Cover Page Employment Services – Building on Success Response to Issues Paper Contents Page 2 Employment Services – Building on Success Response to Issues Paper Executive Summary This section will be developed following feedback from members and the ongoing development of the submission. The principles and recommendations are in draft format and still require some re-wording and reworking. Some sections are not complete and will be finalised this week. Please be forgiving of formatting, layout or issues with sentences, grammar, etc. The full list of references will be updated prior to submission. 3 Employment Services – Building on Success Response to Issues Paper Section 1 Background to consideration of review of DES-DMS services Disability Employment Australia welcomes the opportunity to put forward recommendations in response to the Employment Services – Building on Success Issues Paper. This response will focus on the Disability Employment Services – Disability Management Service (DES-DMS) program. In a review that encompasses Job Services Australia (JSA) and DES-DMS, there is a danger that the distinct role, features and user experience of the much smaller DES-DMS program will be overlooked. Indeed we note that some of the issues that have been raised in relation to JSA – like lack of collaboration with other services, lack of focus on individual needs – are much less evident in DESDMS. Throughout this submission we have tried to draw out some of the distinctive features of DESDMS that support positive behaviours and outcomes, while pointing to areas where improvements could be made. A fundamental difference between the programs is the role of DES as part of an overall effort to enhance the human rights of people with disability in Australia and to address their continuing exclusion from social and economic life. DES-DMS is an essential part of Australia’s response to its commitments under the United Nations Convention on the Rights of Persons with a Disability (UNCRPD), which was ratified by Australia on 18 July 2008. Article 26 of the UNCRPD relates to the establishment of habilitation and rehabilitation services: Article 26 Habilitation and Rehabilitation 1. States Parties shall take effective and appropriate measures, including through peer support, to enable persons with disabilities to attain and maintain maximum independence, full physical, mental, social and vocational ability, and full inclusion and participation in all aspects of life. To that end, States Parties shall organize, strengthen and extend comprehensive habilitation and rehabilitation services and programmes, particularly in the areas of health, employment, education and social services, in such a way that these services and programmes: (a) Begin at the earliest possible stage, and are based on the multidisciplinary assessment of individual needs and strengths; (b) Support participation and inclusion in the community and all aspects of society, are voluntary, and are available to persons with disabilities as close as possible to their own communities, including in rural areas. 2. States Parties shall promote the development of initial and continuing training for professionals and staff working in habilitation and rehabilitation services. Article 27 recognises the right to work and the importance of the right to make choices about work: Article 27 Work and Employment State Parties recognise the right of persons with disabilities to work on an equal basis with others [...] this includes the right to the opportunity to gain a living by work freely chosen or accepted in a labour market […] States Parties shall protect and promote the realization of the right to work, 4 Employment Services – Building on Success Response to Issues Paper including for those who acquire a disability in the course of employment […] by taking appropriate steps […] inter alia … (e) Promote employment opportunities and career advancement for persons with disabilities in the labour market, as well as assistance in finding, obtaining, maintaining and returning to employment […] The emphasis in the Convention on the rights of people to have a say in how services are delivered, and the need to take special measures to improve their capacity to fully participate in society on an equal basis are relevant to Australia today and must inform future thinking about the shape of these services. This section needs to include reference to the National Disability Strategy Employment and disability in Australia While Australia has a high employment rate, people with disabilities are less likely to participate in the labour force, or, once in the labour force, to be employed: Figure 1 Participation and unemployment rates 2009 While the rate of unemployment of people with disabilities has declined since 1993 in line with that of people without disabilities, the participation rate has not increased at the same rate. In other words, the gap has widened in the level of participation and has stayed the same in the level of unemployment. Australia ranks 21st out of 29 OECD countries in employment rates for people with a disability. It is ranked 27th out of 27 OECD countries when it comes to relative poverty risk for people with a disability (Thomas, 2011). People with mental illness have poorer participation and employment rates. In 2009, while the participation rate of people with physical disabilities was 49.7%, for people with mental illness it was 5 Employment Services – Building on Success Response to Issues Paper only 29.2%. The unemployment rate for people with mental illness in 2009 was 2 ½ times that of people with physical disabilities. Figure 2 Selected labour force characteristics by disability group 2009 While some are born with disabilities, many will acquire them. Disability increases with age (Chart 1, ABS (2012)). The largest group of people with disabilities are in the 45 to 54 age range. While mature aged people are more likely to be in work, if they lose their job they are much more likely to become long term unemployed. Age discrimination is more likely to be experienced by those who have an illness, disability or injury and who have a low level of educational attainment (National Seniors Productive Ageing Centre, 2012). Those who acquire a disability, or experience an illness or injury that limits capacity to work are a substantial and growing proportion of our potential labour force (Chart 1). 6 Employment Services – Building on Success Response to Issues Paper Disability by age (,000s) 600.0 500.0 400.0 Moderate core activity limitation 300.0 Mild core activity limitation 200.0 Schooling or employment restriction 100.0 All with reported disability 0.0 15–24 25–34 35–44 45–54 55–59 60–64 ABS 4430.00 Disability, Aging and Carers, 2009 Chart 1 Disability by age The complexity of the challenge of securing employment for people with disabilities was described in WORKability II: Solutions (Human Rights and Equal Opportunity Commission, 2005, p. 13). That report identified and summarised three sets of obstacles facing people with disability and their actual or potential employers. Information – an absence of easily accessible and comprehensive information and advice that assists in decision making processes and responds to ongoing needs; Cost – concern about costs of participation for people with disability and possible costs borne by employers when employing a person with disability; and Risk – concern about any possible financial and personal impact on people with disability and their employers, especially if a job does not work out. The 2009 Shut Out report informed the development of Australia’s National Disability Strategy (National People with Disabilities and Carer Council, 2009, pp. 38-42) and highlighted barriers experienced by people with disability in employment: ‘By far the biggest barrier identified was employer attitudes’ (2009, p. 38); Misconceptions about workplace adjustments and their costs; Stereotypes and misconceptions influencing attitudes and behaviours of employers, recruiters and government; Perception of ‘employment as charity’; and Inflexible Disability Support Pension acts as a disincentive to work. More recently, the United Nation’s Thematic study on the work and employment of persons with disabilities (2012, p. 4) highlighted the following barriers, many of them relevant in the Australian context: Negative attitudes or opinions; 7 Employment Services – Building on Success Response to Issues Paper Deeply rooted stigma and stereotypes; Lack of interest from governments, employers and the general population; and Lack of access to education and training in skills relevant to the labour market. Disability discrimination has been the most common complaint received by the Human Rights and Equal Opportunity Commission over the past five years (2012, p. 131). Figure 3 Complaints received by Act over the past 5 years The challenge of securing equality in opportunity of access to employment is highlighted by the Australian Public Service itself where, despite stated intentions, the level of employment of people with disabilities has declined.1 By international standards, Australia’s record in enabling people with disabilities to secure work on an equal basis is poor. There is no evidence that this is changing despite relatively good overall economic conditions. Those who acquire a disability later in life are disadvantaged both by their disability, illness or injury and by their age (Sedgwick, 2012). The role of DES-DMS This program is described as designed for “job seekers with a ‘temporary or permanent disability, injury or health condition who require the assistance of a disability employment service, and who may require flexible ongoing support but are not expected to need regular, long term support in the workplace at any point in time.” This is a somewhat circular definition. It might make more sense to think of people accessing DESDMS as people who are undergoing, or are attempting to manage, a major life transition arising (at least in part) out of a disability, injury or illness. In many cases this will be an illness injury or disability acquired later in life. This is reflected in the age profile of participants in DES-DMS compared with other labour market programs which is heavily skewed to the older age groups (Chart 2): 1 See, for example, comments by Public Service Commissioner Sedgewick on 16 May 2012 http://www.apsc.gov.au/publications-andmedia/speeches/2012/aps-disabilty-employment-strategy 8 Employment Services – Building on Success Response to Issues Paper Chart 2 Age Profile Across Selected Employment Programs STREAM4 15 to 20 STREAM3 21 to 24 25 to 34 DES-ESS 35 to 49 50 or more DES-DMS 0% 20% 40% 60% 80% 100% LMAO Dec 2011 The aim of the DES-DMS program is to assist people to manage the impact of their condition so that it no longer has a practical effect on their ability to work. This often includes securing the assistance of allied health professionals to assist in managing the condition itself, but it may also include adjusting to a new type of career and to a range of other changes that might have occurred associated with the illness/injury or disability. In other words, the purpose of DES-DMS is vocational rehabilitation – whatever helps someone with a health condition or disability to stay in, return to or move into work. Many in the DES-DMS program do not identify themselves as people with a disability. They are more often on Newstart Allowance than the DSP (Chart 3). They may have considerable work experience, but they are extremely vulnerable to long term unemployment because of the challenge in managing a major life transition, because of their disability and, for many, because of their age. Chart 3 Income Support Types (proportion) DES-ESS Newstart Allowance Youth Allowance (other) STREAM4 Disability Support Pension Parenting Payment Single STREAM3 Parenting Payment Partnered DES-DMS Not on income support 0% 20% 40% 60% 80% 9 100% Employment Services – Building on Success Response to Issues Paper While a higher proportion of people who access DES-DMS services have physical disabilities than those who access DES-ESS, there are as many people with psychiatric/psychological disabilities in DES-DMS as in DES-ESS (Chart 4). DES-DMS is an important part of the rehabilitation infrastructure for those who experience a period of mental illness and are in the process of recovery. Chart 4 Primary disability by DMS and ESS (most common categories) Vision Neurological Intellectual Specfic learning Psychiatric Physical 0 5000 10000 15000 20000 25000 30000 35000 40000 45000 Employment Support Service Disability Management Service DEEWR caseload data, 31st Oct 2012 DES-DMS has been relatively successful in achieving employment outcomes, particularly full time employment, for people who have a disability (Table 2). Table 2 PPM Outcomes (December 2011) DES-DMS DES-ESS Stream 3 Stream 4 Stream 3 (PWD) Stream 4 (PWD) Employed 40.1 34.4 34.9 29 37.9 27 Total positive 47.3 43.6 49 42.4 53.7 39 Not in Labour Force 28 28.6 22.7 31.2 19.3 37.2 DES-DMS has achieved a higher rate of employment, particularly full time, for those over 50 (Table 3). Mainstream services are not always perceived as appropriate by mature aged job seekers (need ref). The DES-DMS service is likely to be perceived as more appropriate as it is (a) less volume driven (b) more geared to older aged job seekers (c) more professionalised. Table 3: Outcomes for people aged 50 or more years (June 2012) 10 Employment Services – Building on Success Response to Issues Paper Stream 3 Stream 4 DES-DMS Employe d fulltime (%) Employe d parttime (%) Employe d total (%) 6.4 6.9 9.4 28.1 18.9 28.7 34.5 25.8 38.0 Unemploy ed (%) Not in the labour force (%) Educatio n& training (%) Positive outcome s (%) 41.9 39.2 29.4 23.6 35.0 32.5 15.2 15.3 9.0 45.9 38.1 44.4 Awareness of assistance to make workplace adjustments and experience in negotiating job flexibilities are more likely to be found in DES providers, which have a specialist focus in this area. While a significant number of people leave the labour force after participating in DES-DMS (Tables 2 and 3), more will remain engaged than their counterparts in Stream 4 or than over 50s in Stream 3. In the light of Government efforts to reduce new entries to DSP, the DES-DMS programs success in this area is critically important. The specialised nature of DES-DMS, its focus on case management rather than volume, and its involvement of vocational rehabilitation professionals appear to be important to its successes in achieving outcomes for people with disabilities, particularly mature aged people. DES-DMS plays a specific role in the suite of employment programs available in Australia. It is specialised – it addresses those with complex needs rather managing large volumes of relatively employable job seekers. It is geared to that group that need transitional assistance, and is particularly important to assisting mature aged people. While we believe outcomes can be improved, it is important to preserve those features of the program that have enabled it to achieve good outcomes for this group. Improving the system. The problem of dealing with complexity. Public employment services range from the straightforward (e.g. provision of information about job vacancies to job seekers, supporting more effective job search) to the highly complex (addressing employer bias, assisting clients with multiple disadvantages). While the structure of JSA has been designed to minimise deadweight and deal with large volumes of relatively job ready job seekers, the DES program includes very few people for whom the transition to work is straightforward. The DES program can be characterised as one concerned with ‘messy’ or ‘wicked’ problems. A problem where the relationship between an action and a result is not clear, which relies on multiple human actors, an open system of influences and sustaining long term behavioural change. The Demos think-tank publication System Failure (Chapman, 2004) argues that the application of reductionist policy approaches to messy problems is liable to fail. Unintended consequences will arise and performance of the system will decline. There is evidence that this is the case in employment services: While the introduction of a JCA/ESAt assessment is an attempt to ensure that jobseekers are connected to the right service, the average wait for an employment service increased (DEEWR, 2012, p. 17). Because the assessment is so important to performance 11 Employment Services – Building on Success Response to Issues Paper rating and funding, DES providers invested time in redoing the assessment and negotiating with the ESAt/JCA, reducing time available to work with the job seeker to try to secure work; While the program is aimed at maximising capacity of participants to participate in work, many of the incentives for providers (and some for participants) emphasise describing in detail disadvantage and incapacity; While the program is uncapped, the need to compete for star ratings may lead providers to keep recruitment of new clients to a minimum (to ‘protect the denominator’); Similarly, services to those with the lowest support requirements may be prioritised to achieve faster results; The star rating system discourages collaboration and compromises the opportunity to work to address structural barriers in an area to employment of people with disabilities (e.g. working with a particular local industry or employer); and While apparently offering choice, procurement based on star ratings stifles innovation and drives risk-averse, homogenous services. When unintended consequences arise the response from governments has often been to introduce another level of scrutiny and/or regulation. But, if we take the view that this system is characterised as one concerned with ‘wicked’ problems, the answer is not to attempt to micromanage, but to take a system wide view of the problem – we need to step back rather than plunging deeper into the detail. At the same time, as Chapman and others have argued, complex problems require greater user engagement (co-production). While objectives are set at a high level, delivery systems are coproduced locally. A shift from block funding to funding which rewards achievement of employment has been positive. Job seekers come to employment services because they want a job, not because they want to be in a service. The use of indicators which measure the proportion of participants that achieve employment is clearly relevant. But the indicators that drive the calculation of star ratings (and payment of funds) are far more specific and far narrower than the outcomes that the DES program is intended to achieve. The Public Service Commission has noted that: There is increasing evidence that some types of pre-set performance measures, especially lower-level indicators, may undermine the responsiveness of the delivery of complex services and could even distort or constrict the services being delivered by making the indicator (or target) rather than the service the focus of provision (Also Nevile, pp63-64) In the case of DES, there are signs that the overwhelming focus on payable outcomes may, indeed, be at the expense of delivering a service that meets the needs of all of its clients. In discussing the performance of employment programs, DEEWR has tended to focus on job placements and outcomes and make comparisons between these and past programs or overseas 12 Employment Services – Building on Success Response to Issues Paper experience.2 However the evidence is that most people will not achieve lasting employment through the program. Latest Post Program Monitoring data shows that around 48% of DES-DMS clients will move into work or education after participating in the program. Around 33% will be unemployed, while 26% will have left the labour force. Of those in work, 37% identify themselves as ‘seeking more work’ (i.e. underemployed). No net impact data is available for DES-DMS or its predecessor programs. ANU Report pp29-31 reflects the experience of staff that they have had to shift away from spending time with all their clients to spending time with those for whom they can quickly achieve a placement. The move away from a holistic service is one reason that skilled workers are leaving employment services (ANU, p38). Nevile and Lohmann (2011, p. 64) propose a shift away from the current performance management framework to one which is characterised by continual dialogue between funder and service provider about what is working and what needs to be changed. Provisional goals are set, but then revised in the light of experience. The contractual relationship is characterised by shared goals and monitoring focussed on diagnosis/learning, not compliance. In considering how we can get better overall outcomes from DES-DMS, we need to think of it as a program designed to deal with complexity. This has implications for its structure. It means that clients must be engaged as much as possible in developing solutions. It means that objectives and KPIs must be able to be adapted to changing circumstances and learnings. It means that collaboration over shared long-term goals will need to take priority over achievement of narrowly defined outputs. 2 See, for example, DEEWR Annual Report 2010-11, APM Evaluation 2010. 13 Employment Services – Building on Success Response to Issues Paper Section 2: Meeting the needs of Job seekers This section … covers three design principles designed to meet the needs of job seekers. Develop introduction / summary. Design Principle 1 Participants should have a greater say in how, when and what services are delivered. Participant engagement in, and satisfaction with the program should be increased. DES was established to enhance the lives of people with disabilities, specifically through supporting their access to employment. It is framed by the Disability Service Standards (DSS) that are designed to ensure that the rights of individuals receiving the service are protected and enhanced. The delivery of disability employment services takes place within the context of exclusion of people with disabilities from many aspects of social and economic life, it is important that the way in which services are delivered enhances the sense of control and inclusion of the people who participate in it, rather than disempowering them. The guiding principles of the UN Convention on the Rights of Persons with a Disability include “Respect for inherent dignity, individual autonomy including the freedom to make one's own choices”. The framing of disability employment services as facilitating the human rights of people with disability underlies the culture and history of the program. It is therefore crucial that the criteria by which government considers its recommendations should include the extent to which proposals would enhance the rights and freedoms of people with disability. This includes the ability for all participants in the program to be treated with dignity and the opportunity to choose services that are appropriate for them. Further to this, there are issues of effectiveness as well as basic rights. The long-term sustainability of outcomes is critically dependent on a good match between the participant, the position and the employer. As people experience greater the sense of control around decision-making, they make a bigger investment in making it work. Employers frequently complain that people referred to them do not really want the job. By showing greater respect to participant wishes and increased time spent looking at labour market options, better long-term matches are generated for both job seeker and employer. In its Disability Care and Support Report the Productivity Commission highlights that is generally more efficient for people to make their own decisions – because no matter how good the case manager, the individual has more information about the complexities of their lives than anyone else. Therefore, they are best able to determine the path that will suit them (2011, p. 356). Self-efficacy can be built through participation in employment services where they are designed to foster decision-making and control by participants. Programs that build self-efficacy respond directly to employer feedback that identifies abilities to make decisions and solve problems as key recruitment attributes. Participants in client directed services report greater satisfaction with the services, with life in general, greater use of mainstream services (Productivity Commission (2011) (esp 359361), Fisher et.al (2010)). Continuing improvement in the level of satisfaction and perceived efficacy of the service will contribute to increased participation of volunteers and those who could benefit from early engagement in the service. 14 Employment Services – Building on Success Response to Issues Paper Current position Overall, participants in the DES-DMS service are positive about the service. Table 4 – Overall quality of service? Survey Type Program Very dissatisfied Dissatisfied Neither satisfied or dissatisfied Satisfied Very satisfied EA/PPS DMS 5.9% 5.3% 11.5% 40.1% 37.2% EA/PPS ESS 7.6% 6.5% 12.9% 39.1% 34% EA/PPS DES total 6.8% 5.9% 12.2% 39.6% 35.6% 6.7% 5.8% 11.8% 39.2% 36.6% Overall average 12.5% 11.8% 75.8% (PPM 1/1/11-31/3/12) However qualitative interviews with participants in DES services show that program design does not always enable individuals to exercise significant control over services. Lantz and Marston (2012) interviewed 80 DES clients over a 12 month period. They found that: “[…] some of the participants experience the administrative and service delivery processes as deindividualising, as failing to recognise their inherent capabilities and internal motivation. The employment services policy and its implementation are perceived as being overly focused on individual deficits, rather than strengths and capabilities. And in the process of implementing this policy, individuals have little capacity to be self-determining; they are asked to choose from a range of limited options that are narrowly determined in terms of education and training to increase employability. Few participants saw that the continuous flow of required ‘activities’ as meaningful steps to achieving employment. They saw it as a ‘performance’ required to fulfil their contractual obligations.” (Lantz & Marston (2012), 865) Aspects of the process raised in the interviews included: the assessment process, which was perceived as focussing on what people could not, rather than could do; frustration at activities for their own sake; lack of time with consultants; being forced to switch providers after eighteen months in the program. The Productivity Commission distinguishes between individualised funding and self-directed support. It identifies key aspects of self-directed support as follows: Resource allocation based on the individual’s needs and aspirations; Capacity for informed and genuine choice; Access to their own individualised budget; and 15 Employment Services – Building on Success Response to Issues Paper Power for the person to tailor the mixture and type of services (including from whom services are received), subject only to their overall budget and reasonable administrative constraints. (Producivity Commission (2011) 354). The Commission points out that while Disability Employment Services have individualised funding, they do not have real consumer power. What features of the current system support participant involvement in the decisions that affect them? The Disability Service Standards set out a framework that places individual needs and aspirations at the centre of the service. In particular: Service Standard 2 provides that the individual’s employment goals are used as a basis for service provision; Service Standard 3 requires that the individual be afforded the opportunity to participate in making decisions about the services and that the service provide acts on the outcomes of their input; and Service Standard 5 requires that individuals be supported and encouraged to participate in the community – reflecting a wider set of values than the simple focus on work. Adherence to these standards is independently audited. The standards have reinforced centrality of clients’ rights and decision-making. Many frontline workers in the sector have a strong sense of ownership of these standards. Advisory and/or governance structures that involve consumer representatives are a characteristic of many long-standing and recently formed DES providers. The importance of appropriate services that are founded on human rights is reinforced by the availability of the independent Complaints Resolution and Referral Service as well as a range of disability advocacy services. Recommendation The Disability Services Standards should continue to be applied to DES-DMS, including ensuring provision of feedback to providers based on client interviews by independent auditors. The CRRS should continue to serve as an independent complaints resolution service for DES-DMS. Other features of DES-DMS support greater responsiveness to participant wishes. Compared to JSA, DES-DMS caseloads are smaller and the program has less burdensome reporting requirements, this enables front-line workers to spend more time talking with participants and tailoring plans to suit their needs. DES-DMS providers either employ, or work closely with vocational rehabilitation and other allied health professionals. In general the DES workforce has a higher skills/qualification base than JSA and lower turnover [do we have any evidence?]. The removal of the ‘time to place’ measures from the DES performance framework signals a greater capacity for providers to focus on job quality and to investigate options to recognise social outcomes. What could be improved? While current program structures are designed so that they can be tailored to individuals the degree of service user control is highly constrained: 16 Employment Services – Building on Success Response to Issues Paper Choice of provider is constrained the choice can be exercised only once, there are limitations on capacity to choose providers outside an ESA; The range of provider offerings is limited. If the experience of JSA is anything to go by, we can anticipate further convergence of provider practice. Competition for star ratings, financial pressure and prescriptive contracts have inhibited innovation and diversity in services on offer; Service users have no control over resources; and Service users cannot make decisions about appropriate hours-benchmarks or about what might be a ‘good outcome’ for them. Disability Employment Australia proposes a number of changes to improve participant control over services: Greater control by participant over pace and nature of job goals. Participants in Lantz and Marston’s study suggested that the determination of what and how much work they should do should be a conversation with their case manager informed by medical advice. This means using third party assessments of job capacity where necessary, and as a reference point. But third party assessments should not be determinative of what a good outcome is. Removal of third party assessments as a matter of course would also reduce cost and red tape, and enable participants to access services faster. Recommendation Participants should be able to work with their service provider to identify pace and level of hours, drawing on expert advice and/or referral to JCA only if this is needed. Third party assessments should not, ultimately, be determinative of what a good outcome is for that participant. Less early focus on ‘barriers’, more on strengths. The UNCRPD emphasises the importance of strengths based assessment (Art 26 above). This principle will underpin the new NDIS assessment. A recent study by the UK Cabinet Office’s Behavioural Insights Team (‘Nudge unit’) found that outcomes were considerably improved (by nearly 20%) where the first contact with employment services focussed on goals and progress rather than form filling and identification of barriers (Boffey (2012)). At present, in DES-DMS, job seekers must pass through several contacts with DHS and JCAs as well as initial processes at the provider’s office, each of which focuses on assessing barriers, before they can talk about how they will move forward. Recommendation Participants should be able to directly register with DES-DMS, with the focus of early engagement on strengths, goals and progress not form filling / assessment of barriers. DEEWR administrative requirements should be modified to enable this shift to occur. Processes associated with compliance. Lantz and Marston’s research into participants’ perceptions of DES services also found that participants often felt that they were being ‘treated as though they were unwilling to work’ (863). The processes associated with JCA assessment, formal appointments and EPPs, both focus attention on processes (as opposed to strengths, aspirations and outcomes) and emphasise the need to continually monitor behaviour. DEA is proposing that this administration and monitoring activity to kept to a minimum. 17 Employment Services – Building on Success Response to Issues Paper Recommendations: In addition to removing the requirement for a JCA assessment, Greater control over services and resources. DEA is cautious about recommending a move to fully individualised budgets in this area. A key challenge is the nature and level of funding. In an extremely resource constrained environment, DES-DMS providers rely on flexibility in deployment of resources in order to be sustainable. DEA is also concerned about the information available to consumers at the point of entering DES-DMS – there is less opportunity for a ‘learning curve’ when one is choosing transition to work services. DEA has proposed a trial of individualised budgets for NDIS Tier 3 clients to explore these issues. While DEA is cautious about all funding being applied through individual budgets, participants can and should be given control over resources associated with long term learning and support. Elsewhere in this submission we argue that investments should be made in long term job retention and career development (XXXX). This could be achieved through establishment of a training and careers account controlled by participants. Recommendation That individual budgets for employment services be trialled in the context of the NDIS (noting that this is most likely to be relevant to DES-ESS participants). That a new participant controlled learning and careers account be considered (see further below). In considering client-focussed design, one of the influential principles is ‘no wrong door’. In the DES context this principle might mean that participants could choose from a range of organisations, provided that they are accredited and are able to provide a service. This could include DES-DMS and DES-ESS providers (wherever located) and could extend to some accredited JSA and other disability specialists. Ongoing Support and Jobs in Jeopardy services should, similarly, be controlled by participants. This change would give participants greater capacity to influence providers through switching – providing, of course, that there is sufficient diversity in the market. Recommendation Jobseekers should be able to move between DSS accredited providers if they feel that they may get a better/more appropriate service elsewhere. This should include moving to any specialist provider in the State, and any provider in their current or adjacent ESAs. Should long term support be required, clients should be able to choose a different provider. Greater support for understanding and decision making about financial consequences of returning to work. The effect of employment on income is highly complex, particularly in an environment where around 60% of participants will move into casual work which is more likely to have irregular hours. It involves understanding of rules around income support, taxation, the health care card and other systems like public housing and child care support and the risk of long term loss of benefits (if on DSP). The more complex the decision the more likely that people will stick with the status quo or will avoid making decisions (Reeson and Dunstall (2009). While providers may attempt to assist job seekers with these decisions, access to better tools and specialist assistance is needed (refer, for example, to the ‘Better off in Work’ calculation in the UK, and the EarnBenefits program delivered by Seedco in the US). Recommendation 18 Employment Services – Building on Success Response to Issues Paper Every client should be entitled to have a clear understanding of their financial position taking into account their personal circumstances and job options. Government should provide providers and jobseekers with tools and/or direct assistance to enable them to calculate the financial consequences of moving into employment at different wage rates and/or hours over the short and long term. Reduced emphasis on coercion, participation reporting. Continued improvement of skills of workforce. [refer Principle 7] Indexation to ensure caseloads can be maintained or reduced. [see principle XX] (change name of program to Transition to work or similar ??) Map the service users’ experience. In May 2012 the Government’s Advisory Panel on Employment Services Administration and Accountability recommended that: R2.2 That DEEWR identify and pursue further opportunities to empower jobseekers as the key participants in, and the immediate beneficiaries of, the Programs…. This work would be informed by independent research on the experiences of jobseekers. At this point we are not aware of independent research commissioned by Government that documents the experience of users in the system. If we are genuine about providing greater say for participants in these services, then mapping their experience of the services and capturing their views on how it might change is critical. Recommendation To inform the design of services from 2015, the Government should commission an independent study of the experience of participants (and employers in the system) – what steps they take, where they are asked to repeat information and at what points they experience program requirements as getting in the way of their progress. In keeping with the UN Convention, user experience of the program should continue to drive program delivery and policy change over the course of the next contract period. This should be independent, transparent, widely shared and include both positive outcomes and unintended consequences of the program: Recommendation: Move to independent monitoring and evaluation, with an emphasis on capturing both positive and negative outcomes, and disseminating information across the sector. Consideration should be given to renaming the program to encourage all eligible job seekers regardless of whether they identify themselves as a person with a disability. Draft Principle 2 Our focus should be on increasing the ability of people to gain, retain and advance in employment over the long term, acknowledging the changing labour market that means that transitions will be inevitable. 19 Employment Services – Building on Success Response to Issues Paper The DES Funding Deed describes the overall objectives of the program as follows: ‘The Objective for the delivery of Disability Employment Services is to improve the nation’s productive capacity by employment participation of people with disability, thereby fostering social inclusion.’ ‘The objective of the Program Services is to help individuals with disability, injury or health condition to secure and maintain sustainable employment. The Program Services will increase the focus on the needs of the most disadvantaged job seekers and will achieve greater social inclusion. The Program Services will boost employment participation and the productive capacity of the workforce, address Skills Shortage areas and better meet the needs of employers.’ From a providers’ point of view, the objectives are operationalised in Key Performance Indicators (KPIs). In particular, KPI 2, which focuses on achievement of prescribed employment outcomes, drives the calculation of star ratings and financial returns for providers. To date, KPI 3 (quality) has had little impact on the way the market operates, in part because it is pass/fail. The Building on Success Issues Paper highlights the continuing structural changes in the Australian labour market and the increased importance of skilled labour (pp9-10). At the same time, work is becoming more insecure. Employees can expect to move jobs more often and many, particularly those most disadvantaged in the labour market, will find themselves in casual positions. DEA proposes that, in this context, the objective of employment services is not just to assist people to get work, but to build their capacity to manage transitions between jobs and to support the development and application of skills. This wider role is encompassed by the concept of employability: Definition of employability: the ability to gain initial employment, maintain employment and make transitions between jobs and roles within the same organisation to meet new job requirements; obtain new employment if required, that is, to be independent in the labour market by being willing and able to manage employment transitions between and within organisations The profile of DES-DMS is of a group that have experienced a significant event that is likely to mean a change in the type and pace of work that they can do. They are, on average, older than clients in DES-ESS or in Streams 3 or 4 of JSA. Some are starting again. There is a considerable risk that these clients, many of whom have skills and have worked, will become trapped casual or part-time work, or jobs where their skills are underutilised. Available evidence suggests that people with disabilities are particularly vulnerable to losing their jobs, and least likely to sustain them (Ref). In other words while the productive potential of the participant group in DES-DMS is likely to be high, this is a group that is likely to struggle to achieve that potential in our labour market. Overall, DES-DMS has achieved a better rate of full time employment and a lower rate of underemployment than JSA (or DES-ESS) (Table 5). In our view this reflects the specialised focus of this service and the importance of job seeker aspirations to services, reinforced through the DSS. However the available data still shows that around 58% of those who gain employment will find themselves in insecure work (Table 5). Research evidence shows that casual workers are less likely to receive training and are more likely to lose their jobs if changes occur [ref]. DES-DMS job seekers 20 Employment Services – Building on Success Response to Issues Paper are likely to be mature aged and this, too, is associated with less access to employer funded training and a greater chance of becoming long term unemployed [ref]. More needs to be done to ensure that DES-DMS participants remain in work, are able to apply existing skills and re-skill over time. Table 5 – Employment Outcomes, June 2012 JSA Stream 3 JSA Stream 4 EA/PPS – DMS EA/PPS – ESS Permanent employee (%) 26.7 34.9 33.1 31.0 Casual, temporary or seasonal employee (%) 64.0 56.8 58.1 63.8 Selfemployed (%) 9.2 8.3 8.8 5.3 Employed, seeking more work (%) 50.9 48.3 37.1 44.2 Full-time employed, seeking more work (%) 5.4 11.3 4.0 3.4 Part-time employed, seeking more work (%) 45.2 37.5 32.8 40.2 Employed & studying (%) 16.0 14.6 10.0 14.4 What is currently working? The specialised DES program and its two distinct programs have promoted the development of providers and workers with capability in helping people to find new ways of applying existing skills and to manage difficult transitions. The application of the DSS has reinforced the importance of building self-reliance, and the importance of participant aspirations and of the quality of employment. Smaller caseloads in DESDMS and the involvement of allied health professionals have facilitated focus on making a successful transition (back) to work. Inclusion of 52 week sustainability indicators in performance measures is positive. The fact that they are not connected with a payment may assist in ensuring that these indicate truly sustainable (quality) jobs. The availability of Flexible Ongoing Support and the Jobs in Jeopardy service have ensured ongoing support provision to retain work. This has been reinforced by the welcome inclusion of Jobs in Jeopardy in the performance framework. But there are limitations in the ongoing support framework – explored further below. What could be improved? Current prescriptive requirements around ‘outcomes’ encourage specific, narrowly defined targets, not long term strategies to ensure labour market attachment. While 13 and 26 week (and even 52 week) outcomes may be indicative of employability in the broad sense used above, they are not the same as it. The fact that many job seekers will find themselves underemployed, in jobs that have no career path, in jobs that don’t use their skills and that they may find themselves back on income support, are all fundamental problems if our goals are to enable to gain sustainable work and to enhance productivity. As Nevile discusses in her study of DES, there is a tendency to ‘reward A while hoping for B’. This arises because of a desire for simple, visible measures and an application of a single framework to what are quite different local circumstances (Nevile & Lohmann, 2011, pp. 63-64). Along with other 21 Employment Services – Building on Success Response to Issues Paper expert commentators in this area, Nevile and Lohmann propose that, rather than emphasising rigid, quantifiable outcomes, complex programs like DES should be based on setting initial goals and then constantly revisiting these in the light of efforts to achieve them (see also Marsh & Spies-Butcher, 2009). The emphasis, in this view, should be on diagnostic information and efforts to improve, rather than on fixed benchmarks. This analysis highlights the reason that picking any set of indicators (e.g. 26 or 52 week outcomes) is bound to generate unintended consequences and prompt government to introduce new prescriptions to address these. It should also be noted that the adoption of this type of approach would facilitate achievement of government objectives in relation to collaboration – see XXX below. Disability Employment Australia recognises that adoption of this approach would require substantial change for both the sector and for DEEWR. Operationalising it would be challenging and would require close engagement with the sector. Elsewhere in this submission we have suggested that, initially, this approach could be applied to specific highly disadvantaged communities (xxx). More immediately, options for consideration might include increasing the period of engagement in the service to three years, with a measure of degree to which all participants have achieved ‘full’ (i.e. not under) employment combined with wages and satisfaction measures. Recommendation: A high value should be placed on the wider concept of employability – the extent to which a person is able, over an extended period, to maintain work and manage transitions between jobs. Long term attachment to the labour market should be included in the Performance Framework, provided that the services to deliver longer term career support are properly funded. Recommendation: There should be an emphasis on continuous learning and improvement embedded in the program structure. This should drive continual focus on the (changing) cohort of people who are missing out on employment or failing to achieve lasting employment. Recommendation: The program should not discourage providers from supporting job seekers to find their own employment. Nor should it discourage provision of appropriate assistance (e.g. ongoing support) where this is needed to improve achievement of quality, sustainable work. Ability to manage employment transitions should be considered a positive outcome from the program. While Government has invested and continues to heavily invest in vocational training, training is not always relevant to the needs of the employer or the job seeker at the time it is delivered. JSA participants often complain about training for its own sake, or training that doesn’t lead to a job (Murphy, Murray, Chalmers, Martin, & Marston, 2011, p. 131). Additionally, we know that casual, part-time and older workers are less likely to receive training from their employer once in work. A more efficient and effective option is needed for people with illness, injury or disability to access career advancement and training support as they enter or re-enter the workforce. Disability Employment Australia proposes that DES-DMS clients be provided with a learning account that 22 Employment Services – Building on Success Response to Issues Paper would entitle them to an amount of career advice and vocational training over a set period (say, 3-5 years). This could be funded through redirecting or notionally assigning existing vocational training funds available to jobseekers and existing workers. This fund should be controlled by the participant not by providers. It is important to note that we are not proposing an Employment Pathway Fund, which is not controlled by participants and has been associated with (apparently) poor targeting, red tape and increased caseloads. Recommendation: Government should establish of learning accounts for DES-DMS clients, enabling them to receive an amount of vocational training and careers support for a period of up to 5 years post referral to DES-DMS. Jobs in Jeopardy [outline limitations of service and recommendations for change – note that this will also be referred to under ‘employers’] Jobs in Jeopardy should be reformed ….and eligibility should be extended to those receiving Sickness Allowance. More can and should be done to encourage those on Sickness Allowance to access vocational rehabilitation (disability management) services through DES-DMS. A payment for people who are employed or self-employed who temporarily cannot work or study because of an injury or illness. The logic that follows is that is more cost-effective to intervene early, as is usually the case with those receiving Sickness Allowance, in order to avoid long-term illness and its associated costs. Most Australian labour market programs have focussed on supply of job seekers, rather than generated demand from employers (Marston & Larsen, 2010, p. 388). While there have been more demand side initiatives in the area of disability employment (through programs like the NDRC, Job Access and wage subsidies) discrimination and lack of willingess or capacity to make ‘reasonable adjustments’ still critically impact on job opportunities for people with disabilities. The Jobs in Jeopardy element of the Disability Employment Services is an important part of the existing program framework, but it has even greater potential as a tool for working with employers and preventing detachment from the labour force. The OECD report Sickness, Disability and Work recommends that Australia can do more to support employers to retain employees with illness or disability, to avoid them ending up welfare (2010). This recommendations is strengthened by DEEWR’s own evidence, that confirms employers are much more likely to retain an employee with mental illness, than recruit a candidate with mental illness (DEEWR, 2008a, p. 27). This suggests that a strategy aimed at employers and employees who have or acquire a disability, injury or illness during their employment is likely to be more effective than intervention after the employment relationship has been ended . However, uptake of the Job in Jeopardy initiative has been relatively poor. In 2008, DEEWR released the report Promoting best practice use of job in 23 Employment Services – Building on Success Response to Issues Paper jeopardy assistance and intermittent support, which found poor JiJ uptake a result of employers having no knowledge (or understanding) of Job in Jeopardy and that its name was too negative(p. 2). Addtionally, providers found the guidelines complex (DEEWR, 2008b) and reported that the funding was insufficient to make JiJ viable. Despite increased funding made available for JiJ in the 2010 DES contract, our members indicate that a key reason that JiJ uptake is low because there was no weighting attached to them in the 2010 performance framework. Considerable effort is required to engage employers and employees in this program. The apparent lack of value placed in it by DEEWR reduced its priority for many organisations (compared, for example, to the engagement of Eligible School Leavers). Nor has the program been promoted through other channels, like Centrelink, employer bodies or services like JobAccess. Many who could benefit would struggle to find the service. The recent parliamentary inquiry report into mental health and workforce participation was critical of the information and support provided to employers and potential participants concerning the Job in Jeopardy program. It recommended that the program be actively promoted and that eligibility criteria be reviewed to encourage greater uptake and awareness of the program (Australian Government, 2012). Recommendation 8 The Committee recommends that the Commonwealth Government support and, where necessary, amend the JobAccess, Employment Assistance Fund and Jobs in Jeopardy initiatives to ensure that: The scope of eligibility requirements does not prohibit employees and employers who require support; and Ways of accessing and information about the JobAccess, Employment Assistance Fund and Jobs in Jeopardy programs and their benefits, including for employment of people with a mental illness, be clarified and readily available to employees and employers. (Australian Government, 2012, p. xix) If disability increases with age, and Australia is experiencing an ageing population and looming skills and labour shortage, and Government is making efforts for people to keep working for longer, then DEEWR can and should reform JiJ to better work with employers and build their disability confidence to retain their current employees through JiJ. We know that employers consider disability employment risky due to a lack of confidence and information (Human Rights and Equal Opportunity Commission, 2005; Waterhouse, Kimberley, Jonas, & Glover, 2010). As this confidence builds through the provision of expert disability employment assistance, trust and rapport with the employer result as business needs are met, opening the door for other candidates with disability (DEEWR, 2011; Sardo & Begley, 2011, p. 9). Given the potential of the Jobs in Jeopardy to better meet the recruitment needs of employers, and to reduce welfare dependency through early intervention, we believe enhancements are required to increase public visiblity of the service. 24 Employment Services – Building on Success Response to Issues Paper Sickness Allowance applicants should be given greater access to, and visibilty of, Job in Jeopardy. By definition this is a group of people who are not able to return to work due to sickness, illness or injury. The current rules around providing service to a person with a residential address in an ESA are limiting and makes it hard for providers to market a service they know they can deliver. It is the nature of JiJ that it is an employer facing service. DEA recommends JiJ provision is permitted where the participant has a residential address in the LMR the provider is contracted in. This allow providers and employers certainty over who will providing what support. Alternatively, DEEWR might consider allowing registrations for employees whose employer is located in a contracted ESA. Job in Jeopardy should be renamed more positively and to reflect its intent to better meet the recuitment needs of employers. For example, Workplace Assistance Program, Employment Assistance Program, ‘Staying at Work’ etc. Government can and should actively promote JiJ through the NDRC, DHS, Job Access, Australian Job Search website, employer networks, HR professional networks, rehabilitation services and trade unions. Recommendation: The Jobs in Jeopardy program should be enhanced so that it can better meet the needs of employers wanting support to retain or reintegrate employees with an illness, injury or disability. This would include: renaming the program to be more attractive for employers (e.g. Workplace Assistance Program, Employment Assistance Program, etc.) active promotion of the program to employers through NDRC, Job Access, employer networks, HR professional networks; promotion to employees who might benefit through DHS, rehabilitation services and trade unions; relaxation or removal of the limitation on provision of services to clients outside the ESA; enabling services to work with clients to secure another job – regardless of with which employer Principle 3 The program should support the development of an effective participant / case worker relationship The quality of the working relationship between each participant and their case manager is critical to successful outcomes. Case workers need good labour market knowledge and understanding of employers, they need to understand the range of impacts that illness and/or disability can have on work and the strategies that can overcome these, they need excellent skills in engaging people who may be reluctant, disheartened or hostile. They also need time to listen to people’s needs, to affirm their strengths and build their confidence. Evidence from JSA suggests that these factors, that underpin quality working relationships, are increasingly rare. Considine et al (2013) paint a picture of declining qualifications, declining age and increasing caseloads. (oculd be strengthened, especially with some data on DES and the startlingly awful stats on JSA) also check Goerge’s work 25 Employment Services – Building on Success Response to Issues Paper Compliance data suggest a heavy reliance on bureaucratic mechanisms to engage clients – for example there were over 400,000 income support suspensions in the year to 30 June 2012 (DEEWR, Jobseeker compliance data, June Quarter 2012). This suggests a lack of skill and/or time to find more effective means of engaging jobseekers, even though more positive engagement is more likely to yield better results for the job seeker. There is some evidence that these problems are less pronounced in DES-DMS. For example the attendance rates of activity tested job seekers is considerably higher for DES appointments, and DES staff are much less likely to report that non-attendance was for an invalid reason. This suggests more effective engagement that would contribute to greater efficiency. Attendance at appointments with employment services DES JSA 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Activity tested job seekers 1/7/11 - 30/06/12 Program Appointments attended Appointments not attended Valid reason Appointments not attended Invalid reason Appointments not attended Discretion Disability Employment Australia considers that it is vital to delivery of effective services to people who have complex needs, like those in DES-DMS, that there be increased focus on and investment in skills. We note that this need is reinforced by the UN Convention which states that: (Art 26, clause 2). States Parties shall promote the development of initial and continuing training for professionals and staff working in habilitation and rehabilitation services. Recommendation: Minimum qualifications standards should apply to staff working with clients with an emphasis on vocational rehabilitation qualifications and/or case management. The requirements should be flexible enough to enable providers to employ people from backgrounds reflecting the client base (eg Indigenous staff, people with experience of mental illness) with supervision by qualified staff. Recommendation: That providers be required to implement an ongoing program of professional development with mandatory requirements for those working in the sector. Government needs to recognise that the service fee structure represents a key constraint on the ability to pay improved wages to attract and retain skilled staff. Demand for skilled workers in the disability sector will be substantially increased as a result of the implementation of the NDIS and possibly the National Injury Insurance Scheme. The Productivity Commission has suggested that 26 Employment Services – Building on Success Response to Issues Paper there is potential for severe staff shortages in this area which will need to be addressed through, amongst other things, higher wages (693). In the lead up to, and during the next contract there is likely to be upward pressure on wages for skilled staff in this sector. Recommendation. That the fee structures be adjusted to reflect the true cost of delivery by a more experienced and skilled workforce. While skills are essential, they are not enough: A highly skilled worker who is a committed and strategic advocate for service users can learn to ‘work the system’, but their effectiveness as a worker depends on the institutional design into which their work fits. If such institutional design does not invite and support them in working effectively and democratically with a service user. They cannot make up for this deficit by their own dedication and skills. (Yeatman (2009), 210) The APESSA Report found that: The very high rate of staff turnover in providers is indicative of systemic problems. The explanations given for the annual average rate of 30% (NESA submission) are the low rates of pay, the high level of administration which is incompatible with the primary interest of many staff to help clients, the mix of pastoral and administrative requirements, the low levels of training, and the emotional toll related to this kind of work (APESSA Final Report, p10). While the situation is better in DES, Nevile and Lohmann’s 2011 research highlighted that the problems of administrative load, lack of capacity to spend enough time with clients, pressure to achieve inflexible KPIs are all placing pressure on staff and making it harder for them to be retained. Disability Employment Australia considers that there is scope to improve program design to ensure better support and greater investment in this critical relationship. Many of the measures that would improve the relationship have been identified under Principle 1 above. A program that is focussed on participants’ strengths and aspirations, that gives them greater control over services, provides a much stronger basis for a collaborative working relationship at the frontline. We also propose two measures that will reduce red tape and increase time spent focussing on strengths and progress: Recommendation: The initial period of engagement with a client should be focussed on building a strong case management relationship rather than administration and compliance. Provider requirements should be minimal eg: after the initial commencement into the service is recorded, for the first three to six months of assistance there should be no further requirement to record appointments. An initial EPP should record only the provider’s agreement to offer the service and the participants agreement to participate. Recommendation: Rather than try to use the EPP as a case management plan, the EPP can be simplified so that it reflects the bare minimum requirements to meet the activity test. A more detailed EPP might be developed in cases where activity tested job seekers were persistently non-compliant. EPPs would be updated only when they needed to be changed. Shorter, simpler EPPs would reduce administration/IT time and make obligations easier for 27 Employment Services – Building on Success Response to Issues Paper participants to understand. EPPs would not be required for volunteers. In accordance with good case management practice and the DSS, case workers would be expected to keep records of their work with clients, including individualised plans, agreed actions, milestones and goals. 28 Employment Services – Building on Success Response to Issues Paper Section 3: Stronger Partnerships with other Services If participants have more say in the delivery of services (Principle 1) and if the case managerparticipant relationship is strengthened (Principle 3), then better linkages with other services should follow. However there are structural impediments to collaboration which are explored here. Principle 4 Program design, performance measurement and evaluation mechanisms should provide the settings for improved collaboration. Many stakeholders that interact with the ‘mainstream’ employment services system express concern over the lack of collaboration – either between providers or between providers and external organisations. It appears that DES providers have tended to operate more collaboratively than their counterparts in JSA. An academic study of DES providers which explored collaboration in the network found that, in addition to high levels of collaboration through industry bodies, conferences and local forums: Over 70% of providers were able to name a specific example of collaboration, ranging from the formation of joint companies or establishing cross-over directorships, to more ad hoc and limited collaborations (Marsh and Spies-Butcher (2009) 247). They noted that these were “a powerful source of best practice information” and that “most collaboration, involving 40% of all respondents, came through engagements with other open employment providers” (248). However this same study found that providers were finding it harder to collaborate. Competition was seen as a major obstacle to collaboration. Working with other organisations might be good for clients, but it also boosts potential competitors and decreases the chance that your own organisation will stand out from the crowd – either in star ratings or in a tender. The willingness of governments to replace long-standing providers in an area with organisations from other locations can also undermine collaboration. Collaboration thrives in the context of ‘thick’ networks – where relationships operate on a number of levels (senior managers, front line workers, range of forums) and are built over time. Organisations seeking partnerships with employment service providers complain about frequent turnover of personnel. Longer term partnerships may be thwarted by changes in provider. Finally, collaboration is undervalued where financial and organisational survival depends on 13 and 26 week outcomes. Collaboration can be time consuming and risky, and it typically focuses on long term outcomes rather than short term outputs. Investment in collaboration initiatives can be hard to justify in a resource constrained environment with narrowly defined KPIs. The Government’s recognition of the importance of collaboration reflects its understanding that the challenges of getting a greater number of very long term or disadvantaged people into work are complex ones. It is in the nature of complex problems that they cannot be solved through application of simple solutions. 29 Employment Services – Building on Success Response to Issues Paper The Public Service Commission has noted that: There is an ever present danger in handling wicked issues that they are handled too narrowly. The shortcomings of traditional approaches to policy making are also due to the social complexity of wicked problems—the fact that a true understanding of the problem generally requires the perspective of multiple organisations and stakeholders and that any package of measures identified as a possible solution usually requires the involvement, commitment and coordination of multiple organisations and stakeholders to be delivered effectively (Public Service Commission (2007)). DEA notes that DEEWR has developed a number of initiatives that reflect the need to engage and coordinate efforts of multiple stakeholders in generating longer term strategies: Employment of Local Employment Co-ordinators in 20 priority areas; Implementation of Family Centred Employment Projects; and Development of new, flexible approach to KPIs within the Remote Jobs and Communities Program. While Disability Employment Australia notes the improvement focus on employment in DES-ESS following the shift from grant based funding to the current arrangements, this has come at the cost of collaboration that could foster longer term impact. The Public Service Commission has noted that while there are benefits of competition (e.g. the ability of consumers to choose between providers) stakeholders typically assume a win-lose outcome (Public Service Commission, (2007)). The study cited above clearly demonstrates that this is increasingly true of DES providers. The alternative, a collaborative – ‘win-win’ – approach, requires greater flexibility in terms of program design, willingness to make mistakes, and an emphasis on local ‘institution building’ so that local stakeholders are engaged, share accountability and investment. Kania and Kramer have described the features of successful approaches applying these principles, coining the phrase ‘collective impact’ (Kania and Kramer (2011)). DEA considers that a ‘collective impact’ approach, based on harnessing the skills, networks and resources of diverse local organisations, offers significant advantages over market solutions in highly 30 Employment Services – Building on Success Response to Issues Paper disadvantaged communities. However we also recognise that this would represent substantial change and would require very different approaches from providers and Government. On this basis we suggest that ‘collective impact’ initiatives be implemented initially in a few highly disadvantaged communities. This would include, in those locations, capacity to adjust local KPIs, recognition of ‘shared outcomes’ and a strong focus on shared learning and accountability. Recommendation: In purchasing services, DEEWR should place weight on long standing community connections and engagement, including evidence of past collaboration. Recommendation: There should be greater flexibility to adjust local objectives and KPIs to reflect local community needs. Through this process it should be possible to identify shared objectives to which many service providers, employers and community organisations would contribute. Outcomes may be attributed to multiple or all organisations that contribute to these shared goals. Funds should be available for collaborative projects. Recommendation: DEEWR should pilot ‘collective impact’ initiatives in key disadvantaged communities, with an emphasis on collection and sharing of evidence at the local level, development of shared objectives, adjustment of local arrangements to reflect community need. Mitigating risk selection Pathway Proposal We propose that program settings are changed to allow providers to claim both a pathway and full 13-week outcome in the same period of service. This can be done in a cost-neutral manner by making the full outcome payment a pro-rata payment if the pathway outcome had already been claimed. The functionality already exists in the Employment Services System through the ‘zero’ dollar claim. In this way, a provider can elect to spread the funding they would receive for a full 13 week outcome over a 26 week period. It is predicted that more employment and education opportunities will be offered to participants, as opposed to fortnightly appointments, or job clubs. This is because providers could achieve additional performance and financial rewards above and beyond quarterly service fees. We submit this will result in greater numbers of participants being engaged in capacity building activities, as demonstrated in the following table. Level 1 ESS Level 1 DMS Level 2 ESS 2nd Service Fee $890 or $1595 or $1900 or 13 Week Pathway $945 + 5% stars $945 + 5% stars $1450 + 5% stars 13 Week Full (Pro-rata) $1915 + 20% stars $1915 + 25% stars $2950 + 20% stars 13 Week Full $2860 $2860 $4400 Disability employment practice (or the open employment ‘place then train’ model) tells us that a principal focus on starting competitive employment sooner rather than later is generally more effective than traditional employment approaches. For example, traditional approaches include ‘train then place’, vocational counseling, sheltered employment or job clubs. 31 Employment Services – Building on Success Response to Issues Paper The evidenced-based model is clear: assessment is best conducted as a continuous process of experience(s) in competitive employment. Evidence also shows that people who secure jobs that reflect their own choices remain in their jobs twice as long as when jobs are not aligned with their preferences (Cocks & Boaden, 2009). Therefore, it follows that: Promoting decision-making and choice will lead to more sustainable employment outcomes; and Employment sustainability is predicated upon a quality job match, informed through reflection on previous employment experiences. We submit that allowing providers to claim both a pathway and full 13-week outcome in the same period of service will diversify service offerings that better meet evidence based principles of disability employment. The principle of jobs as transitions, where all jobs are seen as worthwhile, positive experiences – and do not represent failures to achieve optimal outcomes. But do lead, through continued disability employment assistance, to competitively obtained, permanent employment. It is anticipated that acceptance of our proposal will result in a higher retention rate to optimal outcomes, because the best way of determining a persons’ capacity to work is for them to choose, get and keep employment and to reflect on those experiences. Changing program settings in this way provides greater scope for a participant to exercise choice and control over their vocational pathway by leaving the provider and participant with the opportunity to achieve an optimal outcome in the same period of service. It allows participants who might believe that they cannot work the benchmark hours suggested by medical practitioners or external assessors, to gradually build up their hours. Providers will have a greater incentive to engage all job seekers in pathway type activities with a view to claiming a pathway or full time outcomes. Low rates of pathway outcomes at present suggest a tendency towards an ‘all or nothing’ approach in the context of a highly competitive marketplace. The current framework limits choice by valuing a single job over employment, as providers perceive a disincentive to offer participants any opportunity that is not a full outcome. . The imperative to achieve full outcomes over pathway outcomes could also encourage risk selection: a process by which efforts are focused on those most likely to achieve a full outcomes, while participants that might need to take smaller steps will receive less. Risk selection is likely to be mitigated by rewarding interim milestones which increase capacity of the part of participants to achieve full outcomes (Nevile, 2012, pp. 12-13). 32 Employment Services – Building on Success Response to Issues Paper Section 5 – Working in partnership with employers Principle 5 Improved engagement with employers The DES-DMS service is rightly designed around services for participants. This is reflected in the fee structure, which is participant based, and the performance and quality frameworks. The principal means by which DES-DMS providers engage with employers is around the needs of a specific individual and a specific job. This engagement might be quite intensive and include job carving, education for the employer and co-workers and assistance to identify and secure workplace adjustments. Quite often, a good experience in recruiting one person through a DES provider will open the door for more placements over time. Some employers go on to become champions in their local communities for employment of people with disabilities. The skills and expertise of the disability sector has informed good practice in ‘mainstream’ services. This approach to securing employment is both proven and effective. It reflects evidence of what works. Research into what is most likely to influence decisions to hire people with disabilities shows that personal contact is much more likely to be influential than either industry based campaigns or public campaigns [DEA Conference paper check ref and content]. It is particularly effective in working with small-medium enterprise – which accounts for 70% of all employment, and the sectors with the largest growth. Chart 5 Employment by business size (2009/10) Large (200+) 30% Small (0-19) 47% MediumMedium (20-199) 23% (ABS Cat 8155.0) The DES-DMS service is strengthened by its capacity to offer employers ongoing assistance through Flexible Ongoing Support and Jobs in Jeopardy, and through access to a range of employer subsidies, advice and assistance services available through the Employer Assistance Fund and JobAccess. 33 Employment Services – Building on Success Response to Issues Paper Recent reforms to the NDRC will better equip this body to improve engagement with larger employers. There is room to strengthen the ability of DES-DMS services to support employers and, through this, to support current and future program participants. Research in the vocational rehabilitation sector highlights the fact that the most important factor influencing whether and how fast a person will return to work is the attitude of the employer to that worker. Many of the people who access DES-DMS were in some form of work when they acquired their illness or disability. Service engagement with their employer at the earliest possible point might make it possible for them to return to that job or employer. And, in fact, the Jobs in Jeopardy service has the potential to meet this need. This form of early intervention could generate major improvements in prospects for individuals and substantial budget savings through prevention of long term unemployment. However awareness of the service is poor. Nor is there a focus in Centrelink or in other relevant agencies on referral for preventative action. Recommendation: The Jobs in Jeopardy program should be enhanced so that it can better meet the needs of employers wanting support to retain or reintegrate employees with an illness, injury or disability. This would include: active promotion of the program to employers through NDRC, Job Access, employer networks, HR professional networks; promotion to employees who might benefit through DHS, rehabilitation services and trade unions; relaxation or removal of the limitation on provision of services to clients outside the ESA; enabling services to work with clients to secure another job – regardless of with which employer. While there are strengths in the employer by employer approach, it is limited in its ability to address emerging and projected skills and labour gaps. It is inherently short term (ie addresses an immediate vacancy) and individualised. DEA believes that there is also an important role for demand led strategies that seek to develop long term pathways to skilled work for a larger cohort of job seekers. We note, in particular, the challenges of enabling more people with disabilities to access apprenticeships or to access employment with larger employers, like the Public Service. The NDRC has potential to make a substantial contribution to development of demand led initiatives but its scale, reach and funding structure would limit its current capacity. Enabling it to act as a ‘broker’ for wage subsidies and training funds may enable it to pursue this role. Recommendation: Pilot demand led initiative with NDRC as the lead to determine program design that might support this approach. If demand led approaches are to be encouraged then the structural impediments to their development need to be addressed. To be worthwhile, demand led projects generally need to have reasonable scale. They require considerable investment. But any one provider will have a limited number of people on their caseload interested and/or suitable for work in a particular job/industry. The current competitive model means that providers are loathe to give a leg up to competitors. Nor 34 Employment Services – Building on Success Response to Issues Paper can they justify the considerable upfront investment required to develop a long term partnership with an employer / industry. Localised, collaborative solutions will need to be developed to address employer needs. This review of specific programs and the literature confirms that there can never be one, single, optimal labour market program…Nevertheless this review indicates there is broad agreemet on several key principles that should be incorporated into the design of programs..[these include the] need to engage the local community (resources, employers, local organisations etc in programs, particularly to address local labour market conditions. Local employers should be involved in the design of programs. (O’Neil and Neal (2008) 35) Recommendation: Provide a pool of short term, project funds available to providers in collaborative arrangements (with each other as well as employers) to address industry needs provided that opportunities are promoted across the relevant labour market/s. Allow outcomes to be shared. Intermediaries or employers wishing to develop and invest in strategies to engage more people with disabilities are also frustrated by the lack of any one entity that can aggregate the caseload – a mechanism by which the number of people interested in working in a sector might be identified, or through which opportunities can be communicated. DEEWR has pioneered various attempts to use information technologies to improve connections between people wanting opportunities and those who have them. DEA is of the view that information technology solutions, designed in consultation with participants, providers and employers, have significant potential to better connect people with opportunities. Recommendation: Explore and pilot IT strategies that provide employers and intermediaries with greater ‘visibility’ of candidates with an interest in their positions. While we know that people with disabilities and mature aged workers are more likely to ‘stick’ in jobs, there is still a perception that they represent a high risk to employers. Wage subsidies are important in encouraging employers to accept this ‘risk’. Strong take up of Wage Connect by DESDMS demonstrates the potential of this program to stimulate demand for participants. Recommendation: Wage subsidies, particularly Wage Connect, should be continued and uncapped Disability Employment Australia strongly supports the emphasis on employment in the open labour market and efforts to ensure all employers provide equal access to work in their organisations. However we recognise that opportunities for people with disabilities are not currently available on an equitable basis. Direct discrimination, failure to consider workplace adjustments, lack of accessible transport, a legacy of poor education / unemployment all contribute to a generally poor rate of employment for people with disabilities. Social enterprises have been developed that aim to address that gap, either through permanent employment or through transitional jobs that provide people with skills and experience necessary to work elsewhere. Social enterprise can also be important in generating jobs in job poor communities, or in creating different types of jobs that are more accessible for some people. If we are to address 35 Employment Services – Building on Success Response to Issues Paper the employment gap between people with disabilities and those without, then we need to stimulate initiatives that create more jobs – provided that these are ‘real jobs’ provided on just terms. Recommendation: Encouraging take up of wage subsidies to support job creation and demand led projects, including in social enterprise, by enabling them to be accessed through social enterprise intermediaries (like SOFA, Social Traders) or identified demandled project leads. 36 Employment Services – Building on Success Response to Issues Paper Section 6 – New ideas for a better system Principle 6 The purchasing and contracting systems should foster a diverse sector (size, specialisations, skills, focus) The case for diversity As the Issues Paper points out, the process of structural change in the economy is ongoing. The solutions that might work today may not work tomorrow. The challenge of raising the employment rate of people with disabilities is a complex one. Continual adaptation and innovation are needed to ensure that outcomes for people with disabilities continue to improve. Different labour markets have different challenges. Flexible, localised responses are required to address complex challenges through strong local stakeholder engagement (PC (2007), SIB (2010)). A homogenous provider base is unlikely to deliver diversity in strategies or ongoing program innovation. Nor is it likely that increasing concentration of contracts in fewer, larger, providers will facilitate localised responses. Program design and purchasing has enormous implications for the sector. The implementation of Job Network was meant to harness the innovation and flexibility of the private and NGO sector. However it has been characterised by reduction in provider numbers and convergence of practice (Considine, Lewis, O’Sullivan (2012)). In the establishment of JSA the Government encouraged providers to sub contract organisations, particularly those with a specialist focus on particular cohorts amongst the hardest to place (e.g. disadvantaged youth, homeless). However, to the extent that these arrangements exist at all (and they appear to be quite limited), many smaller providers complain that the terms of these arrangements are unfavourable. In the United Kingdom, prime providers in the Work Programme were, similarly, expected to draw on a range of specialist organisations to ensure strong local connections, innovation and a wide range of expertise. However it appears that the involvement of local or specialist organisations has been much less than expected, with many ‘primes’ opting to deliver in-house (Rees, Taylor and Damm (2013)). Far from devolving decision making, and promoting engagement of more stakeholders, the use of ‘primes’ seems to further disempower those organisations that are closest to the community. Historically, the DEN sector was characterised by relatively small local organisations that had close links with local community organisations and FAHCSIA contract managers. More recently a number of larger organisations have developed through mergers and entry of new players. While there are specialists in particular areas of disability, the experience of Job Network is that the very fact of being ‘unusual’ (i.e. being a specialist) can bring mixed fortunes in a highly competitive, risky and volume driven market. The Issues Paper has implied that greater alignment of the DES and JSA contracts might reduce red tape, noting that some providers hold both contracts. In this submission we have outlined some of 37 Employment Services – Building on Success Response to Issues Paper the key characteristics of DES that distinguish it from JSA. In our view, a process which meant that Disability Employment Services became more like JSA is likely to diminish the programs capacity to respond to the individual needs of participants and to address complexity. It would almost certainly reduce the diversity of the DES provider base. The likely decrease in red tape seems slight – and likely to be of most value to the largest, least specialized providers. But the potential negative impacts for job seekers in greater concentration of the market are substantial. Features of the current system that support diversity in DES deliver include: The ability to bid for small or large contracts; Reasonable level of up front payments, so that capital requirements are not a barrier to entry; Capacity to bid as a specialist; Capacity to directly register clients so that providers can develop new approaches and target specific cohorts for engagement; Retention of two specialist DES programs; and Weight in the purchasing process given to local connections, including, in the most recent tenders, a process of verifying claims in relation to connections. What could be improved? Government’s reliance on periodic purchasing rounds in response to highly prescriptive specifications limits the development of more localised responses to challenges to issues as they arise. There is little scope for the shape of services to be adapted either in the light of experience or of changing circumstances. The program is based on ‘one size fits all labour markets’ – there is no ability for new models (e.g. social enterprise, demand led) to be generated either through non-compliant tenders or through more ‘organic’ development at the local level. DEEWR makes limited investment in sector development, relying on the market to identify specialisations. This means that some areas that might benefit from a specialist service and some specialisations (eg Indigenous services) remain unexplored. DEEWR does not explicitly consider additional social value created through its purchasing process, including the extent to which any surpluses will be reinvested in local clients or the local community. Recommendation: DES-DMS should be retained as a separate program from JSA. Ideally, the differentiation between DMS services – where the employment impact of the illness, injury or disability is expected to require transitional support only – and ESS, should be maintained so as to support differentiation of service offerings and strategies. Recommendation: The purchasing process should encourage a range of providers, including small providers and providers with specialist expertise. Consideration should be given to allowing ‘non-compliant’ tenders, to encourage organisations to put forward alternative models. Recommendation: Rather than rely on the market to offer diversity in an area, DEEWR should work with local stakeholders in key areas to identify needs. This might mean, for 38 Employment Services – Building on Success Response to Issues Paper example, that DEEWR encourages development of particular specialisations in an area of high need (e.g. mental health, AOD, Indigenous). Recommendation: DEEWR should consider encouraging new entrants by testing a regime that allows licensed organisations (those that comply with Disability Service Standards and have appropriate experience) to offer services to the Very Long Term Unemployed on a payment by results basis (with shared outcomes). Recommendation: DEEWR should consider adoption of wider social value commissioning, particularly in highly disadvantaged communities. Principle 7 Any new system should improve overall employment impact Ultimately the measure of success of any system should be the extent to which it improves overall employment rates and equitable distribution of opportunities. In the area of disability employment we would expect to see a decline in the gap between people with and without disabilities in (1) participation rate (2) unemployment (3) underemployment/insecure work (4) wages and/or poverty. At this point we do not have evidence of the net employment impact of the disability employment programs or of the wider employment services system. However some commentators have suggested that the early gains from the introduction of active participation have now trailed off, and new approaches will be needed if we are to make further inroads. Certainly the evidence of increasing numbers of people in the VLTU category; and the lack of any evidence that the gaps in participation or unemployment are closing for people with disabilities; suggest that we need to try something new. DEA considers that the range of recommendations in this paper should contribute to improved net impact, particularly over the longer term. In addition, DEA suggests that better targeting of assistance and increased investment in job generating activity can improve net outcomes. Better targeting of DES-DMS At present, JCA Guidelines state that: Job seekers with barriers that are not sufficiently stabilised or require long term assistance, or job seekers who have multiple non-vocational barriers that prevent them from obtaining and sustaining employment or undertaking further skills development will not benefit from Disability Employment Services and should not be referred to this service. An example of such a barrier is untreated substance abuse or from medical conditions. One of the outcomes of this is that jobseekers with disabilities or illness/injuries that could benefit from the rehabilitation focus and skill set of DES-DMS are not referred to this service. For example, despite the prevalence of disability and chronic illness amongst Indigenous people, they are poorly represented in the DES-DMS service (Chart 6). People who have acquired a disability, or who have had a period of illness but who face other challenges are referred to Stream 4 so that those other ‘non vocational barriers’ can be addressed – but they are not referred back to DES-DMS even though they could benefit from ongoing support. 39 Employment Services – Building on Success Response to Issues Paper Chart 6 Participation of equity groups all programs 45.0% 40.0% 35.0% 30.0% DES-DMS 25.0% DES-ESS 20.0% STREAM3 15.0% STREAM4 10.0% 5.0% 0.0% Indigenous CALD Sole Parents PWD DEA is of the view that the smaller contracts and less volume driven approach of DES-DMS would provide a good foundation for effective engagement and placement of highly disadvantaged job seekers and that the program should be modified to enable them to access the service. DEEWR should encourage the development of specialist provision in areas of need, for example services for Indigenous people or people with Alcohol or other Drug dependencies. Non compliant tenders would enhance innovative approaches in these areas. Participant control would be encouraged by enabling participants to choose between JSA or DESDMS provision, provided that they have a disability illness or injury and that the Disability Service Standards were applied. Recommendation: That eligibility for DES-DMS be extended to those who meet current requirements and have complex non vocational barriers. That substantial weight be given to client choice in determining whether to opt for DES-DMS or JSA. Early intervention based on voluntary engagement by highly vulnerable people DES-DMS has been designed as a program that facilitates entry or re-entry to work after a significant event (illness, injury, acquired disability). Sometimes (but not always) early engagement in work or pre-work activity can facilitate other transitions. For example there is considerable evidence of the importance of work in a positive setting for people recovering from mental illness. National Disability Strategy includes a specific reference to ensure that people with disabilities leaving custody have access to services that will decrease recidivism including education, preemployment and employment services. The very high proportion of offenders in this category suggests that a much greater emphasis should be placed on promoting access pre-release to DES services. 40 Employment Services – Building on Success Response to Issues Paper We have already recommended the early promotion of Jobs in Jeopardy services to employers. The promotion of early access to people who are or may be eligible for DES-DMS is also strongly encouraged. The extension of DES-DMS to people with multiple barriers, the reduced reliance on third party assessments and/or reporting requirements in the early stages of assistance, and the application of the ‘no wrong door’ principle where providers are appropriately accredited would all contribute to facilitating early access. Recommendation: That the DES-DMS program be adjusted to remove existing obstacles to early engagement and intervention with people who are likely to be eligible for the service. This would include engaging with people in rehabilitation programs, the justice system, and the health care system. Providers should be entitled to engage a participant with JCA assessment (if required) able to be deferred. JCA assessment should not result in a change of provider unless the client chooses to exercise the option to change. Place based focus Under Principle 4 we explored the challenge of implementing a collaborative approach to complex challenges. Unemployment is concentrated in key communities and is associated with a range of other indicators of disadvantage and, often, a range of specific challenges associated with a changing labour market (eg decline in manufacturing, narrow industrial base). If we want to improve overall employment impact, it is in these areas that we should focus – as recognised by DEEWR in its identification of employment priority areas. The need for localised responses is confirmed in the literature: DEA proposes that it is in these communities that a collective impact should be developed and tested, with an overall goal of improving overall employment in that area and improving the equitable distribution of employment. The principles outlined by Kania and Kramer (developing a backbone organisation, developing shared objectives and indicators and using data to inform continuous improvement efforts) could be applied in these places to try to achieve a ‘step change’. Recommendation: DEEWR should work with providers to establish a shared agenda for increasing overall (net) employment in key employment areas. In these areas ‘outcomes’ may be attributed to more than one contributor. Flexible funds should be made available to support projects that reflect agreed collaborative objectives and strategies. 41 Employment Services – Building on Success Response to Issues Paper Principle 8 It should offer value for money Australia enjoys low unemployment rates compared to the OECD, while spending significantly less on employment services (OECD (2012). In particular, Australia is well behind most comparable countries in its investments in job generating initiatives. Any additional investment needs to be carefully considered to ensure that it is well targeted. This is particularly the case in the light of recent allegations of ‘gaming’ and the potential for public concern should companies be perceived as making profits while failing to deliver improved performance. The UK Cabinet Office (Office of the Third Sector) provides the following definition of value for money in commissioning: Effective services can maximise value for money for the public purse by delivering activities in a way that: 1. makes the best use of financial and non-financial resources, including the time and skills of the service users themselves; 2. generates positive and lasting service-level outcomes that both create value and prevent future costs; 3. contributes to wider benefits across social, environmental and economic objectives. (NEF (2009)) Figures are available in relation to ‘cost per outcome’ in Job Services Australia but they have not been made available for Disability Employment Services – DMS. We know that JSA is relatively cheap. But the assessment of value for money in employment services requires a wider analysis including: The extent to which financial resources are actually invested in activities that contribute to long term outcomes, as opposed to other activities (e.g. administration, rationing); To what extent the programs are successful in engaging the non-financial resources of range of community actors including community organisations, employers and job seekers; To what extent the programs are successful in achieving net improvements in employment over the longer term; and The extent to which the program contributes to other benefits (e.g. alleviation of poverty or homelessness, improved productivity through application of skills) or losses (e.g. ill health associated with poor quality work, income insecurity, loss of self-esteem). At this stage the available evidence does not shed much light on these wider questions of value. In particular, the lack of long term evaluation of service level outcomes or of wider community benefits is disappointing. However there are a number of indications that value for money could be improved: 42 Employment Services – Building on Success Response to Issues Paper Considerable financial/human resource is applied to administration that does not appear to contribute to employment outcomes or to be necessary to management of an effective system. Examples are provided in DEA’s submission to the APESSA review and the Efficiency Assessment of DES prepared by Nous. It appears that a relatively large amount of the time of frontline workers and of job seekers is spent in processes that are not aimed at getting work (registration, referral to JCA, rereferral, EPF revisions, reporting on job search activity, monitoring of activities). This could be redirected to more productive activities. Attention is focussed on outputs (13, 26 week job outcomes) not service level outcomes – this means concern for attribution of placements over, for example, collaboration with other providers/complementary services. It also means potential waste of productive capacity, as workers are placed in jobs that don’t use their skills. Over 50% of participants in DES-DMS remain out of work after participation. It is not clear that any positive outcomes have been achieved for this group at all – and anecdotal evidence that they may be further marginalised by their experience. Over time this group become less ‘employable’ and more likely to suffer the negative personal, health and family consequences of long term unemployment. This, in turn, generates social cost. Disability Employment Australia is of the view that better value for money could be achieved by: Redirecting resources away from rationing and job seeker compliance processes, and towards forming stronger positive relationships from the beginning of the services; Increasing skills level and resourcing for case management services (which could include minimum case load requirements as well as skill levels); Maximising client choice, including reduction in compulsory activity and emphasis on encouraging voluntary engagement / self-referral to services; Including, in the performance framework, longer term evaluations of service level outcomes and acknowledging attribution of outcomes to multiple players; Developing an approach to purchasing / market allocation based on wider assessment of social value; Ensuring wide access to information about strengths and weaknesses in the program with DEEWR taking a lead role in honest assessment of what is working and facilitating processes to improve overall system design; Considering demand side initiatives to prevent long term scarring and wider social impacts of unemployment for people who do not achieve an outcome from services. Each of these areas has been addressed elsewhere in this submission. However it is important to restate some key points. The pathway to work for people who have an illness, injury or disability is often very complex. It is a period of great change and of vulnerability. The changes that they will need to make are not achieved through coercion, they are achieved through engagement. If we want better outcomes then we need to ensure that participants are engaged, that we work with them on strengths and progress, and that we eliminate processes that get in the way. We have identified some proposals for eliminating red tape that is getting in the way of better outcomes, but unless we engage service users in identification of red tape and of solutions, then we will not improve the system. 43 Employment Services – Building on Success Response to Issues Paper Australia has had active labour market programs in place for many years. We need new approaches if we are going to achieve greater impact. The JSA system has not generated the level of diversity and innovation we would have hoped for. In fact it looks increasingly ‘one size fits all’. Greater concentration of the market through merger of contracts will not deliver local, ‘bottom up’ solutions. This is more likely to be achieved through devolution of resources and decision making. The savings that might be generated for larger providers and in DEEWR’s contract management/purchasing function do not warrant greater homogenization of the market. Supply side initiatives will not suffice. If we are to increase the employment rate of people with disabilities in Australia then we will need to increase investment in demand side initiatives including wage subsidies, employer led initiatives and job generation in social enterprise. 44 Employment Services – Building on Success Response to Issues Paper References Australian Human Rights Commission. (2012). 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