Workskills understands that Employment Services 2015 is not business as usual in the context of Job Services
Australia from 2009.
However, we have some concerns re requirements within the Department’s stance and re the lack of clarity and
potential ambiguities related to some proposed requirements.
1.2 Employment Providers
Page 3 and 2.18: most job seekers will be required to undertake up to 40 job searches per month
We interpreted a job search to be a search for any jobs for which one can apply, not an application in itself but note
that published Q&A from the RFT Exposure Draft specifies that this means job applications to employers. Our
concerns are:
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The impost of inappropriate and speculative applications (for which applicants are neither suited nor qualified)
on employers, with objections expressed in the media and via employer peak bodies; and consequent poor
image of Employment Services
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The demotivating impact on some job seekers of feeling compelled to apply for jobs for which they are neither
suited nor qualified; and consequent cynicism re Employment Services
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The inability of many labour markets, especially rural and regional, to reasonably support this level of activity
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The assumption that many job seekers can use enhanced technology to support independent job search. Many
cannot and will call on their Employment Provider for substantial and frequent assistance; Service Fees and
potential Outcome fees within the whole funding envelope appear unlikely to support such a level of assistance
on top of the purposes for which fees are (partly) provided.
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The focus for Providers seems to have been moved from encouraging ‘engagement’ of Job Seekers to monitoring
‘participation’ and enforcing sanctions. This will create a whole new relationship between Providers and Job
Seekers, which has the potential to become a negative as opposed to a positive one that encourages Job Seekers
to become more confident in improving their skills and knowledge to enhance their employment opportunities.
Page 3 “training for training’s sake
Training for training sake dismisses the value of training. Training engagement, in addition to occupational skills in
most cases, has value in removing option of passive welfare through activation (2.9.2) and accrual of core skills
including employability skills and work-like habits (attendance, punctuality etc.). This is especially so for face to face
courses.
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We appreciate that this is not always the case; there are current rogue RTOs offering vulnerable and desperate job
seekers incentives to commit to, and enrol in, training (e.g., Diplomas in Management funded by Fee Help in
particular solicited in shopping centres and door to door) that is not suitable and feasible for individuals and in the
context of employer needs.
We suggest that training supported by Employment Providers at any level be qualified against how it prepares
individuals to compete in their labour market; both in terms of occupational skills and personal attributes demanded
by employers.
There is risk of a downside for employers and local labour markets. We anticipate, that while providers will not
deliver “training for training’s sake” the more strategic of job seekers under 30, in income support waiting periods,
may well enrol in training in order to claim student income support; thus removing them from the job seeker cohort
and the labour market. Unfortunately, young people who take this option to maintain a level of income support
could be those best equipped to meet employer needs and could crowd the training market. Those not having the
strategic skills to take this option remain with Employment Providers, may be less able to meet employer needs and
less able to compete, in a crowded training market, for places that can be targeted as preparation for employment.
2.2 Objective of Employment Services
We understand that there will be less prescription with regard to the services delivered but that Employment
Providers will be contracted to deliver services they outline in their tender documentation.
We appreciate the Mid-Deed price adjustment proposed and suggest, in addition, a Mid-Deed tender review, in
negotiation with Contract Managers, to ensure that Provider Deeds and services delivered therein remain
appropriate to labour markets and employer needs which may be subject to radical change within a 5 year contract
period.
P 38 and Section2.12 re collaboration between providers in some instances.
Comment: we would expect that the Department facilitate expected collaborations, bearing in mind the competitive
nature of the tender and service delivery.
In regard to “implement large scale redundancies” we would expect that this means to assist redundant workers
with advice and employment assistance, not termination services. We request clarification of this requirement.
Targets for increasing job outcomes for Indigenous Job Seekers. These should be published in the RFT, relative to
regional or local labour markets
2.5.1 Stronger Participation Incentives for Job Seekers under 30.
This framework assumes that there are plenty of jobs available in the labour market. It seems to assume that Job
Seekers just need to be threatened with no benefit to motivate them to get jobs. Reality, for many of these Job
Seekers, is totally different.
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Many Job Seekers have a history of short term, casual employment. So they will not be able to avoid 6 months
of no benefits if they lose their jobs and need to go back on payment. This could be seen as discriminatory, both
because it only applies to a particular age cohort and also because it does not apply in the same way to those
people who have been in fulltime employment who lose their jobs and can count their employment years to
discount their period of no payment.
The social impact of having people who cannot afford to pay their rent and bills or put food on the table does
not seem to have been considered as this will have serious implications for state government welfare agencies
and for other agencies funded to provide emergency or crisis assistance to people in need.
This may also encourage those people under 30 on benefit who do get employment to not declare their earnings
correctly to Centrelink as they may be too scared to go off benefit all together because if their job ceases down
the track they will be forced to wait another 6 months for any payment. This may encourage the ‘cash in hand’
culture to flourish.
A 25 hr per week WFD obligation in addition to 40 job applications per month, especially where Job Seekers lack
the skills to successfully independently job search, will impact substantially on Employment Providers.
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A 25 hour per week Work for the Dole requirement limits opportunities to rapidly engage in skills sets and
industry licensing in response to immediate labour market opportunities and risks locking young people out of
alternative pathways to paid work. The 25 hr per week requirement should be modified where short term
training is needed for immediate opportunities and be counted as WFD hours.
A six-on six-off payment regime for these Job Seekers who struggle, or in labour markets that struggle will
exclude many from basic shelter, food and health necessities. This includes young people whose families can not
or will not support them.
2.5.2 Restart Wage Subsidy
The expectation that Employment Providers administer Restart Wage Subsidy for up to 24 months for Stream A
volunteers who have registered for Restart purposes only imposes a cost and obligation without any recognition for
providers.
2.5.2 The Relocation Assistance to take up a Job Programme
Given the labour market and limited opportunities in Tasmania, and, we imagine in other regions, we suggest that
this programme be available from an earlier point (Day 1, for example, or Day 90) to, in particular, SPI participants
needing support to move and relocate to take up and offer of employment.
2.6.1 Volunteers
We believe that Young Job Seekers aged 15-24 not in Full Time Education and not on income support, Parenting
Payment Recipients without participation requirements and Disability Support Pension recipients without
participation requirements may well, with greater support than self-help and job search facilities, meet the needs of
employers, reduce any welfare dependency and increase productivity. While we understand that services are
targeted at Job Seekers with a Mutual Obligation, we do not see the sense in limited service provision to these
groups.
2.6.2 When is a Job Seeker in Service?
Will all job seekers who commenced Employment Services and then started receiving student payments (Austudy,
Abstudy, Youth Allowance), especially if related to a qualifying short course, exit Employment Provider services or is
there scope for DHS to suspend or exempt those on short courses for the duration?
2.9 Table 2.1 Servicing Requirements
Will guidance be given re “exceptional circumstances” in relation to job application expectations? An outline of
documentation requirements or Dept. Employment’s understanding of this usage will remove misunderstandings if
“exceptional circumstances” are applied.
2.9.2 Common elements across Streams
“If an Employment Provider considers that a job seeker is not benefiting from or actively participating in agreed
vocational or non-vocational interventions, the Employment provider will refer the job seeker to Work for the Dole”.
This indicates that a WFD referral in such a case is non-negotiable and immediate. If this is not the intention, we
suggest the word will is replaced by the words should or may to enable a degree of discretion where a Job Seeker is
currently a risk to, or at risk from, WFD activity.
2.9.7 Employment Fund
Refers to those items that ‘should not’ be funded by the EF. Please clarify what is meant by ‘should not’, i.e. does
this mean it is prohibited or that it should be avoided if possible? Reference is also made to ‘training that is not
directly related to a specific job’. Clarification is also required on what ‘not directly related to a specific job’ actually
means.
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2.9.8 Servicing through improved IT.
Presumes that Job Seekers, particularly in Stream A, can use improved IT to support and prove their job search
requirements. Is this supported by fact re the level of IT skills across the Job Seeker population?
2.9.9. Additional Tools.
The Tasmanian Jobs Programme that could be potentially linked and value add to other incentives/wage subsidies,
has a fulltime job requirement. This assistance will be unavailable where employers cannot commit to this, even
when a job (casual, temporary or sufficiently remunerated part-time) may result in 100% cessation of benefits.
2.9.10 Relocation Assistance
Collaboration between the Employment Providers in both the location the Job Seeker is moving from and to will be
important to ensure that the relocations are successful. Who receives the outcome; why does Job Seeker need a
new Employment Provider in the “receiving” location?
2.9.10 The Annual Work for the Dole Requirement
We are concerned re displacement of paid employees, whether (not for profit) markets can sustain the number of
individual placements needed, that Work for the Dole is widely regarded as seen as punitive, not a development
program and whether future employers will see WFD as of value in developing skills they need or as a stigma. How
will Not for Profits, local governments et al be expected to “Manage” participants that are forced to be there; why
would they want to take jobseekers?
Table 2.4 Mutual Obligation requirements for Job Seekers by age group
 Specifies part time study ‘leading to a Certificate 3 in a skills in demand area’ may be an activity that can be
included to meet WFD requirements. Other Job Seekers who still need to undertake study to become job ready
or to gain entry to a Certificate 3 course, will be disadvantaged if studying part-time at a lower level. They will
still have to undertake either 25 or 15 hours of WFD at the same time, which is logistically unlikely to happen.
 There is no provision for Job Seekers (particularly Early School Leavers) who need to undertake a broad
Foundation Skills course, or, for example, a TAFE Connect Course, to prepare them for further study or to assist
with their work readiness. There is no incentive in this model for them to undertake skills training that is not
categorised as ‘full time study’ for an extended period of time.
 Principal Carer Parents with part-time requirements and people with part-time work capacity cannot be required
to do WFD but may volunteer. In terms of this and other MO activities, 18-30YO have a 15 hour per week
requirement, others in same circumstances except for age have 7-8 hr per week requirement. This is
discriminatory purely on age where circumstances are the same.
Table 2.5 re 50-59 age group
“Work for the Dole, however, will not be mandatory”. Should that read, “unless a Job Seeker in this group does not
choose and commence in another activity that satisfies the annual Mutual Obligation Requirement”?
2.11.7 Unpaid Work Experience
Why don’t jobseekers undertaking unpaid work experience receive the $20.80 Work for the Dole payment, bearing
in mind it is part of their WFD obligation and there are work-like costs involved?
2.11.8 Payments for Work for the Dole
Regarding Group Activities in particular; can monitoring costs of jobseekers be claimed from the (up to) $3500 per
participant? Need to be specific about what the payments for WFD can cover.
2.14.1 Special Arrangements for under 30 year olds during a Payment Waiting Period
The decision that Providers ‘…will determine whether or not the Job Seeker’s payment preclusion period should be
extended and advise Human Services accordingly…’ has the potential to create conflict situations between providers
and Job Seekers. Providers will not be able to have the ‘hands off’ approach that exists currently between the PS
Team and Job Seekers where dealings are over the phone. Providers do not have the funds to provide the same
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level of security that Centrelink offices have. It also has the potential to eliminate the supportive environment that
providers try to encourage in their sites.
2.14.2 Arrangements for Job Seekers in all other circumstances
Should there be extenuating circumstances (outreach areas, where job seekers are resident in outlying locations and
where a job seeker is isolated for personal reasons) where compliance appointments can be completed by phone?
For the majority of Job Seekers, particularly the long term unemployed, confidence building needs to be a priority.
This is supported by research on the psychological impacts of long term unemployment. We need to assist Job
Seekers to overcome the ‘fear of failure’ which is a huge barrier for many people. Encouraging changes in behaviour
will not be easy if Providers largely become the ‘compliance police’.
2.14.5 Job Search Failures
We suggest employers subject to multiple job applications for advertised and unadvertised jobs will regard Employer
Contact Certificates as a further impost and job seekers as a further burden rather than potential employees.
2.4.8 Eight week non-payment penalties
Will there be a safety provision for people in severe financial hardship? Similarly will SPI Job Seekers in a 6 month
non-payment period be able to apply for severe financial hardship relief via a DHS payment rather than administered
by community welfare agencies?
2.15 Payments to Providers
Comment. The new model shifts payments towards Outcomes, which means fewer funds available for Providers to
invest in training and skill development for Job Seekers to better prepare them for work. There are many jobs where
there are specific prerequisites that need to be met regarding certificates or licences. With fewer funds available in
the Employment Fund for this training Job Seekers will become frustrated if their career pathway is unable to
progress because there are not enough funds available for their training requirements.
Outcome payments for Stream A Job Seekers (paid after 3 months) (Tables 2.7 and 2.8).
Providers may have to make substantial investment in additional facilities for the mooted 55% Job Seekers who will
commence in Stream A and have intensive job search requirements. In our experience of Stream 1 JSA, many Job
Seekers in this cohort will not have the skills to effectively job search as prescribed and make job applications; this
particularly applies to SPI participants in income support waiting or non-payment periods. Providers will be under
substantial pressure to assist with jobsearch skills training and direct job application assistance in these first 3
months, while not being able to lay the costs off against potential Outcome Payments.
We suggest that making Stream A Outcome Payments against qualifying placements and Employment Fund credits
available from Day 1 will better incentivise Providers to match affected job seekers to vacancies and to deliver the
level of assistance that individuals need re necessary training and employment costs, reducing time to employment
and reducing direct financial barriers to Stream A job seekers in quickly securing work.
2.15.13 Outcome Payments
 There is no mention of bonus outcome payments where a Job Seeker has completed qualified training – does
this mean that they are no longer available?
2.15.5 Verification
Please clarify what evidence will be required where DHS systems do not support what should be an Outcome
payment. Where it is not possible to verify an employment outcome by existing Human services data, there are
issues of collecting documentary evidence from Employers; some now demand a payment ($50 in some instances) to
provide the required information.
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2.15.6 Non Payable Outcomes
If, when a Job Seeker placed into a qualifying education course, the Job Seeker is aged 17 but turns 18 prior to
completion, is potential for an Outcome based on age at commencement?
Does potential for a ‘Full Outcome Conversion’ include part time employment gained prior to commencement in
Employment Services but converted to fulltime employment after commencement in services and any qualifying
periods?
What is meant by: “and the change occurs during a 26 Week Period”?
CHAPTER 3 WORK FOR THE DOLE COORDINATORS
Table 3.1 Work for the Dole Coordinator Responsibilities.
Should it not be a requirement in this Table that the WFDC liaises with Employment Providers to determined needs?
3.8 Performance Framework
Comment: We would hope that KPIs will be developed and published in the final Request for Tender and Deed
CHAPTER 6 PURCHASING ARRANGEMENTS
6.7.4 The Department’s Rights and Responsibilities
“…. Will not accept any responsibility or liability for any misunderstanding arising from ….any ambiguity contained in
the tender”
Remove any ambiguities and provide a full and complete Glossary including the Department’s understood definition
of words such as “specific “job, “exceptional circumstances” (e.g., Table 2.1 Servicing requirements), “working
towards a Certificate 3”.
CHAPTER 7 BIDDING FOR BUSINESS AND TENDER EVALUATION
7.2.5 Sites – Employment Provider
If you propose to deliver from a Site and you are not awarded the upper end of your bid range so unable to afford a
site you propose; are you nonetheless locked in to all the sites you propose?
We commented above in this response that four to six sites in some low population and low employer population
regions can create financial difficulties for Providers, which will impact on quality of services being delivered.
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