Building Woka Walanga's Policy Framework: What the OCG Standards Actually Required

OCG accreditation is the mandatory approval process for any organisation providing statutory out-of-home care in NSW. To become accredited, you must demonstrate compliance with the Code of Practice: 12 practice requirement areas covering governance, cultural safety, case management, and more. For a new Aboriginal organisation starting from nothing, that means building the entire evidence base yourself.

Nobody warned us it would mean 91 documents.

The OCG website is honest about one thing: the process requires "significant commitment, both in time and resources." What it can't tell you is what that actually looks like. At 7am before anyone else is up, working through policy number 14 of 91, trying to translate a standard written for large NGOs into something that makes sense for a two-person Aboriginal charity in Wollongong.

This is the account of how we did it.

What the OCG accreditation standards actually require

The Code of Practice is the accreditation criteria that replaced the previous 23 Child Safe Standards on 1 October 2025. It covers 12 practice requirement areas:

Organisational leadership and culture

Principal Officer accountability

Quality assurance and continuous improvement

Working with Children Checks

Assessment and suitability of carers and workers

Records management

Family engagement and participation

Cultural competency and protection of Aboriginal and Torres Strait Islander children

Safe physical and online environments

Complaints and concerns response

Staff training and knowledge

Regular review and improvement

The standard reads clearly. The ambiguity isn't in the words. It's in the distance between what the document says and what evidence of compliance looks like inside a small organisation with limited staff.

Take cultural competency and protection of Aboriginal and Torres Strait Islander children. The standard requires it. But for most organisations, "cultural competency" is two paragraphs in a policy document they wrote because someone told them to. For Woka Walanga, an organisation founded by and for Aboriginal community, this standard had to be lived, documented, and defensible at the same time.

What the 91 documents actually are

Before we started, we didn't have a clear picture of the scale. OCG accreditation doesn't require a single compliance document. It requires an entire policy and procedure framework that evidences how you meet every element of the Code of Practice.

For Woka Walanga, we mapped that to 91 individual documents. Some are policies: the "what and why" of how we operate. Others are procedures: the step-by-step "how." Many standards require both.

The 91 aren't arbitrary. They map directly to the 12 practice requirement areas. Case planning alone requires multiple documents: a Case Planning Policy, a Case Plans Review and Monitoring Policy, an Initial Assessment and Placement Policy. Each is a separate document. Each must stand alone. Each must reference the legislative framework it sits under.

Phase 1 covered the most critical documents first:

Child Protection Policy

Case Planning Policy

Case Plans Review and Monitoring Policy

Initial Assessment and Placement Policy

Referral, Assessment and Matching Policy

Transition and Placement Policy

These aren't ticked boxes. When OCG reviews an application, they read these documents. They look for whether the policy reflects genuine operational practice or whether it's a copy-paste job. A policy written for a large NGO reads like one.

What the standard says and what it means in practice

The evidence gap

For provisional accreditation, OCG looks for "indirect evidence." That means they're not watching you operate yet. They want to see that your policies, procedures, and systems demonstrate you're ready.

The problem: indirect evidence only works if your policies are built for your organisation. A generic template (and there are many available) might look compliant on paper. In practice, if a Principal Officer is ever asked to explain how the organisation implements carer suitability assessments, the answer needs to match the policy. If it doesn't, provisional accreditation becomes a liability, not an asset.

We built every document from the ground up, not from templates. That decision added time. It meant every policy had to be thought through, not just filled in.

The small organisation trap

The Code of Practice was written with genuine intent. But the frameworks it references (the Permanency Case Management Policy, the Aboriginal Case Management Policy, the National Principles for Child Safe Organisations) were designed with larger, funded organisations in mind.

A small Aboriginal organisation applying for accreditation doesn't have a dedicated compliance manager. It doesn't have a policy team. The person building the framework is usually also the person doing everything else.

This creates a specific pressure: every hour spent writing policy 47 is an hour not spent on the community relationships that will determine whether the service is any good once it's accredited.

There's no clean resolution to that tension. The work has to be done.

Where AI helped, and where it didn't

I used Claude to build a significant portion of the 91 documents. Not to replace the thinking, but to accelerate it.

What worked:

AI drafts a solid policy structure when you give it the correct legislative references and explain the operational context

AI is fast with the boilerplate parts: doc control tables, legislative framework sections, section ordering. Work that would otherwise take hours.

AI can cross-check whether a policy references all the relevant Code of Practice requirements

What didn't work:

AI cannot know what the organisation actually does. Every policy went through a review pass where I checked whether the document reflected Woka Walanga's actual practice or just "best practice" in the abstract

Cultural safety documentation cannot be AI-generated. The sections of our framework covering cultural competency and ATSICPP application were written last and required more personal input than anything else

AI cannot substitute for the review feedback that comes from someone who knows the OCG assessment process firsthand

The honest version: AI made 91 documents possible without a policy team. But every document still required judgment the AI couldn't provide.

What we got wrong the first time

Policies that were too long

The first drafts were detailed. Too detailed. Policies embedded procedural steps instead of separating the "what" from the "how." This is a common mistake. It makes documents harder to maintain and harder for staff to use.

The fix: a policy defines what we do and why. A procedure defines how. They're separate documents. If you find yourself writing numbered steps inside a policy, stop. That belongs in a procedure, not a policy.

Compliance references as standalone boxes

Early drafts had separate "Code of Practice Alignment" boxes at the end of each policy. Looks thorough. Reads like compliance theatre.

OCG wants to see compliance woven through the body of the policy, not bolted on at the end. References to the Code of Practice belong in the text where they're relevant, not in a summary box nobody reads.

Generic language where specific language was needed

"We are committed to cultural safety" is not a policy. A policy describes specifically what cultural safety looks like in practice for the children and families Woka Walanga works with: what our obligations are under legislation, what our workers do, how we document it.

The more specific the policy, the stronger the evidence. Vague commitments are easy to write and worth nothing when assessed.

What the OCG accreditation review process looks like

Provisional accreditation requires submitting your policy framework to OCG for assessment. There's no fixed timeline published, but current volume means the process takes time.

OCG is prioritising applications from ACCOs and Aboriginal providers, for at least 12 months from December 2025. For Woka Walanga and organisations like it, this matters: you're not at the back of a queue dominated by large NGO providers. This prioritisation reflects the government's ACCOs-first commitment, even while the broader system reforms are still years away.

What the assessment looks like:

OCG reviews the submitted evidence against each Code of Practice requirement

Gaps or insufficient evidence prompt a request for more information

It's not a single pass/fail. It's a dialogue about evidence adequacy.

The best preparation is to submit documents that genuinely reflect how you'll operate. Make OCG's job straightforward by being specific.

Why Aboriginal organisations should apply now for OCG accreditation

OCG's current priority is ACCO and Aboriginal provider applications. That window exists because the system recognises the demand for Aboriginal-led OOHC capacity and the shortage of it.

7,555 Aboriginal children are in OOHC in NSW. Aboriginal children are placed at a rate of 45.1 per 1,000, nearly ten times the rate for non-Indigenous children. The $350 million Family Preservation investment announced in April 2026 to 22 ACCOs confirms the direction of government funding.

The system says it wants more Aboriginal providers. OCG's processing priority says the same. The organisations building their frameworks now, doing the work, writing the 91 documents, will be positioned when that investment and the ACCOs-first transition start to deliver what they're promising.

Frequently asked questions

What is OCG accreditation and why is it required?

OCG accreditation is the mandatory approval process for any organisation providing statutory out-of-home care in NSW. Without it, an organisation cannot take on children under statutory orders, regardless of the quality of the service. Accreditation requires demonstrating compliance with the Code of Practice, which covers 12 practice requirement areas including governance, cultural safety, and case management.

How many policy documents does OCG accreditation actually require?

There's no fixed number stated by the OCG. The requirement is to demonstrate compliance with the Code of Practice. For Woka Walanga, we mapped that to 91 individual policy and procedure documents. The number reflects the breadth of the Code and the decision to build separate documents for each practice area rather than combining requirements.

What is the difference between provisional and full accreditation?

Provisional accreditation (3 years) is for organisations that haven't yet provided statutory services. It's assessed on indirect evidence: your policies, procedures, and systems demonstrate readiness. Full accreditation (3 or 5 years) applies when an organisation renews after actually delivering statutory services. It requires direct evidence of practice in operation.

How long does the OCG accreditation process take?

OCG doesn't publish a fixed timeline. Current processing times are affected by high application volume, particularly ACCO and Aboriginal provider applications, which OCG is now prioritising. Allow several months from submission. A complete, well-evidenced application avoids back-and-forth requests for more information.

Can AI tools help with writing OCG accreditation policy documents?

AI can accelerate the drafting of policy and procedure documents: structure, boilerplate sections, and legislative framework mapping. But the organisation's actual practice, cultural context, and operational specifics cannot be AI-generated. Every AI-drafted document requires review by someone who understands both the OCG requirements and how the organisation actually works.

Is OCG accreditation the same as getting funding from DCJ?

No. Accreditation and funding are separate. Accreditation grants the right to provide statutory OOHC services and makes an organisation eligible to be commissioned. DCJ makes commissioning and funding decisions independently. An accredited organisation is not automatically funded.