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Phone: 02 4228 1946

PO Box 23, Wollongong NSW 2520Facsimile 02 4226 6364

467 Crown Street, Wollongong NSW 2500Email:

SubmissionExposureDraftEmploymentServicesPurchasingArrangementsAug2014

Employment Services Purchasing Hotline

Dear Employment Services Purchasing Team,

Re: Exposure Draft Employment Services Purchasing Arrangements

Thank you for the opportunity to provide comments and feedback on the Exposure Draft, Employment Services 2015-2020 Purchasing Arrangements.

Southern Youth and Family Services (SYFS) is a major provider of support, accommodation and housing services for vulnerable young people, individuals and families in the Capital, Southern Tablelands, Shoalhaven, Illawarra and South West Sydney regions of NSW. In 2013/14 SYFS provided services to over 2,500 young people and more than 1,400 families who experienced homelessness, risk of homelessness and other disadvantage. SYFS provides early intervention and prevention services, case management, family support and counselling, Out of Home Care, primary health care, drug and alcohol, mental health, supported accommodation, Social Housing, living skills and education, training and employment programs. SYFS has specialist psychologist services, specialist youth financial counselling, specialist services for newly arrived migrants, young people with dual diagnosis, young families, Aboriginal and Torres Strait Islander people and young people exiting Juvenile Justice and other situations.

As an organisation with over 35 years’ experience working with young people experiencing homelessness, risk of homelessness, or similar disadvantaged we provide our response to this paper from a youth specialist perspective and concentrate our comments on the impacts of the new arrangements on young people.

Lack of focus on promoting the positive attributes of young job seekers

SYFS has a general concern with the language being used in the new frameworks for both the Employment Services contracts and in the Government’s Welfare Reform. Emphasising compliance and penalties under discussions on incentives has the potential to cast young job seekers in a negative light. The assumptions underlying the reforms to Employment Services, whilst in part recognising that young people may lack skills and job-readiness, do little to promote them as attractive employees to business and employers. The over-riding framework of the proposal reinforces negative perceptions of young unemployed people as unwilling to work.

Our organisation invests considerable resources in promoting to local businesses the positives of employing young people. The young people with whom we work may face many barriers, including family breakdown,

abuse, domestic and family violence, mental health issues in their families or experiences of mental health issues themselves and impoverished backgrounds. At the same time, these young people have talents, personal qualities and aspirations for their future. When they find it difficult to get employment, it is not because they don’t try. We work hard to overcome the stigma and misperceptions that surround young people who find it difficult to gain employment. The language and assumptions underpinning the proposed reforms is counterproductive, reinforces stigma and is demoralising for young people.

Income Support Waiting Periods for under 30 year olds streams A and B

Young people need to develop living skills as they develop into adulthood. These include practicalities such as budgeting skills, tenancy skills and cooking nutritionally on a budget. Removing people under 30 years of age from any form of income for six months out of twelve means that they are not able to sustain tenancies, cannot learn budgeting skills and become dependent on someone else to provide food and other essentials. This removes any possibility of developing the type of life skills that assist in obtaining employment and independence.

Our Services provide support to families who experience housing stress, overcrowding issues, low incomes, family breakdown and a range of other issues that contribute to young people exiting the family home. The proposals for waiting periods are built on the assumption that people under 30 years of age have a ‘home’ and someone who is able to support them financially.It is not possible for many families to undertake financial responsibility for members up until they turn 30 years.

SYFS currently provides Financial Counselling, Emergency Relief and Work Development Order Programs for young people. We work with many young people experiencing financial hardship through debts incurred through mobile phone contracts, accumulated fines and short-term loans taken out to cover living and other expenses. Young people experience difficulties in competing for private rental properties and then sustaining tenancies on low rates of income security payments or low youth wages, particularly those young people in casual and part-time employment. The income support waiting periods of six months out of every 12months will make repayment of debts, maintenance of living arrangements, travel to job interviews or Employment Service Provider appointments impossible. We cannot iterate strongly enough our deep concern for the welfare and safety of young people when denied any income security.

Job Seeker (Mutual Obligation) Requirements

During the waiting periods there is insufficient mutuality built into the ‘mutual obligations’’. Young people are required to make forty job searches per month. In return they receive one session per month with their Employment Service Provider and no income support. Referring to this as mutual obligation is a misnomer.

Individualised and flexible options identified are built on a rigid framework of standard obligations. The system must allow for more flexible participation requirements based on the individual circumstances and the local/regional employment market.

The requirement that participation requirements are met for young people under the age of 30 if they are in Skills in Education and Employment training of at least 25 hours per week, or part-time study, also of 25 hours per week does not recognise individualised and alternative pathways to that have been developed to assist young people to re-engage with education and training. For some young people short courses of, for example 14 hours per week, that combine living skills with introductory sessions to a variety of course options have proven very effective as a bridging pathway back into education and training. These strategies are appropriate for Stream B as well as Stream C young people. Yet, the mandatory requirements, such as the hours required for Work for the Dole, set by the new framework make such participation impossible. Further, many University and TAFE courses have less than 25 hours per week of class time and are still classified as full-time, creating an anomaly in the system.

We recommend that the mandatory hours be reduced and that greater flexibility is allowed in the range of study or skills development activity allowable. Specifically, participation in programs delivered by RTOs and non-government agencies such as: living skills programs, alternative education pathways, short courses, such as ‘TAFE tasters’, and similar educational pathways are included in participation requirements, in addition to the allowable language, literacy and numeracy courses.

No specialist providers

The new system does not adequately provide for the specialist knowledge and skills required for providing service to young people. The only option for specialisation in the new system is that Employment Service Providers can subcontract elements (if approval is given). The payment regime does not provide for a business model that makes this commercially attractive to the Employment Service Provider.

The OECD 2012 Report Activating Jobseekers, How Australia Does It, acknowledged that Employment Service Providers who attempted to include specialisation in Youth at Risk within their overall services were achieving low outcomes for these young people and had on average relatively low Star Ratings. Since the removal of a youth specific arm of the Employment Services System (the disbandment of Job Placement Employment and Training - JPET), we have found it difficult to locate evidence that incorporating some specialist functions into generic Employment Service Providers is achieving the desired outcomes.

Case Management and non-vocational barriers

Stream C and Stream B (in a higher JSCI range) under 30 year olds will receive case management. Stream C young people will have both vocational and non-vocational barriers that must be addressed in the job plan and through case management. However, the Exposure Draft does not provide adequate guidelines on what constitutes effective and quality case management. Case management must be funded through the administration fee and the Employment Service Provider’s resources, with some potential of reimbursement when an outcome is achieved. Stream A and B young people attract an upfront administration fee to the provider of $355, whilst Stream C young people only attract $255. We remain concerned that case management for young people with complex issues remains undervalued and there are insufficient provisions to ensure that non-vocational barriers are adequately addressed.

There are multiple hurdles for young people who are homeless or at risk of homelessness to overcome in order to be job ready:

  • Practical assistance – transport, mobile phones, attire
  • Fundamental skills development – living skills, communication, working with other people
  • Personal attributes – confidence, motivation
  • Service needs – physical and mental health, addictions and substance misuse,
  • Housing / Accommodation – stability and support
  • Family relationships and reconnections – lack of supports provided routinely by families to assist young people to attend Education, Training and Employment

The Exposure Draft states that where young people in Streams B or C do not conscientiously participate in the vocational or non-vocational interventions that Employment Providers deem necessary to make them job ready then the Employment Provider is to refer them to Work for the Dole. The barriers that affect the young person’s capacity to participate in vocational and non-vocational interventions will also apply to their participation in Work for the Dole. These young people, who experience multiple disadvantage, need intensive supports to assist their participation in any activity. Lack of attention to the costs of providing support to overcoming non-vocational barriers is a major omission in the Exposure Draft. The potential is that the system will set young people up to fail, by merely heightening demands on them while not providing adequate services.

The Employment Fund cannot be used for any training that is not directly related to a specific job. It is Southern Youth and Family Services’ experience that Employment Service Providers were not utilising the previous Employment Pathways Fund to purchase support services or expertise from specialist youth and homelessness services. The new Employment Fund, with Stream C rate set at $1,200 will similarly not facilitate purchase of specialist expertise to support employment outcomes through addressing non-vocational barriers.

The DEEWR 2012 Shellharbour and Illawarra Labour Market Overview surveyed 382 employers and confirmed that 30% of employers placed most importance on personal traits and qualities solely, with only 28% placing most importance on technical skills and 41% valuing both equally. Thirty one percent (31%) of applicants in recent employment processes where considered unsuitable because they lacked the employability skills and these personal attributes. The non-vocational work with young people to develop these personal attributes is a significant contributor to employment outcomes and is worthy of greater emphasis and financing.

Disincentives to Education

A young person over the age of 17years who is supported by an Employment Service Provider to re-engage with education and who proceeds to pursue an educational qualification will not attract an outcome payment for the Employment Service Provider. This is a serious disincentive for providers to support educational outcomes as an option for young people.

The system proposed is rigid for job seekers and does not allow for flexibility truly designed to meet their needs. The Exposure Draftargues that providers will have more flexibility to invest in individual jobseekers, but simultaneously, it limits the options for the young person and the strategy of Work for the Dole dominates.

Thank you for considering these comments and recommendations. For enquiries related to this submission, please contact Ms Helen Backhouse, Policy Advisor, Southern Youth and Family Services: .

Yours Faithfully,

Narelle Clay, AM

CEO Southern Youth and Family Services Assoc Inc

Mobile 0412999960

Phone Direct Office: 02-42299739

Phone Main: 02-42281946

Fax: 02-42266364

Email:

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