The Foster Care Association of Victoria (FCAV) broadly supports the intention of the Children, Youth and Families Amendment (Supporting Stable and Strong Families) Bill 2025 (the SSSF Bill). The SSSF Bill seeks to improve outcomes for children involved in the child protection system by:
promoting placement stability;
strengthening support structures for children and families; and
fostering greater interdepartmental collaboration through the development of departmental plans with all Ministers, Department of Families, Fairness and Housing and the Chief Commissioner of Police being jointly responsible for improving outcomes for all at-risk children, young people and families.
The FCAV recognises the importance and potential value of a coordinated, whole-of-government approach to supporting vulnerable children. However, while the objectives of the SSSF Bill are welcomed, the FCAV has some concerns about some aspects of the proposed framework that may limit its effectiveness for carers and children.
Background and Context
The SSSF Bill forms part of a broader package of legislative and policy reforms, including the Children, Youth and Families Amendment (Stability) Bill 2025 (Stability Bill). Together, these reforms are intended to establish a more integrated framework for children in out-of-home care. The Stability Bill focuses on children’s rights to placement continuity, while the SSSF Bill aims to ensure coordinated systemic support across government departments.
Although the Bills are intended to be complementary, the FCAV considers that their alignment and interaction have not been sufficiently articulated and there is a lack of practical detail in the draft Bills as to how they explicitly operate. As a result, some key stakeholders, including foster carers, face significant barriers to understanding the full intent and any possible practical implications of the proposed reforms.
Issues identified in the Proposed Scheme
Although the SSSF Bill mandates departmental plans to coordinate services and supports, the FCAV questions whether certain elements of the scheme’s design could limit its effectiveness and seeks clarification on the following points:
Consultation with Foster Carers
The SSSF Bill does not mandate consultation with foster carers during the development of departmental plans and leaves open the possibility that critical aspects of child protection service delivery may be overlooked or inconsistently addressed.
Whilst Ministers will be required to develop and release a plan outlining their progress against the actions in their plan to improve outcomes for their priority cohort, the SSSF Bill does not mandate consultation with foster carers during the development of the plan. The FCAV considers it imperative that there be extensive consultation with foster carers during the development, as well as the evaluation, of departmental plans. Such an omission would risk excluding the lived experience and expertise of carers, potentially resulting in plans that may fall short of addressing all key issues affecting service delivery.
Children in care do not experience services in silos, and so neither do carers. Education, health, mental health, disability, justice, and child protection often intersect in the everyday experiences of children and their carers. When coordination and resources are deficient, carers absorb the impact, and the children experience further disruption. Coordination is central to this Bill, yet carers are not named as SSSF partners, calling into question how success will be tested in reality at the placement level. If the SSSF plans do not translate into meaningful, timely and coordinated action, carers bear the burden, supporting children through delays and unclear escalation pathways and potentially resulting in crisis-driven responses. Consultation with carers can ground outcome measures in lived reality, identify where accountability becomes diffuse, and test whether coordination is operational rather than aspirational. Without this lens, progress may be reported on paper, while instability persists in homes, until carers can no longer buffer the system’s gaps for the children in their care.
Carer recruitment and retention, for example, is critical to system capacity and placement stability. Without direct consultation with carers on factors influencing recruitment and retention, plans may fail to include meaningful objectives or outcome measures to address these systemic challenges.
Standardised Plans
Whilst outcome measures will be prescribed in Regulations, there is no requirement for a standardised plan template across departments. This absence may hinder assessment of departmental scope, consistency, and potential effectiveness. Without standardisation, meaningful comparison, evaluation, and accountability across departments could be challenging and limiting the practical impact for carers and children.
Non-enforceable obligations
Even where obligations are included in departmental plans, the SSSF Bill provides no mechanisms to enforce compliance or accountability. The FCAV queries whether this absence may risk some departmental plans being theoretical rather than applied, limiting their practical impact for carers and children.
Funding and resources
The FCAV believes that the full effectiveness of departmental plans will depend on ensuring each government department has adequate and sustained funding. If there is limited or insufficient dedicated resource, even well-designed initiatives may be unachievable, which would limit the scheme’s capacity to deliver tangible improvements for children and carers.
FCAV Position
In principle, the FCAV supports the objectives of the SSSF Bill and acknowledges its intended alignment with the Stability Bill to promote more coordinated, whole-of-government service delivery. However, it is essential that the Bill does not impose additional administrative burdens on carers. The development, implementation, and evaluation of departmental plans must involve meaningful consultation with carers to ensure the reforms deliver practical improvements in service coordination and outcomes for children in care. This must be supported by adequate and sustained funding across all departments, so plans are capable of being implemented in practice and result in timely, coordinated support rather than fragmented or delayed responses.
