Chapter 6 - Workforce and service capability

  1. Workforce and service capability

Implementing the governance and service models outlined in Chapters 4 and 5 will rely on the workforce of both the public sector and service partners. This chapter considers issues related to improving the service capability of service partners, including steps to re-professionalise the workforce and other strategies to attract and retain a suitably qualified workforce—a workforce that can support the wellbeing of clients, and build the social and economic capabilities of their disadvantaged caseload.

Frontline staff are a critical element in delivering a quality employment service. The current workforce has become deprofessionalised and de-unionised, with frontline roles now characterised as having low pay, poor job security and limited entitlements—particularly when measured against pay and conditions in other sectors that are commensurate with the required level of skill.

A priority in rebuilding the system must be addressing the rate of staff turnover in the employment services sector, which is twice the rate across the broader Australian labour market. High staff turnover is one of the most common complaints from jobseekers and incompatible to quality case management.

On an individual level, staff in the sector are typically dedicated, passionate, and perform small miracles under very trying conditions. By contrast, settings within the system are not conducive to delivering an effective employment service. Caseload ratios may not be optimal to the provision of quality support. Staff do not spend the bulk of their time helping clients, instead up to 60 per cent of frontline staff’s time will be spent on administrative work and there are other staff whose roles are entirely focused on administrative and compliance matters. The IT system also limits the autonomy of frontline staff, as well as their ability to provide flexible and innovative services. These issues must be addressed when rebuilding the Commonwealth Employment Services System to attract and retain a workforce that can deliver tailored, personalised services.

To re-professionalise the sector, the Australian Government must put in place a framework that includes minimum standards for the skills, qualifications, and competencies of frontline staff. The Committee’s interim report highlighted concerns about the lack of some form of mandatory staff qualifications and competencies for the ParentsNext program. Similar concerns were raised in the context of the broader employment services system. These concerns should be addressed through the professional framework and measures to lift the skills and competencies of staff which balance qualifications with lived experience, applying to staff in both the public and private sector that deliver direct assistance to clients.

Professional development can also be improved through the Australian Government—as part of its role as the steward of the employment services sector—being proactive in identifying and disseminating best practice. This work should be led by the new Employment Services Quality Commission and supported through an Employment Services Capability Fund.

The employment services workforce

6.1According to a survey conducted by the National Employment Services Association (NESA), there were around 20,000 staff in the employment services sector in 2022. This included 12,000 frontline staff and 1,500 staff at the service delivery managerial level (such as regional and site managers). The remainder of the staff within the sector deliver corporate services (for example, HR and finance), or occupy customer service, quality assurance, claims processing, and compliance roles. The majority of staff in the sector have experience in related sectors, such as recruitment, education and training, health, youth work, and disability services.[1]

6.2At the time of the survey, around 87percent of frontline staff held a post-secondary qualification. The highest qualification level most commonly held by frontline staff surveyed was a Bachelor Degree (23 per cent of cases), followed by a Certificate IV (22 per cent). The most common fields of study were ‘mixed field programs’ which includes qualifications specific to employment services (24 per cent) and management and commerce (21percent). Staff without qualifications tended to be older and more likely to have experience in customer service and recruitment.[2]

6.3According to the NESA survey, the average age of frontline staff was 39 years 2022. Approximately 80 per cent of the frontline service delivery workforce was female at the time of the survey.[3] In addition, women made up the majority (70 per cent) of the service management workforce.[4]

6.4Union membership amongst the frontline staff is low, reported at 3 per cent in 2016.[5]

6.5Some stakeholders expressed concern that there has been a de-professionalisation of the sector. For example, Miss Mary Hill, a former employee of the Commonwealth Employment Service (CES), raised concern that skills and qualifications of frontline staff have diminished since the CES ceased operating.[6] Associate Professor Siobhan O’Sullivan similarly noted that when employment services were first outsourced, case managers often held degrees in social work or other relevant fields. Many of these former case managers have left the sector and have not been replaced with staff who hold equivalent qualifications.[7] Jobs Australia noted that the workforce has become younger, less experienced, and less qualified. Moreover, lower levels of training are now required to deliver intensive case management.[8] TheGetting Welfare to Work Research Team provided similar evidence, noting that the proportion of staff with a degree fell from just under 40 per cent in 1998 to less than 20 per cent in 2012.[9]

6.6Australia’s situation and approach after more than two decades of full marketisation contrasts markedly with other nations studied where there is a much greater focus on professional staff qualifications, training, and career development. For example, in Sweden there are contractual requirements for employability professionals to have university education and qualifications,[10] while in the Netherlands the Labour Expert—whose role includes counselling and support for jobseekers—is considered a specialist profession with its own professional body and certification procedures (see Chapter 3).[11]

Frontline staff turnover

6.7According to NESA’s 2022 survey, 45percent of staff in the employment services sector have been in the sector for under two years. Less than 40percent of staff have been in the industry for over fiveyears. 46percent of staff also report working with more than one employer, with 57percent of this cohort indicating that they had worked for three or more employers. High rates of mobility were often explained by the end of contracts: providers exiting a region and frontline staff being taken on by continuing or new entrants.[12]

6.8Several stakeholders reflected on the impact of contract turnover on the movement of staff within and out of the sector. For example:

  • APM Employment Services (APM) noted that in addition to contributing to mobility between providers, contract turnover results in staff exiting the sector;[13] and
  • the Department of Employment and Workplace Relations (DEWR) highlighted the findings of a survey of jobactive site managers, which showed that more than a third of those who resigned from their position left the sector.[14]
    1. NESA observed that contract turnover has a very significant impact on the morale of frontline staff, stating:

We saw the largest exodus from this sector that we've ever seen post the commissioning. They didn't just move between each other. Skills and long-term people left. The common thing we heard is, 'If I can do my job really well, achieve a five-star rating and meet all the objectives that are asked of me, and I still lose my job, it doesn't make sense.' Security is also about maintaining the sorts of talent, skills and re-professionalisation that the committee has talked about wanting to achieve.[15]

6.10The Getting Welfare to Work Research Team noted that annual average turnover of staff in the sector (over 40percent) is more than 2.5 times the national average.[16]

6.11High staff turnover can have negative impacts on jobseekers, who typically require stability and continuity of services to build the rapport necessary for effective support.[17] This was reflected in testimony by current and former participants, who told the Committee about their experiences with a near constant turnover of staff in the sector and a consequent need to retell their story to multiple case managers.[18] One participant said that they were obliged to engage with five different consultants over the course of one year. The participant stated it was tiring to repeat their personal story, career goals, and aspirations to multiple staff.[19]

6.12Discussions during the Committee’s European delegation confirmed that high levels of staff turnover are a concern in many employment service systems. For example, in Denmark high turnover was identified as having a discernible negative impact on the placement of clients in work, with stakeholders indicating that continuity was a key factor in effective caseworker-client relationships.

6.13Jobs Australia rated staff retention as the most serious issue for the sector,[20] while NESA highlighted the need for the government to develop a comprehensive plan to attract and retain frontline staff.[21]

6.14Stakeholders emphasised that recognition, appropriate pay and conditions, and opportunities for professional development are critical to attracting and retaining a qualified workforce, and key to a system which delivers high-quality support to participants.[22] These issues are discussed in more detail below.

Administration and lack of autonomy

6.15High levels of administrative burden, coupled with a lack of autonomy, are significant contributors to staff turnover in the sector. Stakeholders noted that frontline staff spend up to 60 per cent of their time on administration (including compliance related duties) under Workforce Australia, stating that that this situation is materially worse than the situation that existed in previous systems.[23] By comparison, frontline staff in the UK employment services sector spend 40 to 50 per cent of their time on administration, while in Sweden administration accounts for 20 to 30per cent of staff time.[24]

6.16One of the unavoidable issues arising when outsourcing services in quasi-markets are the significant overheads arising from contract administration, compliance, and the impact of IT systems.[25] This and similar issues were discussed and observed in other international systems during the Committee’s European delegation. Other countries reported similar frustrations and impacts on staff productivity, autonomy, performance, and retention when marketisation or contracts with emphasis on employment outcomes were implemented. Not every stakeholder with whom the Committee engaged indicated this was a reason not to utilise contestability in service delivery. However, there was consensus that these issues are real and need to be considered in deciding on the best mix of services and commissioning arrangements and in redesigning the architecture of the employment services system.

6.17MAX Solutions (MAX) stated that staff often enter the sector with the belief that they will be helping participants build their capacity and secure employment, but spend most of their time on administrative work.[26] The Australian Unemployed Workers’ Union (AUWU) similarly indicated that the differences in expectations of the sector and the reality of frontline service delivery, coupled with poor pay and conditions, may cause workers to search for more fulfilling roles elsewhere—including in other employment service programs:

My last caseworker … was [initially] one of the worst caseworkers I have ever experienced. He just had no sympathy whatsoever. [Later] … I went for an appointment and he had left. He had got his head around the system. He did not say anything to me, but you could tell he was very disappointed with what he was doing. He said the pay was terrible, and I only found out recently that he had actually moved into more social support roles because he discovered that, as he was working in the [Disability Employment Services] DES, he was getting much more satisfaction from helping people get on to [Disability Support Pension] DSP and things of that nature.[27]

6.18This was echoed by several other stakeholders, who raised concern that time spent on administration would otherwise be spent building relationships with jobseekers and employers and on organising and delivering support.[28]

6.19The Committee also heard that there has been a gradual disempowerment of and loss of autonomy for frontline staff.[29] This has persisted under several iterations of the employment services system, with frontline staff under previous contracts reporting that they were not empowered to support flexibility or innovation in service delivery.[30] Several stakeholders highlighted that this lack of autonomy contributes to common perceptions of employment services as being inflexible and highly transactional.[31]

6.20The Getting Welfare to Work Research Team highlighted surveys undertaken since 2008, which consistently found that staff believe that the IT system dictates how they do their job.In one survey undertaken in 2016 over 60percent of respondents indicated that they use standard tools and checklists, with 42 per cent reporting that those processes were ‘quite’ or ‘very’ influential in determining assistance delivered to jobseekers. Less than 30 per cent of frontline staff provided similar responses to surveys conducted in 1998.[32]

6.21Stakeholders argued that limited autonomy and high administrative burden creates challenges in attracting and retaining a skilled workforce.[33] Associate Professor O’Sullivan said that these concerns also impact the type of staff who are recruited by providers, noting that providers often focus on recruiting staff who can operate computerised systems and populate dropdown boxes.[34]

6.22Other stakeholders similarly informed the Committee that providers are specifically hiring additional staff and creating new roles specifically focused on administration.[35]

6.23The philosophical and practical dilemma of acting as both helper and compliance officer was also identified as another barrier to the retention of frontline staff.[36] This issue is covered in more detail in Chapter 14, in the context of mutual obligations and compliance arrangements.

High and challenging caseloads

6.24Stakeholders observed that a discrete yet related issue impacting staff retention is high staff caseloads, noting that a lower participant to staff ratio would reduce the level of staff turnover in the sector. However, stakeholders also emphasised that lowering this ratio will require additional investment in employment services.[37]

6.25Stakeholders told the Committee that high caseloads impact the servicing that can be provided to jobseekers, noting that staff have less time to link jobseekers with other supports or to contact employers about potential jobs.[38] Moreover, higher caseloads mean appointments for individual jobseekers are short and often of limited value.[39] The Australian Services Union (ASU) noted that larger caseloads have the following distinct impacts:

  • poor quality support and limited employment outcomes;
  • adverse health and safety impacts associated with unreasonable workloads; and
  • lower job quality for staff, leading to high turnover.[40]
    1. The Getting Welfare to Work Research Team noted that a recent survey found that the ratio of frontline staff to participants increased from 1:100 in 2008 to 1:114 in 2012, and to 1:148 in 2016.[41]
    2. Workforce Australia aimed to lower the ratio of staff to participants to 1:100 or less.[42] DEWR also noted that providers in the New Employment Services Trial (NEST) had difficulty keeping staff to jobseeker ratios below 1:100.[43] Providers with which the Committee engaged during site visits similarly explained that it is difficult to achieve lower caseloads ratios under current funding arrangements.
    3. DEWR advised that the majority of providers committed to ratios of 80:1 or below in their tender responses and that compliance against these commitments is assessed as part of contract management processes,[44] but did not provide actual data as to whether those commitments are being met. The ASU indicated that the ratio has remained higher than 1:100 under the current employment services system for some frontline staff.[45] Evidence from a 2023 survey of frontline staff found that they had an average caseload of around 90 clients, however, those results were subject to a high standard deviation that shows that some staff have substantially larger caseloads while others have much smaller caseloads.[46]
    4. Stakeholders also called for lower staff to participant ratios in specialist and intensive services. For example, the National Youth Commission Australia (NYCA) advocated for a contracted maximum ration of 1:40 in specialist youth services, such as Transition to Work (TtW).[47]
    5. Stakeholders commonly observed that under Workforce Australia, the percentage of clients with the most severe barriers and behavioural difficulties—including anger management and serious mental health issues—is far higher than under previous employment services programs. Increasing levels of aggression among people on the caseload is one factor impacting staff retention.[48] One provider indicated that at some sites they have needed to engage full-time security staff,[49] while another told the Committee that they have invested in safety measures such as duress alarms and back-to-base security systems, augmented with ongoing de-escalation training.[50] WISE Employment asserted that the obligation on providers to perform the dual role of police and supporter can contribute to poor perceptions of providers and staff, as well as to the escalation of challenging behaviours.[51]
    6. During site visits, many current and former frontline staff informally reported that these factors, when combined with the administrative burden and poor pay and conditions (discussed below) are creating an unvirtuous cycle of ‘burn and churn’. Discussion with those staff and relevant workforce data indicate that there are not enough experienced staff with the skills and qualifications (including in particular social work or psychology qualifications) to work with clients with high needs and challenging behaviours. Staff are also not afforded the necessary time to build relationships with clients or to deliver supports over a sustained period.

Pay and conditions

6.32Frontline staff in employment services have relatively low pay, with annual salaries in the range of $51,000-$65,000.[52] Evidence from the ASU similarly indicated that frontline staff are paid around $30 per hour.[53] Accordingly, frontline staff are paid between 54 and 69 per cent of the Australian annual salary of $94,000.[54] By comparison, frontline staff in the UK earn between 70and 99percent of the gross median salary.[55]

6.33Stakeholders asserted that remuneration in the employment services sector must be competitive with comparable roles in other service industries.[56] Evidence indicated that other sectors have arrangements in place to ensure a competitive wage. For example, the ASU noted that community services workers are subject to an equal remuneration order that guarantees regular wage increases.[57]

6.34The ASU also expressed concern at high levels of mobility within the sector which impact on the ability of staff to accrue entitlements such as long-service leave, sick leave, and annual leave. The ASU indicated that portability of entitlements would assist to address recruitment and retention issues and support workers to build careers in the sector. The ASU noted that other sectors with transient workforces—such as nursing, allied health, public servants, and teachers—have portable leave entitlements.[58]

6.35Portable leave entitlements exist in other sectors and jurisdictions. For example, four states have introduced portable long service leave in the contract cleaning industry.[59] A 2016 Senate inquiry also identified several benefits of a national long service leave system, including improved retention and an increased supply of skilled workers.[60]

6.36Stakeholders indicated that challenges exist in attracting and retaining staff compounded by the fact that employment services are not viewed as an employer of choice—especially for young people finishing their education.[61] IntoWork stated:

It's not a sector that when you are at uni or you are at school you go, 'I want to be an employment consultant.'[62]

Qualifications, skills, and professional development

6.37Stakeholders expressed concern that many frontline staff lack the skills, training and qualifications necessary to effectively support jobseekers, and particularly those in provider-led services who experience complex disadvantage.[63] One submitter noted that staff are qualified in administration and management, but not equipped to deliver person-centred services.[64] Another indicated that their consultant lacked adequate knowledge of the service system and demonstrated almost complete disregard for the submitter’s financial, emotional, mental and physical needs.[65]

6.38Other stakeholders emphasised that frontline staff must be able to deliver culturally appropriate assistance to a diverse group of jobseekers.[66] For example, Multicultural Australia stated:

Our hope is that the future design of the employment service program is informed by and responsive to the diverse needs of communities, including First Nations communities, as well as culturally and linguistically diverse communities. We also seek a gender-responsive program design and a strong focus on supporting youth job seekers. We think it is fundamentally important that employment service providers and their workforce have the requisite capabilities in key areas, such as disability awareness, mental health, drug and alcohol awareness, cultural sensitivity, and domestic and family violence, to ensure that the services provided are individualised and fit for purpose.[67]

6.39This was reflected in evidence from providers, who also highlighted the importance of a workforce that reflects the communities it serves.[68] DEWR similarly noted that research indicates a positive impact on employment outcomes where consultants and jobseekers have similar characteristics.[69]

6.40The Disability Royal Commission identified several training gaps for Disability Employment Services (DES) staff, and advocated for resources that would improve disability awareness, cultural competence, knowledge of human rights, reasonable adjustments, employer engagement, and service guidelines and procedures.[70]

6.41Evidence highlighted attributes that are key to effective service delivery, indicating providers should have a mix of these attributes within their frontline workforces. Key attributes included:

  • lived experience and highly developed listening skills;[71]
  • an understanding of social work, training, and psychology;[72]
  • community engagement, partnership, and cross-organisational skills;[73] and
  • the capacity to understand specific challenges faced by, and needs of, different groups of jobseekers at different life stages.[74]
    1. DEWR indicated that frontline staff should possess a capacity to understand barriers to employment; knowledge of appropriate interventions and local services; the ability to develop tailored plans to address barriers; and problem-solving skills.[75]
    2. Stakeholders also told the Committee that in Australia—and globally—there is an increasing focus on jobready participants being managed via online or hybrid services delivered by the public sector. A result of this is that frontline employment consultants increasingly concentrate on providing intensive support for participants with multiple barriers to employment.[76]
    3. The Institute of Employability Professionals (IEP) emphasised that the relationship between frontline staff and clients are paramount to the delivery of effective human-centred services. The IEP asserted that services must be adaptive to the jobseeker and their circumstances and must be built on mutual trust and respect.[77]
    4. In discussion with the Committee, the IEP identified the most important quality required of an effective case manager is empathy, while the most important factor in a successful relationship and employment outcome is trust between the client and their case manager. Without trust, the client is likely to be unwilling or unable to be vulnerable with their case manager, to disclose important personal information, and to seek help to address their barriers. Moreover, without trust the case manager will be less able to support the client progress towards their goals. Furthermore, the skills needed for advisers to gain trust, and to then direct motivation and action towards employment choices, are well understood. Effective programs provide circumstances in which these skills can be deployed flexibly, responding to clients' personal needs and situations. This advice was echoed consistently throughout discussions with international jurisdictions and with experienced Australian providers and staff.
    5. Research conducted in 2007 in the UK made similar findings, asserting that one of the strongest conclusions to be drawn from evaluations of employment services is that personal advisors (similar to case managers in Australia) are critical to the success of interventions. Evidence suggested that the greater the flexibility given to these advisors, the better they are able to fulfil their role and to meet the specific needs of the individual client.[78]

Mandatory qualifications and competencies for frontline staff

6.47DEWR decided not to mandate qualifications for the employment services sector on the basis that this could:

  • lock out experienced individuals with lived experience but no formal qualifications;
  • impact the sector’s ability to deliver services in regional labour markets; and
  • have flow-on consequences on other community service providers, given the existing skills shortages for workers with the relevant qualifications.[79]
    1. DEWR indicated that minimum standards are implicit in commitments that providers make in their tender responses as to the skills and competencies of their staff. Many successful tenderers indicated that they would work towards or expect frontline staff to hold a Certificate IV in a relevant field.[80]
    2. Consistent with DEWR’s observations regarding the tender process, some providers indicated that they enrol staff without relevant qualifications in Certificate IV programs and are working towards ensuring staff hold professional qualifications. Providers also claimed that it can be difficult to secure the relevant qualification in employment services given a dearth of Registered Training Organisations (RTOs) equipped to deliver relevant Certificate IV courses.[81]
    3. By contrast, Dr David O’Halloran observed that that there was almost no detail in tenders as to the expected competence or expertise of casework staff,[82] and the Community and Public Sector Union (CPSU) pointed to job advertisements for frontline staff where the only requirement was a driver licence.[83]
    4. DEWR advised that there is some mandatory training for frontline staff including mandatory training on claims processing and compliance action, as well as fraud and privacy training. DEWR also noted that the Quality Assurance Framework (QAF) and associated accreditation processes assess whether providers employ staff with the relevant skills and abilities; have training and development in place and ensure that staff possess necessary cultural competencies.[84]
    5. Notwithstanding mandatory training for staff and that many providers are implementing their own qualification and competency standards, stakeholders advocated for mandating minimum qualifications and competencies for the sector.[85] For example, the Career Development Association of Australia (CDAA) stated:

[M]inimum qualifications and experience should be mandated for all Workforce Australia staff directly assisting clients with complex needs. This should apply to all aspects of support - whether in career guidance, job search, mental health, physical health, relationships, financial matters, or other specialist fields.[86]

6.53Stakeholders highlighted that comparable federally-funded programs such as the Humanitarian Settlement Program managed by the Department of Home Affairs have contractual requirements mandating minimum qualifications.[87]

6.54A variety of approaches are taken in other countries. For example, the UK does not mandate minimum qualifications or competencies, while Sweden has strict qualification requirements in place—at least for staff delivering employment services on behalf of the government.[88]

6.55During its European delegation, the Committee similarly heard that whether specific skills or qualifications are mandated varies between countries. For example, tenders for the Belgian public employment services initially required staff to hold a Bachelor degree or to have lived experience. Belgium is now asking for specification in tenders as to how staff are provided with training and support to deliver a quality service. France decided not to implement qualification requirements, preferring instead to ensure job counsellors receive training to reinforce their skills. The Netherlands places significant importance to their Labour Experts, which are recognised as a specialist profession with its own professional body, certification requirements and governing bodies, as well as having in place a national centre for knowledge in labour expertise. Training to become a Labour Expert involves a one-year specialist course for individuals and a Bachelor-level qualification.[89]

6.56Stakeholders also emphasised the importance of a mix of skills that may need to be addressed through training, including the ability to work with people with complex or unique needs (for example, older people, single parents, people with disability, and First Nations peoples)[90] and an understanding of the programs and training courses in and external to the employment services sector.[91] For example, the former Age Discrimination Commissioner recommended training sessions to reduce incidences of ageism being a factor in their approach taken to older clients with whom they work, with the assumption that they will not be able to get a job.[92]

6.57Evidence indicated that this skills mix is not always supported under the Workforce Australia contract. For example, Yilabara Solutions told the Committee that its staff were increasingly disillusioned with Workforce Australia as the contract does not support delivery of assistance in a culturally sensitive way.[93]

6.58Stakeholders also asserted that lived experience is critical to quality service delivery and called for measures to balance qualifications with lived experience to support a diverse workforce.[94] For example, Professor Green et al stated:

If the government mandates minimum qualifications for paid staff positions, there should also be an ‘equivalence’ framework in which ‘lived, practiced experience of the employment services system and life skills’… coupled with on-the-job training, permit recognition of prior learning.[95]

6.59Some stakeholders (largely providers) did not support mandatory qualifications for frontline staff. They raised concerns about existing labour market shortages and challenges in attracting people to the sector and indicated that imposing minimum qualification requirements may exacerbate those challenges.[96] These views were echoed by the IEP.[97]

6.60Stakeholders also told the Committee that there are a variety of different roles in the sector, each with unique qualifications, competencies, and skillsets. Accordingly, it would be difficult, if not impossible, to mandate a single qualification for all frontline staff.[98]

6.61Additional concerns with mandatory qualifications included proliferation of low-quality training to meet new minimum standards, the potential for such a requirement to miss important core skills which may not be captured by academic qualifications, and the potential for additional financial burden and limits on providers’ ability to innovate.[99]

Ongoing capability development

6.62Stakeholders told the Committee that frontline staff should be given opportunities for ongoing professional development. In this respect several providers highlighted the importance of ongoing professional development to the capability of frontline staff, stating that investment in staff capability results in improved staff retention, greater expertise, and improved service quality.[100]

6.63A consistent theme was that government needs to be more actively involved in the ongoing capability development of the entire workforce across the public, not-for-profit and private sectors. For example, Dr Harrison asserted that government must establish systems to ‘raise the bar’ for providers by:

  • establishing minimum qualifications for frontline staff;
  • regulating the salary of frontline workers, and making it commensurate with their qualification level and with comparable roles in other service industries; and
  • providing quality professional development opportunities for frontline staff and establish mechanisms that make it attractive for providers to encourage their staff to pursue their professional development using these tools.[101]
    1. NESA noted that prior to the establishment of Job Network, government was more active in capability development, and that government involvement has reduced over iterations of the employment services system.[102]
    2. The former Employment Service Regulatory Authority (ESRA) delivered a Practice Improvement Programme focused on areas it could contribute to improving case management. This focused on workforce development, minimum standards for case management and the measurement, establishment and sharing of best practice.[103]
    3. The Brotherhood of St Laurence (BSL) stated that ongoing professional development comes with additional costs, and that those costs would need to be incorporated into pricing, funding, and commissioning arrangements. This may include:
  • dedicated funding for professional development in the program budget; and
  • competitive salaries and manageable caseloads for frontline staff.[104]

Committee comment

6.67Frontline staff are the backbone of a quality employment service. The Committee, through its program of site visits, met many exceptional frontline staff dedicated to helping jobseekers however they can. However, it is clear that these dedicated staff are often held back from delivering high-quality support to jobseekers by constraints in the system which are beyond their control. Virtually every aspect of the system appears to work against the ability of dedicated staff to focus on the delivering of quality services to their clients. It is also clear from desktop research and from reports by current and former participants and staff that there are staff in the system who are manifestly unqualified or unsuitable to work jobseekers—particularly those with higher needs and/or who are experiencing disadvantage.

6.68The Committee understands that reluctance in previous contracts to hold the system and providers to account and re-professionalise, well after the de-skilling of the sector’s workforce was clearly apparent, was in reality driven primarily by a concern or reluctance to invest the funding which would be necessary.

6.69In its interim report on ParentsNext, the Committee raised concerns about ongoing de-professionalisation of the employment services sector. These concerns have been reinforced, if not heightened, by the additional evidence the Committee has received.

6.70There is also an urgent need to address factors contributing to staff turnover. Any sector subject to annual turnover rates of 40percent cannot deliver a quality service to those it is notionally designed to support. This level of turnover is patently ridiculous and cannot be allowed to continue.

6.71The Committee was deeply concerned to hear that up to 60percent of staff time is spent on administration, and that many providers are recruiting additional staff to focus largely if not entirely on administrative and compliance matters rather than using resources to improve the quality of services they deliver to clients. That decisions are increasingly based on the outputs of a computer, as opposed to staff applying professional judgement and discretion, is also a very significant concern. Measures to address administrative burden and lack of autonomy are included in other chapters. The Committee is strongly of the view that the suffocating level of redtape and lack of autonomy in the sector must be addressed in the near term.

6.72In addition, too many frontline staff are still burdened with large caseloads with high proportions of very disadvantaged clients, making their task impossible. Given this reality, a re-examination of caseloads is critical if an effective service is to be achieved. The Committee in subsequent chapters will outline its views as to an increased role of government in fostering learning and identifying and sharing best practice to achieve quality. These efforts should include analysis and proper evaluation in relation to optimal caseloads and ratios for frontline staff to various cohorts of clients. This should be accompanied by appropriate policy settings and additional investment. Of course, the other reforms proposed in this report would also fundamentally change the system and free up time and resources. It would also be expected that some people would not be referred to contracted providers but would be supported by other organisations or services and/or enabled to engage in activities which are more appropriate to their needs and circumstances.

6.73The employment services sector also competes with other sectors for a limited pool of staff. Evidence received indicates that, relative to those sectors, employment services offer: lower pay; less job security; and worrying risks of harm associated with dealing with clients with challenging behaviours. The increased need for staff to support clients with challenging behaviours is in part a design outcome as people closer to the labour market are now largely in digital services, in part the reality that there are some clients who simply should not be in employment services, and in part a consequence of the very strong labour market which makes it easier to help people with fewer barriers to secure work more quickly.

6.74Cost of living pressures, combined with the unacceptably high rates of payment suspensions and the compliance responsibilities of providers, heap significant pressure on frontline staff.

6.75There is also a pressing need to address the broader pay and conditions of frontline staff. The Committee does not consider that current rates of pay for the sector are commensurate with the often-demanding nature of frontline service delivery in this sector or the real value that frontline staff should generate for their clients. Rates of pay in the Australian employment services sector are low even when compared to employment services in other marketised models with no minimum professional qualification standards such as the UK.

6.76Other sectors under the Social, Community, Home Care and Disability Services Industry Award are receiving increases to remuneration. The Fair Work Commission has recently determined a 15per cent wage increase for staff in the aged care sector, while the Disability Royal Commission recommended the disability support workforce receive equal remuneration for work of equal or comparable value. Given staff turnover rates of 40percent and other issues outlined above, the Committee considers a wage increase should be considered for employment services staff.

6.77The Committee was also concerned to hear that, as a result of high staff churn and contract turnover, many in the sector have been unable to accrue entitlements such as long service leave. The Committee accepts that this creates additional challenges in attracting and retaining staff, as core entitlements that should naturally accrue from long-term service often fail to materialise. The Committee considers that a portable entitlements scheme is needed to support workers to build a career in the sector, and notes that other sectors—including those with which the employment services system may be competing for staff—offer portable entitlements.

Recommendation 14

6.78The Committee recommends that the Australian Government take account of the findings of this report in relation to pay and conditions, support appropriate short-term actions to help stabilise the workforce, and link medium-and longer-term arrangements for pay and conditions in a rebuilt system focused on quality to a coherent plan to re-professionalise the sector’s workforce. Such a plan should also include measures to ensure that the ratio of clients to staff is sufficiently low that staff are able to deliver effective, person-centred services to clients.

6.79Staff qualifications and capability is also an issue in relation to which the Committee made preliminary observations and recommendations in its interim report. Concerns in relation to this issue persist and are heightened by the further evidence received during the inquiry. While noting evidence that providers often implement measures to develop their own staff, the Committee is unconvinced that this piecemeal approach is sufficient to uplift the skills of staff across the sector to the necessary standard to support an increasingly diverse and vulnerable cohort of clients.

6.80The Committee acknowledges DEWR’s evidence that minimum qualification requirements are implicit in the commitments that providers make in their tenders. However, the Committee is unconvinced that these commitments are being delivered in practice or that the government’s ‘hands-off’ approach is effective. In addition, it is clear that market forces alone are not sufficient to ensure that clients have access to support delivered by appropriately qualified staff. It is also telling that the mandatory training provided by DEWR relates to fraud and compliance, and not to quality service delivery or working with disadvantaged people or employers.

6.81In its interim report, the Committee recommended minimum competency standards for frontline staff and a typology of staff capabilities for providers. Evidence received throughout the rest of the inquiry has only served to reinforce this conclusion. The Committee considers that there is no alternative but to implement a framework to re-professionalise the sector over time, including a typology of minimum standards for staff skills, qualifications, and competencies. The development and implementation of the standards should be led by the new Employment Services Quality Commission, working with the sector and informed by rigorous policy research.

6.82In developing qualifications and competency standards, consideration must be given to the value of lived experience and core foundational skills such as empathy, communicating, and the ability to build trust. Lived experience and core skills are critical to effective service delivery and must not be lost from the sector. Standards must also have regard to the realities of the labour market.

6.83The Committee considers that providers should be enabled to hire people with lived experience and demonstrated core skills. However, this should be subject to the person completing mandatory minimum training, and to their commitment to completing additional training and qualifications to build their capability over the short to medium term. Ultimately, minimum competency and a typology of skills should set desirable qualifications and a mix of skills that are expected in a provider’s workforce. The measures should provide that it is acceptable for a certain proportion of staff not to have achieved minimum qualifications at any point in time, provided there is ongoing investment in staff development and that a minimum percentage of the provider’s workforce possesses appropriate qualifications.

6.84Cultural competency and the ability to recognise and address unconscious bias is critical to the delivery of high-quality service. Employment services staff must be competent to support all cohorts including First Nations peoples, people with disability, older people, people from culturally and linguistically diverse backgrounds, women, single parents, and ex-offenders. This should include introducing proven training programs such as those highlighted by the former Age Discrimination Commissioner. The Disability Royal Commission recommendation that resources be developed to support the upskilling of DES staff would equally apply to Workforce Australia. Noting issues raised by jobseekers as to a lack of privacy at appointments with providers (detailed in Chapter 11), the Committee considers that there would also be merit in implementing additional privacy training and reasonable privacy requirements in future contracts.

6.85The quality and effectiveness of service delivery will also be driven by ongoing professional development, supported by active government involvement and robust measures to identify and disseminate best practice. Measures to improve cooperation and information-sharing are captured in Chapters 7 and 8.

6.86Minimum qualification and competency standards, the typology of staff capabilities, and measures to support ongoing capability development should apply equally to service providers, staff in the new Employment Services Australia (ESA), and any public sector staff who deliver direct assistance to clients. This is consistent with the Committee’s strong view that the DEWR (via the DSCC) is in fact a provider of services to jobseekers in Workforce Australia Online and now in a number of thin markets and must be appropriately resourced and skilled to perform its role.

6.87The Committee also sees value in establishing an Employment Services Capability Fund to support ongoing capability development. Funding could be tied to the overall appropriation for employment services. For example, 0.02 per cent of the annual budget of $1.7 billion for employment services (that is, $3.4 million) could be allocated to the Fund. Funding could be ring-fenced and used only for training and staff development activities. Allocations from the Fund could be administered by the Employment Services Quality Commission, as part of their role in workforce standards and sector professional development.

Recommendation 15

6.88The Committee recommends that the Australian Government work with the sector and key stakeholders to codesign a professional framework of skills, capabilities, and qualifications for frontline staff consistent with this report. Development of the framework should be led by the new Employment Services Quality Commission. The framework should include:

  • a typology of skills, qualifications, and competencies that frontline staff must hold;
  • measures to ensure that frontline staff possess the necessary competencies to support a diverse cohort of clients, including First Nations peoples, older people, and people with disability;
  • measures to ensure that required competencies can be adjusted to account for regional variations and labour market contexts; and
  • measures to enable service partners to recruit and retain staff who do not possess formal qualifications where appropriate, including measures to enable service partners to:
  • recruit staff with lived experience in or experience delivering pre-employment or employment services; and
  • support staff to gain formal qualifications post-commencement.

Recommendation 16

6.89The Committee recommends that the Australian Government work with the sector and key stakeholders to co-design a new approach to support ongoing capability development of frontline staff in the employment services system. This should include establishing an Employment Services Capability Fund.

Footnotes

[1]National Employment Services Association (NESA), Submission 260 (Attachment 1), pages 8, 12.

[2]NESA, Submission 260 (Attachment 1), pages 19–20.

[3]NESA, Submission 260 (Attachment 1), p. 14.

[4]NESA, Submission 260 (Attachment 1), p. 21.

[5]Associate Professor Siobhan O’Sullivan, private capacity, Committee Hansard, 14March2023, p. 3.

[6]Miss Mary Hill, Submission 181, p. [1].

[7]Associate Professor O’Sullivan, Committee Hansard, 14March2023, p. 13.

[8]Jobs Australia, Submission 185, p. 12.

[9]Getting Welfare to Work Research Team, Submission 191, p. 12.

[10]Institute of Employability Professionals (IEP), Submission 291, p. [5].

[11]Organisation for Economic Co-operation and Development (OECD) (2023) Contracted employment services in the Netherlands: Study visit report, p. 8, www.oecd.org/els/emp/Project21SE03StudyVisitReport.pdf, viewed 20 November2023.

[12]NESA, Submission 260 (Attachment 1), p. 11.

[13]Mrs Karen Rainbow, CEO, APM Employment Services (APM), Committee Hansard, 14March2023, p. 57. See also MatchWorks, Submission263, p. 10.

[14]Department of Employment and Workplace Relations (DEWR), Submission 254, pages 85–86.

[15]Ms Annette Gill, Principal Policy Adviser, NESA, Committee Hansard, 20 September 2023, p. 21.

[16]Getting Welfare to Work Research Team, Submission 191, p. 13.

[17]See, for example, Youth Projects, Submission 141, p.12; Sarina Russo Job Access (SRJA), Submission 145, p. 18; Getting Welfare to Work Research Team, Submission 191. p.13.

[18]See, for example, Ms Aeryn Brown, Submission 114, p. [1]; Name Withheld, Submission 115, p. [1]; Name Withheld, Submission 116, p. 2; Name Withheld, Submission 230, p. [2]; Melissa Fisher, Submission 235, p.[1]. This was also identified as an issue by the Australian Services Union (ASU), Submission 205, p.[7].

[19]Lewis, private capacity, Committee Hansard, 19 September 2023, p. 30.

[20]Jobs Australia, Submission 185, pages 12, 14.

[21]Ms Sally Sinclair, CEO, NESA, Committee Hansard, 14March2023, p. 36.

[22]See, for example, Dr Colin Harrison, Submission 152, p. 9; ASU, Submission 205, pages [6, 8–9]; Refugee Council of Australia (RCOA), Submission 226, p.9.

[23]See, for example, Getting Welfare to Work Research Team, Submission 191, p. 12; Dr Michael McGann, private capacity, Committee Hansard, 14March2023, p. 3; Ms Sinclair, NESA, Committee Hansard, 14March2023, p. 36; Mr Bryan McCormack, Senior Advisor—Government and Policy, Jobs Australia, Committee Hansard, 20 September 2023, p. 16.

[24]IEP, Submission 291, p. [7].

[25]OECD (2022), Paying for results: Contracting out employment services through outcome-based payment schemes in OECD countries, Social, Employment and Migration Working Papers No. 267, p. 7, https://doi.org/10.1787/c6392a59-en, viewed 20 November 2023. See also K Breidahl and F Larsen (2020), Marketization of employment services – Historical insights and inherent dilemmas, Aalborg University, p. 5. Breidhal and Larsen observed that by the end of Job Service Australia in 2015, the annual costs for administration was 21per cent of total expenditure on employment services.

[26]See, for example, MAX Solutions (MAX), Submission 146, p. 22. See also SRJA, Submission 145, p. 19; WDEA Works, Submission 168, p. 5; MrsKathleen Newcombe, Group CEO, SRJA, Committee Hansard, 6June2023, p.14.

[27]Mr Jeremy Heywood, President, Australian Unemployed Workers' Union (AUWU), Committee Hansard, 19September 2023, p. 5.

[28]See, for example, Brotherhood of St Laurence (BSL), Submission 249, p. 60; Associate Professor O’Sullivan, Committee Hansard, 14March2023, p. 13; Mrs Newcombe, SRJA, Committee Hansard, 6June2023, p. 13.

[29]See, for example, BSL, Centre for Policy Development (CPD) and University of Melbourne (UniMelb), Submission 256, p. 32; NESA, Submission 260, p. 90.

[30]DEWR, Submission 254, p. 82.

[31]See, for example, South East Community Links (SECL), Submission 38, p. 8; Name Withheld, Submission 137, p. [2]; RCOA, Submission 226, p. 4; Professor Mark Considine, private capacity, Committee Hansard, 14March2023, p.10; Ms Emma Dawson, Executive Director, Per Capita, Committee Hansard, 14March2023, p. 29.

[32]Getting Welfare to Work Research Team, Submission 191, p. 13.

[33]See, for example, MAX, Submission 146, p. 43; Jobs Australia, Submission 185, pages 21–22; Getting Welfare to Work Research Team, Submission 191, p. 14; NESA, Submission 260, p. 90.

[34]Associate Professor O’Sullivan, Committee Hansard, 14March2023, pages 13–14.

[35]See, for example, CoAct, Submission 151, pages 22–23; Ms Gill, NESA, Committee Hansard, 14March2023, p. 37.

[36]See, for example, Campbell Page, Submission 150, p. [8]; NESA, Submission 260, p. 90.

[37]See, for example, MAX, Submission 146, p. 21; National Youth Commission Australia (NYCA), Submission 166, p. [11]; ASU, Submission 205, p.[4]; BSL, Submission 249, p.75.

[38]See, for example, NYCA, Submission 166, p. [9]; Getting Welfare to Work Research Team, Submission 191, p. 12; RCOA, Submission 226, p. 9; Workways Australia Ltd (Workways), Submission 239, p.21.

[39]See, for example, Name Withheld, Submission 109, p. [1]; Name Withheld, Submission142, p. [2]; NYCA, Submission 166, p. [9].

[40]Mr Angus McFarland, Branch Secretary—NSW and ACT, ASU, Committee Hansard, 16June2023, p.13.

[41]Getting Welfare to Work Research Team, Submission 191, p. 11.

[42]DEWR, Submission 254, pages 72–73.

[43]DEWR, Submission 254, p. 73.

[44]DEWR, Submission 256.8, p. [3].

[45]See Mr McFarland, ASU, Committee Hansard, 16June2023, p.13.

[46]Getting Welfare to Work Research Team (2023), The New Digital Governance of Welfare-to-Work: Industry Report on Survey of Workforce Australia Frontline Staff, p. 14, https://arts.unimelb.edu.au/__data/ assets/pdf_file/0011/4783781/2023_Australian-Industry-Report_FINAL_16Oct2023.pdf, viewed 9November2023.

[47]NYCA, Submission 166, p. [10].

[48]See, for example, ASU, Submission 205, pages [7–8]; Mrs Nicole Mattsson, National Services Design and Integration Leader, IntoWork, Committee Hansard, 14March2023, p. 62; Mrs Rainbow, APM, Committee Hansard, 14March2023, p. 63. The management of jobseekers who display challenging behaviours is also considered in Chapter 5.

[49]The BUSY Group Ltd (BUSY), Submission 227, p. 2.

[50]Salvation Army Employment Plus (SAEP), Submission 199, p. 62.

[51]WISE Employment, Submission 169, p. 21.

[52]See, for example, Dr Harrison, Submission 152, p. 11; Nirrumbuk Aboriginal Corporation (NAC), Submission180, p.[3]; BUSY, Submission 227, p.5; Mr McFarland, ASU, Committee Hansard, 16June2023, p. 11.

[53]Mr McFarland, ASU, Committee Hansard, 16June2023, p. 10, in quoting feedback from one of their members. An hourly wage rate would equate to an annual salary of around $62,000.

[54]Australian Bureau of Statistics (ABS), Average Weekly Earnings, Australia–November 2022, www.abs.gov.au/statistics/labour/earnings-and-working-conditions/average-weekly-earnings-australia/nov-2022, viewed 22August2023.

[55]IEP, Submission 291, p. [6].

[56]See, for example, Dr Harrison, Submission 152, p. 11; Greater South East Melbourne (GSEM), Submission155, p. [4]; Mr McCormack, Jobs Australia, Committee Hansard, 20 September 2023, p. 16.

[57]Mr McFarland, ASU, Committee Hansard, 16June2023, p. 11. The Fair Work Commission also recently determined a 15percent wage increase for staff in the aged care sector. See Fair Work Commission, Work value case aged care industry decision, www.fwc.gov.au/hearings-decisions/major-cases/work-value-case-aged-care-industry/decisions-statements-work-value, viewed 22August2023.

[58]ASU, Submission 205, pages [3, 10].

[59]Fair Work Commission, Long Service Leave Advice, www.fairwork.gov.au/leave/long-service-leave#portable-long-service-leave, viewed 22August2023.

[60]Senate Education and Employment References Committee (2016), The feasibility of, and options for, creating a national long service standard, and the portability of long service and other entitlements, pages 5, 20, 37.

[61]See, for example, ASU, Submission 205, p. [3-4]; atWork, Submission 210, p.14.

[62]Mrs Mattsson, IntoWork, Committee Hansard, 14March2023, p. 59.

[63]See, for example, Name Withheld, Submission 92, p. 13; DrDavid O'Halloran, Submission 108, pages[2,5,7]; NFAW, Submission 135, p. [3]; Youth Projects, Submission 141, p. 12; Name Withheld, Submission 161, p. 3; NYCA, Submission 166, p. [10]; Name Withheld, Submission 229, p. [5]; Mr Jeremy Poxon, Officer, AUWU, Committee Hansard, 19 September 2023, p. 5.

[64]Name Withheld, Submission 92, p. 13.

[65]Mr Mark Goodrick, Submission 144, p. 2.

[66]See, for example, National Indigenous Australian Agency (NIAA), Submission 176, p. 5; Ethnic Communities Council of Queensland (ECCQ), Submission 206, p. 5; RCOA, Submission 226, p. 8; BSL, CPD and UniMelb, Submission 256, p. 33.

[67]Ms Christine Castley, CEO, Multicultural Australia, Committee Hansard, 6 June 2023, p. 2.

[68]See, for example, MAX, Submission 146, p. 22; WISE Employment, Submission 169, p. 22; Asuria People Services (Asuria), Submission 246, p. 15; Ms Naome Rusera, Executive Officer, ECCQ, Committee Hansard, 6June2023, p. 3.

[69]DEWR, Submission 254, p. 83.

[70]Disability Royal Commission (2023), Final ReportVolume 7: Inclusive education, employment and housing—Part B, p. 418.

[71]Ms Emma Morris, Executive Manager—Client Support Services, Women’s Health and Family Services (WHFS), Committee Hansard, 1February 2023, p. 7.

[72]Ms Felicite Black, CEO, WHFS, Committee Hansard, 1February 2023, p. 7.

[73]IEP, Submission 291, p. [3].

[74]BSL, CPD and UniMelb, Submission 256, p. 10.

[75]DEWR, Submission 254, p. 82.

[76]See, for example, IEP, Submission 291, p. [5]; Mr Con Kittos, Executive Chairman, Asuria, Committee Hansard, 26May 2023, p. 20.

[77]IEP, Submission 291, p. [4].

[78]UKGovernment Department of Work and Pensions (2007), What works for whom? A review of evidence and meta-analysis, pages 3–4, https://webarchive.nationalarchives.gov.uk/ukgwa/20130314011325/http://research.dwp.gov.uk/asd/asd5/rports2007-2008/rrep407.pdf, viewed 20 November 2022.

[79]DEWR, Submission 254, pages 84–85.

[80]DEWR, Submission 254, p. 84; Ms Robyn Shannon, First Assistant Secretary—Workforce Australia Provider Support, DEWR, Committee Hansard, 3November2022, p. 17.

[81]See, for example, SSI, Submission 193, p. 16; Workskil, Submission 196, pages 31–32; Asuria, Submission246, p. 19.

[82]Dr O’Halloran, Submission 108, p. [5].

[83]Mr Michael Tull, Assistant National Secretary, Community and Public Sector Union (CPSU), Committee Hansard, 16June2023, p. 11.

[84]DEWR, Submission 254, pages 83–84. See also DEWR, Workforce Australia Services Deed of Standing Offer 2022 – 2028, clauses 56.3, 97.1, 157.

[85]See, for example, Dr O’Halloran, Submission 108, p. [8]; Dr Colin Harrison, Submission 152, p. 11; ProfessorJeff Borland, Submission 171, p. 12; SSI, Submission 193, p. 4; Australian Council of Social Service (ACOSS), Submission 203, p. 32; Antipoverty Centre, Submission 276, p. [15].

[86]Career Development Association of Australia (CDAA), Submission 101, p. 1.

[87]See, for example, SSI, Submission 193, p. 16; ACOSS, Submission 203, p. 32.

[88]IEP, Submission 291, pages [2, 5].

[89]OECD (2023), Contracted employment services in the Netherlands: Study visit report, p. 8.

[90]See, for example, Name Withheld, Submission 130, p. [1]; NFAW, Submission 135, p. [3]; Youth Projects, Submission 141, p. 12; NIAA, Submission 176, p. 5; ECCQ, Submission 206, p. 5; Mrs Muriel Bamblett, Committee Member, Coalition of Peaks, Committee Hansard, 17May2023, p.23; Mrs Christine Castley, CEO, Multicultural Australia, Committee Hansard, 6June2023, p. 2.

[91]See, for example, Mrs Rainbow, APM, Committee Hansard, 14March2023, p. 54; Mr Kieran Kearney, CEO, Workways Australia (Workways), Committee Hansard, 6June2023, p. 18; Dr O'Halloran, Advocacy and Research Officer, AUWU, Committee Hansard, 19 September 2023, p. 9.

[92]The Hon Dr Kay Patterson AO, private capacity, Committee Hansard, 19 September 2023, p. 38.

[93]Mr Matthew Clarke, CEO, Yilabara Solutions, Committee Hansard, 26May2023, p.39.

[94]See, for example, CDAA, Submission 101, p. 3; WISE Employment, Submission 169, p. 22; atWork, Submission 210, p. 14; Jobs Statewide, Submission 272, p. 9; IEP, Submission291, p. [4]; Mr Mark Glasson, CEO, Anglicare WA, Committee Hansard, 1February2023, p. 2.

[95]Professor Leila Green, Dr Kylie Stevenson, Dr Kelly Jaunzems, Ms Claire Hanlon and Mr Arthur Hanlon (Professor Green et al), Submission 120, p. [12].

[96]See, for example, CVGT Employment (CVGT), Submission 106, p. 26; Dr Harrison, Submission 152, p.11; IntoWork Australia (IntoWork), Submission 156, pages 5–6; Jobs Statewide, Submission 272, p. 9.

[97]IEP, Submission 291, pages [2, 4].

[98]See, for example, SAEP, Submission 199, p. 66; NESA, Submission 260, p. 90; Mrs Newland, Jobfind, Committee Hansard, 14March2023, p. 59.

[99]See, for example, CoAct, Submission 151, pages 22–23; IEP, Submission 291, pages [4–5].

[100]See, for example, CVGT, Submission 106, p. 26; CoAct, Submission 151, pages 22–23; IntoWork, Submission 156, pages 5–6; SSI, Submission 193, pages 4, 16; IEP, Submission 291, p. [4].

[101]Dr Harrison, Submission 152, p. 11.

[102]Ms Sinclair, NESA, Committee Hansard, 14March2023, p. 41.

[103]Employment Services Regulatory Authority (ESRA) (1996), Employment Services Regulatory Authority 1995–96 Annual Report, pages 50–51.

[104]BSL, Submission 249, p. 75.