Response to the Changes to Indigenous Employment Program (IEP) Assessment and Funding Processes Discussion Paper

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1 Response to the Changes to Indigenous Employment Program (IEP) Assessment and Funding Processes Discussion Paper Contact for this submission: Anthony Steel A/Executive Leader, Employment Solutions

2 Mission Australia Mission Australia is a large national, non-denominational Christian community service organisation that has been transforming the lives of Australians in need for more than 150 years. Our vision is to see a fairer Australia by eliminating disadvantage for vulnerable Australians. This aim is reflected in the breadth and diversity of our programs from early learning and youth services, extensive family support and homelessness initiatives, employment and skills development, to provision of affordable housing. In our 326 Community Services (including 28 Early Learning Services) assisted 110,389 individuals and 5,732 families. MA Housing also grew its housing management portfolio to 1,418 dwellings in the same year, substantially increasing the number of people we have been able to support into stable accommodation. Mission Australia Employment Solutions Our Employment Solutions division is one of Australia s largest not for profit providers of governmentfunded employment services, including programs administered under Job Services Australia. Since the commencement of JSA in July 2009 Employment Solutions have placed some 65,000 job seekers into sustainable employment. Specifically in , we offered ten programs that helped 165,000 individuals and assisted 15,850 people move into sustainable employment 1. Mission Australia is a leading provider of IEP programs based on our experience and success working with Indigenous communities and our understanding of the barriers that prevent Indigenous people from working. Working closely with local communities in metro, regional and remote areas, we work to address training, employment, housing, youth and families needs. In we worked with the Queensland Reds, Brisbane Roar, the Football Federation Australia, Accor Hotel Group, Intercontinental Hotel Group, BHP Billiton Mitsubishi Alliance (BMA) and Leighton Contractors, and ran 13 Indigenous Employment Programs. Our response Mission Australia recognises the unique status of Aboriginal and Torres Strait Islander peoples as the original owners and custodians of Australia s lands and waters and we are committed to addressing the cultural, social and economic needs of Aboriginal and Torres Strait Islander communities. We therefore welcomed the Australian Government s introduction of the Indigenous Employment Program (IEP) as a way to contribute towards meeting the Closing the Gap employment target. We also applaud the Australian Government s intention to improve the administration of the IEP by seeking to provide greater clarity around how proposals for funding will be assessed and prioritised. As a provider of the IEP we are keen to provide insights from this experience into the review the assessment and funding processes attached to the IEP. Our response to the Changes to Indigenous Employment Program (IEP) Assessment and Funding Processes Discussion Paper is provided below. 1 Mission Australia (2012) Annual Report Mission Australia: Sydney. Page 2

3 Prioritising IEP Projects Q1. Are there any other principles that the Department should consider when prioritising IEP proposals for funding? Mission Australia supports, in principle, the six key principles that will underpin the assessment of proposals and the prioritising of projects for funding from onwards. A definition for each principle should be clearly articulated in the documentation so that there is a shared, common understanding of the assessment process to be applied. We would particularly like to see outcomes defined in relation to the principle of outcome focused. Our views on what should be included in definitions or considerations for each of the six principles are provided in the related section below. In our view there is a missing element/s to the principles for the IEP. As an organisation committed to addressing the cultural, social and economic needs of Aboriginal and Torres Strait Islander communities we developed a Reconciliation Action Plan (RAP). Part of the next stage of our Plan s implementation and ongoing development is to embed cultural competency and cultural safety in our workplace. Given the importance of these elements we would suggest that consideration be given to the addition of a principle of cultural competency and safety. By cultural competency we mean an ability to work respectfully and effectively across cultures and that our relationships are built on consultation and consideration of those we seek to support. Culturally competent organisations extend beyond merely hiring and professional development opportunities for their staff. It is reflected by maintaining a cultural mix of staff relevant to client numbers. Mission Australia has developed a Cultural Values Sharing program as part of our RAP which requires all staff to share best practice and engage through developed relationships. Leadership development of our Aboriginal and Torres Strait Islander staff through the Australian Indigenous Leadership Centre also ensures we have a closer contact to the community and are better equipped to understand the local situation to allow adaption of projects and programs so that all members of a community have equal access. Cultural safety on the other hand is the provision of a culturally safe environment for Aboriginal people. Those most able or equipped to provide a culturally safe atmosphere are people from the same culture and it is therefore important that organisations providing services for Aboriginal clients to critically evaluate their work practice by examining any preconceived ideas and stereotypes which may exist. This can be done through a cultural self-assessment process which we have built in to our Reconciliation Action Plan as a way to facilitate a continuous process to improve cultural competence. Outcome Focused Q2. How can employment outcomes be maximized through IEP projects? Mission Australia fully supports the commitment to Closing the Gap in employment outcomes between Indigenous and non-indigenous Australians. We do however think there is a need to clearly articulate that one of the key outcome measures is an improvement in sustainable employment outcomes therefore the outcome focus and sustainability of employment should be linked. In our response to the final report of the Advisory Panel on Employment Services Administration and Accountability we indicated that in our view an outcome of sustainable employment for jobseekers sits Page 3

4 comfortably within a goal to improve social inclusion and economic participation however we would note that achieving social inclusion and economic participation is a strong statement that will not be possible to achieve in the absence of sustainable employment. We would therefore like to see a focus on the sustainability of employment outcomes rather than just employment outcomes included in the definition of outcome focused as one of the key principles. Although there is mention of assistance to support sustainable employment in the support for employment activities for the IEP, we think there should be a greater focus and specific mention on the sustainability of the employment outcomes offered. This could be through the nomination of a particular employer or the establishment of an Indigenous employment strategy to facilitate sustainable employment, as long as there is a clear method to maximise employment outcomes that will have long-term implications for individuals and communities alike. Another way to potentially maximise employment outcomes is to modify the payment structure. We consider this to be particularly relevant for an outcome of sustainable employment. In our submission to the 2015 Employment Services Building on Success discussion paper we suggested a bonus payment should be provided, in addition to the 13 and 26 week outcome payments, based on maintenance or achievement of status at 52 weeks. A similar approach could be adopted for IEP or alternatively milestone payments rather than outcomes payments could be adopted that pay IEP programs as they demonstrate progress towards outcomes. Q3. How can a direct line of sight to employment outcomes be demonstrated through the application process? Mission Australia is confident that a direct line of sight to employment outcomes can be demonstrated through the application process and extend beyond a requirement to specifically nominate an employer who will provide employment for IEP participants. Direct line of sight to employment outcomes could be demonstrated by identification of existing employment opportunities. This could include: the identification of industry specific opportunities; identified growth areas resulting in employment opportunities; existing networks the applicant has with employers through which employment opportunities could be generated; or labour market analysis to demonstrate need in support of the application. This could also involve requiring those who apply for IEP funding to relay their prior experience of delivering outcomes. For example, in our experience as a broker in The Australian Apprenticeships Access Program (the Access Program) we have adopted just such an approach when we sub-contract services and do so to maximise the ability to deliver outcomes for our jobseekers. All of our subcontracted providers undergo rigorous due diligence for every pre-vocational training program they deliver. Each sub-contract with a provider contains a limited number of commencements and performance indicators that are based on each training program and future business is brokered based on outcome performance against previous contracts. We think such an approach could be applied for the assessment of direct line of sight to employment outcomes for IEP funding. To undertake our functions as a broker we have designed a provider selection process that requires: evidence of a proven track record in accredited training delivery; evidence of an established employer database; evidence of achieving Australian Apprenticeship outcomes in applicant s nominated specialty industries; and the methodology they would implement to recruit and select eligible Access Program Page 4

5 candidates in all Categories. Providers also need to demonstrate a commitment to structured post program and post placement support. We have the following strategies to ensure that Access Program Providers are able to meet the specific needs of their Labour Market Region: Providers are required to submit a Program Request which includes detailed information addressing: labour market needs; industry trends; employer demand and partnerships; jobseeker profiles; referral agency linkages and research; training competencies to be delivered; placement assistance; and post placement support; Rigorous analysis of Program Requests to assess the ability of Providers to: achieve the required level of Australian Apprenticeship outcomes; provide the appropriate level of assistance to participants; deliver a quality program; and deliver the full range of Access Program services; Past performance of Providers to deliver against claims is also be used as a factor in determining potential success of a proposed program; and Links are established with industry and labour market sources to underpin our assessment of program requests. Relevant Q4. How can Government work better with employers, industries, Indigenous businesses and panel members to ensure IEP funding is targeted to the areas of greatest need and opportunity? Q5. How should the Government's priorities be communicated particularly to employers? In our response to the 2015 Employment Services Building on Success discussion paper we stated that to avoid future skills shortages, we believe industry has a role to play in hiring marginalised job seekers and investing in on-the-job training and skill development to help get them work ready. In many instances it should not be too onerous to address some of the skills shortages reported by employers with whom we work as they are talking about skills shortages of a basic nature; for example, driver s licences, machinery tickets, Responsible Service of Alcohol (RSA), Responsible Service of Gaming (RSG) certificates. They also note that aged care and child care Certificate and Diploma level skills remain in high demand, as well as warehouse, food processing and security industry skills. Government could therefore work with employers, industries, Indigenous businesses and panel members on specific projects to address some of these skills shortages given they represent an already identified need and opportunity. We also argued that the future employment system needs to effectively build in demand-led employment as a key principle. This requires effective partnerships between Government, employers and providers. Part of that process should encourage providers to work more closely with businesses to understand their long term workforce needs. One way we indicated that this could be achieved was through the consideration of workforce needs analysis and people development planning as part of the broader toolkit employment service providers offer to employers. This approach could deliver more effective and targeted solutions for employers in achieving their current and future workforce requirements as well as provide an opportunity to identify need and opportunity for the range of entities mentioned above. Page 5

6 Having an inclusive process such as those outlined above would also give Government an opportunity to communicate their priorities. The identification of workforce needs and demand led initiatives would also provide an opportunity to broaden the scope of need and opportunity beyond demographic and labour market data. We would therefore like to see panel members be given a greater role in the identification of areas of greatest need and opportunity and share some responsibility for promoting these needs and opportunities in addition to the aims and objectives of the IEP program. Primary responsibility for communicating the Government s priorities should, however, rest with Council of Australian Governments (COAG) as part of the broader Closing the Gap strategy commitments. Sustainable Q6. What does sustainability look like for employers (Small to Medium Enterprises or large employers), Indigenous businesses or panel members? See our response to Q2 in relation to including sustainability of employment outcomes as a core outcome measure. In our view the development of sustainable practices around recruitment, retention and development are means by which employers can increase these sustainable employment outcomes but can take time to embed and may therefore not result in sustainable employment outcomes for participants in earlier phases of the respective program. That said, we consider sustainability for employers, Indigenous businesses and panel members could be achieved when the practices around recruitment, retention and development are embedded and routinely result in sustainable employment outcomes. This should include a commitment to embed cultural competency and cultural safety in the workplace (as per our response at Q1). From our experience this requires mentoring and support post-placement to help participants meet and overcome any challenges of their new employment. This ongoing mentoring also ensures participants cultural needs are met and that participants have built strong support networks. In addition we offer mentors to our IEP participants work with the participant and the employer to identify pathways to more aspirational roles in that business or industry. We do so because our experience has shown us that moving people from entry level to higher roles is personally rewarding for them and it also opens up another entry level position for future Indigenous participants. Q7. How could sustainability of outcomes be demonstrated through the application process? Refer to our response to Q3. Capacity Building Q8. How can capacity building be demonstrated through the application process? Refer to our response to Q3 in relation to the strategies we require funding applicants to meet. Similar criteria but in relation to demonstrating a commitment to, and understanding of, the Closing the Gap targets and the employment of Indigenous Australians more generally could be required as part of the application process. Page 6

7 Q9. At what stage in an organisation's development is it reasonable to expect that they should be able to support their own Indigenous Employment Strategy? As outlined above, capacity building is vital if we are to embed sustainable recruitment and retention of Indigenous job seekers into an organisation s operational practice. Mission Australia have firsthand experience of supporting employers become employers of Indigenous people and have achieved longterm outcomes from seed funding provided by the IEP. On that basis we consider many businesses should be able to support their own Indigenous Employment Strategy reasonably quickly in their own development if they are assisted to develop their strategy through support. For example, our Employment Solutions division ran an Indigenous Employment Strategy with fifty local businesses in south-western Queensland predominantly Warwick and Brisbane - in The strategy was designed to give local employers the tools and understanding they needed to tap into the local Indigenous workforce by connecting employers with Indigenous job seekers and assisting both parties to achieve positive results. Through this initiative we supported 50 employers to develop their own Indigenous Employment Strategy (IES) to enable them to be better equipped to recruit, retain and develop their Aboriginal and Torres Strait Islander staff. This included collecting local employment and market trend data that was important for the organisation to establish a business case to embed the need for an IES to gain internal support for the finished product. The strategy also assists the businesses to provide culturally supportive and inclusive workplaces that encourage Indigenous employment. The program was very successful with each of the 50 businesses having an IES in place at the end of the twelve month project and employment opportunities being provided as a result. This success provides a good indication of what can be achieved when the right support is provided. It is important to note however that some businesses will take longer to be able to support their own Strategy. In our experience with the IES project, all of the employers were able to develop their strategy but did so at differing rates. Also many of our businesses were small to medium businesses who would have taken much longer to develop their strategy without the support offered through the program. Obviously the time taken will be dependent upon where the business is with regards to developing and embedding a Strategy (i.e. their starting point) and also what broader support they have to develop and embed a strategy. Q10. How can the Government ensure equity of access to the IEP, so that businesses/employers that are new to Indigenous employment have an opportunity to access support? As IEP funding is not designed to be recurrent or ongoing operational funding 2 we consider the easiest way to ensure equity of access is to assess applications for funding against those criteria. Such an approach would also ensure that programs that operate similar but not identical project offerings year in and year out are not excluded from funding where they can demonstrate that the funding will be applied by the same recipient but for a different cohort or business outcome. For example, our innovative 18 month partnership with the Queensland Reds looked at tackling Indigenous unemployment. The program worked with 25 Indigenous young people from south Brisbane to create positive long-term educational and employment benefits. Participants learnt about motivation, goal setting, employer expectations, nutrition, fitness, healthy lifestyles and career planning through ongoing contact with Mission Australia while the Queensland Reds players acted as mentors 2 As stated on page 6 in the Changes to Indigenous Employment Program (IEP) Assessment and Funding Processes Discussion Paper Page 7

8 for the young people involved in the program offering guidance, support and motivation. All of the participants in the program achieved an employment outcome which they have sustained since the program s conclusion (between six to twelve months). It is a program we hope can be rolled out throughout the country in the coming years and we would apply for IEP funding to do so. As per the requirements that IEP funding is not designed to be recurrent or ongoing operational funding, any application we made would clearly articulate that although we are working with the same partner (the Reds), we would be working with a different cohort of young people and also placing young people with other employers which would also help these businesses develop their own capacity to employ Indigenous Australians. We also think there is merit in ensuring the IEP offers businesses/employers the opportunity to link with panel members who have contemporary experience of the program. One way we think this could be managed is to impose a time limit for registration on the panel, with panel members who do not maintain their involvement in the program (e.g. have not make an application for IEP funding within a set period of time) being required to reapply for their status as a panel member. The benefit of this approach is that it ensures only fewer panel members are listed which makes it easier for government to manage and also easier for businesses seeking to access IEP funding in partnership with a panel member to identify those with contemporary experience. In our view this also provides an extra layer of credibility to IEP program. Complementary Q11. How could the IEP be better targeted to ensure that it complements the support available through other mainstream and Indigenous programs? The IEP was intended to complement other existing services and programs by providing wrap-around support linked to employment opportunities 3. In our view this is particularly important as addressing the substantial disadvantage Indigenous job seekers face to achieve sustainable employment outcomes requires holistic service provision to help them overcome both their vocational (e.g. lack of education, training and work experience) and non-vocational barriers (e.g. disability, homelessness, geographic location). Further, there is a need to ensure programs provide a balanced focus between nonvocational and vocational support. As we stated in our submission to the 2015 Employment Services Building on Success discussion paper, in order to deliver a holistic service to disadvantaged job seekers (i.e. providing each individual with the services they require based on an accurate assessment of their barriers to employment), employment service providers need to supplement and enhance their own core service offering with services purchased from other providers and/or funded by agencies in their local community. In our view this should not prevent a JSA provider who also offers IEP services as a panel member from referring to their own IEP service to provide supplementary offerings to the core JSA services and receiving payment for doing so. While we are aware that this allows a situation whereby organisations can double-up or double-dip on their outcome payments, in our view this isn t necessarily problematic particularly if the organisation can establish that the support offered by the IEP was additional and complementary to that offered through the JSA rather than duplicative. This would in fact replicate the situation currently in place with both providers (JSA and IEP) receiving an outcome 3 As stated on page 7 in the Discussion Paper Page 8

9 payment for the same job seeker, albeit with payments made to different organisations. Some consideration could also be given to developing a refined outcome payment model for JSA providers who also deliver IEP services as panel members. In our view the current system potentially creates greater duplication of resources as the individual is required to work with two different providers and undertake duplicative administration processes as a result. They may also receive duplication of servicing as the IEP will be unaware of the full extent of service offerings being provided by the job seekers existing JSA provider, something that wouldn t happen in a shared provision arrangement where the JSA also operates the IEP. As an organisation we pride ourselves on offering IEP programs that are individually designed, but built around a service delivery model that aligns job seeker aspirations with employer needs. We are therefore concerned in any changes to IEP that may restrict a jobseekers access to a full and complete range of services, and might result in poorer service delivery, particularly for Indigenous job seekers given the Closing the Gap targets. Partnership Focused Q12. What kinds of partnerships should be encouraged to support sustainable Indigenous employment or economic development initiatives? Our success in placing hundreds of Indigenous people into sustained work each year is based on the relationship we build with employers, our cultural understanding and sensitivity to the needs of Indigenous job seekers, and our capacity to holistically address personal challenges. To do this Mission Australia works closely with local communities in metro, regional and remote areas, to address training, employment, housing, youth and families needs. Our IEP participants are trained and assisted in the workplace and are clear about their jobs and employer expectations. Partnerships in each of these areas are therefore particularly important. Our suggestion for a Collaborative Prime Provider model - where a prime provider sub-contracts or purchases services from other local agencies - offers a meaningful way to encourage partnerships. Such a system must be underpinned by explicit methods of collaboration that are built into contracts, funding deeds, and ingrained through training and leadership into organisational culture to offer the best outcomes and support sustainable Indigenous employment or economic development initiatives. Partnerships between training and employment services providers would also develop more naturally through a model such as that of prime provider. From our own practice experience, the delivery of the Access program demonstrates elements of best practice in the area of sub-contracting and collaboration. The Access program is a capped procurement program that provides vulnerable job seekers who are aiming to enter skilled employment with nationally recognised pre-vocational training, support and assistance. Delivery requires a coordinated approach through which brokers enable the delivery of training through Registered Training Organisations (RTO s) which are subcontracted to deliver services. Access program delivery has been developed to provide a consistent standard across Australia. For Mission Australia, Access is delivered through a central contract management team that subcontracts training delivery to a set of RTO s using a standardised approach to contracting and managing delivery. Mission Australia is recognised as the national leader in this program and our achievements to date have largely been attributed to the consistent standard of service delivery, Page 9

10 holistic approach to ongoing support and long-term relationships developed with employers, RTOs and GTOs. There is also merit in considering the benefits of the partnership model used in Tasmania where we deliver the Gateway Service in conjunction with alliance partners. The relationships in this model are facilitated through shared governance, resources and strategic alignment. Gateway provides a single access point for individuals, service providers and other professionals to refer clients for information and advice on disability services in the area. Mission Australia s role is to connect with key agencies including education, housing, and health - to support clients, particularly at key transition points like education and work. We also collaboratively raise awareness to reduce service duplication and address community issues. IEP Application Processes Q13. How do we balance the need for greater consistency, equity of access and accountability for decisions with program flexibility and responsiveness in the design of competitive assessment processes? Q14. Is there anything further the Department needs to consider when designing competitive assessment processes? In our view greater consistency, equity of access and accountability for decisions is not inconsistent with program flexibility and responsiveness in assessment processes as long as the assessment process adopted is transparent. The proposed approach of a Request for Quote (RFQ) for panel members and a quarterly assessment process for all other applications 4 rightly acknowledges the important role panel members play in the IEP by allowing them to apply for both funding types. We think this is significant as it is often the organisations who have applied to become panel members who have demonstrated they are better equipped to address both the vocational and non-vocational issues Indigenous people experience as barriers to employment. Panel members are also well placed to support businesses to develop their Indigenous Employment Strategy so the new funding options could be used as a way to double the opportunities for panel members to work collaboratively with businesses (if the RFQ enables collaborative tenders). This is particularly relevant given our point earlier about government, employers, industries, Indigenous businesses and panel members being well placed to work together on specific projects to address already identified skills shortages. We also consider the replacement of aspects of the IEP with the Remote Jobs and Communities Program (RJCP) will enable IEP to focus more on the needs of metro and regional areas which may often share common issues rather than try to incorporate the geographic and community specific issues often experienced in remote and very remote areas. This should make it somewhat easier to identify specific priorities based on identified need or opportunity, particularly as there will be quarterly assessments as well. It could also potentially provide an economy of scale afforded by an ability to deliver more widespread programmatic responses as less tailoring for program design would be required given commonalities of geography and circumstance in the non-rjcp sites evidenced by our ability to extend our Indigenous Employment Strategy to different locations in Queensland. The only limitation to competitive assessment, and therefore competitive tendering, we note from the proposed funding opportunities relates to the proposal to commission strategic investment projects in 4 As stated on page 8 in the Discussion Paper Page 10

11 response to crises brought about through natural disasters or unanticipated labour market impacts. If the proposals for these strategic investment projects will be assessed against the same principles and have an emphasis on demonstrating capacity building and sustainability of outcomes we would ask why they couldn t form part of a special category RFQ process that is open to panel members and other identified candidates; this approach would provide more transparency to the entire process as invited tenderers could be identified and information on panel members is already public information. Page 11