, we acknowledge that the AFP needs to change in order to meet the growing demand and complexity of the environment in which the AFP operates. Even within current staffing levels, the AFP is working under immense pressure and ongoing activity at current operational tempo will increase health risks for its staff.
4.21
During Senate Estimates in May 2018, the AFP confirmed that in terms of the 2018‑19 budget, there was a reduction of $205 million over the forward estimates and a reduction in AFP’s annual appropriations for ASL from $6,448 in 2018‑19 to 5,881 in 2021‑22. This staffing and resourcing reduction is due, in part, to programs that lapse or terminate over the forward estimates and which require ongoing discussion about renewal, transfer or adjustments. The AFP Commissioner indicated that in terms of considering how to meet the budget, his priorities included investing in officer support and improving ‘some of the areas that various reviews have said we need to work on’.
4.22
At the public hearing for this inquiry, the AFP stated that although the budget was unclear beyond the financial year, the AFP was ‘seeing discussions around budget reduction and staffing number reduction having an impact on members’ morale’. In response to the Committee’s query on AFP’s investment into mental health, the AFP advised that it has increased ‘investment in health related support since the 2015-16 Financial Year’ and that it ‘spent approximately $8.3 million on employee costs and $17.1 million on suppliers to support health related outcomes’ in 2017‑18 and a similar investment is expected in 2018‑19.
4.23
The Psychological Services team is one of seven mental health support services and undertakes a range of psychological functions in the AFP. The ANAO audit found that as at October 2017, the ACT‑based team consisted of six registered AFP psychologists and two social workers. These staff were responsible for undertaking or oversighting ‘all mandatory health assessments, mandatory psychological clearances for specialist roles (pre‑employment psychological clearances are outsourced), mandatory debriefs, and training for AFP staff nationally and internationally’.
4.24
The Phoenix Review reported that feedback from staff at all levels of the AFP in regards to Psychological Services indicated that ‘the responsibilities and demands placed upon the service were too high given their limited resources’. The Phoenix Review identified staff concerns about the ‘perceived cuts to welfare and psychological services over the past decade’ and stated that ‘there were no regionally based psychological services’. According to the Phoenix Review, FTE and resources for psychological support services have decreased from 23 FTE to nine in the past decade.
4.25
The Royal Australian and New Zealand College of Psychiatrists (RANZCP) noted the potential contribution that health professionals, in particular psychiatrists, may bring to organisations. This includes providing support, expert advice, and valuable insights regarding mental health training frameworks and improving workplace awareness and attitudes towards mental health. RANZCP also explained that psychiatrists have extensive experience and knowledge on the risks faced by employees in first responder organisations. RANZCP recommended that:
The AFP should increase the roles and input of psychiatrists in their organisation, including increased consultation with psychiatrists to ensure programs and services are appropriately designed and targeted.
4.26
The Phoenix Review also noted the potential value that health professionals may have regarding organisational strategy. The Phoenix Review noted that although the Mental Health Strategy Board (the Board) established by the AFP is administrative rather than clinical, it recommended that the Board’s ‘role in shaping the mental health strategy indicates that the Board should include at least one mental health professional’.
4.27
At the public hearing, and in response to the ANAO audit and the Phoenix Review, the AFP advised that it has ‘made a commitment to increase resources, particularly around psychologists and mental health professionals, to support the workplace’. The AFP noted the aim to recruit psychologists that ‘have a strong appreciation of law enforcement’ and indicated that the AFP would increase staffing ratios for mental health professionals to a ratio of one to 250 employees. This would be an improvement from a previous approximate ratio of one psychologist/social worker for every 723 AFP staff. The AFP also stated that the recruitment activities for psychologists and social workers have ‘been directed towards regional presence staffing’.
4.28
Following the public hearing, the AFP provided further detail regarding the recruitment activities undertaken to employ psychologists. The AFP recruited one psychologist in 2017 and another three psychologists commenced employment between August and October 2018. The AFP also recently finalised the recruitment of a further five psychologists on 13 September 2018, and is currently processing a clearance for an additional psychologist and undertaking a selection process for a chief psychologist.
Comcare claims
4.29
AFP employees may seek support to recover from injury or illness by lodging a claim for compensation with Comcare. Comcare makes a determination to accept or reject an injury claim under the Safety, Rehabilitation and Compensation Act 1988. The ANAO found that in recent years, there has been an increase in the number of Comcare claims for psychological injury and the costs claimed by employees that are related to psychological injury:
In 2007‑08 there were 11 AFP claims related to psychological injury that were approved by Comcare at a cost of $2.8 million. By 2016‑17 this had increased to 35 claims approved with an associated cost of $16.7 million.
4.30
The ANAO noted that the Comcare data available only included accepted claims for psychological injury and did not include AFP employees who did not report psychological injury to Comcare.
4.31
In 2016‑17, the AFP’s total insurance premium was $33,774,832 and, of the total claim numbers, 25% were for psychological claims. The growing Comcare premium and the increasing cost and number of accepted psychological injury Comcare claims resulted in the AFP formally recognising mental health as a strategic risk to the organisation in October 2016.
4.32
At the public hearing, the Committee noted the increase in the number of Comcare claims for psychological injury. The Committee requested that the AFP provide a response as to whether investments into mental health support and other recent changes are expected to lead to a decrease in the number of Comcare claims for psychological injury. The AFP responded that:
In relation to the Comcare claims, the high risk nature of the operational work undertaken by AFP employees carries an inherent risk of psychological harm and/or injury. The health and wellbeing strategy seeks to put in place support to minimise injury.
Governance
Health and wellbeing strategy
4.33
In September 2016, the AFP developed a draft Mental Health Framework and a Mental Health Strategic Action Plan with the aim to ‘reset the direction in the AFP for mental health’. In March 2017, the AFP commenced a review of the AFP’s mental health support services. The draft framework and the action plan were to be finalised and approved depending on the outcome of this review.
4.34
The ANAO concluded that the AFP did not have ‘an organisational health and wellbeing strategy which incorporates policies, programs and practices to address mental health risks’. As a result, the ANAO recommended that:
The AFP develop a comprehensive organisational health and wellbeing strategy and governance arrangements based on an integrated approach to staff mental health and wellbeing which incorporates policies, programs and practices that address the AFP’s specific risk profile.
4.35
The AFP developed a Health and Wellbeing Strategy 2018‑2023 and launched it to the organisation on 15 May 2018. The Health and Wellbeing Strategy outlines three key objectives to be achieved over a five‑year period:
Health protection: all our people are committed to self‑care and our leaders are educated and supportive of delivering a culture of health.
Health intervention: timely access, irrespective of location, to appropriate support options for all our people.
Health frameworks: a governance structure of standards and quality assurance, partnered with industry experts.
4.36
The AFP also developed an accompanying document, the AFP Health and Wellbeing Implementation Plan, which includes ‘specific projects, timelines and responsibilities’.
Governance arrangements
4.37
The ANAO outlined that at the organisational level, AFP employee mental health was delivered through seven support services. The delivery of the support services was managed by two separate business areas, National Manager Reform, Culture and Standards, and Organisational Health.
4.38
The ANAO found that there was ‘no formalised governance mechanism to support co‑ordination, information sharing and reporting between the two interrelated areas’. As a result, the audit identified concerns regarding AFP’s ability to identify employees at risk and to coordinate the AFP’s activities to address employee mental health. The ANAO concluded that:
AFP has not established a clear governance structure for decision making, information sharing and oversight in relation to employee mental health arrangements. This includes both organisational and committee arrangements.
4.39
Other reviews undertaken by the AFP have suggested improvements to AFP’s organisational governance framework. In regards to the AFP’s mental health policy framework, the Phoenix Review recommended the AFP develop a policy and procedure document which included an outline of the role of each component of staff support services, the relationships between each component, and the governance arrangements.
4.40
At the public hearing, the Committee requested an update regarding AFP’s actions to improve ‘governance structures for decision making, information sharing and oversight’. In response, the AFP referenced the 2017 KPMG review of AFP’s governance framework and explained that the review involved the examination of the AFP’s ‘governance structures holistically, not just governance structures around employee health’. The AFP outlined:
That KPMG piece of research around our governance framework rightly highlighted that we had complexity and, as the Auditor General said, we had many different committees involved in many different parts of employee wellbeing, which could contribute to confusion or a lack of clear decision authority…we are now in the process of transitioning into a new, simplified governance structure which reduces the number of committees.
4.41
The AFP’s response at the public hearing focused on changes to the AFP’s governance structure at the committee level and did not address whether improvements were planned or being made at the organisational level. However, the Health and Wellbeing Strategy outlines that the AFP will create an Organisational Health strategic and governance framework by using a risk based approach. Organisation Health will be re‑designed and the AFP will implement ‘a new service delivery model adopting core, contingent and partnership mode with enhanced regional footprint’.
4.42
The ANAO audit found that at the committee level, both nationally and regionally, there were a range of committees with functions relevant to AFP’s organisational and mental health. The ANAO’s analysis found that it was unclear as to ‘which committee has the primary responsibility for the governance of employee mental health and wellbeing’.
4.43
The Functional and Efficiency Review of the AFP also identified concerns with the clarity of committee accountabilities, responsibilities and discipline. Additionally, an internal review of the AFP’s committee structure was underway and not yet finalised at the time of the ANAO audit.
4.44
At the public hearing, the AFP outlined that in response to the findings of the KPMG review and the ANAO report, the AFP is now ‘transitioning into a new, simplified governance structure which reduces the number of committees’. In July 2018, the AFP commenced implementing a ‘realigned three tier committee framework’ with a dedicated People Committee focused on ‘strategic people issues, including health and wellbeing’. The People Committee consists of eight members and reports to the executive board, which is chaired by the AFP Commissioner. The People Committee focuses on the management of people matters and compliance with internal and external requirements, which includes the Health and Wellbeing Strategy.
Risk management and aligning resources
4.45
At the entity level, the AFP formally recognised mental health as a strategic risk in October 2016. As at August 2017, mental health injury was identified as one of 22 entity level risks on the AFP’s Enterprise Risk Profile. Mental health injury was considered a ‘High’ risk and the AFP has documented risk controls and treatments. However, of the nine planned risk treatments, only two are expected to be implemented in 2017–18 and five are not due until 2022.
4.46
The ANAO found that risk assessments and treatment plans at the functional level did not reflect the identification of mental health injury at the entity level. Further, within the functional areas that did identify employee mental health as a concern, ‘there remains scope to improve the specificity of controls and treatments’, although more recent treatments did list precise actions and interventions.
4.47
The ANAO outlined that the AFP’s Organisation Health team had commenced activities in order to address the need for the improved identification of mental health and physical injury risks across the AFP. This included seconding a staff member from AFP’s Strategic Risk section and developing an informal pilot project aimed at examining work stresses in operational areas identified as potentially high risk.
4.48
Organisational Health (under National Manager, People, Safety and Security) is allocated centralised funding to undertake core mental health activities for all AFP employees. In terms of functional and geographical areas, each area is allocated an annual operating budget and each area allocates resources to employee mental health. However, there was no specific funding amount allocated to employee mental health in these areas and no visibility over how much is actually allocated to employee mental health. The ANAO concluded that ‘the AFP does not have arrangements to ensure resources and funding are aligned to key mental health risks’.
4.49
ANAO Recommendation No. 2 stated that:
The AFP analyse, define and report on mental health risks across the organisation in a consistent manner and develop arrangements to align employee mental health and wellbeing resources to areas assessed as highest risk. During this process, the AFP should also assess the effectiveness of the existing controls and treatments used to mitigate mental health risks.
4.50
At the public hearing, the Committee queried whether employee mental health resources were allocated appropriately to regional areas. In response, the AFP explained that it had moved to a new model for mental health resources in regional areas that now involves direct reporting to ‘an area within Canberra that had professional guidance and oversight to ensure that service delivery was appropriate in terms of health’.
4.51
The AFP’s Health and Wellbeing Strategy outlines that the AFP will ‘develop arrangements to align employee health and wellbeing resources to areas assessed as highest risk’ and also ‘define a holistic risk assessment framework which identifies and monitors health risks across the AFP workforce’.
Psychological injury: prevention, identification and return to work
Preventing psychological injury
4.52
As part of managing employee mental health and ensuring that employees meet the physical and psychological competencies required by AFP work, the AFP undertakes psychological assessments. Psychological assessments aim to assess employee psychological preparedness for AFP work, and must be conducted at pre‑employment and prior to an internal employee transferring to a specialist role.
4.53
The ANAO outlined that although psychological assessments were being undertaken consistently for pre-employment, they were not undertaken consistently for existing employees transferring to a specialist role in the AFP. The ANAO conducted analysis to examine the psychological assessment process for the Joint Anti Child Exploitation Taskforce (JACET). The ANAO found that ’34 per cent (13 of 38) of current JACET employees did not have a recorded psychological clearance registered against their name’.
4.54
The ANAO report outlined that the AFP was previously notified of non‑compliance with psychological assessment procedures. In October 2017, the AFP Mental Health report stated that ‘on several occasions Psychological Services have been requested to clear members after they have commenced in Child Protection Operation roles…Psychological Services have reminded Coordinators of the importance of clearance prior to exposure’. In 2015, an AFP minute paper noted that ‘there were identified instances where business areas, in trying to meet their outcomes, decided to progress with an individual for a task who had not cleared employment gateways’.
4.55
The ANAO recommended that the AFP ‘develop formal processes to monitor and provide assurance that employees in specialist roles have their psychological clearance in place before commencing in the role’. In response to the recommendation, the AFP stated that it is ‘currently reviewing all employees who hold positions in high risk areas to ensure that appropriate screening and assessment has been undertaken. Work has also commenced to ensure that all associated employee records are up to date to reflect any screening, assessment and/or debriefing’.
4.56
At the public hearing, the AFP stated that ‘every person who works in the child exploitation area is psych assessed before they start’ and that this screening process is ‘an ongoing review; it doesn’t just happen once’. Further, the AFP’s Health and Wellbeing Strategy outlines that the AFP will ‘develop a formal process to monitor and provide assurance that employees in specialist roles have their gateway clearance in place before commencing in the role’.
4.57
In addition to psychological assessments, training aimed at improving employee awareness and resilience is another key method for preventing psychological injury. At the time of the audit, Psychological Services provided training, if requested by a business area, for the purpose of supporting ‘specific operational requirements or as part of preparation for overseas deployment’. The Psychological Services team developed and delivered a series of 31 courses on an ad‑hoc basis between 2010 and 2017. The ANAO found that ‘the AFP does not have a specific mental health training framework aimed as a pre‑emptive measure to improve employee resilience’, and the AFP’s leadership programs did not include mandated mental health literacy content.
4.58
At the public hearing, the Committee noted concerns regarding the trust deficits in AFP’s workplace culture and ensuring that the AFP Commissioner’s focus on mental health is pushed down through senior management. The Committee queried whether the AFP is measuring and monitoring workplace culture. In response, the AFP outlined that it has introduced a mental health first aid program which has been specifically tailored for the AFP’s law enforcement environment. The AFP explained that the program included a focus on AFP employees identifying signs in themselves and in their buddy or colleague, and understanding where to seek assistance. The AFP acknowledged the role of stigma and outlined that ‘as the health literacy of the workforce improves, we would hope that more people come forward because they feel safe and secure in disclosing that either they or their colleagues are struggling’.
4.59
The AFP’s Health and Wellbeing Strategy outlines that as part of the strategic objective of health protection, the AFP will ‘develop a health education framework tailored to the AFP career lifecycle’ because ‘education enhances health awareness and challenges stigma’.
Identifying psychological injury
4.60
In order to identify AFP employees at risk of psychological injury, the AFP has developed a number of key mechanisms that the ANAO found were affected by limitations, as in Table 4.2 below.
Table 4.2: Identifying psychological injury: mechanisms and limitations
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Employee self‑reporting
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Workplace stigma around mental illness, the perception that firearms will be removed, and concerns about career prospects and confidentiality
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Supervisor observation
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Limited training and support for supervisors in identifying and supporting employees at risk
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Mental health assessments and psychological debriefs
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Inconsistent delivery and tracking of mandatory mental health assessments and psychological debriefs
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Source: ANAO Report No. 31 (2017-18), pp. 40-41.
4.61
Mental health assessments consider employees’ psychological status by comparing an employee’s incoming testing results to previous results, and are the ‘key mechanism to manage an employee’s risk of psychological injury once they are in the role’. The Psychological Services team undertakes mandatory mental health assessments for employees in specialist roles. AFP policy is for mental health assessments to be conducted annually; employees in the role for less than two years must undertake additional mental health assessment screening tests. Mental health assessments are also mandatory on exit or re‑entry to the specialist role.
4.62
The ANAO’s analysis of ‘AFP employees currently working in the Joint Anti Child Exploitation Teams (JACET) showed that 26 of the 38 team members were in breach of the requirements’. Further, audit fieldwork and the submissions received indicated that ‘mental health assessment do not occur routinely, particular in relation to exit assessments’.
4.63
Psychological Services is also responsible for conducting psychological debriefs following AFP employee completion of long‑term deployments or overseas missions. The purpose of a psychological debrief is ‘to assess whether AFP employees are at risk in their role as well as providing a baseline measurement for the ongoing monitoring of their psychological wellbeing’. Psychological debriefs may be requested after a critical incident, but are mandatory after a long‑term deployment.
4.64
The ANAO ‘was unable to assess whether mandatory debriefs following a long‑term deployment occurred in all cases, as it was not evident how the AFP monitors whether deployed staff attend a briefing’. The ANAO also found that mandatory debriefs did not occur routinely for mission postings pre‑2010 and debriefs were also absent for more recent deployments. The ANAO recommended that the AFP ‘develop formal processes to monitor and provide assurance that mandatory mental health assessments and psychological debriefs are undertaken for all those that require them, in a timely manner’.
4.65
The AFP’s Health and Wellbeing Strategy outlines that as part of the strategic objective of health intervention, the AFP will ‘develop a two phased (upon return and subsequent) health and wellbeing screening for employees returning from overseas deployment’.
Explicit material and traumatic events
4.66
AFP employee exposure to explicit material is recognised as a psychological health and safety workplace hazard. The 2017 AFP Handbook: Managing the Psychological Health Impact on Staff from Explicit Materials (the Handbook) outlines AFP policy and procedure for managing the psychological and health impacts on AFP employees exposed to explicit material. The Handbook recognised the potential health risks associated with long‑term exposure to explicit materials. The ANAO suggested that the long‑term exposure of AFP employees to explicit materials should be monitored by the AFP.
4.67
The AFP recognises that sixty‑six per cent of AFP employees will experience a potentially traumatic event at some stage during their career. According to the draft 2017 AFP Mental Health Review, ACT Policing employees ‘have a higher rate of exposure to potentially traumatic events in their career than any other business area’.
4.68
The ANAO outlined that the AFP commenced an informal pilot process in 2017 to identify exposure of AFP employees to potentially traumatic events; the AFP was also examining the Safe‑T‑Net system used by the Victorian Police Force. The Safe‑T‑Net system is ‘an early intervention wellbeing support system designed to identify, record, and monitor our employees’ exposure to events that have the potential to impact their wellbeing’. Following the registration of an operational incident, the system is designed to trigger a welfare conversation between supervisor and employee.
4.69
The Royal Australian and New Zealand College of Psychiatrists suggested in depth consideration of ‘cumulative exposure to trauma and secondary trauma’ and undertaking mitigating strategies such as ‘tracking incident exposure and ensuring mandatory mental health checks following certain incidents’.
Claims processes and return to work
4.70
As discussed previously in paragraph 4.29, AFP employees may choose to lodge a Comcare claim when injury or illness occurs within the workplace. In the period 1989 to 2017, the ANAO found a higher rate of withdrawal of psychological claims as compared to non‑psychological claims during Comcare’s assessment processes. The ANAO noted that the higher withdrawal rates, anecdotal evidence from audit fieldwork, and the results of the draft 2017 AFP Mental Health Review, may indicate that ‘making a Comcare claim, when struggling with psychological injury, can exacerbate the injury and delay recovery’.
4.71
The Phoenix Review noted concerns in the feedback from AFP employees and family members regarding the Comcare claims process. The claims process was described as costly, stressful and adversarial. The Phoenix Review made six recommendations around interventions for staff with a mental health disorder, including Recommendation 21 which focused on the Comcare claims process:
Establish a patient‑centred approach to claims management in collaboration with Comcare to minimise the distress associated with injury claims and the associated potential for exacerbation of injury.
4.72
The AFP’s Health and Wellbeing Strategy outlines that the AFP intends to minimise the distress associated with the claims process, which will be achieved by working with Comcare to make the claims process easier for affected AFP employees. This action is intended to assist to normalise injury and illness, and ensure individuals feel supported in their recovery.
4.73
In terms of return to work arrangements, the ANAO outlined that general evidence from policing organisations showed employees have ‘a proportionately lower rate of return to work for psychological injuries than for physical injuries’. The draft 2017 AFP Mental Health Review ‘identified weaknesses in the AFP’s rehabilitation and return to work arrangements’ and ‘made a range of recommendations to improve the AFP’s rehabilitation and return to work processes for employees experiencing psychological injury’.
4.74
The Royal Australian and New Zealand College of Psychiatrists (RANZCP) suggested that AFP policies ‘should prioritise a rehabilitation first approach to mental health – aiming to return an individual to either their pre injury position or supporting their return to another role within the service’.
Mental health support services
Evaluation of mental health support services
4.75
The AFP offers seven support services with mental health support elements; Psychological Services, the Welfare Officer Network, the Employee Assistance Program, AFP Chaplaincy, Safe Place and the Confidant Network. The Organisational Health Triage team is also available, but was not examined by the ANAO as it commenced in July 2017.
4.76
The ACT‑based Psychological Services team, as discussed previously in paragraph 4.23, undertakes a variety of psychological functions including employee wellbeing training, debriefs, psychological assessments, and mental health assessments for AFP staff nationally and internationally. Available data included number of sessions delivered, and users of the service by geographical location and AFP portfolio.
4.77
The Welfare Officer Network consists of professional and sworn members of the AFP that are in full time welfare officer support positions. The primary role of a Welfare Office is to ‘be a conduit to professional support, advice and counselling on an as required basis’. In July 2017, the AFP expanded the Welfare Officer Network from two Welfare Officers supporting ACT Policing employees to 22 Welfare Officers nationwide. The ANAO found that there was no formal reporting or performance arrangements for ACT Welfare Officers and that performance data was not yet available for the newly expanded network.
4.78
The Employee Assistance Program (EAP) is available to AFP employees and family members for confidential personal and professional support. The ANAO found that the EAP was the only support service that provided regular reporting and that the AFP ‘is not effectively managing the EAP provider from a quality or contractual compliance perspective’. In response, the AFP outlined that ‘since June 2017, it has engaged regularly with its EAP provider to improve service delivery’. The Phoenix Review made three recommendations directed at the AFP’s management of the EAP.
4.79
The AFP’s Health and Wellbeing Strategy outlines the AFP’s focus on external partnerships. This includes the intention to ‘engage the services of external health specialists with experience and expertise in working with emergency services personnel, and educate them on AFP processes, including individuals who provide Employee Assistance Program services’.
4.80
The AFP Chaplaincy provides spiritual, religious and pastoral wellbeing support to all AFP employees, retired members and family members, and is involved in other activities such as support at critical incidents, emergency situations, and memorial services. The AFP Chaplain has been based in the ACT from 1999. The AFP commenced using contractor Chaplains and Honorary Chaplains in other states from October 2017. The ANAO found that there was no performance information available for the Chaplaincy service.
4.81
AFP Safe Place was established in response to the Culture Change review and, although it is not specifically targeted at employee mental health, is aimed at supporting current and former AFP employees who have experienced harmful workplace behaviour that may affect mental health. AFP Safe Place has received 318 referrals since establishment in August 2016.
4.82
The AFP Confidant Network is an informal network of experienced AFP employees available to provide advice or support to colleagues regarding workplace integrity concerns or when employees experience difficulties in the workplace. The network was established in 1996 and, as at 30 August 2017, was available in 15 locations in Australia and overseas with 109 Confidants. Reporting within the network is limited to incident type due to confidentiality. In 2016, the AFP’s review of the Confidant Network resulted in 23 recommendations and, as at November 2017, 13 recommendations have been implemented. The outcomes of the review included the aim to improve regular monitoring of the network’s performance.
4.83
The ANAO examined the results of the draft 2017 AFP Mental Health Review and found that AFP personnel were more likely to seek support from external services, such as a private general practitioner or family and friends, rather than internal AFP services. The ANAO noted that external sources of support were not clearly or consistently promoted as options by the AFP. The ANAO concluded that:
The AFP does not have systematic evaluation arrangements in place to assess the effectiveness of mental health support services, and to evaluate whether the AFP has in place the optimal services to target areas of highest risk.
4.84
The AFP outlined that as part of the strategic objective of health frameworks in the Health and Wellbeing Strategy, it would develop ‘a feedback mechanism to ensure AFP Health and Wellbeing services remain relevant and accessible’. This will involve activities such as developing an Organisational Health Evaluation Plan, implementing online survey tools for AFP employees to provide feedback, and creating ‘a reporting capability to track, analyse and report on AFP health and wellbeing’.
Support for former AFP employees
4.85
The ANAO outlined that the only support services available to former AFP employees at the time of the audit were Safe Place, the AFP Chaplaincy, and the Organisational Health Triage Team. The ANAO’s analysis showed that former employees were more likely to lodge a psychological claim than a physical or other claim. The ANAO did not make a recommendation but did suggest that:
The AFP could investigate opportunities to improve employee exit/departure processes, such as providing advice and information on available services that can be accessed, including a mental health assessment or checklist into employee exit/departure processes, or developing transition plans for employee accessing AFP support services prior to departure.
4.86
The Royal Australian and New Zealand College of Psychiatrists (RANZCP) outlined that activities such as providing advisory services and conducting pre‑retirement screening would be beneficial to employees transitioning out of first responder organisations. RANZCP recommended that the AFP implement ‘greater support systems for employees leaving, or planning to leave, the AFP. In particular, these services should be targeted at those with mental health conditions that carry a significant risk of worsening morbidity’.
4.87
At the public hearing, the AFP explained that it had now expanded the EAP to cover former AFP members, with the aim is to ‘ensure that former members have avenues to continue to get support, noting that issues sometimes present after they’ve left our employment’. The AFP also stated that it was looking at how to ‘help people transition out of the organisation’, and acknowledged that this process is not as mature as would be preferred. The AFP broadly outlined in the Health and Wellbeing Strategy that it would ‘prepare employees for separation from the AFP’ and ‘recognise the important role ex‑employee networks provide in supporting former employees’.
Information and data
4.88
The AFP holds information related to employee mental health across a number of sources, including hard copy files located within various business areas and six bespoke Microsoft Access databases. The AFP also collects data on workplace incidents and hazards, and has access to Comcare claims data through the Comcare Client Information System, and to unscheduled leave data and deceased personnel data on the AFP’s human resources information system. The ANAO found that the multiple hardcopy records and the range of disconnected information systems made it ‘difficult for the AFP to monitor and respond to emerging issues in employee mental health’.
4.89
As a result, the ANAO recommended that the AFP:
consolidate disparate system and hard copy records in order to establish an electronic health records management system that allows a single point of access to high level health information for each AFP employee; and
establish a strategy for analysing employee health information against data in areas such as workplace incident reporting, Comcare claims, unscheduled leave, exposure to explicit material and information on deceased personnel in order to assist in identifying and addressing known psychological injury risk factors.
4.90
The AFP’s response to the recommendation outlined that the AFP had commenced a transformation program which involves enhancing and consolidating information systems. This will include activities such as the ‘automation of processes and procedures within the Organisation Health Branch’ as part of ‘investment in innovative early intervention strategies to manage workplace health proactively’. The AFP’s Health and Wellbeing Strategy outlines that as part of the strategic objective of health frameworks, the AFP will ‘design and implement a new case management system and e‑health portal’.
12 February 2019