Assurance Strategy Guideline
Document change history
Version
Start date
Effective date
2.2
10 08 16
12 09 16
2.1
27 06 16
27 06 16
11 09 16
Narrative – correction to Transition to Work guideline
reference (p7)
2.0
15 02 16
15 02 16
26 06 16
Policy – throughout document, inclusion of Transition
to Work Services (Transition to Work Deed 2016-2020);
Quality assurance, addition of specific requirements
for each programme (p6-7); Tip-offs and complaints –
new section (p7); Data analytics – new section (p7);
Programme Assurance Activities (p7-8); Remedial
action section removed; Measurement of compliance
section removed.
Narrative – Figure 1 text (p3); Prevention strategies
(p3); Deterrence strategies (p4); Detection strategies
(p5); Correction strategies (p6); Programme Assurance
Activities (p10).
1.1
25 08 15
25 08 15
14 02 16
Policy – text deletion (p2); Detection strategies – slight
wording changes (p6); Quality Assurance Framework –
Investors in People removed (p6); Contract monitoring
– insertion of reference to the tip-off line (p7); Provider
Site visits – insertion of reference to jobactive Deed
2015-2020 – Work for the Dole Coordinator (p7);
Rolling random sample reviews – terminology change,
removal of referral to Work for the Dole activities, and
text amended to reflect that reviews will be
undertaken of claims/activity over a three month
period (p7); Targeted Programme Assurance Activities
– slight wording changes (p7); Remedial action –
terminology changed from sanction (p8); Deeming
heading added (p8)
1.0
1 05 15 for
jobactive Deed
2015-2020 –
Work for the
Dole
Coordinator
1 05 15 for
jobactive Deed
2015-2020 –
Work for the
Dole
Coordinator
24 08 15
Original version of document
1 07 15 for the
jobactive Deed
2015-2020
1 07 15 for the
jobactive Deed
2015-2020
Assurance Strategy Guideline
TRIM ID: D16/1225291
End date
Change and location
Narrative – replacement of Figure 1 with new diagram
at Attachment A
Effective Date: 12 September 2016
1
Explanatory Note
All capitalised terms have the same meaning as in jobactive Deed 2015–2020, jobactive Deed 2015–2020 –
Work for the Dole Coordinator and Transition to Work Deed 2016-2020 (the Deeds).
For the purpose of this document:

Providers under the jobactive Deed 2015–2020 or Transition to Work Deed 2016–2020 and Work for the
Dole Coordinators under the jobactive Deed 2015–2020 – Work for the Dole Coordinator will be
collectively termed ‘Providers’

Participants under the jobactive Deed 2015–2020, Eligible Job Seekers under the jobactive Deed 2015–
2020 –Work for the Dole Coordinator and Participants under the Transition to Work Deed 2016–2020
will be collectively termed ‘Participants’.
In this document, ‘must’ means that compliance is mandatory and ‘should’ means that compliance represents
best practice and that compliance is discretionary.
Disclaimer
This Guideline is not a stand-alone document and does not contain the entirety of Providers’ obligations.
It must be read in conjunction with the Deeds and any relevant Guidelines or reference material issued by the
Department of Employment under or in connection with the Deeds.
Relevant Deed clause/s
This Guideline relates to the entirety of the Deeds.
Relevant references
Reference documents relevant to this Guideline include:
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Public Governance, Performance and Accountability Act 2013
all Guidelines relevant to the jobactive Deed 2015–2020
all Guidelines relevant to the jobactive Deed 2015–2020 – Work for the Dole Coordinator
all Guidelines relevant to the Transition to Work Deed 2016–2020.
Summary
This document outlines the Department of Employment’s approach to assuring the integrity of the delivery of
employment services programmes.
The management and assurance of employment services programmes needs to balance operational flexibility
with appropriate accountability while aiming to keep the administration burden on Providers as low as possible.
The Department uses a risk-based approach to assure the integrity of its employment services.
The Assurance Strategy aims to:
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inform Providers about the various ways the Department encourages Providers to voluntarily comply
with requirements
inform Providers of the range of remedial actions that can apply if they are non-compliant
target areas of risk.
Policy Intent
Providers must have in place their own governance and control frameworks that support their delivery of
quality services and performance and accuracy of payments consistent with the Deeds.
The Department acknowledges that the majority of Providers are willing, able to, and do comply with
contractual and Guideline requirements. However some Providers will engage in inappropriate activities that do
not meet the contractual requirements or be inadvertently non-compliant due to poor governance or
procedures.
Assurance Strategy Guideline
TRIM ID: D16/1225291
Effective Date: 12 September 2016
2
The Department employs four strategies to provide assurance:
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prevention—making it easier for Providers to comply
deterrence—making clear the risks and penalties of non-compliance
detection—processes are in place to identify non-compliance
correction—acting on detected non-compliance.
A diagram of the Department’s Assurance Strategy is provided at Attachment A.
Prevention strategies
The primary focus of the Department’s assurance activities is prevention, as most Providers strive to be
compliant and the Department wants to support and encourage these organisations by making compliance as
easy as possible.
The most critical ways that the Department can help to prevent both inadvertent and wilful non-compliance are
to provide sound programme design, clear Deeds and Guidelines, and IT Systems that prevent ineligible claims
being made and support compliance. The goal is that:
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Providers clearly understand their requirements and obligations
Providers have a clear expectation of appropriate standards of behaviour
complexity, loopholes and ambiguity are minimised
IT systems aid compliance.
The Department will seek to raise awareness of the correct procedures and appropriate maintenance of
evidence by:
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providing training materials (for example, Learning Centre training modules)
answering Provider queries as quickly and clearly as possible
communicating feedback from assurance activities to Providers, including areas for improvement.
Providers must ensure that they comply with requirements by having appropriate governance, procedures,
training and monitoring in place.
Compliance with the Third Party IT Provider Deed and full Information Security Manual accreditation will
strengthen the governance framework and provide additional controls to reduce risk.
Deterrence strategies
The Department uses deterrence strategies that are designed to increase the proportion of Providers that are
voluntarily compliant. The Department’s deterrence strategies include:
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making clear to Providers all of the ways in which the Department monitors them and what factors
influence the level of scrutiny of each organisation (see ‘Factors that may influence the level of scrutiny
of Providers’ below)
making Providers aware of the range and severity of remedial actions that can be applied, and any
impacts on their performance, so that they are fully aware of the ramifications of non-compliance.
The Department’s risk and compliance model (see Figure 1—Risk and compliance model) shows how the
Department will treat instances of non-compliance according to the Department’s determination of the nature,
level and causes of non-compliance and the Provider’s level of cooperation. It also shows the Department’s risk
differentiation approach, under which the risk rating assigned to each organisation informs the intensity and
frequency of scrutiny.
Assurance Strategy Guideline
TRIM ID: D16/1225291
Effective Date: 12 September 2016
3
Figure 1—Risk and compliance
Use full force of remedial actions
Actively exploit ambiguity/loopholes in
the Deed
Deter by detection, moderate degree of
remedial action
Try to comply but don’t always succeed
Help to comply, lesser degree of
remedial action
Make it easy to comply, minimal or no
remedial actions
LOWER RISK
Willing to do the right thing
more frequent monitoring and
higher likelihood of targeted review
Wilful non-compliance or manipulation
of any Records, processes or the
Services to maximise Payments.
Risk differentiation
periodic monitoring and lower
likelihood of targeted review
Compliance strategy
HIGHER RISK
Attitude to compliance
Detection strategies
The Department’s detection strategies are designed to identify practices that impact on the integrity of
employment programmes. Programme and Provider level risks will be identified using a combination of
qualitative and quantitative sources, including:
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random or targeted sampling of claims or activity
desktop analysis of data from the Department’s IT Systems
data analytics and actuarial modelling to highlight claims for targeted review
verification with Department of Human Services data
tip-offs and feedback received from Participants or Provider staff (including through the Department’s
National Customer Service Line and Employment Services Tip-off Line)
intelligence gathered from industry
information sourced by the Department’s Account Managers and contract managers, including from
Provider visits
accessing Providers’ third party IT systems, using the Department’s access rights under the Third Party IT
Provider Deed.
The Department’s risk differentiation approach (as shown in Figure 1) will determine the frequency and
intensity of scrutiny applied to each Provider and/or Employment Region/Site (as relevant). A Provider assessed
as high risk would be monitored more frequently than others and will be more likely to be the subject of more
intense and targeted programme assurance reviews.
All Providers will be monitored using a variety of ‘risk filters’ to detect matters of concern that may indicate
potential non-compliance (for example, a high number of claims of a particular fee relative to caseload or
national benchmarks). Any findings that vary significantly from industry norms or past performance/activity may
trigger a targeted programme assurance review or a change in a Provider’s risk rating.
Assurance Strategy Guideline
TRIM ID: D16/1225291
Effective Date: 12 September 2016
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Factors that may influence the level of scrutiny of Providers:
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Amount or pattern of claims that varies from industry norms or past performance.
Complaints and/or poor feedback from Participants have been received through the National Customer
Service Line.
Intelligence about manipulative or potentially fraudulent behaviour has been received through the
Employment Services Tip-off Line or other sources.
Audits indicate concerns or practices that increase risk of non-compliance.
Provider visits indicate poor record keeping or other factors that increase risk of non-compliance.
The Department assesses that governance structures are poor, inadequate risk and fraud controls are in
place or there are other indicators that the organisation is at risk of non-compliance.
High staff, management or corporate board turnover.
A history of acting in a way that exploits ambiguity to maximise fees and/or otherwise acting in a way
that is not consistent with programme policy intent.
A past record of non-compliance and/or debt recoveries.
The Department may make direct contact with employers, Participants or other relevant parties to verify
evidence supplied by a Provider.
Correction strategies
Where activities or actions arise that are not consistent with the Deed, including the Guidelines, the Department
will undertake appropriate preventative strategies (such as working with Providers to improve their practices to
enable future compliance; or amending Guidelines and other material to ensure that requirements are as clear
as possible). The Department will also consider what, if any, correction strategies should be applied.
Correction strategies may include one or more of the following actions:
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recovering payments that the Provider was not entitled to claim, consistent with the Department’s
obligations under the Public Governance, Performance and Accountability Act 2013 and/or
exercising other remedies available under the relevant Deed such as, but not limited to, imposition of
additional conditions on payment of fees or imposition of additional reporting requirements.
As set out in the Department’s compliance model (see Figure 1), the level of any remedial action applied will be
informed by the nature and level of non-compliance that has been identified, the causes of the non-compliance
and the Provider’s level of cooperation with any review or investigation. Where a Provider undertakes a
self-audit of activity and voluntarily discloses non-compliance, the Department may elect not to apply remedial
action (in addition to recovery of any relevant fees). An appropriate level of remedial action, commensurate
with the degree of non-compliance, will be considered in all other instances (refer to Remedial Action
Approach). The strictest remedial actions with the most impact will be more likely to be applied where the
Department determines that Records, processes or the Services are wilfully manipulated.
Any cases of potentially criminal behaviour will be referred to the Department’s Investigations Branch to be
investigated.
Should any disputes, problems or issues arise, these will be handled in the first instance in accordance with the
Joint Charter of Deed Management.
Assurance Strategy Guideline
TRIM ID: D16/1225291
Effective Date: 12 September 2016
5
Assurance elements
Quality assurance
The Government is committed to ensuring the delivery of high-quality employment services for Participants and
employers.
jobactive – Employment Provider Services
As set out in the jobactive Performance Framework Guideline, Providers are required to gain and
maintain certification against the Quality Assurance Framework which comprises:
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Demonstrated conformance with Quality Principles; and
Certification against one of the Department’s approved Quality Standards: ISO 9001, the
National Standards for Disability Services or the Employment Services Industry Standard.
Certification against an approved Quality Standard establishes a foundation of quality management,
while the Quality Principles address the minimum requirements for delivering quality employment
Services. Consistent with each of the Quality Standards, there is a strong focus on continual
improvement.
Certification will be undertaken by an accredited third party auditor from a list of auditors appointed by
the Department.
jobactive – New Enterprise Incentive Scheme (NEIS)
NEIS Providers performance will be assessed against a Performance Management Framework which
includes an assessment of performance against the NEIS specific Key Performance Indicators and Joint
Charter of Deed Management for the Employment Services 2015 NEIS model.
jobactive – Harvest Labour Services (HLS)
HLS Providers performance will be assessed based on the supply of quarterly and annual Reports, as
well as continued value for money and compliance with the Deed.
jobactive – Work for the Dole Coordinators
Work for the Dole Coordinators are subject to the Work for the Dole Coordinator Quality Framework,
and are required to complete a Self-Assessment Quality Report to demonstrate adherence to four
Quality Principles: Governance; Labour Market, Employers and Community; Operational Effectiveness;
and Continual Improvement. Work for the Dole Coordinators are required to submit to the Department
a Self-Assessment Quality Report within six months of their Deed Commencement Date.
Transition to Work Services
The Transition to Work Performance Management Framework includes assessment of quality through
the Provider’s performance against Key Performance Indicators and compliance with the Service
Guarantee and Service Delivery Plan. The assessment will utilise both IT system and Provider generated
reporting and other relevant information sources including Participant and employer feedback. To
promote the delivery of quality services, Transition to Work Providers are encouraged to follow a set of
‘best practice’ quality principles, as outlined in the Transition to Work Performance Framework
Guideline.
Contract monitoring
The Department will undertake contract monitoring of the full spectrum of each of the services on an ongoing
basis. Monitoring activities can include, but are not limited to, Provider visits and data interrogation;
investigation of tip-offs received through the Department’s Tip-off Line; and desktop monitoring audits, which
utilise the systems information available to the Department. Results of these activities inform ongoing
programme assurance and, where results indicate more investigation is required, they can trigger a targeted
Programme Assurance Activity.
Assurance Strategy Guideline
TRIM ID: D16/1225291
Effective Date: 12 September 2016
6
During each Performance Period, the Department’s Account Managers and contract managers will monitor
performance against any representations in the Provider’s tender response to the Request for Tender and
assess service delivery against the Provider’s Service Delivery Plans and the Service Guarantees.
Provider visits
In addition to any scheduled Provider visits that the Department undertakes in the normal course of the
contract management of its programmes, the Department may conduct unannounced visits in certain
circumstances. These circumstances include where the Department has reason to believe that a breach of the
Deed may have occurred, there is suspected fraud, or for the purposes of Programme Assurance Activities.
Where an unannounced visit occurs, the Provider must cooperate with the Department’s employees and must
provide access to premises and Records and provide assistance in accordance with the clauses of the relevant
Deed.
Tip-offs and complaints
The Employment Services Tip-Off Line allows interested parties, including current and former employees of
Providers, to alert the Department to any potential breaches of the Deed or fraudulent practices. Similarly the
National Customer Service Line provides an avenue for Participants, employers or other relevant parties to
provide feedback to the Department about the quality and appropriateness of services delivered by Providers.
The Department values all feedback, and where further investigation is warranted will act appropriately,
including through seeking clarification from the Provider or by undertaking targeted Programme Assurance
Activities.
Data analytics
The Department’s data analytics capability allows patterns of Provider behaviour, which may not otherwise be
apparent, to be identified from available data. Data analytics can be applied across all the programmes
managed by the Department. Where outlier or aberrant patterns of behaviour are identified, the Department
may discuss the findings with the Provider to identify the source of the anomaly, or may conduct a targeted
Programme Assurance Activity.
Programme Assurance Activities
Programme Assurance Activities allow the Department to determine whether Providers are meeting their
obligations under the Deed and any Guidelines, and may be conducted on a national or targeted basis.
Targeted Programme Assurance Activities assess areas of emerging or identified risk that may arise due to the
dynamic environment in which employment services are delivered. Projects may involve only one Provider or a
smaller group of Providers; they may be restricted to a specific location or region; or they may target a specific
element of employment servicing.
Risk is assessed with reference to various factors, including but not limited to:
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programme expenditure or transaction volume (higher levels of programme expenditure or frequency
of transactions are assessed as containing significantly higher levels of risk)
risk assessment of individual Providers
results of past Programme Assurance Activities.
In conducting targeted Programme Assurance Activities, the Department utilises a range of methods, including
but not limited to conducting surveys of employers or Participants; and analysing data and examining available
information. This will include the examination of evidence uploaded at the time of claim (requested by ESS
Web), or any other evidence requested by the Department.
jobactive Employment Provider Services – Rolling Random Sample reviews
The Department will undertake quarterly reviews of a random sample of claims/activities from each
Employment Provider in each Employment Region in which they operate. Claims and other in-scope
activities that occurred over the previous three months will be reviewed.
Assurance Strategy Guideline
TRIM ID: D16/1225291
Effective Date: 12 September 2016
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In scope claims and other activities may vary from quarter to quarter but may include such programme
elements as:
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Outcome payments
Wage Subsidies
Employment Fund reimbursements
Job Seeker Classification Instrument updates resulting in a change of stream
Relocation Assistance to Take Up a Job
Work for the Dole.
Findings of the Rolling Random Sample, along with findings of all other compliance reviews, will be
incorporated into the Compliance Indicator which may be taken into account when assessing Providers’
performance (for more information refer to the jobactive Performance Framework Guideline).
jobactive (jobactive Deed 2015–2020) and Transition to Work Services – Deeming
As part of its Programme Assurance Activities, the Department may choose to review a sample of the
Provider’s claims and extrapolate the findings to similar claim types (‘deem’). The Department may
exercise its rights under the Deed to recover, or otherwise apply remedies to, all or a proportion of the
extrapolated claims (including associated claims) which are deemed to not meet requirements.
Assurance Strategy Guideline
TRIM ID: D16/1225291
Effective Date: 12 September 2016
8
ATTACHMENT A
Assurance Strategy diagram
Key :
(1) jobactive Employment Provider Services
(2) Excluding ParentsNext
(3) jobactive Employment Provider Services, Transition to Work and ParentsNext (Project Guarantee)
Prevention
Deeds
including
Guidelines
Joint Charter of
Deed
Management(2)
Service
Guarantee(3)
and service
offer
Detection
Correction
TRIM ID: D16/1225291
Learning Centre
Assurance activity results
Provider Portal
Remedial Action
Approach
Compliance
Indicator(1)
Tip-offs and
complaints
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

Programme Assurance
Activities


Rolling Random Sample(1)
Targeted assurance activities
Department’s corrective actions
Debt recoveries
Remedial actions
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
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Adjust policy settings
Amend Guidelines
Provider education
Effective Date: 12 September 2016
9
Data analytics
Assurance Strategy
Deterrence
Assurance Strategy Guideline
Contract
management
activity
IT system
controls
Quality Assurance Framework(1)
Department’s risk management approach
Star Ratings(1)
Provider education