042 Workskil

							Response to the consultation request from
           Minister Kate Ellis




                                        Ken Lodge
                            Chief Executive Officer
                                          Workskil

                                     08 8275 6100

                           klodge@workskil.com.au
                              www.workskil.com.au




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                          Workskil – Response to Consultation



Workskil is pleased to be given the opportunity to contribute our views on how
employment services within Job Services Australia and Disability Employment Services
can be improved from 30 June 2012.

Workskil’s submission draws on our experience of continuously delivering employment
services since 1982. Over the last 29 years Workskil has provided direct employment
services to thousands of unemployed Australians, through programs that include Job
Network, Personal Support Program, Work for the Dole and JPET. Currently Workskil
delivers the Job Services Australia program and the Disability Management service.

Workskil’s JSA service is provided from 20 sites in South Australia and nine in Victoria.
As the largest JSA provider in South Australia, and the ninth largest in Australia, the
views put forward in this submission are based on our direct experience and were
developed in consultation with Workskil Managers and staff in both South Australia and
Victoria.

In addition to JSA and DES, Workskil delivers a major social inclusion project in
Victoria, the Family Centred Employment Project (FCEP). This is a demonstration
DEEWR funded project that builds on the JSA services provided to individuals and
extends the focus to the needs of the family unit.

The social inclusion principles of the Family Project have been carried across the entire
range of Workskil programs. As a not for profit community organisation Workskil has a
particular interest in working with disadvantaged members of the community who are at
risk of social inclusion. Our mission statement is: ‘to contribute to social and economic
self-reliance by developing people’s skills, knowledge and opportunity.’

Workskil agrees with the Minister that the new employment service models meet key
policy parameters. In particular we believe integrated service provision has led to greater
efficiencies and a less fragmented service to job seekers, while the stronger focus on
highly disadvantaged and long term unemployed Australians through Stream Four
servicing has enabled providers to give greater assistance to those who most need it. Our
view is that the current model of employment assistance addresses the major past failings
of the Job Network and is a more effective employment services system.

Consequently we do not believe there is a need for substantial reform to the delivery of
employment services and in our response to the key consultation questions we have
mainly recommended a number of practical improvements that Workskil believes would
further improve services. In particular, we point to inefficiencies and weaknesses in the
areas of contractual compliance, a level of administration that is still too high, and an
overly complex payments structure.

Workskil’s experience delivering the DES service is limited to the last year and a half so
our submission related to this service will be in the form of a general statement of our
support for integrated service provision delivered following an open purchasing process.


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                           Workskil – Response to Consultation


How can JSA services for long-term unemployed people who face multiple
disadvantage be improved?

Workskil has considerable experience assisting Australian job seekers who are unable to
take advantage of the current climate of low unemployment due to their complex needs
and serious barriers to employment. The current Stream 4 servicing system has been
successful and should be retained in the new contract, while being extended to allow for a
more intensive support program for those with significant barriers.

Workskil’s success with the Family Centred Employment Project has shown us the vital
importance of an accurate assessment of barriers and needs, delivered by staff that have
the appropriate skills and have developed the required level of rapport with the client.
Our experience is that a job seeker with multiple barriers frequently has these barriers
omitted in their initial assessment with Centrelink, particularly when the assessment is
conducted over the phone. Workskil recommends that employment service providers
should be the primary assessors of client needs and barriers, including undertaking the
Stream Services Review.

The work experience phase has, in our view, not been as effective as it could be for long
term unemployed and those who face multiple disadvantages. Workskil recommends that
the value of the work experience phase be reviewed for the new contract. Workskil
believes that it often adds little to the services provided to a job seeker while he or she is
in a Stream and in some cases adds obligations and requirements that impact negatively
on the intervention being followed. Our view is that soft skill development and training is
the most beneficial activity for many long term unemployed people and is of more value
than the majority of available options for work experience. In the current labour market
employers are often simply asking us for employees who have a good attitude,
commitment and motivation, and have no barriers that will affect their workday.

A particular option that should be removed is the current allowable activity of part time
work. For some long term unemployed people this is an opportunity to continue
undertaking part time work that is topped up by the benefit, something that is directly at
odds with the independence from income support that a provider is working to achieve.

Workskil also recommends that the new employment services model should include a
bonus payment from the EPF to the client when a long term unemployed client reaches
26 weeks of employment. As well as celebrating the achievement with the new
employee, it will also ensure the individual remains in contact with their employment
services provider for the full outcome period.

It should also be stated that in the new contract providers need to be able to deal more
effectively with long term unemployed WITHOUT multiple disadvantages but who are,
for a variety of reasons, reluctant to take advantage of today’s buoyant labour market.
The current compliance system has swung too much in the jobseeker’s favour, and
Workskil recommends that the new system allows a provider’s compliance
recommendations to be actioned more often than at present.


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                           Workskil – Response to Consultation



The compliance process should be simplified through the removal of Comprehensive
Client Assessments which in our experience are not effective.


How can better links between vocational education and training providers,
employment services and employers be developed?

Workskil believes that the linkages between these groups are still more fragmented than
ideal. The key issue for an employment services provider is that education and training
providers often do not have the responsibility of taking the course participant to the
labour market. This frequently leads to skills acquisition but a loss of momentum after the
course and no clear pathway into employment. The current bonus payment for
employment that follows training is positive, and Workskil recommends that in the new
contract this is extended.

However the barriers to gaining this claim are not inconsiderable, and we wish to detail
the process as just one example of the many time consuming practices that currently exist
and should be reduced in the new contract. To make a bonus claim we must confirm we
have documentary evidence on file, such as a copy of the Apprenticeship Agreement.
Some training organisations won’t provide these due to privacy issues and as clients are
working they can’t come in person to our sites. Asking the individual to photocopy their
agreement then post it out to us is unnecessarily time consuming. The new JSA model
should simply require us to retain confirmation from the employer that the client is doing
an apprenticeship/traineeship, without having to ask the RTO for Apprenticeship
Agreements.

To continue the illustration of operational difficulties that we must overcome,
employment service providers are able to claim the bonus claim for clients who have
completed a course within 12 months of commencing employment, as long as it is coded
on ESS. If a client has finished a Certificate before they are linked with a JSA provider, it
is necessary to enter the course details into ESS but not enter an end date. The
Consultant then emails the Contract Manager and requests that he or she enters the
correct dates as they have the authority to backdate.

This results in a situation where the payment has the worthwhile policy purpose of
encouraging providers to link training more closely with labour market shortages. But the
reality is that the staff time required to lodge the claim means it is hardly worth making it.
Like many of the examples we raise, the solution is simple – give providers the ability to
backdate the commencement and end dates, up to the 12 month period, instead of the
current 28 days.

On a broader level, Workskil hopes the new contract will be flexible enough to allow
providers to meet the training needs of all job seekers. It should allow a range of training
pathways for ex-prisoners, DSP recipients, parents, at risk youth, recent migrants and
other groups, which may include more home based, flexible training options.


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                          Workskil – Response to Consultation


Education outcomes should move from the current formal reliance on semesters and start
/ end date and allow more personalised and informal training that is tailored to meet the
needs of an individual who may previously have found the formal education and training
system inappropriate or inaccessible.


How might the JSA model encourage and support providers to better address the
needs of employers, including employers in the private sector, those operating
nationally and those in growth industries?

A key way in which the new JSA model can encourage and support providers to better
address the needs of employers is to allow more flexible and targeted employment
outcomes that take into account the current labour market. The new system should
recognize and reward providers for assisting a job seeker into a casual position or short
term contract work. The current arrangements for seasonal workers should be retained
and improved, while there should be a complete revamp of rules and payments for
assisting self employed people who work under their own tax numbers.

Both employers and job seekers benefit from taking steps towards full time employment,
but the current JSA contract does not easily accommodate these steps. The rigid outcome
requirements relating to working ‘each and every week’ and the allowable break
conditions are just two of the disincentives faced by a provider who wishes to encourage
job seekers to take advantage of the more flexible work conditions that are increasingly
being offered by employers.

On a more operational level, the new contract must allow a more collaborative approach
between employers and service providers by reducing the amount of information required
to lodge a claim. In many cases the day to day interaction between an employer and
employment services provider consists of the provider asking for detailed information on
wages and hours of a new employee. This significant degree of information the employer
must give is annoying and time consuming.

When canvassing for new employers, Workskil Business Development Consultants
report that they frequently receive as a first response that the employer refuses to deal
with employment service providers because ‘they’re always ringing up asking for
information’. The new system must assist providers to convince employers that using
their services is of benefit to them, and not an imposition.

Workskil also wishes to put forward a view on a subject of considerable debate, the
appropriateness of offering wage subsidies. Our experience is that the use of employer
wage subsidies has been a successful method of creating sustainable employment for
disadvantaged and long term unemployed, particularly in small and medium sized
businesses.


We recommend that the new model for JSA formalises the use of wage subsidies in a
similar way to the indigenous wage subsidy. A model may be for DEEWR to set

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                          Workskil – Response to Consultation


conditions and a maximum level of expenditure for each stream level and allow job
seekers to market themselves at this amount. Employers would more easily understand
the purpose of a wage incentive and the practice would be more transparent.


How can JSA play a greater role in increasing mature age employment and
participation?

Workskil’s caseloads in both States have increasing numbers of mature aged job seekers.
Supporting and assisting them into employment is made more difficult by the current
rules relating to job seeker obligations. Improving this would allow JSA providers to
play a greater role in increasing mature age employment and participation.

The current system of requiring some mature age to receive JSA servicing, but not report
work efforts to Centrelink, is immensely frustrating to both the individual and the
employment services provider. It is difficult to see the reasoning behind requiring a
mature age person to work (paid or voluntarily) 15 hours a week to remove their
obligations to Centrelink, yet still require them to connect with an employment services
provider caseload and accept assistance to gain full time employment. The requirements
should be aligned and Workskil suggests the most appropriate way would be to introduce
an assessment for all jobseekers between the age of 55 and 60 years to assess their
potential to work. The possible outcomes may be that they are required to undertake JSA
services and have work requirements to work for either 15 hours per week or full time
work, or that they have no employment requirements and can receive assistance from a
provider on a voluntary basis. The latter may be the option for job seekers when they
reach the age of 60 years.


How can services for recently unemployed people be improved?

Workskil’s experience is that the key to delivering effective services to recently
unemployed people is by the provider conducting an accurate initial assessment that
identifies barriers, skills and strengths. This determines the best type of assistance to
provide the job seeker and the system should allow the provider to use discretion to
decide if the individual is likely to need minimal assistance or if immediate assistance
should be given to prevent possible long term unemployment.

The current system of outcome claims for short term unemployed has not been successful
in Workskil’s opinion and has led to considerable job seeker frustration. The removal of a
four – twelve month outcome payment is, in our view, false economy. Employment
Service providers in the new contract should be resourced and funded to actively assist
clients with less than a year’s unemployment. This is particularly important if the current
labour market conditions remain for a sustained period. If a job seeker has still not found
work after, say, six months of looking, then it is apparent that they need more intensive
assistance than is able to be given under the existing JSA model.



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                          Workskil – Response to Consultation


What steps can taken to further strengthen the performance of JSA providers?

Workskil believes there are a number of service provision aspects that, if introduced or
changed, would significantly strengthen the performance of JSA providers. In summary,
Workskil recommends:
    Removing the distinction between brokered and assisted outcome and job
      placement payments – our view is that it serves no useful purpose. To keep the
      change cost neutral, the fees could be evened out
    Remove the current suspended category for job seekers. Job seekers should
      receive regular and consistent support from a provider, even when they are not
      capable of working. All job seekers should be required to maintain contact with
      their provider, even if it is by a phone call
    A particular suspension issue is related to servicing jobseekers with a current 0-7
      hour work requirement. Simply suspending all job seekers in this category is of no
      benefit to either the job seeker or the provider. Rather than being suspended and
      not required to contact their provider, Workskil recommends that job seekers in
      this situation are required to connect with providers. Assistance could then be
      given to address non vocational barriers and there would be a great advantage to
      both parties by simply maintaining communication and preparing and planning for
      when the suspension ends
    The Earn or Learn rules for jobseekers under the age of 21 who haven’t finished
      year 12 are not leading to the benefits intended and should be changed in the new
      contract. Not allowing employment service providers to require youth to engage
      in jobsearch activities is counterproductive
    The new contract should remove a major disincentive for providing early
      assistance to a job seeker. Currently, if an employment services provider assists a
      job seeker into employment before the individual receives their first payment
      from Centrelink we receive no fee. A provider is penalised for providing
      immediate employment assistance to a job seeker
    The administration of EPF is complex and time consuming. A suggested
      improvement in the new contract that would maintain accountability is to continue
      the current method of calculating EPF due, but pay the provider upfront and
      acquit the money, rather than maintaining a notional bank. The money can be kept
      on the provider’s balance sheet as a prepayment and drawn down as it is spent.
      The provider will audit as normal under accounting standards and DEEWR can
      also fully audit the expenditure
    Workskil strongly recommends stricter compliance from Centrelink. More
      participation report recommendations need to be upheld, rather than Centrelink
      accepting excuses from the job seeker without evidence being given. One
      example is of a job seeker not starting employment in a new job. Full
      documentary evidence is compiled, and a participation report is entered after the
      job seeker and employer are spoken to. Some days later Centrelink contacts the
      job seeker and then rejects the participation report on the basis of “medical
      condition, no evidence provided.” The ability of an employment service provider
      to work effectively with clients is being hindered by a compliance system that has
      swung strongly in favour of the job seeker.

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                          Workskil – Response to Consultation


      Workskil supports the upcoming change that will centralise the Job Capacity
       Assessment process through Centrelink. We believe it will lead to consistency of
       decision making. However we recommend that in the new contract the Job
       Seeker Capacity Instrument interview should be conducted by the provider, rather
       then Centrelink. If the JSCI is retained by Centrelink in the new contract, it must
       be done face to face with the client. Workskil’s experience is that conducting a
       JSCI over the phone leads to considerable inaccuracies

How can JSA be further improved to help meet the Government’s commitment to
close the gap in employment outcomes for Indigenous Australians by 2018?

Workskil supports the retention of indigenous wage subsidies and other incentives, but
rather than the current ‘one size fits all’, incentives should be based on local employment
conditions and the indigenous population size in an area. We believe the key to
increasing indigenous outcomes lies with local initiatives and linkages, rather than with
high profile ‘celebrity’ national indigenous employment initiatives, and we recommend
that the new JSA ensures providers are sufficiently resourced at the local level.

Workskil recommends that providers be given the discretion to offer from the
Employment Pathway fund a financial incentive to a new indigenous employee when
they reach the 26 weeks mark, and believes that all indigenous job seekers should be
automatically classified as Stream Four, allowing a more holistic and long term approach
to be taken to addressing their barriers.


What changes to employment services in remote areas would better deliver
employment outcomes and meaningful participation activities?

Workskil does not provide employment services in remote areas so will not put forward
suggestions in response to this question.


What future initiatives can be taken to reduce to reduce administrative
requirements, balanced against the need for appropriate accountability and
performance information?

The wording in this question of “appropriate accountability and performance
information” suggests that the main cause of provider complaints over administration is
still not being understood. An analysis of our staff’s administrative duties shows that the
cause of most inefficiencies is not due to the need to enter full and complete information
for accountability purposes, but instead because we are required to use an ineffective and
most unsatisfactory IT program. ESS is a layer of old and new which gives DEEWR
some control and reporting functionality, but is complex and cumbersome for providers.
Small changes would go a long way to reducing the administrative burden in the new
contract. A sample of the many suggestions Workskil could give include:



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                          Workskil – Response to Consultation


      Developing templates for common processes. Currently nine mouse clicks are
       needed to record that a jobseeker has attended an appointment, and many other
       basic tasks that should be simple are too time consuming
      The new requirement to enter the National Minium wage for a vacancy has solved
       a problem that in our experience did not exist. This is simply an administrative
       burden that provides no value and should be removed
      Diary appointments should be included on the on case summary screen to reduce
       screen changes
      Job search activities should be required to be entered into the EPP only – currently
       a Consultant is required to duplicate them by entering into the activity screen as
       well
      The resume program on ESS is not user friendly – for example it should be
       compatible with Word and not lose formatting when a Word document is saved to
       it

These are just a few of a long list of improvements that should be made to the ESS
system. Workskil would repeat that the main cause of complaints over the heavy
administrative burden is directly related to an inefficient IT system. Outside ESS,
Workskil recommends that the new contract:

      Reduces the complexity of outcome claims, preferably reducing the number to
       four or five claim types that are based on length of unemployment, not stream.
       The only exception would be an extra payment for Stream Four job seekers
      Lessens the Post Placement Support burden. For example if Centrelink enters a
       DNL (did not lodge) or FTW (full time work) exit, a provider should be entitled to
       an automatic full claim without having to gain verification. Centrelink should
       also share information on employment that is provided to them by a client
      Makes better provision for self employed clients. Currently those people working
       on a self employed basis are required to provide considerable information to their
       employment services provider, in fact more information than they give to
       Centrelink


Disability Employment Services

What purchasing process is the most appropriate vehicle to improve the access of
job seekers with disability and employers to high performing DES providers?

Workskil supports the integration of both DES programs within Job Services Australia. It
is important that an industry whose core business is to find employment is also actively
working to assist people with disabilities. This would result in a single worthwhile and
clearly understood common aim – to assist clients into sustainable employment.

The integration of Personal Support Program clients into the current JSA model has, in
our view, been an outstanding success. It is evidence that JSA providers could


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                         Workskil – Response to Consultation


successfully integration both the Employment Service and Disability Management
service into their operations.

Workskil can point to its own success in integrating DES and JSA. Both services adopt a
common approach of identifying barriers and strengths, addressing barriers, providing
training (vocational, soft skills or a combination) assisting the job seeker into
employment and maintaining support for the new employee. Workskil strongly supports
the integrated service provision introduced in JSA and recommends that the integration
policy continues, with JSA, Employment Support Service and Disability Management
being delivered by the same provider, after an open tender purchasing process.




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