Facilitators Guide - Disability Employment Australia

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1
Table of Contents
Program overview ........................................................................................................... 3
About this training program ................................................................................................. 3
Aims and objectives .............................................................................................................. 3
Target audience .................................................................................................................... 3
Training program structure .................................................................................................. 4
Learning objectives ............................................................................................................... 5
Program delivery information .......................................................................................... 6
Delivery schedule.................................................................................................................. 6
Icons ...................................................................................................................................... 7
Conducting workshop activities ........................................................................................... 7
Session plans ................................................................................................................... 9
Program Introduction ........................................................................................................... 9
Topic 1: Understanding Compliance .................................................................................. 11
Topic 2: Managing Service Quality ..................................................................................... 29
Topic 3: Quality Documentation Practices ......................................................................... 39
Topic 4: Monitoring and Continuous Improvement of Program Delivery ......................... 59
2
Program overview
About this training program
The DES Contractual Compliance Training Program has been developed by Disability
Employment Australia (DEA) to provide DES employment practitioners, particularly
frontline managers, with the skills and knowledge to effectively comply with the DES
provider contract requirements (DES Deed).
The training program centers on ‘getting back to basics’ to ensure that employment
practitioners are able to meet the DES provider contract compliance requirements.
Aims and objectives
The aim of this training program is to provide support to DES providers to ensure that
frontline management staff understand the legal and ethical imperatives relating to
contractual compliance and accountability of government funding. This entails:




Building capability to understand the legal nature of the DES Deed and the
contractual obligations of DES providers
Understanding the transactional element of the Department of Social Services and
Disability Employment Services provider relationship and documentary evidence for
key employment services milestones
Understanding the importance of the frontline manager role in terms of DES
provider compliance with the DES Deed
Utilising support mechanisms, tools and techniques to assist in effectively complying
with the DES Deed.
Target audience
This training program is designed for Disability Employment Services provider staff, with
particular focus on managers operating at the frontline.
Individual sections / topics can also be used as ‘back to basics’ tools to deliver to
experienced DES employment practitioners, with the purpose being to confirm or update
existing knowledge and skills.
3
Training program structure
The DES Contractual Compliance Training Program is a 1-day facilitator-led workshop. The
workshop is supported by a participant workbook which contains core knowledge
requirements to assist workshop participants in achieving the learning outcomes. The
workbook content and practical activities are designed to build underpinning skills and
knowledge associated with DES compliance. Training program learning will be in the form
of group work, individual activities and facilitator-led questioning and discussions.
The wide range of activities included in this program allows the DES provider to select those
activities that are best suited to their staff needs, organisational imperatives and pertinent
compliance issues.
The DES Contractual Compliance Training Program consists of four topics. A brief overview
of each of these topics is provided below.
Topic 1: Understanding compliance
This topic examines the key concepts of compliance and outlines the Department of Social
Services' approach to DES program assurance. It also provides an overview of the core
provider obligations to DSS.
Topic 2: Managing service quality
The second topic of this training program explores the foundations of service quality: duty
of care, ethical decision making, the National Standards for Disability Services and quality
documentation.
Topic 3: Quality documentation practices
Topic 3 examines in detail the principles and practices of quality documentation
underpinning the provision of Disability Employment Services – from program entry
through to providing ongoing support.
Topic 4: Monitoring and continuous improvement of program delivery
The final topic considers the practical aspects of monitoring compliance and facilitating
continuous improvement of program delivery. It considers the compliance monitoring and
improvement process and provides strategies to assist monitoring, evaluation and
continuous improvement.
4
IMPORTANT NOTE
Many documents referred to and used as resources in this training program refer to the
Department of Education, Employment and Workplace Relations (DEEWR). Please note that
the government regulatory responsibility for Disability Employment Services programs now
rests with the Department of Social Services (DSS) and many of these documents are now
in the process of being reviewed and updated to reflect this regulatory change.
Learning objectives
When learners have completed the DES Contractual Compliance Training Program they
should be able to demonstrate:
1. The key legislative and contractual compliance requirements associated with the
provision of disability employment services
2. The relevance of key contractual requirements to your own role and responsibilities,
and those of your organisation
3. How to ensure compliance with the DES Deed and guidelines via a range of
appropriate methods
4. How to adjust plans, processes and procedures to improve performance against key
contractual requirements
5
Program delivery information
The DES Contractual Compliance Training Program is a one-day interactive facilitator-led
workshop. The learning will take the form of whole group work, individual activities and
facilitator-led questioning and discussions.
NOTE: Whilst this training program is designed for delivery as a one-day workshop, due to
the nature of the topic and the comprehensiveness of the learning materials and the
interactive approach, the delivery period may be extended according to the DES provider
and learner needs.
The workshop group should consist of no more than 20 participants at a time to ensure
maximum impact and engagement.
Delivery schedule
A delivery schedule for the workshop, including detailed session plans, is provided on the
following pages.
Time
Session Title
Slides
9.00 – 9.20am (20 min.)
Workshop/module introduction
1-4
9.20 – 10.30am (70 min.)
Topic 1: Understanding compliance
5 - 27
10.30 – 10.45am (15 min.)
Morning tea break
--
10.45 – 11.30am (45 min.)
Topic 1 continued
11.30am – 12.30pm
(60 min.)
Topic 2: Managing service quality
28 - 36
12.30 – 1.15pm (45 min.)
Lunch break
--
1.15 – 3.15pm (120 min.)
Topic 3: Quality documentation practices
37 - 54
3.15 – 3.30pm (15 min.)
Afternoon tea break
--
3.30 – 4.00pm (30 min.)
Topic 3 continued
4.00 – 5.00pm (60 min.)
Topic 4: Monitoring and continuous
improvement of program delivery
6
55 - 63
Icons
The session plans for the workshop provided on the following pages include a number of
icons to assist you in easily identifying facilitation requirements:
PowerPoint slide
Evaluation /writing
Activity – individual
Distribute materials
Activity - group
Use the white board
URL/links and/or additional
information
Use the flipchart
Question
Checklist
Reference documents (i.e.
readings)
Break (lunch, afternoon tea
etc)
Note: Where references to ‘PW’ are made in the Facilitator Guide, for example ‘PW 6’,
please note that these references refer to a particular page in the Participant Workbook,
such as ‘Participant Workbook page 6’. These references are made to assist you in easily
accessing participant workbook information and to also help to quickly refer learners to
specific information in the participant workbook.
Conducting workshop activities
When facilitating the various activities included in this training program you will need to
reflect on your organisation’s Service Delivery Model. The model answers to the activities
that are provided in the session plans for the workshop are very broad in nature, however
there is an opportunity to tailor these activities to your specific organisational structure and
DES program services delivered by your organisation.
7
Activity delivery options
There are a number of options that can be used to facilitate and deliver activities:
Activity delivery option 1 – individual learner activity
Conduct the activity as a self-paced, individual learner activity that the learners can use to
reflect on their own thoughts about working in Disability Employment Services and what
they believe is important from the job candidate’s perspective.
Activity responses can be written directly into the participant’s workbook. Once the activity
has been completed, the facilitator can randomly ask participants to share their answers
and generate discussion.
Activity delivery option 2 – small group activity
Split the class into groups of three or four (depending on the activity itself, the number of
learners, and the number of questions in the activity). Each group is to answer one of the
questions and summarise on butcher’s paper. Each group should then present their
findings to all other learners.
Activity delivery option 3 – round robin activity
Some activities can be delivered as a round robin activity where the facilitator has the
question/s written on the top of butcher’s paper and hangs them on the walls of the
training room. Split the class into small groups of 3-4 and allow them a few minutes to
discuss one idea regarding each question and to write this down on the butcher’s paper
and then move onto the next question. This will allow for diversity of different ideas to be
generated from the whole group.
8
Session plans
Program Introduction
Time allotted to this session: 9.00am – 9.20am (20 minutes)
Slide
Slide 1: DES
Contractual
Compliance
(Title Slide)
Type of
Activity
Facilitator Notes / Instructions
Introduce yourself & welcome learners.
Explain that the DES Contractual Compliance Training Program
has been developed by Disability Employment Australian (DEA)
to provide DES employment practitioners with the skills and
knowledge to effectively comply with the DES provider contract
requirements (DES Deed).
Address housekeeping and evacuation arrangements:

Please ensure your mobile phone is switched off or set to
meeting mode

Please be aware of any trip hazards as you move around the
room

In case of an emergency our nearest exit is…

Our assembly point if evacuated will be…
Slide 2: Agenda
Outline the agenda for today’s workshop.
Slide 3:
Program
Objectives
Outline the purpose of the workshop – i.e. program objectives.
Slide 4:
Learning
outcomes
Provide an overview of the learning outcomes for the workshop.
ASK learners: What do you hope to get out of this workshop? –
as a lead in to activity in the introduction of Participant
Workbook...
Activity: Your objectives

What are the key areas you would like to address as part of
this training?

What are the key compliance skills you would like to
9
Slide
Type of
Activity
Facilitator Notes / Instructions
improve as a result of this training?
Learners to complete activity individually and share responses.
This activity should be returned to at the end of the day to
determine whether the key objectives have been satisfied.
10
Topic 1: Understanding Compliance
Time allotted to this session: 9.20am – 11.30am (115 minutes – with 15 min. break @
10.30am)
Slide
Slide 5: Topic 1
–
Understanding
Compliance
Slide 6: The
importance of
compliance
Type of
Activity
Facilitator Notes / Instructions
Topic 1 – Understanding Compliance:

Examines the key concepts of compliance

outlines the Department of Social Services' approach to DES
program assurance

provides an overview of the core DES provider obligations to
DSS
Use the statistics to emphasise the importance of contractual
compliance.
ASK: ‘Why do you think that compliance can be difficult at
times?’ as a lead-in to the following activity.
Activity: Compliance challenges (PW 8)
Advise learners that they have 60 seconds to write down all the
words associated with compliance & the challenges that it
brings.
After 60 seconds writing time is completed, seek responses.
Responses are likely to include the following:

Complexity, changing guidelines/rules, trying to stay up to
date

No room for human error, getting dates mixed up, not
having time to document everything / keeping on top of file
notes

Paperwork and documentary evidence

Audits

Administration heavy

Program assurance

Difference between activity test & participation
requirements

Time management
11
Slide
Slides 7-8:
Defining
compliance
Type of
Activity
Facilitator Notes / Instructions

Understanding the different types of participation
requirements for each cohort

Department changing the rules to compliance and eligibility
for DES program

Ambiguity in the DES Deed and Guidelines

National Standards that overarch the DES Deed are
conflicting

Understanding Social Security Law

ES IT System too complex

Demanding caseload of participants/job seekers

Not having enough time to work with participants to assist
them into employment as there is too much administration
Read out general & DES definitions of ‘compliance’ (Slide 7) and
then show Slide 8 – advise that in practical terms this means that
DES providers and their staff are required to comply with the
DES Deed and all of the deed guidelines in delivering program
services.
ASK: ‘What does “compliance” mean to you personally?’ as a
lead-in to the next activity...
Activity: What does ‘compliance’ mean to you? (PW 10)
Refer learners to PW 10 and get them to reflect on the following
(either individually, in small groups or as whole workshop
group):

Thinking about your day-to-day work as a DES practitioner,
what does 'compliance' mean to you?

How would you personally define it?
Seek responses and explain that ‘compliance’ is about ensuring
that...

the correct documentary evidence is available in the job
seeker file, the ES IT System & completed in full and that the
evidence demonstrates the activities that have been
undertaken by both the job seeker and the DES provider

the government is satisfied regarding the services that have
been delivered and it is of value for money

as a practitioner you have met the Employment Services
12
Slide
Type of
Activity
Facilitator Notes / Instructions
Code of Conduct and delivered DES services to participants
as per the Service Guarantee
Slide 9:
Principles of
compliance
Outline the fundamental principles that underpin DES
compliance – see PW 10-12
Activity: How the principles of compliance impact on your work
Break learners into 6 small groups / pairs and assign each group
one of the principles to consider & report back on (alternatively
break into 3 groups & assign two of the principles). Provide
groups with butchers paper & markers for recording their
responses.
Possible learner responses should address the following:
VALUE FOR MONEY

Ensuring money paid to the DES provider is paid accordingly
for the achievement of the DES Objectives – i.e. paid,
sustainable and open employment.

In the process of providing assistance to the job seeker,
assistance is provided and paid by the provider that will
deliver on the individual job seeker’s goal ensuring that their
right are protected and the individual is treated with dignity
EFFECTIVENESS

Achieving KPIs / reaching targets

Commencement of DES Participants in the DES program

Education Outcomes

Job placements

Employment Outcomes

Winning DES business at tender and/or reallocation

Achieving high star rating performance

Passing DSS audit
EFFICIENCY

Passing quality assurance audits

Placing participants into employment quickly / within
reasonable times and achieving outcomes quickly

Engaging clients in activities to achieve employment and
13
Slide
Type of
Activity
Facilitator Notes / Instructions
independence in the workplace

Achieving KPIs within the required timeframes

Claiming fees and outcomes within required timeframes
ETHICAL BEHAVIOUR

Positive relationship with job seekers and staff

Treating clients with dignity, respect and upholding their
human rights

Maintaining confidentiality and privacy, e.g. keeping the
filing cabinet locked or personal information out of view of
the public

Placing clients into employment that meets their objectives

Providing individually tailored DES services

Being non-judgmental and accepting of people’s diversity,
sex, religion, cultural backgrounds

Conducting work honestly and fairly

Ensuring compliance is met to the best of your ability and
knowledge

Abiding with WHS laws
TRANSPARENCY

Sharing own expertise and knowledge with staff and clients

Not withholding information that is pertinent to business

Open and honest communication
ACCOUNTABILITY
Slide 10: DSS
approach to
program

Responsiveness to job seekers

Responsive to contract compliance

Performing required job tasks as per position description

Ensuring compliance to the DES Deed

Compliance to the National Standards

Responsiveness to the public for the achievement of
results/outcomes
The Department of Social Services’ approach to assuring the
integrity of disability employment services is set out in:
14
Slide
assurance
Type of
Activity
Facilitator Notes / Instructions
(a) the Employment Services Compliance and Assurance
Framework – which outlines the way in which DSS will work
with employers to ensure integrity of employment services
(b) The Employment Services Charter of Contract
Management – which sets out the minimum standards of
performance and conduct that DES providers can expect
from the Department
Refer to PW 13 - provide an overview of the four strategies used
by DSS to provide assurance for DES programs:
1. Prevention
2. Deterrence
3. Detection
4. Correction
Slide 11: A risk
based
framework
Advise learners that a risk based framework is used by DSS to
gain assurance that program objectives and requirements of the
DES deed and guidelines are being met by DES providers –
outline the mechanisms used to do this (see slide & PW 14).
Slide 12:
Prevention
Outline the ways in which the DSS uses ‘prevention’ as a
program assurance mechanism. (See PW 14)
Slide 13:
Deterrence
Outline the ways in which DSS uses ‘deterrence’ as a program
assurance mechanism (see PW 14).
ASK: Does anyone know what the DSS’s 2014 targeted program
assurance activities are?
In 2014 the Department has identified areas of risk which may
be the focus of targeted assurance activities as:

Direct Registration

Employment Pathway Plans

Ongoing Support

Outcome Fees

Wage subsidies

Exits.
These assurance activities allow DES providers to ensure they
have good governance and procedures in place to support the
delivery of these services, and that payments are accurate and
15
Slide
Type of
Activity
Facilitator Notes / Instructions
consistent with the Deed arrangements.
Targeted program assurance activities enable the Department to
identify the risk of non-compliance and to detect actual noncompliance. The Department’s compliance activities will be
provider specific, looking at claims / activities by an individual
provider or a small number of high risk providers.
Slide 14:
Detection
Outline the detection strategies used by the DSS to identify noncompliance / practices that impact on the integrity of
employment programs. (See PW 14-15)
Advise that the DSS may also make direct contact with
employers, participants and other relevant parties to verify
evidence provided by the DES provider.
Slide 15:
Correction
Outline the correction strategies used by the DSS to address
non-compliance by DES providers.
Explain that the level of sanctions used will depend on the
nature and level of non-compliance identified.
Advise that DSS does not usually apply sanctions other than debt
recovery where the provider self-identifies non-compliance. See
PW 16)
Slide 16: The
risk level
continuum
Explain the risk level continuum and advise that each provider is
assigned a risk level (which is periodically reviewed)
This risk differentiation approach determines the frequency and
intensity of scrutiny which is applied to each provider and/or
site.
All DES providers are scanned using a variety of ‘risk filters’ to
detect matters of concern.
Activity: What attracts DSS’s attention? (PW 16)
ASK: What types of things are likely to attract DSS’s attention in
terms of detecting non-compliance?
Depending on time available, conduct activity as either a small
group activity or individual activity where learner responses can
be sought and written on whiteboard or butchers paper for
recording purposes.
Note: For guidance regarding model response you should use
the ‘Checklist of what will attract attention’ on page 6 of
16
Slide
Type of
Activity
Facilitator Notes / Instructions
Employment Services Compliance and Assurance Framework.
In addition, possible learner responses may include:

Very high rates of exit / return to employment services

Variations on patterns of claims as a result of desktop
monitoring

Higher amount of special claims indicating internal
inefficiencies to lodging claims with the required time period

Past record of non-compliance

Complaints from job seekers and/or CRRS

ES Staff tip off line reporting levels of non-compliance

High amount of recoveries identified

High amount of claims/fees not taken by the provider

Unusual patterns of activity in particular with outcome
claims with the one employer

Non-compliance with the DES Deed
Activity: Helping ensure compliance (PW 18)
Ask each person to mention one way in which the DSS program
assurance approach can be explained to staff until responses
have been exhausted. Learner responses are likely to include the
following:

Talk about the difference between ‘should’ and ‘must’
compliance requirements – ‘must’ is a non-negotiable that
needs to occur; ‘should’ is something that it is
recommended you do

Program assurance – DSS approach is a risk management /
risk minimisation approach, i.e. DSS will look for signpost
data and where they see signposts that might indicate noncompliance they will take a closer look

Evidence that an effective service has been delivered

Demonstrates a participant’s journey to employment

File notes tells the story and documentary evidence supports
the events that have been undertaken

Compliance is about justifying value for taxpayers money –
demonstrates provision of service and progression of job
17
Slide
Type of
Activity
Facilitator Notes / Instructions
seekers
Slide 17: The
Employment
Services Charter
of Contract
Management
Slide 18: DSS
site monitoring
by contract
managers

Legal requirement under Social Security Act and Disability
Services Act

Evidence can be used in the law of court if subpoenaed

Ensures that the objectives of DES program are being met

Program assurance makes sure that DES are doing the right
thing in the right way

Continuous improvement practices
Outline underpinning principles of the Employment Services
Charter of Contract Management (see slide & PW 19) and
explain that the Charter:

Sets out minimum standards of performance and conduct
that providers can expect of DSS

Outlines transparent practices and standards regarding DSS’s
dealings with DES providers

Seeks to strike a balance between achieving the goals of the
program and creating an environment that fosters and
encourages good practices – it endeavours to achieve this by
ensuring effective consultation, communication,
collaboration and consistency in the DSS’s relations with DES
providers and by building supportive, positive business
partnerships with key stakeholders
Site monitoring of DES providers is conducted by DSS contract
managers as part of the informal performance assessments
undertaken as part of the Deed requirements (ref. Section
133.4). Explain that in practical terms this means that contract
managers visit the sites where services are delivered and
go through files and check evidence and the provider must
provide reasonable assistance to:

inspect its sites or premises

inspect the performance of services, and

locate, inspect, copy and remove, all material including data
stored on the provider’s ES IT system, and any other IT
systems.
18
Slide
Type of
Activity
Facilitator Notes / Instructions
Activity: Interactions with DSS personnel (PW 21)
Note: This is an optional activity and depends on specific group
needs – based on responses provided in the Compliance
Challenges activity.
Activity instructions:

Place two sheets of butchers paper on the wall – one
labelled ‘Contract Manager’ and the other labelled ‘Account
Manager’ (alternatively, just one sheet of butchers paper
labelled DSS).

Provide post-it notes to learners and ask them to reflect
on/write down on the post-it note the challenges that they
personally have in their interactions with contract managers
and account managers – or DSS as a whole.

Share and discuss learner responses – learner responses to
this activity may include the following (see ‘Challenges’
below).

Following discussion re challenges, discuss ways in which
communications could be improved (see ‘Improvements’
below).

Important Note: Many will say they never see their contract
manager any more (government resources have been
constrained), BUT there is usually lots of communication
(email, phone etc) between providers and contract
managers.
CHALLENGES
Contract Manager:

Difficult to have direct contact with Contract Manager as
communication is via a central email box

Internal communication protocols and channels must be
exhausted before contact can be had with contract
managers

Responses received from DSS are quotes from Deed or
guidelines without the desired contexualisation needed to
effectively address an issue/problem

DES organisations may not want to raise issues as this may
spark an audit by the Department

Delays in receiving responses from Department (e.g. may
have to wait up to a week to receive a response)
19
Slide
Type of
Activity
Facilitator Notes / Instructions
Account Manager:

Communications with Account Managers are usually had
with senior of DES providers

Operations staff of DES providers may not be aware who the
Account Managers are
IMPROVEMENTS
DES practitioners should keep contracts professional, concise
and accurate – don’t ask (or try not to ask) questions the
department has gone to efforts to answer on the provider
portal, they will think you have not done your ‘homework’ and
they will simply refer you to the portal. It is always best to
outline the steps you have already taken to determine an answer
before asking DSS a question or for clarification, e.g. the
Employment Assistance Knowledge Base (EAKB), Provider Portal,
Deed, Guidelines, etc.
DES practitioners will say they are only allowed to email their
contract manager to a central email box. This is the current
preference of DSS, so considerations need to be around the
quality and accuracy of the written communication i.e.:
Slide 19: Core
obligations of
DES provider

Be clear and concise in the communication with DSS
personnel

Provide actual examples and/or case study of a real situation
that needs to be clarified when seeking clarification of any
ambiguity in the Deed or Guidelines

Ensure positive and open communication with DSS at all
times

Be aware of DSS service levels & sometimes slow response
times from DSS
Outline the core obligations that DES providers have in regard to
provision of services and programs are that they meet the
requirements of the DES Deed and guidelines – as per slide.
The obligations are set out in the DES Deed, with clarification
and guidance provided in the operational guidelines.
The DES Deed is the legal contract that sets out the terms that
will apply when a DES provider is appointed to deliver program
services – it contains:

Basic conditions of delivery of services
20
Slide
Type of
Activity
Facilitator Notes / Instructions

Information and information management requirements

Deed administration

The specific DES programs to be delivered by the provider

Fees associated with delivery of the services / programs

Code of Practice and Service Guarantee.
Explore the core obligations further – refer to the following
slides for detail.
Slide 20:
1. Maintain high
standards of
service and
conduct
Slide 21:
2. Achieve KPIs
Advise how each of the following are used by the DES provider
and individual staff members to ensure high quality standard of
service and conduct (refer to PW 23-25)

Internal policies and procedures

The DES Deed and guidelines

The National Standards for Disability Services

The Service Guarantee

Employment Services Code of Practice to inform your work
There are a number of KPIs set out in the DES Performance
Framework that a DES provider must achieve as part of its
obligations to provide the disability employment services set out
in its DES Deed – outline the components of the framework (as
per slide & PW 26-30)
The key objectives of the DES Performance Framework are to
ensure it delivers:

A fair system of performance measurement (Star Ratings)
that measures provider performance, and produces reliable
comparison based on actual performance of DES providers

Transparency for participants and employers as to how
providers are assessed and rated

Improved information available for job seekers and
employers in choosing a DES provider

A consistent focus on achieving outcomes for participants

Clearer and more timely information to assist DES providers
to manage and improve their own performance

A performance framework that supports a commitment to
continuous improvement.
21
Slide
Type of
Activity
Facilitator Notes / Instructions
Make sure you address the following in detail:
1. The DES provider’s Star Rating which is based on
measurement of their performance against KPIs (see
Figure 5: KPIs – objectives and measures on PW 28)
2. Weightings and financial values for each of the
performance measures (see Figure 6 on PW 29).
Activity: Other performance assessment factors (PW 30)
Refer learners to activity in workbook and ASK:
What compliance considerations arise in relation to the
additional performance assessment factors (from Section 133.3)
outlined above?
Conduct as a group round robin activity. Possible responses
include:

Updated complaints register clearly documenting the action
and outcome of all complaints

Results of previous audits and program assurance activities

Delivering individual and tailored services to job seekers

Ensuring case notes are clear, relevant and concise

Management of stakeholders, i.e. RTO, community services,
etc

Internal forms used are relevant for the delivery of DES
services

Compliance with documentary evidence

Appropriate record management and storage of files

Compliance with the National Standards

Accurate recording of job seeker activity in ES IT System

Evidence of job seeker appointments, actioning of notice
board etc
Activity: The impact of the Performance Framework on my role
(PW 31)
Note: Do either the group activity above (Other performance
assessment factors) or this individual learner activity.
Learner responses should include some or all of the following:
22
Slide
Slide 22:
3. Document
and report on
service
provision and
key milestones
Type of
Activity
Facilitator Notes / Instructions

Site and individual KPIs for placement and outcomes are
reviewed to ensure good performance in the star rating

DES commencement KPIs

Quarterly KPIs, ensuring claims are lodged at the end of each
quarter so that they are counted towards star ratings

Increase in post placement support activities to ensure job
seekers remain in employment for the 52 week indicator

Placing clients into long term and sustainable employment
for the star rating weightings

Up to date JSCI

When to perform an exit of a job seeker from the service
without impacting and effective performance

Effective record keeping and meeting contract compliance
and documentary evidence

Directs focus on what DES services are required to be
delivered and the type of employment outcomes that need
to be achieved

Part of a practitioner’s professional development plan

Determines a DES provider’s training requirements

Performance framework can drive a DES provider’s business
and service delivery model to ensure it meets the objectives
of DES

Provides guidance on attracting suitable employers and
vacancies for job seekers

Guidance on partnering with relevant training organisation
to develop a skilled workforce

Relevant legislation (such as Social Security, Privacy and
Disability Services Act) drives the appropriate behaviours to
ensure integrity is delivered through the performance
framework
A fundamental compliance requirement for DES providers is to
record and report on key milestones and to demonstrate that
services have been delivered to support each service fee claim.
The key milestones (as shown on slide) are associated with:

confirming and documenting participant eligibility – e.g.
direct registration
23
Slide
Type of
Activity
Facilitator Notes / Instructions

assessment and planning – e.g. initial service fee

job placement – e.g. job placement fee, 13 week outcomes,
26 week outcomes

providing ongoing support – e.g. flexible OGS fees
Advise that the key milestones & documentary evidence
associated with each of the milestones will be examined in Topic
3.
Slide 23-25:
4. Operate
ethically and
prevent fraud
ASK learners:

What is fraud?

How do we prevent fraud?

What are the consequences of deliberately providing false
information?

What about unintentionally providing incorrect or false
information?
Provide definition of fraud (see slide) and outline what it means
to operate ethically and prevent fraud – see PW 33-35.
DES providers have an obligation to operate effectively,
efficiently and ethically – this extends to detecting, preventing
and reporting any fraudulent activity and taking necessary
disciplinary and preventive action.
Prevention of fraud can be achieved through vigilance and
effective internal policies, processes and procedures and also
having an open, honest workplace culture which actively
encourages adherence to compliance requirements.
NOTE: This section should highlight that fraud in DES is used too
loosely and there needs to be clear distinction on the actual
definition of ‘fraud’ as related to the Criminal Code Act 1995.
Clearly make this distinction and emphasise that fraud is
committed based on the premise that the intent or deception
was deliberate.
Use examples provided on Slides 24 & 25 to illustrate this point.
Activity: Detecting or preventing fraud (PW 35)
Refer learners to activity in workbook and ASK:
What strategies does your organisation use to (a) prevent
fraudulent activity; and (b) detect whether any fraudulent
24
Slide
Type of
Activity
Facilitator Notes / Instructions
activity has occurred?
Conduct as either small group activity with debrief/share with
whole group or as whole group activity with responses
contributed individual learners – whiteboard responses.
Learner responses may include:

Checklist to ensure compliance and documentary evidence
for claim

Periodic internal audits

Team leader or site manager checks documentary evidence
before claims are made

Centralised claims

Monitoring of complaints

Staff complaints of internal activities
Activity: Fraudulent activity (PW 36)
ASK: What are the likely sanctions for behaviour found to be
consistent and wilful? What is consistent and wilful behaviour?
Facilitator Note: Draw answers from the Sanctions Framework
for the Employment Services Deed and the Disability
Employment Services Deed (available on Provider Portal).
Gather verbal responses from learners, which may include:

Loss of employment

Government imposed ban working for any agency that is
contracted to deliver government contracts

Loss of practicing licence, i.e. accountant, etc

Criminal record

Fines

Sanctions on business, i.e. not able to tender for more
business in the future

Imprisonment
Following the activity, refer learners to the information in their
workbook (PW 36) regarding the Employment Services Tip-Off
Line – this tip off line lets current & former employees of
providers who suspect, or have evidence of, any activities that
may be a breach of the DES Deed to report their concerns
25
Slide
Type of
Activity
Facilitator Notes / Instructions
(confidentially) to the appropriate authority in full confidence
that any allegations will be properly investigated.
Slide 26:
5. Use the ES IT
System to aid
compliance
One of the core obligations that DES providers have in regard to
provision of services and programs is that they use the
Employment Services IT System to document service provision
and demonstrate compliance.
Managers need to understand the ES IT System clearly and they
need to ensure their staff know how, why and when to use the
system and that they complete training in how to use the ES IT
System.
Provide learners with some tips and techniques that they can
employ to help them better use the ES IT System – refer to tips &
techniques on PW 37.
Activity: IT system challenges, tips and techniques (PW 37-38)
Note: Optional activity
ASK learners: What issues and challenges do you face when
using the ES IT System?
Learner responses re challenges may include:

Internet may be down and cannot access the information

Not able to find the answer you’re looking for as there is too
much information

May need to read and understand several guidelines before
you can answer a question

Too many updates and bulletins, difficult to keep track of all
the changes as well as work with job seekers

No training available on how to use the Provider Portal
Sharing of tips and techniques, e.g.:

Keep a work journal where you list the priorities for the day

Ensure all file notes are recorded before you leave at the
end of the day

Using templates (which can be edited) for file notes – this
can help cover off on contractual obligations, e.g. a note to
confirm you have reviewed the EPP

During regular staff meetings focus on a particular IT or
compliance issue.
26
Slide
Type of
Activity
Facilitator Notes / Instructions
Following discussion regarding challenges associated with using
the ES IT System, ask learners to share their own tips, techniques
or strategies that they use to use the System as effectively as
possible for recording and reporting service delivery.
Activity: Compliance and the frontline manager
Frontline managers have considerable accountabilities and
obligations in relation to contractual compliance.
To complete Topic 1 learning, ask learners, working in small
groups (with groups based around specific job roles, if possible),
to complete this optional activity by reflecting on the following
questions:
What are the ways in which you as a manager ensure that your
organisation and relevant staff members meet the DES Deed
obligations and maintain compliance?
Possible learner responses:

Conduct spot audits / random file audits

Regular reviews with staff, e.g. allocate a senior staff
member to lead peer reviews of files

Bring up compliance concerns during staff meetings; discuss
‘lessons learned’ through compliance audits

Regular staff training, e.g. ensure sufficient staff time to
complete learning centre modules and attend compliance
training

Checklists

Centralised claiming units

File notes

Documentary evidence retained in client file or third party
management software systems

Ensure a learning and improvement culture in your team
What specific compliance responsibilities do you have as part of
your job role?
Possible responses, depending on job role, may include:

Auditing

Quality officer, ensuring procedures and checklists are
available for staff
27
Slide
Slide 27: Core
obligations of
DES provider
Type of
Activity
Facilitator Notes / Instructions

Contract trainer, delivering training in a series of formats to
ensure contractual understanding of the DES program

Check documentary evidence before claims are made

Employer liaison staff have responsibility of ensuring
placements meet payable outcome guidelines for valid
claims

Employment consultants – EPP, diary management, payable
outcomes, assessments such as JSCI, direct registration, etc
To close topic, briefly recap on the core obligations of the DES
provider (that have been examined in this topic), i.e.:
1. Maintain high standards of services and conduct
2. Achieve Key Performance Indicators
3. Document and report on service provision and key
milestones
4. Operate ethically and prevent fraud
5. Use the ES IT System to aid compliance
28
Topic 2: Managing Service Quality
Time allotted to this session: 11.30am – 12.30pm (60 minutes)
Slide
Slide 28:
Topic 2 title
slide
Slide 29: The
Foundations of
service quality
Type of
Activity
Facilitator Notes / Instructions
This topic examines those elements of service quality that form
the foundations for effective compliance.
Provide an overview of the four foundational elements that
constitute ‘service quality’ as presented in the diagram, i.e.:

exercising a duty of care

ethical decision making

adherence to the National Standards for Disability Services

producing and keeping quality documentation to support
DES program delivery
Each of these elements will be examined in this topic in the
context of complying with DES Deed contractual obligations.
Slide 30: Duty
of care
Explain the duty of care framework for DES practitioners – key
areas for consideration include:

Who do you have a duty of care to?

What is your duty of care to those in or associated with your
organisation?

What do you need to do / not do to ensure that there is no
breach of duty of care, and that no one will suffer harm or
loss because of your actions / inactions?
As part of duty of care to program participants, you need to
carefully assess the person’s capabilities and risks (both
physically and emotionally), taking into account the relevant
issues, rights and interests and attending to the consultation
requirements.
The framework for duty of care is designed to assist you in
making such assessments and managing your duty of care.
The JobAccess website (see PW 41) also provides useful
information regarding the duty of care of DES providers and their
employees.
29
Slide
Type of
Activity
Facilitator Notes / Instructions
Activity: My duty of care (PW 42 - optional activity)
As an employment practitioner, to whom do I have a duty of
care and what is this duty of care?
Seek responses from learners until all duty of care obligations
have been addressed.
Responses should include:


Slide 31: Ethical
decision making
Duty of care to the job seeker/participant is to ensure that:
o
they are working in a stable environment that has good
WHS practices
o
their rights and privacy are respected when they attend
the DES provider
o
they are free from discrimination to access the service
freely and they have the supports that they choose
Duty of care to employer is to assure that:
o
the participant is meeting WHS policies and that there
are reasonable adjustments in place to ensure safety of
all
o
there is a clear and concise plan for the participant to
follow & to allow informed decision making and choices
Read quote and advise that:

DES practitioners must demonstrate a high level of personal
ethics and principles in the management and delivery of DES
programs.

Section 2B of the Deed requires providers to carry out the
DES program services efficiently, effectively and ethically.

DES providers must at all times act in good faith towards the
DSS and their customers, and in a manner that maintains
the good reputation of the DES sector.

Ethical conduct and decision making is about the standards
expected and it’s concerned with values, principles and
adherence to the DES Deed, Service Guarantee, the
Employment Services Code of Conduct and internal policies
and procedures.

The Employment Services Code of Practice emphasises
“behaving ethically and acting with honesty, due care and
diligence”.
30
Slide
Type of
Activity
Facilitator Notes / Instructions
Activity: The impact of ethics (PW 43 – optional activity)
ASK: What do the terms ‘honesty, integrity, probity, diligence,
fairness and consistency’ mean to you when you go about your
everyday work?
Ask learners to work in small groups and assign one of the terms
(honesty, integrity, probity, diligence, fairness, consistency) to
each group. Each group should:

Write their own definition of the term

Brainstorm how this term applies to their role / different
roles within the DES organisation.

Share their responses with the other groups.
When undertaking this activity, prompt learners to consider
what ethical issues / decisions they’ve been faced with in their
own experiences and how they’ve dealt with them.
Slide 32:
REFLECT
decision making
model
It can sometimes be difficult to make informed decisions about
the management and delivery of DES programs given the myriad
of legal and ethical issues associated with working in this sector.
The Australian Public Service Commission has developed the
REFLECT decision making model is a useful tool that can be used
when faced with making difficult ethical decisions.
Go through the REFLECT model and ASK learners how and when
they might apply this model in the course of their work.
Activity: What if... (PW 42)
Refer learners to activity on page 42 of their workbook.

Break learners into five small groups and assign one of the
situations/ethical dilemmas to each group.

Ask each group to consider the ethical dilemmas: (i) What
questions do you need to ask yourself? (ii) What action do
you need to take? (iii) How do you address / resolve this
situation?

Ask each group to report back on how they would deal with
the ethical dilemma.
Model responses for each situation are provided below for
activity debriefing purposes.
31
Slide
Type of
Activity
Facilitator Notes / Instructions
Situation 1 – model response:

What are the circumstances of Jay’s personal situation? Is he
at risk of not engaging?

Should I notify Centrelink that Jay is at risk and may require
intervention from a social worker or a psychologist?

Have I rescheduled appointment times with Jay when it is
suitable for him to come into the office?
Situation 2 – model response:

Will this claim pass an audit? Do I have the necessary
paperwork completed to substantiate the claim? Can the
claim be taken without all the relevant documentary
evidence? What additional evidence do I need to ensure the
claim is valid?

Documentary evidence must be adhered to ensure valid
claim. You can’t be sure what you have entered is accurate –
you need to ensure you have declarations in writing or
comprehensive file notes to support claim evidence.

Contact the client to collect the missing information for valid
claim. Prepare the paperwork for the client to sign verifying
the correct information. Contact the client’s employer to
ensure appropriate information is retained in file.
Situation 3 – model response:

Will recording the department store as the employer
withstand scrutiny? Will this pass audit? Does this meet
outcome and documentary evidence guidelines? Will I be
committing fraud by recording incorrect information in the
ES IT System?

Ask the client to bring in their pay slip to verify who their
employer is. Ask the client if you can contact their supervisor
to verify details of their employment.

Ask the staff member to correct the mistake. Implement
correct training for the staff member to ensure that they
understand the requirements of an outcome claim and
correct documentary evidence.

Retract the placement and anchor from the ES IT System
until correct employer details have been gathered and
ensure this is documented in the file notes and corrective
action is taken.
32
Slide
Type of
Activity
Facilitator Notes / Instructions
Situation 4 – model response:

Ask the staff member the reasons for the contradiction and
identify whether the client/employer confirmed hours of
employment.

Identify whether the information in the file notes was
incorrectly documented and ensure a file note of the
incorrect information is noted and corrected.

Identify with the employer the correct hours:

o
Ask employer or client of a payment summary over the
26 week period confirming hours
o
If possible, check JRRR/JEHR of what was declared to
Centrelink to confirm hours of employment on the
signed declaration.
Where further evidence cannot be gathered, retract the full
claim and claim a pathway outcome.
Situation 5 – model response:

Double check file notes and other forms of documentary
evidence to ensure all employment hours have been
correctly recorded.

Explain to the manager that the client had not worked the
required hours for a full outcome, thus a pathway outcome
will need to be claimed.

Negotiate with the employer and client, if possible, to work
the extra two hours for the claim period.

Consult with other staff regarding the situation of the claim
and explain a full outcome cannot be claimed due to
compliance issues.

Consider the repercussions of claiming outcomes based on
incorrect information – remember it is the person lodging
the claim or providing the information that will be at risk of
providing false or misleading information.
Activity: Workload and decision making (PW 47 – optional
activity)
Break learners into small working groups for this activity –
provide groups with butchers paper & markers to record their
responses.
Refer learners to the activity in their workbook (PW 47) and ask
33
Slide
Type of
Activity
Facilitator Notes / Instructions
them to reflect on the comment by an employment practitioner
regarding workload and decision making.
Ask them to think about how, if they found themself in a similar
situation, they would you deal the situation.
Following group reflection time, ask each group to report back
and discuss responses in relation to how employment
practitioners can effectively make appropriate decisions about
supporting participants and stay on top of their workload at the
same time.
Activity responses may include the following:
Slide 33:
National
Standards for
Disability
Services.

Speak to the manager and determine what assistance can be
provided to support the demands of the case load

Support the client to take more control over making their
own appointments with health professionals

Restructure appointment times and increase the duration so
that EPPs and other relevant documentation can be done
during client appointments

Consider what other external community services are
available to assist, e.g. Personal Helpers & Mentors (PHaMS)

Where sites have administration staff, request assistance
from in preparing resumes and application letters

Empower clients by providing them with the resources to
support their own job search where possible.

Create group appointments for those clients who are more
job ready and facilitate a job club –more clients can be seen
during the same appointment time providing more time to
attend to other clients during one-on-one appointments.
The NSDS are designed to ensure a nationally consistent
approach to improving the quality of disability services – they
use a person-centred approach and focus on the rights and
outcomes for people with disability.
The 6 standards are supported by 26 KPIs which state the
Australian Government’s expectations of service quality, and
which link directly to core organisational processes and
outcomes under Quality Assurance principles.
Each standard is underpinned by the same basic elements:

the rights for people - the individual rights that each
34
Slide
Type of
Activity
Facilitator Notes / Instructions
standard promotes or supports
Slide 34:
Indicators of
practice

the outcomes for people - what an individual using services
or supports should experience through the effective
achievement of each standard

the standards for service - the requirements involved for
services to achieve each standard.
ASK: So how do you know if you are compliant with the NSDS?
Seek verbal responses and discuss the indicators of practice (see
PW 50) in the NSDS Evidence Guide which provide guidance on
the activities and ways of working that should be in place to
support each of the standards.
Also refer learners to NSDS resources – PW 52.
Activity: Evidence to show standards are being met (PW 51)
(Note: Activity can be done as either a group activity – where
group is split into 6 small groups and each group assigned a
standard, individual activity or round robin activity.)
For each of the indicators of practice listed, ask learners to
outline how they would provide evidence to demonstrate that
they and the organisation are meeting the required standard.
Share responses. Responses may include:
1. Rights

Disability access to premises

Information about DES can be received in various forms to
ensure the client understands the services they can expect

Policies and procedures on discrimination

Grievance handling policies and procedures

EPP outlining roles and responsibilities between the client
and the DES provider

Duty of care - staff display ethical behaviour when working
with participants

Code of conduct

Staff training and development on rights and duty of care
2. Participation and inclusion

DES provider has links to employers, community service
35
Slide
Type of
Activity
Facilitator Notes / Instructions
providers and training organisations that can support their
employment goals

MOUs with community organisations

DES participants have appropriate access to participate in
activities relevant to their employment goals

DES participants have the right support to enable their
participation in employment and training
3. Individual outcomes

Up to date EPP which aligns with activities & supports

Activities in EPP are individualised and tailored to support
the client’s needs and meet their employment goals

EPPs are negotiated with the client and they have the
opportunity to negotiate the support that they require to
meet their employment goals

DES provider delivers the supports as per EPP, taking into
consideration any limitations of the client

Client is placed into open employment, receiving the correct
wages according the relevant Award

Employer workplace meets the relevant WHS laws

Client is provided the opportunity to enter the open labour
market
4. Feedback and complaints

Client access to CRRS

Internal policies and procedures

DES provider has clear/visible mechanisms and processes
where clients can provide feedback and complaints

Complaints are addressed and actioned

Clients are given an opportunity to be heard should they not
be happy with the services they receive, e.g. access to
external complaint facility, National Abuse & Neglect Hotline
5. Service access

Skills assessment

ESat/JCA are reviewed and barriers are addressed to ensure
access to supports and services
36
Slide
Type of
Activity
Facilitator Notes / Instructions

JSCI is up to date and the information is correctly recorded

EPP activities address the barriers to employment
6. Service management
Slide 35: Quality
documentation

Continuous improvement processes

Internal procedures and processes are regularly reviewed
and updated to ensure currency of services

Internal audit of service provisions

Continuous improvement feedback mechanisms available
for staff and clients

Improvements to services are evidence based
Outline the DES Dee requirements regarding quality
documentation.
ASK: What constitutes quality documentation?
Discuss and refer to next slide.
Slide 36: What
constitutes
quality
documentation
Outline what constitutes good quality documentation that helps
deliver services effectively and supports compliance.
Explain that it’s good business practice to keep comprehensive,
evidence based, well-ordered records which are supported by
efficient business processes – this helps make sure day-to-day
work practices are conducted as effectively as possible and that
compliance requirements are met in a systematic way.
Activity: Documentation practices (PW 54)
Question 1:

Provide each learner with 6 post-it notes.

Place two sheets of butchers paper on walls (1 – titled ‘Does
Well; 2 – titled ‘Could Do Better’).

Ask learners to share / write their responses on the post-it
notes and place them on the butchers paper.

Conduct whole group debrief to discuss similarities &
differences in responses.
Responses are likely to include:
(Note: these answers can go in either column as they will be
37
Slide
Type of
Activity
Facilitator Notes / Instructions
relevant to the practices within each organisation)

File notes

Internal procedures on documentary evidence collection

Third party software that assists with better practices and
compliance

Central claiming units

Practices identified for improvements during internal audits

Forms that enable collection of correct documentary
evidence for claiming

Over-compensating on documentary evidence, i.e. some
organisations request that pay slips and signed employment
forms are required for claims

Forms stored electronically

All documentary evidence is checked for compliance before
claims are taken
Question 2:
Ask learners to write down one improvement they could
immediately make and to share/discuss this with the person
next to them.
Responses are likely to include:

Ensure documentary evidence is correct before claims are
made

Prepare documentary evidence ahead of time, checking that
all relevant information is recorded so it is prepared for
verification

Regular reporting of what fees and outcomes are coming up
for claiming so nothing is missed

Track KPIs to ensure performance is being met

Continuous improvement - record & action appropriately
NOTE: Advise learners that quality documentation practices will
be looked at in detail in the next topic.
38
Topic 3: Quality Documentation Practices
Time allotted to this session: 1.15pm – 4.00pm (150 minutes – with 15 min. break @
3.15pm)
Slide
Type of
Activity
Facilitator Notes / Instructions
Slide 37: Topic 3
– quality
documentation
practices
Show title slide and advise that this topic examines the
principles and practices of quality documentation that
underpin the delivery of DES programs – from program entry
through to providing ongoing support.
Slide 38: DES
program
structure &
compliance
obligations –
documentary
evidence
Provide an overview of the general obligations that DES
providers and the associated documentary evidence
obligations that DES providers and their staff are required to
comply – refer to PW 55-56.
Emphasise the importance of keeping good case notes to meet
these documentary evidence requirements.
Use the media items/quotes provided on PW 57 to highlight
the importance of keeping comprehensive, evidence based,
orderly records.
Slide 39:
Keeping good
case notes
Outline what constitutes good case note record keeping.
Provide tips to help learners keep good case notes – refer to
PW 58.
Note:
Slides 40-41:
Case notes –
best practice

Unofficially, employer written evidence, such as a pay slip,
attracts less scrutiny than say verbal evidence from a job
seeker, however, each form is acceptable under the Deed
and guidelines.

Changes to policy now only occur on a quarterly basis and
bulletins are posted in a weekly digest, with the exception
of news that needs to be conveyed immediately. It would
be good practice for a manager to ensure they read the
weekly digests & all/any policy updates for each quarter.
Provide guidance on what constitutes best practice on case
note keeping to help ensure appropriate evidence is gathered
and recorded and that the organisation’s case notes are
compliant – refer to PW 59.
39
Slide
Type of
Activity
Facilitator Notes / Instructions
Activity: Case notes – journey and progression (PW 60)
Refer learners to the activity in their workbook.
Question 1:
ASK: How do you ensure that case notes ‘tell the story’ and
record the progression of the employment services program
participant?
Learner responses may include:

Record reasons JSCI updates and explain each change

Document employment related information in the case
notes

Reflect on file notes from previous appointments and
ensure consistency of information – where activities were
arranged record the outcome of the activity from previous
appointment

Ensure file notes reflect the EPP, e.g. client is looking for
retail work and EPP goals and activities need to support
this

Record any attempts of contact with the client; this will
assist with compliance reporting

Detail any assessment of the client that is related to
employment

Identify any barriers to employment, strategies to minimise
the barriers and any outcomes from these strategies
Question 2:
ASK: What case note recording tips can you share with other
workshop participants?
Write up on whiteboard, or if time permits, ask each table to
write additional tips on butchers paper & then pin up on walls
& groups do a walk around to look at tips.
Learner responses may include:

Write objectively and record facts only, e.g. use words such
as “the client stated...” and “the client appeared...”

Do not record any personal opinions of the client

Keep case notes that are limited to employment related
assistance; do not record irrelevant information (e.g. what
the client ate for breakfast) unless it will impact their
40
Slide
Type of
Activity
Facilitator Notes / Instructions
employment

Avoid jargon and slang

Write clearly and concisely
Activity: What’s missing? (PW 61-62)
Provided are examples of file notes completed by a DES
practitioner. Spilt learners into three groups, assign a file note
to each group and ask them to analyse the file note to
determine:

What information is missing and what could be included /
improved

What the benefits are of producing comprehensive file
notes
Ask each group to report back with their responses. Some
suggested responses for each file note item are provided
below.
Item 1 – Outcome file note:
Missing information / what could be included:

Start and end dates for Outcome period

Total & average hours worked during the outcome period

Wage earned over the period

Name of the DES staff member who confirmed the
participant’s employment

Location of employer and their contact details
Benefits of comprehensive file notes:

Determine that the participant worked the required hours
for the outcome period for a valid claim

Meet documentary evidence requirements for a valid
outcome

Withstand scrutiny of audit

Meets Standard 3 of the National Standards – Individual
Outcomes

Determine that the correct wages are being paid to the
participant for the work for which they are engaged
Item 2 – Review appointment
41
Slide
Type of
Activity
Facilitator Notes / Instructions
Missing information / what could be included:

Her appearance to the appointment was not addressed nor
was the smell of alcohol

Review of her progress in job search activities was not
addressed

Barriers to employment not identified and addressed

A discussion of the type of employment that Samantha
applied for to determine suitability

Employment goals not identified

Next steps - what to expect at the next meeting

Discussion of suitable employment options

File notes need to be objective - better way of wording the
client’s appearance would be “Samantha appeared with a
distinct smell of alcohol and her appearance appeared
dishevelled. Spoke to Samantha about this and she stated
that she is on a new medication that is giving her side
effects and is causing restless sleep.”

A broader discussion about employment goals needs to be
case noted to determine whether Samantha requires other
non-vocational interventions to address any barriers to
employment

Assessment of referral services is needed to address any
issues with alcohol or appearance which may be a barrier
to employment
Benefits of comprehensive file notes:

Documenting file notes objectively is important so that
other practitioners do not form prior judgement of client

Under Freedom of Information, clients can access their
records - reading statements in their case notes that
appear to be derogatory may have a negative impact on
the client

Case notes provide information on the progress of a
participant from the last appointment, to current situation,
and the next steps that will be taken. It sets out clear
expectations of the services that need to be delivered and
ensures continuity of service provision should another
practitioner take over the client.
42
Slide
Type of
Activity
Facilitator Notes / Instructions

Evidence for auditors regarding services delivered.

Shows progress of the participant over time towards
meeting their employment goals - can celebrate successes
Item 3 – Initial appointment
Missing information / what could be included:

Confirmation that ID had been sighted

Relevant paperwork discussed, i.e. privacy forms

Confirmation that DES services have been discussed

Employment goals

Assessment of the participant employment aspirations,
skills and abilities

Evidence of any changes of the JSCI

Assurance that the client understood the information

Strategies towards achieving employment

Any identified barriers to employment and strategies to
overcome these

Any identified barriers that have been updated in the JSCI
Benefits of comprehensive file notes:

Documenting initial appointment helps set out the service
provisions and expectations about the services the client
will receive

Identifies what employment types the client is striving for
which will assist in directing the client to the services that
they require from the DES provider

Ensures that the strategies set out in the EPP are reflective
of the client’s goals and that any limitations to
employment are recorded and addressed
Advise learners of some of the resources that they can access
to help them produce better case notes – refer to information
on PW 62.
Slide 42: Quality
documentation
for each stage of
the employment
Advise learners that the next section of this topic will focus on
the quality documentation that underpins each phase of the
DES process – from program entry to providing ongoing
support.
43
Slide
Type of
Activity
Facilitator Notes / Instructions
services process
Slide 43:
1. Program
entry
Slide 44: Direct
registration
eligibility
requirements

Program entry focuses on determining eligibility for DES
programs – i.e. understanding, confirming and
documenting eligibility.

In most cases participants are referred to the DES provider
by an ESAt or JCA assessor – referrals can also be made by
Centrelink, DSS, Job Services Australia providers or by
another DES provider.

Outline the minimum information that must be set up on
the ES IT System for the participant (as per slide).
Go through the program entry requirements for Direct
Registrations, as per flowchart (see PW 64).
The eligibility criteria that a participant must meet and that
must be documented so as to meet the claim payment
requirements for the first 13 week period service fee include,
the participant is:

aged between 14 and 65 years of age

is an Australian resident

is not studying full time (unless the participant is an Eligible
School Leaver)

is not working at or above their employment benchmark
hours

participant has a CRN (where they do not, one needs to be
arranged through DHS).
Must record on the Direct Registration Form that proof of
identify documents have been sighted.
Activity: Direct registration requirements (PW 65-66)
Have learners complete the short answer questions. Seek
responses from learners. Model answers are provided below:
Question 1:
Determine person’s eligibility for Direct Registration &
complete the Direct Registration Form with the person at the
initial interview.
Question 2:
44
Slide
Type of
Activity
Facilitator Notes / Instructions
The person must (a) be an Australian resident, (b) not be
currently serviced by another DES provider, (c) have a
disability, injury of health condition, (d) be aged between 14 –
65, (e) have a permanent address in the Employment Services
Areas specified in the DES provider’s schedule is contracted to
deliver program services, as specified in schedule, (f) not have
a current and valid ESAt/JCA referral recommendation to
another service, (g) meet any other relevant eligibility criteria
which are prescribed in the Deed.
Question 3:
Name & date of birth, or Centrelink Customer Reference
Number.
Question 4:
A participant with a current and valid ESAt/JCA with a referral,
a JiJ participant, a Special Class Client Participant, or an Eligible
School Leaver.
Question 5:
Current passport, current driver’s licence or other form of
photo identification from a government department of agency.
Activity: Eligible or not? (PW 66)
Break learners into 3 groups and assign a scenario to each
group. Each group should:

Determine whether the person is eligible to be
commenced in DES

Explain why this is the case

Outline what evidence you’re required to gather and
document to demonstrate that the person has met the
eligibility criteria
Each group should be prepared to share their responses with
the whole workshop.
Model answers for each scenario are provided below.
Scenario 1
A person with cerebral palsy wishes to access to DES to help
them into employment once they have finished university.
Eligibility: Not eligible; full-time students are not eligible.
45
Slide
Type of
Activity
Facilitator Notes / Instructions
Evidence required: None; ineligible to commence DES.
Scenario 2
A young person in year twelve with Down Syndrome who is
currently studying in Year 12 wishes to seek after school work.
Eligibility: Eligible School Leaver, eligible for direct registration
if evidence requirements can be met.
Evidence required: Attracts additional education funding due
to disability, in final year of school, after. After school work
clearly relates to their employment goals.
Scenario 3
A person with mental illness employed full-time approaches you
for assistance to keep their job.
Eligibility: Job in Jeopardy, eligible for direct registration if
evidence requirements are met.
Evidence required: Employment must actually be in jeopardy.
All other direct registration requirements should be met; must
have been employed for at least 3 months (or if less, the job
must be ongoing at least for three months in principle); must
have evidence of disability; must be likely to require ongoing
support (must otherwise be eligible for DES).
Slide 45:
2. Assessment
and planning
Outline the focus of the assessment, planning and employment
assistance phase of DES (as per slide & PW 67).
Slide 46:
Contact
requirements
Advise of mandatory contact requirements - DES providers
must conduct contacts with participants face-to-face and they
deliver the mandatory minimum number of contacts as
required in the DES Deed (refer to slide).
Each contact appointment must be tailored to meet
participants’ individual needs. Services to be delivered at each
contact may include:

Identification of and referral to appropriate activities and
services

Discussion of job search activities and appropriate job
vacancies

Reviewing and updating the EPP

Reviewing progress and outcomes and recording
46
Slide
Type of
Activity
Facilitator Notes / Instructions
information in file notes

Reviewing the appropriateness of activities the participant
has engaged in and the skills that they have developed as a
result of these activities

Recording referrals to jobs and job interviews and the
outcomes of these referrals

Organising assessments to determine a participant’s
limitations or abilities, such as functional capacity
evaluations or physical assessments.
Contact results must be recorded in the ES IT System and must
confirm that the contact was conducted face-to-face.
Activity: Additional evidence (PW 69)
ASK: In addition to the evidence outlined in the PW / our
discussions, what other evidence should be retained (either in
electronic form or hard copy) where there has been a failure by
a participant to attend a scheduled contact appointment?
Obtain verbal responses from learners.
Additional evidence may include: (i) evidence relating to the
event that has resulted in the failure to attend; (ii) relevant
information on the participant’s individual circumstances; (iii)
any relevant reasons given by the participant for the nonattendance / non-compliance.
Slide 47:
Employment
Pathway Plan
Explain that the EPP should clearly outline the steps to be
taken by both the DES provider and the participant to work
towards a suitable employment goal.
Address how EPP is maintained and updated at each scheduled
contact appointment. (Refer to PW 70)
Slide 48:
Identification of
and referral to
services
Explain the compliance requirements associated with
documentation of identification of and referral to appropriate
activities and services. (PW 71)
Activity: Initial service fee eligibility and evidence (PW 71-72)
Break participants into 6 small groups and assign a scenario to
each group. Ask the groups to consider: (i) Is the DES provider
eligible for service fee?; and (ii) What evidence is required to
47
Slide
Type of
Activity
Facilitator Notes / Instructions
be gathered and documented?
Each group should report back to the whole workshop group.
Model responses for each scenario are provided below.
Scenario 1
Participant was referred to DES-ESS program by an ESAt with a
0 Benchmark.
Eligibility: Participant is not eligible to be commenced in DES as
all participants must have an assessed capacity to work a
minimum of 8 hours per week.
Evidence required: A referral from the ESAt confirming that the
participant has the capacity to work a minimum of 8 hours per
week.
Scenario 2
Participant attended initial appointment. The participant has a
mental health condition and is required to participate in job
search. The ESAt has a recommended referral to Stream 4 with
a JSA provider.
Eligibility: Participant must have an ESAt recommended referral
to a DES program to be eligible to commence in DES program
services.
Evidence required: ESAt recommended referral to the DES
program is required to determine eligibility to participant in
DES services.
Scenario 3
Participant referred to DES with Benchmark 15 hours but is
currently working at a bowling alley and has been working
there for three months.
Eligibility:

Should the participant not be working on average of their
benchmark hours at the time of Initial Appointment they
may be eligible to participate in DES.

Should the participant be working their average hours of
employment they cannot proceed with the initial interview
and the client must be exited from DES.
Evidence required:

Average hours worked in last 13 weeks.
48
Slide
Type of
Activity
Facilitator Notes / Instructions

Where the client averages below their benchmark, DES
provider can continue with providing services and the
employment will be considered as Pre-existing
Employment.

The job placement activity must be recorded in the ES IT
System and the average hours of employment in the last
13 weeks.
Scenario 4
Participant referred to DES by an ESAt with Benchmark 8 hours.
Participant has cerebral palsy and is currently not working and
looking for employment. Participant is currently receiving DSP.
Eligibility:
The client may be eligible to participate – the DES provider
needs to determine that the participant is not in full-time
study, that they are a permanent Australian resident, and that
the participant is not linked to another DES provider.
Evidence required:

ESAt assessment confirming referral

EPP completed and approved, including the contact
regime; AI09 activity code must be included

Privacy information signed and dated

Confirmation of the participant’s ID

Explanation of DES services, including Service Guarantee
and Code of Practice

Information about local labour market, employment
opportunities and skill shortage areas
Scenario 5
Participant has been referred to DES by an ESAt but is also
working with an ADE 7 hours per week. Benchmark has been
assessed at 8 hours and the referral was made by an ESAt after
a Direct Registration was conducted.
Eligibility:

Concurrency is allowed from ADE to DES and the
participant must be working below their benchmark

ESAt referral confirming eligibility for DES

As the participant is working with the ADE that is below
49
Slide
Type of
Activity
Facilitator Notes / Instructions
their benchmark hours, they may be eligible for DES
provided all other requirements are met
Evidence required:

Direct Registration form and privacy form completed in full

ESAt assessment confirming referral

EPP completed and approved, including the contact
regime; AI09 activity code must be included

Confirm the participant’s ID

Explanation of DES services, including Service Guarantee
and Code of Practice

Information about local labour market, employment
opportunities and skill shortage areas

Job Placement at the ADE to be recorded as pre-existing
employment confirming the average hours of employment
with the ADE over the last 13 weeks
Scenario 6
Direct Registration was conducted for a worker with a disability
after the employer requested that the worker required
assistance to keep their job.
Eligibility:

Employer must confirm that the participant’s employment
is at risk due to their disability, injury or health condition

Participant must be assessed as requiring assistance from
DES to maintain their employment and require ongoing
support

May be eligible to register as JiJ participant – JiJ participant
must be working minimum 8 hours per week
Evidence required:

Direct Registration form

Evidence of the worker’s disability, injury or health
condition

Employer Form completed and signed by the employer
where the worker has given permission for disclosure of
their disability, injury or health condition

Signed and dated file note by the DES provider that the
50
Slide
Type of
Activity
Facilitator Notes / Instructions
worker will likely require ongoing support

Slide 49:
3. Job
placement
Employment Pathway Plan completed and approved with
the AI09 activity code
Describe the compliance requirements related to job
placement activities (refer to slide and PW 73-75).
ASK: So what exactly do the ‘details’ mentioned in the slide
include in terms of providing supporting documentary evidence
up which claims for service fees can be made?
Following brief discussion, go through information in ‘Figure
15: Record keeping requirements associated with the Job
Placement process’ (PW 75).
Activity: Job placement fee eligibility and evidence (PW 76)
Break learners into small groups and ask them to consider the
scenario and provide responses to each of the questions.
Ask each group to share their response to one of the questions
until responses to all questions have been provided /
discussed.
Question 1 – model answer:
8th May
ASK: If the employer was not happy with Annette taking time
off and suggested that her continued employment would be at
risk, would you still enter 8th May as the Job Placement Start
Date?
The idea here is to generate a discussion on how to ensure that
the employment will continue beyond 13 weeks, perhaps the
practitioner may need to delay the start date until they are
sure the employment will be stable enough and meet the
expectation that it will continue beyond 13 consecutive weeks
to satisfy Job Placement Fee
Question 2 – Model answer:
10 Consecutive Days over a 14 day calendar period from the
Job Placement Start Date entered into the ES IT System
Question 3 – Model answer:
Yes
Question 4 – Model answer:
51
Slide
Type of
Activity
Facilitator Notes / Instructions
10 May as this is the day that the participant achieved their
benchmark hours within the 10 consecutive working day
Question 5 – Model answer:
Slide 50: Post
placement
support

Job Placement Start Date

Dates and hours worked excluding meal breaks within the
10 days

Name of the person who confirmed the hours either the
participant or employer

Name of the employer and their contact details

Date the confirmation of Job Placement received

Name of the DES staff member who confirmed the Job
Placement

Wages and the Award of the participant
The frequency and level of support provided to the participant
must be documented during the PPS phase as it is this
information that will help determine whether the participant
will require Ongoing Support after the 26 Week Outcome. For
those participants receiving PPs, regular contact is provided as
deemed appropriate by the DES provider.
Outline the full outcome and pathway outcome documentary
evidence requirements (as per slide and PW 77).
Slide 51:
Claiming the
outcome fee
In order to claim the outcome fee, evidence must include a file
note or a signed and dated written statement or email from
the employer or participant – outline what information must
be included in the file note (as per slide / PW 77).
Slide 52:
Anchoring the
PPS phase
Describe the documentary evidence requirements associated
with anchoring the PPS phase.
Activity: 13/26 week full outcome eligibility and evidence (PW
78-80)
Refer learners to the activity in their workbook.
Break learners into two large groups or an even number of
small groups and assign one of the scenarios to each group.
52
Slide
Type of
Activity
Facilitator Notes / Instructions
Each group to report back on their responses to the scenarios.
Use the following model answers to assist with activity debrief.
Scenario 1 - Victor
Q1: Weeks 1 to 4 – 25 hours per week (i.e. 100 hours); Weeks 5
& 6 – 15 hours per week (i.e. 30 hours); Weeks 7 to 13 – 12
hours per week (i.e. 72 hours).
Q2: Average hours – 15 .5 hours per week; total hours – 202
hours
Q3: Yes, you can you claim a Full 13 Week Outcome.
Q4: What documentary evidence would you need to gather
and keep to claim an outcome?






Hours of employment each week
Name of the award wages
Dates of the outcome period
Signed or verbal confirmation from either the
employer or participant verifying employment
The date the verification was received
The name of the DES staff member who received the
verification and the date
Scenario 2 – Samantha

Employment Anchored a week after the Job
Placement Start Date. Provider had been
documenting hour for employment for 13/26
week outcome claim based on Job Placement Start
Date rather than Anchor date

Anchor date is 13/1/2014 and week ending date is
12/1/2014. There has not been a whole week of work
in week 1. It appears that the anchor date commenced
before the working week ended. This has put all the
outcome period dates out of order
Annual Leave is not considered as a Permissible Break



Incorrect dates for 13 week outcome period
Signed prior to 26 week outcome period
Activity: Outcomes quiz (PW 81)
Refer learners to activity in workbook. Have learners complete
the quiz individually & then seek response from learners.
Model answers are provided below to assist in activity debrief.
Q1: 8 hour benchmarks aren’t eligible for a pathway outcome,
53
Slide
Type of
Activity
Facilitator Notes / Instructions
see outcome determination table.
Q2: Refer to outcomes determination table (Appendix 4 in PW)
for answers
Q3: Working each week means being at work each week.
Remaining in employment each week means being employed,
but not necessarily working, e.g. being on annual leave or sick
leave (intending to go back to the same employer) is being
employed but not working.
Q4: Not necessarily, a person must work their benchmark
hours in the 13 week period but if they have worked additional
hours in that period those hours can count towards the 26
week period. The claim is based on one period of 13 weeks
and one period of 26 weeks, not two separate periods of 13
weeks. For example, if a person with an 8 hour benchmark
worked 154 hours in the 13 week period, they would need (at a
minimum) to work at least 54 hours in the second thirteen
weeks to get to 208 hours in a twenty-six week period.
Remember all other conditions must be met – such as
remaining in employment for a twenty six week period (i.e. still
employed at the end of the 26 weeks)
Q5: Youth under 21 without year 12, principle carer parents,
refer to claims determination table for more information.
Slide 53:
5. Ongoing
support
Provide an overview of documentary evidence related to
providing ongoing support to participants – refer to PW 82-83.
Slide 54:
Documenting
ongoing support
Discuss the documentation requirements and circumstances
associated with documenting ongoing support.
Activity: Flexible ongoing support fee eligibility and evidence
(PW 84-89)
Refer learners to the case study activity in their workbooks.
Read through the case study with the learners.
Break learners into small groups and ask them to discuss the
case study and provide responses to the questions.
Each group is to report back to the whole group with their
responses / findings.
Discuss similarities and differences between the responses
54
Slide
Type of
Activity
Facilitator Notes / Instructions
during the debrief. Model responses are provided below.
Q1: Anxiety, depression, chronic back pain, long term
unemployment
Q2: Flexible Ongoing Support is to be delivered for Alice. There
was a total of 4 hours of support that was provided during the
26 week outcome period. Although the DES provider had
frequent contacts with Alice and her employer, not all contacts
required support or interventions to be delivered.
Q3 – Goals:

Alice’s short term goal is to learn her new job and pass her
probation period. Long term goal is to continue working for
Franklin Community Centre and potentially gain full time
employment.

Alice wants to learn as much as she can in her job to the
best of her ability over the next six months.

Alice wants to develop her skills, confidence and
capabilities to competently work as an Administration
Assistant on a part time basis. Alice will work with her
employer and DES provider and engage in activities that
will assist her to work independently.
Q4 – Support requirements:

DES provider to assist Alice to complete all the relevant
paperwork regarding her tax file number and bank account
details, explain her meal breaks, meet the staff and go over
her job description.

Workplace modifications and adjustments which include
readjustment of Alice’s desk, ergonomic chair, foot stool,
new keyboard.

Counselling for her anxiety with the DES employment
practitioner. Alice made a clerical error in her job and this
left her feeling anxious and in need of support to approach
her manager.

Assistance with non-vocational intervention for Alice’s
anxiety.
Q5 – Method of support (phone, face to face, workplace visit):

Main methods of contacts were face-to-face contact, both
at the place of work & appointments with DES provider.

There were also a number of telephone contacts with
55
Slide
Type of
Activity
Facilitator Notes / Instructions
Alice, however the telephone contacts were just to touch
base with Alice to ensure that she didn’t require any
further assistance.

Phone contact also with the employer to provide Alice’s
manager with support.
Q6 – Support required to other parties (e.g. employer, family):

John, the manager, required support from the DES
provider to assist with workplace modifications and also
required assistance regarding how to approach Alice’s
behaviour in a sensitive manner.
Q7 – Other relevant information / considerations can include:

Follow up with Alice regarding identifying the triggers at
work or at home that have had an impact on her raised
anxiety.

Outcome of the counselling sessions.

Was it appropriate for the DES Provider to make
impromptu visits to the workplace? What could have been
the impacts of this?
Q8 – The decision and the reasons for making the decision
where the DES provider:

assesses a Participant for entry into Ongoing Support

performs a Provider Exit from Ongoing Support

changes the level of Ongoing Support for Employment
Support Service Participants
For each Instance of Flexible Ongoing Support:

The date(s) that support was provided and the details of
the support that was delivered.
For moderate or high ongoing support:

The contact schedule specified in the participant’s EPP.

Details of circumstances which prevent a face-to-face
contact for each contact not delivered face-to-face.

Results of each contact to be recorded in the electronic
diary (on the same day as the participant had the contact
or as soon as practicable if not possible on the same day).
56
Slide
Type of
Activity
Facilitator Notes / Instructions
Activity: Contractual quiz
To complete Topic 3 learning, refer learners to activity / quiz in
workbook. Have learners complete the quiz individually & then
seek response from learners. Model answers are provided
below to assist in activity debrief.
Q1: More than 3 hours but less than 25 hours in the last 6
months.
Q2: A DES provider cannot increase the level of a participant’s
ongoing support. Where a participant has been identified as
requiring high ongoing support, a DES provider will need to
refer the participant to the OSA, with the additional evidence
determining that a high level of Ongoing Support is required.
Q3: A participant would require a referral to an Ongoing
Support Assessor after the 26 week employment outcome has
been claimed in the following circumstances:

48 weeks from the Anchor Date of the 26 Week
Employment Outcome, or

It has been 48 weeks or 74 weeks since the participant’s
last Ongoing Support Assessment.
Q4: Evidence provided could include, but is not limited to:

Details of instances of Flexible Ongoing Support

Details of contacts, including date, time & method of
contact

Details of hours and type of support provided

Reports and assessments from doctors or other
professionals

Invoices and receipts

File assessments completed by the DES provider

Observation records

Information from interviews with the participant and/or
other stakeholders, including parents, advocates,
employers and supervisors

File notes that detail the date and time of each interview
or phone conversation, including reason for the contact.
Q5: A DES provider can provide a maximum of 6 instances of
Flexible Ongoing Support (FOS) to a participant in any 26
57
Slide
Type of
Activity
Facilitator Notes / Instructions
calendar week period.
An instance can cover an accumulated number of smaller
contacts (e.g. several face-to-face contacts), or a single
instance of more intensive support (e.g. visiting the workplace
to adjust equipment). An instance is contact/s that equate to a
minimum of 4 hours of service.
Q6: Between 25 and 42 hours of support in the last 6 months.
Q7: Examples of support that can be delivered during a
participant’s ongoing support phase:

On the job assistance and guidance

Co-worker training

Advising or counselling family members

Workplace adjustments and modifications

Vocational training

Referrals to counselling or other non-vocational
interventions

Financial assistance and counselling

Re-adjustment of job tasks

Disability awareness training in the workplace

Training on using equipment that supports the
participant’s employment

Assisting employers to create mental health plans in the
workplace

WHS training and checks
Q8: Manually suspend the participant for the period they do
not require ongoing support.
Q9: An instance can cover an accumulated number of smaller
contacts (e.g. several face-to-face contacts), or a single
instance of more intensive support (e.g. visiting the workplace
to adjust equipment). An instance is contact/s that equate to a
minimum of 4 hours of service.
Q10: A participant can be exited at any time if they do not
require support and they are now an Independent Worker. The
participant should be notified and the decision discussed
before actioning the exit.
58
Topic 4: Monitoring and Continuous Improvement of
Program Delivery
Time allotted to this session: 4.00pm – 5.00pm (60 minutes)
Slide
Type of
Activity
Facilitator Notes / Instructions
Slide 55: Topic 4
– Monitoring &
continuous
improvement of
program
delivery
Show title slide and advise that this topic focuses on the
practical aspects of monitoring and evaluating compliance and
facilitating continuous improvement of program delivery.
Slide 56:
Monitoring and
evaluating
compliance
Provide an overview of the five basic elements for compliance
monitoring:
The topic looks at the compliance monitoring & improvement
process and provides strategies that can be used to assist in
monitoring, evaluation and continuous improvement.
1. Ensuring a compliance process is in place
2. Determining the frequency of monitoring required
3. Adopting a methodical approach to monitoring
4. Appropriate documenting of compliance monitoring
and improvements
5. Taking action as a result of compliance monitoring
Advise that this next section of the topic will look at each of
these elements in more detail.
Slide 57:
1. The
compliance
process
Outline the requirements associated with establishing and
maintaining a compliance monitoring process.
Provide examples of strategies that can be used to monitor and
evaluate compliance by DES operational staff – refer to PW 94.
ASK learners if they have any other suggestions regarding
strategies to monitor compliance.
Slide 58:
2. Frequency of
monitoring
ASK: How often do you think compliance should be monitored?
Seek responses ad advise that as a guide, high risk areas should
be monitored and reviewed regularly, say on a monthly basis,
medium risk areas should be monitored and reviewed
quarterly, and low risk areas, at least once a year.
ASK: So how do you know what’s a high risk, a medium risk or
59
Slide
Type of
Activity
Facilitator Notes / Instructions
low risk?
The key is to conduct a risk assessment to help you determine
what level / priority of risk the compliance activity presents.
Discuss the reasoning behind conducting a risk assessment –
refer to PW 95.
The information provided here is a guideline only and it’s highly
likely that there will be other factors that need to be taken into
account before you make a decision about how regularly to
monitor and review specific compliance related DES activities,
policies, procedures and business practices.
Activity: High, medium or low risk? (PW 95-96)
Refer learners to the activity in their workbook.
Ask learners to consider each of the DES program delivery
activities presented in the table and rate the risk – i.e. the
likelihood and impact if non-compliance occurs and the overall
risk to the organisation. Based on the risk, they should indicate
the frequency of monitoring that they think is required.
Instructions:
1. Rate the likelihood out of 10 using the scoring method
provided below.
2. Rate the impact out of 10 using the scoring method
provided below.
3. Calculate the resultant risk: Likelihood + Impact ÷ 2 =
Overall Risk (e.g. 7 + 8 = 15 ÷ 2 = 7.5, therefore risk can be
rated as a ‘Medium’ risk).
4. Determine required monitoring frequency.
Following completion of risk assessment, compare similarities
and differences between ratings by learners. Discuss the
reasons where there are differences.
Note: Risk ratings will vary from provider to provider
depending on policies and procedures in place and other
relevant factors.
Slide 59:
3. Approach
Discuss the reasons why it’s important to adopt a methodical,
thorough and well documented approach to monitoring
compliance. (See PW 96-97)
Key reasons: Ensures compliance, helps identify where
60
Slide
Type of
Activity
Facilitator Notes / Instructions
improvements are needed, builds a compliance profile for
auditors.
Slide 60:
4. Documentation
Slide 61:
5. Taking action

Documenting the results of compliance monitoring and
improvement, and keeping a record of this documentation,
is critical to effective compliance with the DES Deed and
guidelines.

Without an audit history, there is little evidence to show
the DSS auditors that your organisation is consistently
ensuring that it meets the Deed and guidelines, i.e. there is
no ability to demonstrate to the DSS that you have been
complying and continuously improving your services.
As a result of the monitoring of compliance it is quite likely that
there will be areas identified where improvements to policies,
procedures and business practices can be made.
There may be follow up points and further queries arising as a
result of the compliance monitoring. That’s why it’s good
practice to... (refer to slide).
Activity: Aligning monitoring activities to DSS identified areas
of risk (PW 98)
Refer learners to activity in their workbook.
Each year, the DSS identifies and publishes the key areas of risk
to DES program integrity. These are the risks that will be
subject to contract monitoring and/or program assurance
projects during the year. (Refer to 2014 DSS program assurance
activities if required – see PW 18)
Remind learners / write on whiteboard that DSS has identified
the following areas of risk which may be the focus of targeted
assurance activities in 2014:

Direct Registration

Employment Pathway Plans

Ongoing Support

Outcome Fees

Wage subsidies

Exits.
61
Slide
Type of
Activity
Facilitator Notes / Instructions
ASK: What does your organisation do to ensure that its
governance and procedures in relation to these areas of risk is
in place and working effectively?
Note: Providers are encouraged to ensure that they have good
governance and procedures in place relating to these risks. In
addition to the published risks, the DSS also undertakes further
targeted reviews to assess areas of emerging or identified risk
that may arise.
Activity instructions:
Conduct as whole group or break learners into groups and
assign one of the program assurance areas to each group to
identify what the organisation currently does to ensure that it
has appropriate governance and procedures in place to ensure
program compliance.
Model responses for debrief:
Slide 62:
Continuous
improvement

Participate in DEA delivered webinars on Program
Assurance areas to develop skills and capabilities in this
area. (note webinars are only available to DEA members)

Develop and deliver training on the relevant procedures to
ensure compliance with the program assurance activity

Monthly desktop audits

Quarterly site audits

Also complete ECSN learning centre modules and
participate in DSS facilitated webinars and information
sessions
As well as meeting mandatory compliance requirements, DES
providers need to think beyond minimum requirements and
benchmarks to continuously improve the services that they
deliver.
This requires taking steps to continuously improve compliance
related systems, processes, communications by:

Developing action plans to improve delivery of program
services (refer to the Performance Improvement Plan
Template provided on slide as an example of an action
plan)

Implementing actions plans to ensure progressive
improvement of compliance, and
62
Slide
Type of
Activity
Facilitator Notes / Instructions

Monitoring and evaluating improvements to ensure they
achieve the desired objectives.
Address the Performance Improvement Plan (PIP) example on
slide and provide examples (as per PW 100) of:

PIP goals that may apply

Improvement strategies that may be relevant
Activity: Continuous improvement strategies (PW 100-101)
Ask learners to reflect on what they’ve discussed and learnt
today and to identify an improvement that they would like to
implement in the workplace to improve contractual
compliance.
Develop an action plan (using the Performance Improvement
Plan template provided) for this improvement goal.
Following individual reflection and completion of PIPs, ask
learners if they would like to share their intended
improvement / action plan.
Note: Action plans will vary from learner to learner and
organisation to organisation. The basis of this activity is for
workshop participants to have identified during the course of
the day those areas of DES program delivery that can be
improved to ensure better contractual compliance.
Slide 63:
Workshop close
Conduct a brief workshop recap – revisit the desired workshop
outcomes that workshop participants established at the start
of the day.
Ask learners if they have any further questions
Ask learners to complete the workshop evaluation forms
before they leave the training room
Thank learners for their participation
63
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