Employment Services 2015-2020:Feedback from NORTEC Employment and Training
NORTEC is pleased to have the opportunity to provide feedback on the Exposure Draft for Employment Services 2015-2020 and has made comments on two parts: Employment Provider Services and New Enterprise Incentive Scheme (NEIS).
Employment Provider Services
Financial
We applaud the inclusion of a mid-contract price adjustment.
Regional areas often have a significant part-time/casualised workforce (e.g. Tweed is over 40%). Providers in these areas will be significantly disadvantaged financially as part-time/casual roles usually generate only partial outcomes where no 26 week outcome is payable.
If a jobseeker does a mix of activities to meet mutual obligation, will the Work for the Dole (WfD) payment still be $1,000 or will it be pro-rated?
Given that Stream B under-30 jobseekers will have more barriers than Stream A under-30 jobseekers, shouldn’t the administration fee be higher for Stream B?
We recommend that a Regional Loading should be paid even if a regional jobseeker re-locates to a non-regional area for an employment outcome.
Some regions have caseloads with low job seeker flow and would be negatively impacted by the proposed administration fee/ outcome fee mix.We suggest the Department consider a higher administration feefor regions with low caseload flow to ensure thefinancial viability of all providers in those regions.
We are concerned that the start date for an outcome will be the first day of the DHS payment fortnight after commencement. This could mean outcomes are up to 13 days longer than payment is made for. i.e. 4, 12 and 26 week outcomes become almost 6, 14 and 28 week outcomes which may reduce the number of outcomes possible due to non-completion of the extra time and hence create a financial impact for providers.
Non-Financial
Is the monthly contact requirement for under-30’s a face to face requirement?
Clause 2.9.7 of the Statement of Requirements states that one of the prohibited items for funding through the Employment Fund is “training that is not directly related to a specific job.” Does this mean a specific job-type that will be applied for after training or to a specific job vacancy? i.e. Can a job seeker be trained in hospitality skills and then apply for barista jobs or are they restricted to training as a barista position when it is advertised? We suggest that training funded from the EF should be at the industry level rather than specific job level
otherwise it is too restrictive. This training could be justified through provision of evidence to avoid “training for training’s sake”.
40 Job searches per month will place a burden on small employers in small towns and regional areas where there are more job seekers than vacancies.This will be exacerbated where job seekers are issued with Employer Contact Certificates as it will place a further administration burden on employers and potentially make them less inclined to use Government Employment Services.
The East Point QLD Employment Region crosses the border and cuts off below Kingscliff. Is the Department aware of the cross-border issues, particularly daylight savings, and the problems for job seekers, employers and providers that this will create?
The Department is encouraging providers to be more efficient. Where providers have DES ESS and/or DES DMS contracts which continue to operate on an ESA basis, they will find it difficult to be efficient (initiatives such as regional managers, staff that service all contracts etc) due to the added complication of ESA/Employment Regions not being aligned.
We seek clarification about what constitutes a job seeker contact.
Wage subsidies need to be payable in instalments. Employers will reject retrospective subsidies that are only payable after 6 months. We suggest the subsidies align with the outcome periods of 4, 12 and 26 weeks as a minimum.
We recommend that attachmentsare allowed in tender submissions so that service delivery models can be presented visually to assist the tender reviewers to better understand what is being presented.
NEIS
Financial
Is there any reason why the NEIS program is excluded from a mid-contract price adjustment? Costs have increased for the NEIS program and will continue to increase as they will for Employment Provider Services which receives a mid-contract adjustment. Additionally, is there any reason NEIS is excluded from the regional loading applied to Employment Provider Services when it will be operating alongside ES in the same market?
There are significant cash flow implications (especially for small providers) when 80% of payment is received after business commencement which can be many weeks after placingNEIS participants in training.We suggest that consideration be given to a mid-training or training commencement payment to make the program more financially viable. Additionally, moving the final post-program outcome from 52 weeks to 65 weeks will place further financial strain on NEIS providers. We recommend the final outcome remains at 52 weeks.
We believe that access to the Employment Fund is critical to ensure the success of start-up businesses and would like to see this clearly articulated in the NEIS RFT document.
Non-financial
We welcome the decision to limit the number of NEIS providers in each region to 3 as the current arrangement with 5 providers (Tweed, North Coast, Richmond, Clarence) is too many given the limited size of the market.
Page | 1