comprise a relatively small proportion of overall child protection expenditure compared to tertiary services.180 127. First Nations children are significantly over-represented in the child protection system. Between 2017 and 2021, the rate of Indigenous children in out-of-home care increased from 51 per 1000, to 58 per 1000. 181 128. The Commission notes the extent to which children in care ‘crossover’ to the youth justice system. The Australian Law Reform Commission found that that ‘the links between these systems is so strong that child removal into out-of-home care and juvenile detention could be considered as key drivers of adult incarceration’.182 This is due in part to systemic issues related to outof-home care, such as ‘badly trained and poorly supported staff’ and a ‘readiness to call police to manage children’s behaviour’.183 129. The Royal Commission into Institutional Responses to Child Sexual Abuse revealed the extent to which children have been maltreated while in the care of institutions such as schools, recreational organisations, residential care, youth detention and immigration detention. The Royal Commission highlighted the ‘significant life-long impacts’ of sexual abuse, including ‘deep and complex trauma’ that may affect all aspects of a victim/survivor’s life.184 The Commission welcomes the steps taken thus far to implement the recommendations of the Royal Commission. In particular, the Commission notes the National Redress Scheme,185 and the development and endorsement by all governments of the National Principles for Child Safe Organisations.186 The Commission urges continuous efforts to ensure the full implementation of all the Royal Commission recommendations. 130. The Commission notes that, on the whole, there are significant gaps in the implementation of children’s rights in law, and across policy, programs and service delivery. The legal protections of children’s rights in Australia are not comprehensive. Independent monitoring of children’s rights, including the ability for children to make complaints, is limited. Overall, approaches to children experiencing vulnerability are fragmented and are largely reactive rather than preventative. The Commission has recommended the development of a National Plan for Child Wellbeing, a dedicated Cabinet Minister with overall responsibility for children’s rights, and a national children’s data framework to improve and coordinate children’s policy and service-delivery across government portfolios.187 Recommendation 29: The Australian Government increases prevention and early intervention measures and responses to family violence that address the distinct impacts of violence on children. Recommendation 30: Governments resource prevention and early intervention measures to address child abuse and neglect; and ensure 30