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INDEPENDENT REVIEW OF THE JOB SEEKER
Education, Employment and Support Programs Division
Independent Review of the Job Seeker Compliance Framework
This submission provides a background to Centrelink’s implementation and delivery of the current job
seeker compliance model which was implemented from 1 July 2009.
The submission covers:
Centrelink’s role in compliance
Centrelink’s job seeker compliance service model
Preparing for implementation
Service delivery experience
A number of case studies have also been provided
The introduction of the new Activity Test compliance model from 1 July 2009 signified a fundamental
shift in compliance policy, from the sanctions-based approach which defined previous models, to a
flexible and multi-faceted approach more in keeping with the new employment services model.
The new compliance model takes an outcomes-focused approach to participation non-compliance and
aims to achieve multiple objectives:
to actively encourage ongoing engagement with employment services and participation
to address deliberate non-compliance, and
to protect and pro-actively assist vulnerable job seekers who may fail to meet requirements
through no fault of their own.
Changes to the job seeker compliance legislation were a response to specific feedback about the
previous model. The legislation is complex, increasing the discretion available to Centrelink decision-
makers and including a very wide range of features aimed at ensuring compliance responses are
appropriately tailored to the nature of the non-compliance event, and to a job seeker’s individual
The implementation of the compliance model occurred in parallel with significant changes to
employment servicing arrangements. Given the extent of change in July 2009, and the
interconnectedness of employment services and compliance policy, the model as a whole is in the
relatively early stages of implementation. While the transition period has been challenging,
Centrelink’s application of the new compliance framework has evolved and strengthened over the last
twelve months. Over this same period, the strength of collaboration between Centrelink, the
Department of Education, Employment and Workplace Relations and providers has been a pivotal
factor in embedding the model to ensure that emerging strengths and opportunities have been
harnessed along the way.
Early trends have shown a significant, although not unexpected, increase in the volume of compliance
transactions when compared with previous models. This is largely due to the high job seeker contact
nature of the new employment services arrangement, and the impacts of the new No Show, No Pay
legislation. Increased provider flexibility, including the use of Contact Requests, has also contributed
to the increased volume.
Early indicators suggest that the model appears (by and large) to be working as intended, and that the
number of eight week non-payment penalties has significantly reduced. Centrelink data indicates that
the vast majority of job seekers are complying (most without the need for any compliance action at
all), and that it is 10% of the job seeker population that accounts for 77% of all failures and Contact
The Comprehensive Compliance Assessment has harnessed existing specialist expertise within
Centrelink, and potentially offers a basis for further development of future specialist assessment to
underpin and strengthen employment servicing. Strengthening the integration of a holistic specialist
assessment into the compliance model informs and adds value for both Centrelink decision-making
and providers alike, enabling an early interventionist and strengths-based approach that supports
compliance decision-making and informs employment servicing.
In summary, the implementation of the compliance model so far has highlighted strengths and some
challenges in its delivery. While results indicate that many of the overarching aims of the model are
being achieved, there appears to be scope to strengthen the operational application of the policy
framework through continued collaboration with the policy agency and providers in the delivery of an
integrated employment servicing and compliance model.
3. Centrelink’s Role
As the service delivery agency, Centrelink plays a critical role, working with the community, the
Department of Education, Employment and Workplace Relations (DEEWR), and other agencies in the
interests of a collective and informed approach to legislative, policy and service delivery objectives
within an integrated government response. This is particularly relevant to the delivery of this piece of
legislation given its impacts for employment services providers, and the job seekers who are our
At the operational level, Centrelink’s role in compliance is primarily that of ‘impartial decision maker’.
This is aimed at assuring government and the Australian community that job seeker mutual obligation
principles are reinforced fairly and equitably by way of a holistic and unbiased application of
administrative law and activity test and compliance legislation, and related policy. Centrelink is not the
policy agency but takes its direction on the interpretation of legislation and policy from DEEWR.
The introduction of the new job seeker compliance model from 1 July 2009 heralded a very deliberate
shift in compliance legislation from the prescriptive, largely sanctions-based compliance tools
employed under previous models (most recently Welfare to Work). The new model brings a greater
focus on maintaining job seeker engagement with employment services using early intervention and
incentives-based reengagement tools wherever appropriate, rather than financial penalties. The
changes were intended to be more responsive to the needs of an increasingly disadvantaged job
seeker population, and to more effectively underpin the new employment services arrangements from
1 July 2009.
The compliance legislation that underpins the model is thus relatively complex, containing a number of
different elements and approaches to non-compliance dependent upon the participation requirement
or the seriousness of the non-compliance. It also includes a number of ‘safety net’ features aimed at
ensuring fairness and equity in its application, and to protect vulnerable job seekers. The legislation is
set out within twenty-four separate sections of the Act and is further informed by the Guide to Social
Security Law and seven Legislative Instruments. Centrelink’s e-Reference suite brings together all
related policy, legislation, systems and processes to provide a holistic reference point for Centrelink
staff administering the model. (Employment services providers use different reference material with a
greater focus on employment servicing and contract management).
In line with the legislative changes, Centrelink’s role in compliance has become somewhat ‘multi-
dimensional’ in nature – that is, both ‘sanctions-based’ where this is deemed the appropriate
response, but also engagement focused and/or interventionist where this response is determined
more appropriate or effective. The legislation also gives Centrelink ‘considerable discretion when
deciding if a job seeker has a reasonable excuse for failing to meeting their requirements’ but notably
also ‘in deciding if they have been persistently non–compliant’ - under previous models, ‘persistent’
non-compliance (which currently attracts an eight week non-payment penalty) was defined within the
legislation itself. Late amendments agreed with the Senate to secure the passage of legislation very
deliberately expanded the use of Centrelink discretion.
The Comprehensive Compliance Assessment is a key feature of the new model. It is conducted by
Centrelink specialists (principally social workers) and is intended to provide the platform for a holistic,
individualised, more effective approach to repeated non-compliance more closely linked to the
underlying cause(s). Legislation requires that this assessment occurs before an eight week non-
payment penalty can be applied; policy requires that the assessment is used as an opportunity for
Guide to Social Security Law (version 1.166 – released 1 July 2010) at 3.1.13
Hansard 5 Feb 2009, amendments to Employment Services Reform Bill, Amendments 1,3, 4 and 6
intervention where that is the more appropriate response. The objective is to maintain job seeker
engagement. Thus the primary output of a Comprehensive Compliance Assessment is a ‘CCA report’
for the job seeker’s provider. This is prepared by the Centrelink specialist conducting the assessment
and, where barriers are identified as a key component of the job seeker’s non-compliance, sets out
the impacts of identified barriers so as to inform future servicing and intervention. The new
Comprehensive Compliance Assessment thus gives both Centrelink decision makers and employment
services providers alike, access to a range of Centrelink specialist staff (including social workers) for
an enhanced awareness of the challenges in meeting and setting requirements for vulnerable job
seekers. This is aimed at improving decision-making, and supporting ongoing engagement with
Provider / Centrelink relationships
New employment services arrangements from 1 July 2009 have also increased the flexibility and
discretion available to providers in managing their job seekers. Providers have access to a range of
different options and tools to encourage compliance, so that it is entirely up to the individual provider
to determine the best means of re-engaging with a job seeker on a case-by-case basis. While this
supports a more flexible approach to job seeker non-compliance based on individual circumstances, it
can potentially give rise to different approaches within and across employment servicing
The effectiveness of the new model as a compliance tool has been built around expectations of a
complementary and relatively consistent approach across agencies, and based on assumptions of a
reasonable level of job seeker responsiveness to this increased flexibility and alternative methods of
re-engagement. As Centrelink and providers are the key agents responsible for delivery of overall
employment servicing and compliance policy, and in the interests of developing a consistent and
effective cross-agency approach within a discretionary framework, Centrelink’s role therefore also
includes a very strong focus on provider relationships.
Participation Solutions Teams are active participants in the local six-weekly meetings with providers
and in the delivery of provider training. The Participation Solutions Team also operates a local
provider enquiry line and encourages ‘job shadowing’ with local providers to further assist in building
relationships and sharing knowledge across both sides of the employment spectrum.
4. Centrelink’s Job Seeker Compliance Service Model
Centrelink’s administration of compliance policy is undertaken in a nationally-networked operation of
fifteen Area-based Participation Solutions Teams, whose primary roles are compliance investigation
and decision-making, and maintaining job seekers’ engagement with employment services. Given the
extent of externally-driven change from 1 July 2009, the Participation Solutions Team service model
was retained to ensure a solid foundation for the transition to the new model, and to allow a very
strong focus on the training and skilling of the staff in the lead up to implementation.
The structure of the Participation Solutions Team reflects the intent and multi-faceted nature of the
current model, so that each team is supported by specialist staff, including Social Workers and
Indigenous Cultural Consultants, who are available to assist the completion of Comprehensive
Compliance Assessments, and for consultation and referral as required for all other compliance
Staff are recruited to the Participation Solutions Team from their local area and are provided with eight
weeks of preliminary (induction) training. This is in addition to Centrelink induction training that is
provided for all new recruits to Centrelink. The objective of the Participation Solutions Team induction
program is to provide new team members with core foundational knowledge and soft skills. The
program provides a background to the evolution of the current compliance servicing model and
service delivery priorities
demand management principles
Participation Solutions Team coaching, and
Occupational Health and Safety training targeted to the Participation Solutions Team
The training strategy aims to deliver facilitated training in a logical sequence that allows learners to
build upon their knowledge and skills incrementally. It includes one-on-one coaching sessions and
opportunities for access to a contextual framework for the formal learning, for example, via dual head-
setting with experienced staff.
A nationalised service delivery approach has been in operation since October 2007 and, in line with
staff recruitment and training principles above, is focused on maintaining core servicing standards
(including timeliness and responsiveness), and developing quality and consistency of servicing and
decision-making in an increasingly high volume environment. There is a very strong and ongoing
focus on staff development and coaching to build expertise and quality and consistency of decision-
The Participation Solutions Team network caters for local issues and specific customer demographics;
this network manages incoming customer calls nationwide, and local calls from Job Services Australia
and Disability Employment Services providers, between the hours of 8.00 am and 5.00 pm Monday to
Areas North Australia and Central North Queensland Participation Solutions Teams are not nationally
networked. The footprint in these Areas directs compliance calls to the local Participation Solutions
Team. This ensures that Indigenous customers in these two areas will have their specific
characteristics taken into account when assessing compliance – the local team members are aware of
local issues, have been trained in Indigenous matters and thus are able to use the appropriate
judgement when determining outcomes.
The Participation Solutions Team operates under a national management unit which has been
structured to ensure a strong focus on quality and consistency of operations and performance. Roles
Operations and demand management
Quality, performance and stakeholder relationships
Leadership and professional supervision of Participation Solutions Team social work staff
Business process coordination and consistency
Workload planning, scheduling and coordination
Each Participation Solutions Team has an on-site manager and a local leadership team which may
include the team leaders, social worker(s), and other specialist or more senior staff.
As of June 2009 there was a total of 511 staff attached to the Participation Solutions Team network.
This included 68 staff members focusing on specialised activities including:
38 Social Workers
16 Indigenous Cultural Consultants
8 members of the Quality Team, and
6 members of the Operational Support Unit.
These figures do not include Centrelink specialist staff undertaking Comprehensive Compliance
Assessment in Customer Services Centres.
For the four-week period ending 26 June 2010, Centrelink’s Participation Solutions Teams handled
(on average) a weekly incoming volume of 17 674 transactions comprised of:
8 585 Participation Reports (provider generated)
5 916 Contact Requests
2 883 Centrelink-initiated failures
290 Comprehensive Compliance Assessments
During this same period, there was, on average, a weekly incoming call load of:
21 355 job seeker calls
8 958 provider queries (4 524 calls and 4 434 emails)
There was also an average of 91 appeals to Centrelink review officers per week.
Day-to-day practice in the Participation Solutions Teams aims to meet dual objectives – to implement
participation compliance policy as intended by legislation and policy, while at the same time, delivering
a holistic service which responds appropriately to the needs of individual job seekers and providers.
The challenge for Participation Solutions Team service delivery is in maintaining the quality of
operations and decision-making in a high-volume environment within a discretionary and complex
policy framework and agreed servicing standards.
Despite an increasingly high volume of compliance transactions since 1 July 2009, all performance
measures relating to timeliness and decision-making have been maintained.
5. Preparing for Implementation
Robust cross-agency project management disciplines were in place to support the development and
delivery of the new job seeker compliance model. Within this framework, Centrelink maintained a high
level of involvement at both the program and senior executive levels with and/or through the
Department of Employment, Education and Workplace Relations (DEEWR). In this way, the
development of all aspects of the policy development and program delivery was collaborative.
Similarly, adherence to project management methodologies across all aspects of Centrelink’s internal
project planning and delivery helped to ensure the integrity of Centrelink’s implementation. The
development of the new compliance model occurred in parallel with the development and
implementation of inter-reliant changes to employment servicing and the new Employment Pathway
Plan. Due to the scope and complexity of the compliance and employment services related changes
from 1 July 2009, a dedicated Centrelink Senior Executive Service officer was engaged to oversee
both projects to ensure the project deliverables and critical interdependencies were closely monitored
and collectively managed. Project staff were deployed on the basis of their compliance and
employment programs background and project management credentials. A social worker with recent
experience in the Participation Solutions Team was also engaged to support the further development
of Participation Solutions Team Social Work practice and to lead the development of the new
Comprehensive Compliance Assessment.
Given the extent of the change, and the need to manage multiple, interdependent milestones for
implementation, project teams sought to develop a fully defined policy framework early, so as to
provide the critical blueprint for project planning. This discussion occurred against a backdrop of
frequent and ongoing modification to policy as the Bill was debated in Parliament, and the model
continued to evolve over time. Despite delays in a full and comprehensive articulation of policy,
Centrelink progressed the analysis and development of the model early, based on the known key
(legislative and policy) deliverables at the time. This strategy was vital in achieving a 1 July 2009
The provision of clear and consistent messaging to job seekers about the new model was a significant
focus during implementation. Existing publications were reviewed and updated. Two new publications
were developed, market-tested and released on 1 July 2009 to provide targeted information on the
changes. The Centrelink Life Events products, the Indigenous Flagship booklet and the Centrelink
Information Handbook were also updated. The Centrelink website was reviewed with new pages
added to support the key features of the new job seeker compliance model and links to new online
publications. Thirty-five new paragraphs and one transition mailout letter were also developed for the
new model. Alongside the changes to legislation and policy, the letter text required for the new
compliance model underwent considerable modification over time - some paragraphs were still in
development through late May 2009.
Centrelink’s internal consultation and communication strategies were ongoing and extensive over the
implementation period, with Participation Solutions Team and Area Business Managers providing a
clear line of sight in developing awareness and maintaining communication with network staff during
the implementation period.
A strong focus on management and performance information requirements helped to ensure a
comprehensive reporting framework was in place to monitor and manage the implementation of the
model from the outset. Similarly, the establishment of joint business assurance processes with
DEEWR were aimed at collectively guiding and directing the implementation of the end-to-end
Centrelink’s implementation strategy also included provision for a number of pre-implementation
quality assurance measures including:
full systems testing to test the integrity of Centrelink systems in a range of situations and the
user assurance - trialling and fine-tuning of the end-to-end systems support for Centrelink
piloting of new work processes in the Centrelink concept office, and
market-testing and refining communication messages and products with a range of
The implementation of the Comprehensive Compliance Assessment was a key area of internal focus
in the lead up to implementation. The establishment of a Comprehensive Compliance Assessment
Social Work reference group and a Comprehensive Compliance Assessment stakeholder group
informed and supported the development of policy with DEEWR, and process and Comprehensive
Compliance Assessment specialist practice within Centrelink. The stakeholder group included
representation from the Participation Solutions Team, Social Work branch, Indigenous and
Multicultural services, remote servicing and process design teams. Centrelink also drew on the recent
experiences from the Serious Failure Alert process (which had been in place under Welfare to Work to
help ensure a full assessment of barriers occurred as part of the third failure investigation). A
Comprehensive Compliance Assessment Management Committee was also created prior to
implementation to manage and monitor the rollout of new assessment.
The following provides a more detailed summary of three specific areas of Centrelink focus during
implementation: policy development, IT systems development and training.
Delays in the passage of legislation (which was not passed until February 2009), and consequent
delays in the provision of a clear and comprehensive policy framework, had flow on implications for
Centrelink, both in the scoping and planning phases of the project, and across multiple areas of focus
during the development phase, including systems development and training.
Despite the compressed timeframes however, a strong internal project management framework and
experienced project staff, helped to ensure that risks were well managed and substantially mitigated.
Cross-agency project management disciplines and structures were also established early, and
included the formation of a range of joint working groups with DEEWR, as the policy agency. These
groups brought together key stakeholders across both agencies at the program level, and provided a
practical forum for the joint analysis of end-to-end policy, and the early identification of issues and
risks. Minutes and outcomes of these meetings were circulated widely within Centrelink to provide all
impacted stakeholders adequate opportunity for input in the crucial development phase. Within this
framework, a Compliance Working Group was established and met regularly throughout the project to
focus holistically on the development of the compliance measures. A Steering Committee comprising
membership from DEEWR, the Department of Human Services and Centrelink supported a broader
whole-of-government discussion across all related projects, and provided an escalation point for the
individual working groups.
Given the level of complexity inherent in having different penalty calculations for different penalties,
and its effect on job seeker payability, Centrelink commenced the analysis of this aspect of legislation
early to ensure the equitable application of legislation across a full range of circumstances. The
analysis and consultation phase was lengthy, and drew on the specialist expertise of a range of
internal and external parties, including Centrelink and DEEWR legal advisers, and the Australian
Taxation Office. Late legislative decisions requiring a deferred recovery of penalties added another
dimension to these discussions. The timing and focus on this analysis phase paid dividends in the
delivery of a stable and fully supportive IT solution on 1 July 2009.
The policy framework for the new Comprehensive Compliance Assessment was also a key area of
joint focus at both the program and the senior executive levels across agencies. DEEWR and
Centrelink discussions largely focused on:
the intended outcomes of a Comprehensive Compliance Assessment,
the expected interrelationship with the Job Capacity Assessment, which was potentially both a
Comprehensive Compliance Assessment outcome and an alternative assessment referral
communication of Comprehensive Compliance Assessment outcomes with providers via the
The further definition and development of Comprehensive Compliance Assessment practice was a
key area of continuing focus for Centrelink over the implementation period given the multi-dimensional
nature of Comprehensive Compliance Assessment in its entirety, and its pivotal role in addressing
non-compliance and/or supporting and maintaining job seeker compliance. While the legislative
expectations of Comprehensive Compliance Assessment have been clear from the outset, the policy
and end-to-end (Participation Solutions Team/provider) practice, in regards the expected
interventionist and preventative aspects of this assessment, has continued to strengthen over time.
The intended application of discretionary legislation and policy such as persistent non-compliance has
been an evolving process. While detailed internal policy guidelines (e-Reference) assist in translating
discretionary and complex policy into tangible and unambiguous operational approaches for
Participation Solutions Team staff, the challenge for Centrelink has been achieving an adequate level
of detail to support consistency of application without over-complicating instructions for staff. We
believe this has been achieved.
The delay in finalisation of the content for the Legislative Instruments that underpin various aspects of
the legislation, created both challenges and opportunities. The extent of discussion that preceded the
development of the Legislative Instruments served to inform the content of the Instruments and to
develop a mutual understanding of the intent.
As policy was evolving and changing over an extended period, the development of the business
requirements for systems, and the e-Reference and training material, was very successfully used as a
further opportunity for articulation and endorsement of end-to-end policy assumptions with DEEWR.
For policy with a degree of technical complexity to be fully effective and consistently applied, clarity of
policy and clear unambiguous processes are required, preferably built into streamlined and ‘intelligent’
workflows wherever this is possible.
The Centrelink systems build for the new model was extensive. Centrelink’s Business Requirements
Statements (which provide the blueprint for the IT development) included 197 separate requirements
in all (17 in December 2008 and a further 180 in June 2009), and impacted multiple IT platforms within
A split system delivery (over December 2008 and June 2009 releases) was progressed to maximise
the project delivery by relieving some of the pressures on capacity for the major build in June 2009,
and to support the transition to the new model. While the scope of the December build was ultimately
limited by delays in the legislation and policy, it did allow the implementation of some preliminary
foundational changes to codes, and the expansion of Vulnerability Indicator policy from December
As for all other aspects of the project, development of the Centrelink IT systems occurred in
consultation with DEEWR to ensure the integrity of the end-to-end policy, and the connectedness of
systems. A key principle of the build was to provide for as much transparency and connection across
agencies as possible within the existing IT architecture, so as to strengthen communication between
Centrelink and providers.
A comprehensive and cross-representational series of internal analysis and design sessions were also
conducted to provide opportunity for the review and analysis of key aspects of the build, including the
design and function of systems workflows. Re-use and re-modelling of existing functionality was a key
principle wherever this was possible.
The systems testing for the model was also extensive, covering all aspects of the build, including the
interface with DEEWR systems. Senior Participation Solutions Team staff were seconded to the task
enhance the integrity and scope of the testing, and
capitalise on the skills developed by staff during testing so as to provide a technical (IT)
resource for all other Participation Solutions Team members post implementation.
User assurance testing was also conducted prior to implementation, again using experienced
Participation Solutions Team members. This was aimed at assuring the useability and integrity of
participation compliance systems workflows and screens.
A post release Joint Command Centre was established from 1 July 2009 to oversee and support the
post deployment period. The Joint Command Centre involved subject matter experts drawn from IT,
business and network support areas along with similar representation from DEEWR. The Joint
Command Centre played a pivotal role in incident and problem management over the release period.
The extent of analysis and systems testing pre-implementation helped to ensure IT systems were
robust from ‘Day One’, with no critical compliance incidents reported over the period. The IT support
developed for the penalty rate calculator and recovery system (perhaps the most challenging
component of the compliance build) has been virtually problem free.
Training development and delivery
Centrelink developed a comprehensive training package to convey key messages and changes to all
staff involved in the employment services reforms. The Employment Services Model training was
undertaken in two phases and was supported by the concurrent development of comprehensive e-
Reference information which Centrelink operational staff use as their primary reference point. The first
phase of training provided all Centrelink staff with a contextual overview. This was followed by more
detailed face-to-face training prior to implementation. Transitional e-Reference materials were made
available to staff prior to implementation to assist in responding to job seeker queries about the new
arrangements prior to 1 July.
Contextual overview training was delivered to all Centrelink staff in Customer Service Centres,
Participation Solutions Teams and Call Centres from March to April 2009 to supplement internal
messaging already delivered, and to prepare Centrelink staff for the transition to the new model.
Phase two of the training was delivered to all employment staff in June 2009 and focused on the detail
of policy, process and IT systems required to support implementation. Face-to-face trainer
familiarisation sessions were delivered to assist in supporting an effective and consistent rollout of the
training across the national network.
The training was delivered to staff as a facilitated face-to-face learning experience using a mix of e-
learning, videos, electronic reference material, examples and scenarios.
The compliance-related training material was structured as a series of nine interactive modules, each
focusing on a separate element of the model (for example, Connection and Reconnection Failures, No
Show, No Pay, Comprehensive Compliance Assessments, etc), and tailored according to the varying
learning needs of staff with differing job roles and responsibilities. Additional time was allocated for
discussion and Comprehensive Compliance Assessment report-writing practice for specialist staff.
Delivery of the Comprehensive Compliance Assessment training to specialists was particularly
designed to maximise input from social workers based in the Participation Solutions Team.
Participation Solutions Team social workers worked together with their Area Facilitator to co-facilitate
delivery of the Comprehensive Compliance Assessment module to Specialists, and after completion of
the module, ran a supplementary component aimed at strengthening understanding of:
engagement with job seekers and strategies for engaging with job seekers who have barriers
social exclusion and the impacts of long-term unemployment,
applying a strengths-based perspective to Comprehensive Compliance Assessment practice,
key features of a quality Comprehensive Compliance Assessment report.
The training strategy combined an interactive, scenario-based format with a reference-based
approach designed to enable participants to understand how to undertake sound compliance
assessment and decision-making in accordance with the legislation, while also strengthening skills in
engaging with job seekers and developing appropriate interventions to meet individual needs.
In preparing for implementation, Centrelink also undertook a range of other strategies to strengthen
In the twelve months prior to July 2009, the Participation Solutions Team maintained a strong focus on
developing the skills of staff in preparation for the changes to the model in July 2009 and conducted
Motivating and Influencing - engaging effectively and holistically with customers
Cultural Awareness - engaging with customers from diverse cultural and linguistic background
Cultural Awareness - engaging with Indigenous customers
Application of Administrative Law in compliance decision-making
Homelessness and Mental Health - these sessions were delivered by Participation Solutions
Team social workers and were aimed at raising awareness of the circumstances and issues
affecting vulnerable job seekers.
A Comprehensive Compliance Assessment pre-implementation information package was also
developed and disseminated to Centrelink specialist staff in May 2009. This was aimed at providing an
introductory platform and initial orientation for Comprehensive Compliance Assessment intent and
6. Service Delivery Experience
Centrelink was well positioned for the implementation of the new job seeker compliance model –
Centrelink people were well prepared, IT systems were stable, and strong reporting frameworks were
in place from the outset to support the early identification of trends and the active management of
Centrelink has been highly aware of the discretionary nature of the model and has actively engaged
with DEEWR in the assessment and analysis of early trends. Joint ongoing business assurance
exercises have resulted in modifications to guidelines for both Centrelink staff and providers over time.
A comprehensive transition policy framework provided the platform for a smooth transition from the old
compliance model to the new. While the smooth rollout of the new employment services arrangements
were perhaps more evident at the time, the transition for compliance was similarly strong due to:
the level of collaboration and communication between Centrelink and DEEWR in the lead up
to implementation, and with the new providers from 1 July 2009;
early provision of compliance transition policy which allowed sufficient lead time for Centrelink
to plan and prepare for delivery;
the reliability of IT systems;
‘clean-slating’ provisions which clearly separated the provisions of the new model from its
the closure of Financial Case Management over an extended period to September 2009 - this
was enabled through the co-operation of Centrelink Social Work services and assisted in
minimising otherwise potentially detrimental impacts for vulnerable job seekers and their
the opportunity for a split systems delivery which (amongst other things) supported an
expansion of Vulnerability Indicator policy from December 2008 to enable a strengthened
transition for CDEP job seekers and an expanded use of the homelessness indicator in
preparation for 1 July 2009 changes; and
access to new waiver provisions for certain job seekers still serving an eight week non-
payment period applied under previous legislation as of 1 July 2009 - eligible job seekers were
contacted prior to 1 July via a Centrelink mailout, and many responded positively and quickly
to the opportunity to have payments reinstated through reengagement with employment
Early observations and trends
In practice, this model appears to provide a good balance of warnings and sanctions with strong and
effective safety nets in place to protect the vulnerable. While the legislation is complex, concepts have
been relatively easy to explain to job seekers, and the new legislation has simplified the previous
Welfare to Work reconnection failure rules for job seekers. Connection failure provisions have enabled
the opportunity for one-on-one reinforcement of requirements, and potential consequences of
continued non-compliance with job seekers without the risk of penalty. These conversations
demonstrate that some job seekers take longer to fully understand expectations, while others take
longer to accept the reality of an expected level of participation in return for income support.
The rate of appeal of compliance-related decisions with Centrelink review officers has decreased by
approximately 83%, from an average of 1850 per month over the period January to June 2009, to an
average of 312 per month over the same period in 2010. This will largely be due to a substantial
reduction in eight week non-payment penalties and the availability of waiver and hardship provisions
from 1 July 2009. There is no financial penalty for Connection failures which account for the majority
of applied failure decisions.
Providers have responded positively to the opportunity for increased discretion and a more
individualised approach to managing job seeker non-compliance, and to the use of Contact Requests,
in maintaining job seeker engagement which has worked very well for some job seekers.
The deferred recovery of penalties for No Show, No Pay and reconnection failures has confused some
job seekers, due to the lack of an immediate effect. Where the impact is not immediately felt, some job
seekers are not able to understand or accept that a financial penalty is continuing to accrue. As it is
possible for a significant penalty to have accrued before the impact of the penalty is felt by the job
seeker, Centrelink has been actively managing this aspect of the model to reduce the impact on job
seekers who may have difficulty understanding the system.
Centrelink is also actively managing the impact of financial penalties for Income Managed job seekers
through additional reallocation interviews with impacted job seekers.
Centrelink data suggests that the changes to the model appear to have been successful in reducing
the financial impact of penalties for job seekers:
Since 1 July 2009, there has been a reduction in the duration of reconnection penalty periods
when compared with short non-payment penalties under the previous model. This is likely to
be due to a combination of legislative changes to the start date of the penalty, and a
successful Centrelink outbound call strategy.
There have also been fewer eight week non-payment penalties applied when compared with
the previous model. This is due to a number of contributing factors including a positive
response to Contact Request and Connection failure ‘warning provisions’ for some job
seekers, and the deterrent effect of Reconnection and No Show, No Pay penalties for others.
Legislative and policy changes which determine the accrual of failures that trigger a
Comprehensive Compliance Assessment will also have contributed to this reduction in
Centrelink data for job seekers who have had three or more failures generated since 1 July 2009
indicates that they represent less than 4% of all job seekers and that approximately:
51% are in Streams 3 and 4 services
20% are Indigenous
71% are male, and
50% are under 25.
The introduction of the new model has seen a significant increase in the volume of compliance
transactions. This is largely due to:
the high job seeker contact nature of the new employment services model;
the impact of No Show, No Pay legislation, and
the use of Contact Requests.
Comprehensive Compliance Assessment
The operational framework for the Comprehensive Compliance Assessment has harnessed existing
Centrelink organisational resources within the new legislative framework to provide an effective safety
net. Centrelink social workers apply a professional and client-centred approach to the engagement of
job seekers, the assessment of barriers and the development of interventions:
Unlike previous models where ‘persistence and wilfulness’ has been simplistically defined
and/or assumed by a certain number of point-in-time failures, Comprehensive Compliance
Assessments have allowed the opportunity for a more holistic assessment of the reasons for a
pattern of non-compliance, and thus the ability for a more targeted treatment.
In practice, this investigation into job seeker non-compliance by Centrelink specialists often
leads to intervention rather than sanction;
With referral to Job Capacity Assessment a potential outcome of a Comprehensive
Compliance Assessment and a pre-requisite for Stream 4 referral, some job seekers are
currently required to undergo multiple similar assessments. There may be potential for some
integration and streamlining of existing assessments with a psycho-social focus.
During the six-month period January to June 2010, for all the Comprehensive Compliance
Assessment specialist assessments completed approximately:
68% of job seekers presented with barriers to employment;
48% of the Comprehensive Compliance Assessment reports included recommendations for
non vocational intervention;
37% required a further referral to a Job Capacity Assessment; and
10% had a Serious Failure applied.
Amendments to the legislation which prescribes a Serious Failure non-payment penalty start date,
have removed the administrative tensions for Centrelink in balancing quality and timeliness to meet
‘retrospective’ non- payment penalty start date legislation which was a feature of the previous model.
It also allows job seekers to be advised of the application of a failure/penalty before it starts to apply.
Access to Compliance Activities have enabled job seekers the opportunity to mitigate the potential
impacts of a serious failure, while hardship waivers have provided an additional safety net for
vulnerable job seekers.
Approximately 39% of job seekers who have had a serious failure applied in 2009/10 have
initially taken up the opportunity for waiver.
An additional 1.6% of this cohort have been eligible for hardship waiver.
Service delivery challenges
The service delivery environment for frontline Centrelink staff has been characterised by the following
Finding the expected balance between ‘firm’ and fair’
Maintaining quality and responsiveness in an increasingly high volume environment
Interpreting detailed guidelines aimed at supporting the consistent application of complex
legislation and discretionary policy
Compliance servicing is, by definition, the point at which compliance policy, participation policy and
employment servicing converge. When considering the impacts of compliance policy and/or delivery, it
can often be difficult, on the surface, to clearly differentiate the impacts of one from another.
No Show, No Pay end-to-end processes for reporting non attendance where a third party organisation
is involved can be difficult to negotiate, as non-compliance is managed by the third party through the
Job Search Australia provider to Centrelink. This can create delays and some confusion for those
Similarly, the rollout of the new compliance model in remote communities has occurred in parallel with
changes to the Community Development Employment Projects program and the ongoing development
of the participation model in these areas.
Given the extent of simultaneous inter-related change in the employment policy arena from 1 July
2009, and the increased flexibility and discretion for providers and Centrelink staff, achievements to
date have been considerable.
7. Case Studies *
Comprehensive Compliance Assessment Case Studies
Case Study 1
Van has three children under the age of 12. She is in Stream 3 services with her Job Services Australia
provider and has been out of the workforce for many years.
Van lives with her children, after separating from her husband late in 2009. Before her separation, Van was
primary carer for her husband, who suffered from a mental illness and was in receipt of a Disability Support
Van was referred to a Social Worker for a Comprehensive Compliance Assessment in April 2010, having
incurred three No Show, No Pay failures for late or poor attendance at a skills training program.
During the Social Work interview, Van disclosed that she had been subjected to ongoing domestic violence
perpetrated by her husband for many years leading up to their separation. Since the separation, Van has
experienced increasing feelings of stress and anxiety and, although realising that the separation was a
positive step forward for her, is struggling to come to terms with her new circumstances as a sole parent.
Van told the Social Worker that she often feels overwhelmed with distress and that she finds herself crying
frequently and unable to control her emotions.
Van described to the Social Worker the difficulties she has with sleeping (despite sleeping tablets), and
problems caused by an undiagnosed complaint which makes her ill on a daily basis. Van’s doctor recently
prescribed stronger medication for her – however declined to provide her with a medical certificate as he
was unable to identify a formal diagnosis.
Van explained to the Social Worker that as she has been arriving late at her skills training program due to
her ill health each morning she sought to re-negotiate a change in hours. Her Job Services Australia
provider consultant changed her hours to the middle of the day however the training now finishes too late to
allow her enough time to get to school to collect her youngest children. Van expressed feelings of confusion
and desperation as to how to manage her requirements, while also managing to meet her parenting
obligations – and at the same time struggling to cope with her ill health, in a state of distress which impacts
Through the discussion, the Social Worker assessed that Van was presenting with indicators of depression,
and that she is socially isolated with minimal supports to assist her through a period of significant transition.
When the Social Worker explored with Van the types of interventions which may support her, Van advised
that her provider has already sought to refer her to a psychologist however Van had declined, as she was
fearful that this could result in increased medication. The Social Worker discussed different counselling
options and approaches, and together with Van developed a case plan which involved seeking out
counselling and support pathways. The Comprehensive Compliance Assessment report was used as a
communication mechanism to strengthen the provider’s understanding of the impacts of Van’s personal and
health issues on her capacity to meet her current requirements so as to be able to support her effectively.
Case Study 2
Dale is a 19 year old Indigenous male in Stream 4 services. He was referred to a Social Worker for a
Comprehensive Compliance Assessment as he was consistently failing to meet his participation
* For privacy reasons, the names in these case studies have been altered
The Comprehensive Compliance Assessment interview was lengthy and required a sensitive
approach to engagement and building trust, as Dale initially presented as reluctant to disclose
Dale left home at age 18 following a long history of domestic violence. In talking with the Social Worker, his
description of his family circumstances indicated that his family dynamics were pervaded with grief and loss
associated with multiple family deaths. The Social Work assessment found that Dale was impacted by a
range of long-standing, complex issues as well as the more immediate stressors related to establishing his
independence, such as budgeting and maintaining accommodation.
Dale’s difficulty in readily disclosing his circumstances had led to barriers to engagement with his provider,
who had limited knowledge of Dale’s issues and had felt that Dale's non-compliance with requirements was
During the Comprehensive Compliance Assessment interview, the Social Worker worked at strengthening
the linkages between Dale and his provider. She consulted twice with Dale’s provider, and also with the
local Indigenous Services Officer. Conducting these discussions as an intrinsic part of the Comprehensive
Compliance Assessment interview - with Dale’s consent, and in his presence - was crucial to achieving a
positive outcome, in that this approach supported Dale’s engagement with his provider, and harnessed
local linkages to identify opportunities for Dale.
The Social Worker’s discussion of Dale’s circumstances with his provider enabled the provider to gain a
greater understanding of Dale’s issues. The Indigenous Services Officer was able to provide information on
local Indigenous Youth Programs, which the provider agreed to explore as options for Dale. Through the
brokerage work undertaken during the Comprehensive Compliance Assessment, the Social Worker,
Indigenous Services Officer and provider were able to work collaboratively based on a positive
engagement, shared understanding and flexible approach.
These scenarios illustrate typical day-to-day operations of the Participation Solutions Team in their
interactions with job seekers and providers.
Jamie, who has been in receipt of income support payment since 2007, is a 32 year old Indigenous male.
He is in Stream 3 services.
Following a history of multiple non-attendances, Jamie was referred for a Comprehensive Compliance
Assessment. Identified issues included overcrowded accommodation affecting Jamie’s health, and family
bereavement. The Participation Solutions Team consulted with Jamie’s provider, and via the consultation it
was agreed that a Job Capacity Assessment was required. The consultation process assisted in developing
a shared understanding of the issues Jamie was facing. Given the grief and loss issues for Jamie in
relation to multiple family bereavements in the weeks immediately preceding the CCA, it was determined
that a period of exemption was appropriate in the interim, with the JCA to be scheduled at the end of the
Mark is aged 23, is in Stream 3 services, and has been in receipt of Newstart for 18 months. His provider
lodged a No Show, No Pay for missing the first day of a five day IT course. Mark attended the remainder of
In discussion with the Participation Solutions Team in relation to the No Show, No Pay, Mark advised that
he had been ill on the first day of the course, but could not afford to travel to the doctor, and so was not
able to supply a medical certificate. The Participation Solutions Team discussed Mark’s circumstances with
the provider, and the No Show, No Pay was rejected. The Participation Solutions Team also reinforced with
Mark the importance of remaining engaged and complying with activities, providing positive messaging to
Mark in relation to his attendance generally.
David is in Stream 1 services and has a mixed attendance history. In discussion with the Participation
Solutions Team in relation to a connection failure, a range of barriers was identified. David was referred for
a Job Capacity Assessment on the basis of the issues raised, and as a result is now in Stream 4. His
record since then indicates that he has attended the three subsequent appointments with his provider.