3. Program design

Eligibility, assessment and referrals

3.1Parents are required to participate in ParentsNext if they fall within a class specified by legislative instrument under the Social Security Act 1991 (Social Security Act). Eligibility criteria for the program are outlined in Chapter 1.

3.2Eligible individuals are identified based on data in Services Australia’s system. Where a person is identified as eligible, Services Australia sends them a letter advising them that they will be a participant in ParentsNext. Following the letter, Services Australia sends the person a text message advising them that Services Australia will contact them by phone. This call is always from an unknown number. Thereafter, a staff member from Services Australia’s outsourced contact centre calls to conduct a phone interview. The interview lasts approximately 10 minutes and is focused on confirming the person’s eligibility and discussing next steps.

3.3The interview with Services Australia involves using the Job Seeker Classification Instrument (JSCI) to identify the participant’s needs, including whether the participant is ready for employment and key barriers to social and economic participation. Unlike in mainstream employment services such as Workforce Australia, the JSCI is not used to determine eligibility for ParentsNext.

3.4Where Services Australia’s contracted call centre confirms the person’s eligibility, the person will be referred to a service provider for an initial appointment.[1] During that first appointment, only then is the participant given detailed information about the program. Over the following month, the participant will discuss their goals with the provider and develop a Participation Plan which sets out a pathway towards meeting those goals. The Plan must include at least one activity that the parent agrees to undertake.[2]

Initial contact by Services Australia

3.5The Committee heard repeatedly and consistently—from every provider and from numerous participants—that communication from Services Australia at the point at which a person is referred to ParentsNext is poor. Little information is provided about the program and its potential benefits, and the reasons for the person being referred to the program are not well explained. This adds considerably to the stress and anxiety already experienced by many parents.[3] For example, one participant, who is a survivor of domestic violence, recounted her initial experiences of the program:

I will never forget [when]... I received a phone call from ParentsNext that left me shaken, much like leaving my ex did. I was told several times that it wasn't compulsory to answer the questions, but, if I didn't answer the questions, there would be consequences and my payments would be suspended. By the end of that phone call, I was on my bedroom floor crying, and all I could think of when I finished that phone call was, 'I've left one abusive relationship and one abuser, just to be given another one, and one I can't leave from anymore.'[4]

3.6Consistent with this testimony, other stakeholders indicated that initial communication about ParentsNext has a heavy focus on the compulsory elements of the program, and on compliance and enforcement. For example, CVGT Employment stated that participants referred to its services:

[F]requently come with a confused or misunderstood position on the ParentsNext program, often with a sense of “punishment” that they have to participate or “lose their support payments”.[5]

3.7SYC Ltd (SYC) noted that inaccurate information about mutual obligations from sources such as Services Australia, the media, and other participants, can make it very difficult for participants to know what to expect from ParentsNext. Accordingly, SYC called for updated training for Services Australia staff about the information they give to participants, more accurate and welcoming language on the letters Services Australia sends to parents, and a general change of language within ParentsNext to better align with the pre-employment focus of the program. SYC stated that this would reduce the apprehension many parents feel when they are referred.[6]

3.8The National Employment Services Association (NESA) similarly highlighted issues in relation to how ParentsNext is promoted and perceived, stating that information about the program is often incomplete and ‘clinical’. NESA also indicated that there may be too great a focus on employment during initial engagement with Services Australia, stating:

NESA’s ParentsNext providers continue to be concerned many parents believe that they have been referred to a work first employment service, which in some cases leads to unnecessary anxiety and an initial reluctance to engage.[7]

3.9During its program of site visits, the Committee spoke to many participants and frontline staff who confirmed that it was common for participants to arrive at their initial appointment with a provider with incomplete information about ParentsNext. Participants and providers also told the Committee that the initial interview with Services Australia follows a pre-determined format, and that Services Australia staff are unable to respond to questions about the program or to engage with participants’ needs where this would deviate from their ‘script’.[8]

3.10Participants and providers also confirmed that there is a perception among many participants that they have been referred to ParentsNext due to some wrongdoing, and that they will have to search for work (and rely on the goodwill of their provider) to receive income support. This perception can create challenges in terms of building trust between participant and provider, particularly in the early stages of engagement.

3.11Submitters and witnesses also raised concerns about the assessment undertaken during the initial interview with Services Australia. For example, Economic Justice Australia (EJA) stated that the interview is ‘heavy handed’ and does not support parents to disclose information about their personal circumstances, including experiences of family violence.[9] EJA also expressed concern that while this initial interview may be a suitable point for a person to be referred to a social worker, often such referrals do not occur due to the person not being enabled to disclose key information or to a lack of social workers on staff:

[C]lients, particularly clients in vulnerable situations, have found the ParentsNext interview intimidating and an invasion of privacy. This is especially so where the purpose and relevance of the JSCI questions has not been made clear. Clients who have experienced domestic violence, for example, may be unable to disclose or discuss their experience of domestic violence on the phone with a stranger or cannot broach the issue as the perpetrator is with them.[10]

3.12Services Australia confirmed that while the initial interview with people who have been identified as eligible for ParentsNext is usually made by phone, participants also have the option to request a face‑to‑face interview.[11] Services Australia also stated that staff in its contact centres receive specialist training to ensure they understand the operation of ParentsNext, can determine whether the program is appropriate for a participant, and can identify circumstances (including family violence) which may require referral to a social worker.[12]

3.13The Department of Employment and Workplace Relations (DEWR) and Services Australia both expressed general support for more face-to-face contact with parents at the initial stages of their engagement with ParentsNext, including referrals to social workers where appropriate. However, both emphasised that there may be significant resourcing implications associated with this proposal.[13] For example, Services Australia stated:

[W]e could do anything that has been described here based on a revised funding model, but at the moment the agency has a certain number of social workers and the[y]... support a range of programs... not just ParentsNext. Certainly, social workers could play an increased role. That would reflect an increase in the funding model to support that, however.[14]

Application of current eligibility criteria

3.14Several submitters and witnesses expressed concern that current eligibility criteria for ParentsNext are not adapted to the individual circumstances of parents, and that the application of those criteria may lead to parents being inappropriately referred to the program, including where they have little to no capacity to benefit.[15]

3.15The Council of Single Mothers and their Children (CSMC) stated that the application of current eligibility criteria results in over‑servicing and over‑reach, noting that many women in the program are taking time off to raise their children, and do not need support gaining employment as they have a job to return to or a ‘solid’ work history.[16]

3.16Workways Australia Ltd (Workways) stated that it often receives ineligible referrals to ParentsNext from Services Australia (for example, parents without a current JSCI assessment, parents with children under six months of age, and parents who are currently working or studying). Workways (like other providers) typically commences these participants and then sends them back to Services Australia to have their referral amended. Workways expressed concern that while this is effective in terms of meeting performance targets, it is not the best action for the participant and often results in a negative perception of the program which damages the relationship between the participant and the provider.[17]

3.17Workways encouraged further training for Services Australia employees, to ensure referrals are accurate and are the right service for the participant. Workways also requested that providers not be required to commence ineligible referrals, but instead be enabled to flag such referrals in DEWR’s employment services system.[18]

3.18NESA estimated that 10 per cent of those referred to ParentsNext do not meet the criteria for an exemption yet receive little benefit from the program. Examples of this cohort include parents with strong social or community networks, high levels of educational attainment, or extensive work histories. NESA recommended that further assessment criteria be introduced to help ensure the program offers benefit to participants, with the flexibility to make participation voluntary where appropriate.[19]

3.19The Australian Council of Social Service (ACOSS) noted that their analysis of the 2021 ParentsNext caseload indicated that 40 per cent of participants would not benefit from the program, as they already had TAFE or university education.[20]

3.20EJA noted that where people with higher levels of education or current employment are referred to ParentsNext, they may have difficulty engaging because the program is not adapted to their needs:

I... have a colleague who has [a PhD], who also was in ParentsNext and was having difficulty trying to suggest that maybe things such as story time might not have been as beneficial as other things to the ParentsNext provider and had trouble with that. And then the... provider basically said that they didn't really have anything that was relevant for her. So she was kind of left in limbo.[21]

3.21yourtown noted that current eligibility criteria are not appropriately adapted to the circumstances of large families, including families with three or more children who are close in age. yourtown stated that it could be reasonably expected that parents in such families will have difficulty engaging with ParentsNext.[22]

3.22Some submitters noted that foster, kinship, and grandparent carers may step in to take over primary care of a child, temporarily or on a long-term basis. This cohort typically does not need support with education or employment, or parenting support such as playgroups. However, current eligibility criteria may result in members of this cohort being referred to ParentsNext.[23]

Eligibility for voluntary participation

3.23Some stakeholders expressed concern that the eligibility criteria for voluntary participation in ParentsNext may exclude individuals who would benefit from the program and called for the criteria to be expanded to capture additional cohorts.

3.24For example, Workways stated that some parents who are not eligible for Parenting Payment should be considered for voluntary eligibility for ParentsNext. Workways observed that parents whose partner earns above the relevant income threshold, and parents on Non-Protected Special Category visas, are at risk of becoming long-term unemployed and would benefit from support with education and employment. Workways provided a case study to illustrate the gap in current eligibility criteria:

[The participant] was originally eligible for ParentsNext... [She] attended her appointments consistently and began to build rapport with her Employability Coach, who was able to speak with her in her own language... [She] felt that the appointments were a good outlet and... was referred to local workshops to assist with her confidence and work towards employment, to support her goal of financial independence, and to ultimately leave the situation she was in... Unfortunately, [the participant] has had to exit ParentsNext, as [her] partner now earns too much money, and she is no longer eligible... [T]his has negatively impacted [the participant] in reaching her goals for safety for herself and her children.[24]

3.25Wesley Mission stated that parents on Carers Payment may benefit from ParentsNext, and drew attention to testimony from a Senior ParentsNext consultant:

I have had several parents contact me over the years who have a child with severe needs, but still wanted support for education and employment. But as they are on a carer's payment, they were not eligible. This leaves an already isolated cohort of parents even more isolated and vulnerable while dealing with the care and needs of their children. They are not eligible to register with other job services, leaving a huge gap that ParentsNext could fill, and opening up opportunities for increased servicing.[25]

3.26Metro Assist stated that as a result of an apparent lack of knowledge about ParentsNext, Services Australia’s frontline staff often refer parents who are eligible for the program to employment services. Metro Assist expressed concern that there may be many more vulnerable parents who are turned away from ParentsNext despite needing support.[26]

Compulsory participation

3.27As outlined in Chapter 1, participation in ParentsNext—including meeting mutual obligation requirements such as attending interviews, agreeing to a Participation Plan, and undertaking certain activities—is compulsory for those who fall within the class specified by legislative instrument under the Social Security Act. Where a participant fails to meet their mutual obligation requirements, they may have their income support payments suspended, reduced, or cancelled.

3.28This issue of compulsory participation is discussed below. The discussion covers the matter of compulsion generally, compulsory activities, and the cohorts who are compelled to participate. Consequences for failing to comply with participation requirements are discussed separately in Chapter 4.

Arguments against compulsory participation

3.29A significant number of stakeholders held the strong view that all participation should be voluntary, arguing that compulsory participation is too onerous for and can cause significant harm to already vulnerable parents, devalues work already being done by parents and carers (including the task of raising children), and does not contribute to improved economic equality or workforce participation for women.[27]

3.30The National Council of Single Mothers and their Children (NCSMC) outlined some of the negative experiences of participants around compulsory participation, stating:

Women talk about being forced to attend weekly, fortnightly, monthly [appointments], and they do that because, if they don't comply, they lose their payments. Basic work, health and safety is not taken into consideration.

[W]hen I talk about coercive control, when I explain that to the broader community, I talk about using coercive control to harm, to punish, to frighten; to provide basic needs, such as food; monitoring your time, your activity, throughout the day; and taking control over every aspect of your life, such as where you can go, whom you can see, what activities your children can or cannot undertake. I find this definition consistent with the ParentsNext program.[28]

3.31Dr Eve Vincent noted that several participants had spoken to her about the anxiety associated with mutual obligation requirements, stating that these participants do not feel supported to achieve their goals but rather feel as if they are under constant surveillance and supervision. Participants also reported difficulties with onerous reporting requirements. For example, one participant stated:

The reporting I cannot stand. I have three different alarms in my phone to remind me to report and sometimes you get interrupted and then you just... you totally forget and then you’re not paid. Your rent’s due, all my credit card repayments are due, my loan’s due.[29]

3.32The experience recounted in Dr Vincent’s submission was broadly consistent with experiences shared by participants during site visits. While participants generally reported positive experiences of ParentsNext, activity reporting and the threat of payment suspensions were often highlighted as negative aspects of the program. Many participants reported setting multiple alarms to ensure they reported on time and having experienced stress and anxiety around reporting deadlines. These experiences were reflected in written evidence. For example, one participant stated:

The one thing that has made things hard is if you miss an appointment your payment will get cut off... [B]eing a single parent it is hard to get appointments at times and it makes it harder when payments get cut off because of that.[30]

3.33Associate Professor Elise Klein noted that many compulsory activities are superfluous, largely because participants are already undertaking those or similar activities to improve their prospects. In this respect, Associated Professor Klein stated:

[Some] women were already studying for degrees when they were put on ParentsNext and their activities given to them by the provider was just to continue doing the study. The interviewees often were aware the provider was paid up to AU$600 to have them part of the program, despite the provider offering no further value or financial support to activities they were already doing themselves.[31]

3.34The Brotherhood of St Laurence (BSL) stated that while there is little connection between compulsory participation and improved education or employment outcomes, there is significant evidence of harms caused by payment suspensions, including creating further barriers to employment.[32]

3.35Dr Janet Ramsey and Dr Katherine Curchin noted that other pre‑employment programs have been successful without compulsory participation or associated financial sanctions. Examples include the Jobs through Education and Training program in Australia and the Making it Work program in Scotland.[33]

3.36Some submitters, including the Australian Human Rights Commission (AHRC), also contended that linking any income support payments to mutual obligations is likely to be incompatible with Australia’s human rights obligations, particularly if there are financial consequences for failing to comply with those requirements.[34]

Arguments for compulsory participation

3.37In contrast to the views set out above, some stakeholders supported compulsory participation as a means of encouraging engagement with the program by parents who would not otherwise have sought help, including parents who are isolated or in situations of coercive control. There was a common and continued concern amongst these stakeholders that removing all participation requirements would see the most vulnerable people miss out on help.

3.38There were also widely divergent views as to the extent to which the program should be compulsory, including which activities should be compulsory and which should be undertaken at the discretion of the participant.[35]

3.39For example, Mission Australia observed that its staff report difficulties in engaging some participants for their first appointment, stating that compulsory attendance creates an opportunity to explain ParentsNext and its benefits. Mission Australia noted that if the program were entirely voluntary there would be a missed opportunity to provide early intervention support to parents and their children.[36]

3.40This was also reflected in evidence from Family and Relationship Services Australia (FRSA), who stated that compulsory participation:

• brings in participants with limited social supports, resources, and knowledge of how to access support services, who would not necessarily have the emotional and mental reserves or the trust in social services to voluntarily enter the program; and
• brings into visibility parents and children at safety risk who have otherwise fallen through the gaps of child and family safety services, which may involve families experiencing or escaping domestic and family violence.[37]
  41. FRSA also expressly recommended ‘de-linking’ ParentsNext from the Targeted Compliance Framework (TCF), and implementing more proportionate, flexible compliance requirements.[38]
  42. OCTEC Limited (OCTEC) observed that compulsory participation is an effective way of ensuring engagement and supporting employment and education outcomes, particularly for vulnerable cohorts. OCTEC stated:

When used positively, as part of an overall engagement strategy, OCTEC has found the compulsory participation requirements to be an important tool for our consultants to connect with parents, and to remain engaged with them, even in circumstances where a participant might otherwise disengage.[39]

3.43The Settlement Council of Australia (SCA) stated that removing compulsory participation would reduce opportunities to engage with migrant and refugee women who otherwise would not engage. SCA noted that there are women in this cohort for whom compulsory engagement has led to a positive outcome.[40]

3.44Metro Assist similarly noted that women from culturally and linguistically divers (CALD) backgrounds are often very socially isolated and may be confined to their households due to cultural and gender norms. According to Metro Assist, the compulsory nature of ParentsNext:

… allows these most vulnerable participants to engage with services and support free of their partner’s interference and objection…to step out of their partners control and to challenge the cultural gendered norms imposed on them.[41]

3.45The value of compulsory participation, particularly for initial appointments, was reflected in statements to the Committee during site visits, including from numerous participants. The Committee heard that these appointments were of particular value for participants experiencing family violence and coercive control. Participants also saw value in compulsory activities, for similar reasons. However, this was not universal, and depended heavily on the quality of the provider and whether the relevant activities were appropriate to the participant’s circumstances.

3.46DEWR highlighted the connection between compulsory participation, improved engagement and better outcomes for participants, stating:

One of the lessons in terms of evidence from those pilots [Helping Young Parents and Supporting Jobless Families] was that the pilot that had both compulsory appointments and compulsory attendance at activities was generally more effective at achieving the education and other goals.[42]

Age of the youngest child

3.47Many stakeholders argued against requiring participation in ParentsNext when a person’s youngest child is nine months of age and called for the minimum age to be increased. Submitters and witnesses asserted that requiring participation when a person’s youngest child reaches ninemonths implies that person should be thinking about returning to work. This is not realistic for many parents.[43]

3.48Views on the most appropriate age of the youngest child were varied and depended on factors such as parenting responsibilities (particularly for single parents and those with higher‑needs children), access to childcare, access to transport, and the costs of participating in the program.[44]

3.49In addition, some evidence indicated that the appropriate age for the youngest child should be a matter for ongoing discussion—for example as part of the co-design process proposed for a replacement service for ParentsNext (see discussion in Chapter 2). For example, Dr Katherine Curchin asserted that it is parents themselves who are best placed to judge when it is the right time to engage with the service.[45]

3.50Several providers advocated for raising the minimum age of the youngest child to 12months, noting that this would better align ParentsNext with the policy and legal frameworks for maternity leave in most jurisdictions.[46]

3.51Other stakeholders asserted that 12 months may still be too early for some parents, noting the importance of parental involvement during the first thousand days of a child’s life. These views were strongly linked to the importance of valuing the work of caring for children.[47] For example, the Centre for Excellence in Child and Family Welfare stated:

Within the first months and years of a child’s life, they form strong, secure attachments with their parent. When parents are forced to undertake compulsory participation requirements, this can take away precious time spent parenting and cause additional stress to parents and children. By enforcing participation requirements on lone parents, the government is sending the message that parenting is not a respected form of labour.[48]

3.52The CSMC stated that if compulsory participation is retained, it would be more appropriate for activity requirements to commence when the participant’s youngest child is three years of age. In this regard, the CSMC noted that this is the age at which many children begin pre‑school.[49]

3.53Across all States and Territories, children are typically able to begin preschool when they are three years old, turning four between 30 April and 31 July of the year when they commence.[50] From 2023, Victoria is also rolling out free kindergarten for children aged three and four years. This will include children who are two years old, provided they turn three in the year they commence. Five to 15 hours of free kindergarten will be available for children aged three years, while 15 hours of free kindergarten will be available to children aged four years.[51]

3.54By contrast to the CSMC, Djerriwarrh Community and Education Services expressed support for requiring compulsory participation when a person’s youngest child is 9months of age, stating that early intervention is ‘essential to ensuring improved social wellbeing outcomes and multigenerational systemic reform to welfare dependency’.[52]

3.55DEWR was unable to point to evidence that expressly supports starting compulsory participation in ParentsNext when a person’s youngest child is nine months of age but indicated that the decision to start compulsory participation at that point was based on interactions with participants and on eligibility criteria relating to age which existed under the previous iteration of the program.[53]

A ‘lighter touch’ approach to compulsory participation

3.56As outlined above, several stakeholders supported some compulsory participation in ParentsNext, but indicated that levels of compulsion in the current program are too high for some participants. Those stakeholders generally supported a ‘lighter touch’ approach to compulsory participation, which would encourage participants to engage with the program without creating undue burden, stress, or anxiety.

3.57A common view was that while attendance at the initial appointment should remain mandatory, the participant should be able to choose whether and to what extent they participate from that point (including whether they attend subsequent appointments and participate in activities).[54]

3.58Other stakeholders suggested that attendance at regular scheduled appointments remain compulsory but that other tasks or activities be undertaken on a voluntary basis. The Committee heard that this approach would broadly reflect the Transition to Work program.[55]

3.59There was also support for participants attending voluntary appointments in addition to mandatory appointments. However, the Committee heard that providers must make clear which appointments are voluntary and which are mandatory, with some evidence put forward of participants being compelled to attend appointments every twoor three weeks.[56]

3.60The Committee’s engagement with participants during site visits indicated that participants are unlikely to experience undue hardship if the frequency of mandatory appointments is (reasonably) increased. The Committee heard that many participants—particularly those who are actively engaged in the program—are in regular contact with their providers, and frequently seek advice from their case managers outside of scheduled appointments. However, it was also clear that while the frequency of appointments could increase, the timing of appointments must be appropriate to the participant’s circumstances.

Granting of exemptions

3.61ParentsNext providers and Services Australia can grant exemptions for parents who are temporarily unable to participate in ParentsNext. Exemptions may be granted for various reasons, including incapacity, personal crisis, caring responsibilities, and domestic and family violence. Exemptions durations will differ according to the grounds on which they are sought and may last up to 52weeks. Where a parent is exempt from ParentsNext, they are not required to sign a Participation Plan, attend appointments with a provider or undertake compulsory activities.[57]

3.62Providers are typically aware that there are broad grounds for exempting parents from ParentsNext. For example, YFS Ltd observed that:

Grounds for exemption from the program are broad, enabling participants to opt out of ParentsNext for a period if their circumstances make it unreasonable for them to meet requirements... Providers have the discretion to extend exemption periods. At any given time about 20 per cent of parents referred to ParentsNext are on an exemption.[58]

3.63The Committee heard that despite there being a range of grounds for exemptions, some participants have difficulty securing an exemption despite meeting relevant criteria. Moreover, current exemption periods may not be sufficient in some cases.

3.64At present, a participant who has experienced domestic violence in the previous 26 weeks must be granted an exemption for 16 weeks. During this time the participant may engage with their provider on a voluntary basis and is not subject to compliance activity. For other participants who have experienced domestic violence, a 16-week exemption can be granted on a case-by-case basis. Further 16-week exemptions can also be granted on a case-by-case basis to any participant who has experienced domestic violence.[59]

3.65The Committee heard that current exemptions for domestic and family violence are insufficient for many participants. In this regard, submitters and witnesses noted that impacts of domestic violence can persist for much longer than 16 weeks, particularly when matters such as engagement with the justice system are considered. For example, Domestic Violence NSW stated:

[D]omestic and family violence can have very long impacts, particularly if people are involved in the Family Court, for example. People can participate in those hearings for up to or five years or even longer.

I think that it's [also] variable how long the crisis phase [of escaping domestic violence] can take... [T]hree months would be a very conservative amount of time... six months would be more usual, noting that crisis accommodation—for example, refuges, et cetera—generally have a three-month period and then there's a time where people, if they choose that pathway or they're able to access it, would be trained to transition into another type of housing.[60]

3.66Submitters and witnesses called for exemptions for domestic and family violence to be extended to 12 months, or6 months at a minimum.[61] Some submitters also called for exemptions for participants who have experienced domestic violence to be automatic in all cases.[62]

3.67Exemptions for participants experiencing domestic violence was also raised during the Committee’s site visits, with participants who spoke to the Committee calling for exemptions made on this ground to be extended and to be automatically granted in most, if not all, cases. Notably, participants who expressed concern about exemptions otherwise expressed strong support for ParentsNext.

3.68The Committee also heard that the current payment framework for providers may act as a disincentive to granting exemptions. For example, Per Capita noted that under the current framework a provider receives $600 for every six months that a parent remains on their caseload. However, that six-month period does not include time during which a participant is exempt from the program.[63]

Incentives to participate

3.69A key theme was that there would be value in using incentives to encourage engagement with ParentsNext—particularly if participation requirements are to be reduced or removed from the program altogether. Incentives might be used in addition to or as an alternative to sanctions.[64]

3.70Several possible incentives were suggested. For example, Sarina Russo Job Access stated:

As an alternative to a compliance regime based on financial penalties (suspensions or cancellations), the government could consider incentives for participation. These could take the form of:

• small incentive payment, directly to the participant, in return for participation such as attending the first appointment;
• additional subsidies for services such as childcare;
• discounts on student fees (or subsidies for student loans).[65]
  71. Several submitters suggested free or heavily subsidised childcare as a possible incentive to participation in ParentsNext, noting that childcare remains a key barrier to workforce participation for many parents.[66]
  72. NESA observed that there would be value in supporting and linking participants with crisis support services, including supports for mental health concerns and for drug and alcohol dependency. Other suggestions included assistance with the costs of housing, education, and training, and a bonus payment.[67]
  73. Other suggestions for incentives in the evidence before the Committee included working credit arrangementsand grocery or fuel vouchers.[68]

The Participation Plan

3.74The Participation Plan is an agreement between the participant and their provider which sets out the participant’s education and employment goals and provides a roadmap for how those goals are to be achieved. All participants must agree to a Participation Plan and complete and report on mandatory activities set out in the Plan as a condition of receiving income support.[69]

3.75The ParentsNext guideline sets out requirements for providers for the Participation Plan. Key requirements include:

• providers must prepare the Participation Plan in consultation with the participant over the 20 business days following the initial appointment with the provider;
• activities are only included in a Participation Plan with the agreement of the participant, however, the Plan must include at least one compulsory activity that is designed to assist the participant to meet their education or employment goals;
• providers must explain to the participant that they have 10 business days ‘think time’ to consider their Participation Plan before signing; and
• the Participation Plan must be reviewed at each quarterly appointment.[70]
  76. There was consensus that the Participation Plan should remain a core component of ParentsNext and that the objectives of the Plan are appropriate.[71] For example, DrAnn Nevile stated:

[I]f the ParentsNext program is to achieve its policy objectives to help participants develop work and study goals, the major tool or policy instrument is the [P]articipation [P]lan. For the participation plan to be effective, it really has to be a meaningful collaboration between the participants and the service providers.[72]

3.77However, concerns were raised in relation to how the Participation Plan is used by providers and participants. These are discussed below.

Participation Plans in the context of a compulsory program

3.78Some submitters and witnesses noted that there are unique challenges in adapting a Participation Plan (which is intended as a roadmap to achieving individual goals) to a compulsory program such as ParentsNext. For example, Dr Curchin noted that participants may agree to a Plan to avoid having payments suspended, rather than out of a genuine belief that the Plan reflects their goals and sets out an appropriate pathway to achieving them.[73]

3.79Experiences shared by participants indicated that Dr Curchin’s concerns may be borne out in many cases. For example, Ms Ella Buckland, a parent advocate and former participant, stated:

I've advocated for at least 300 women to varying degrees—women who have been forced, two days postpartum... to sit in a ParentsNext office, with someone demanding that they sign a privacy waiver and a participation plan, otherwise their payments [will be cut off]. There are women in varying stages of education who are being bullied by their providers, women who are so frightened that they can't sleep, women who are really worried about the payment suspension and the obligations the program demands.[74]

3.80This issue reflects broader concern with the power imbalance between providers and participants in a compulsory program. For example, Dr Nevile observed that:

[D]eveloping an effective participation plan takes time and a relationship of trust will probably need to be developed. This is unlikely to happen. That is because service providers are in a position of power over the participants, as they are the ones who decide, if a participant doesn't meet a participation requirement, whether the reason for not doing so is reasonable or unreasonable.[75]

Tailoring of the Participation Plan to the individual participant

3.81The ParentsNext guidelines provide that Participation Plans must be tailored to suit the unique circumstances and goals of each participant. Providers must consider various matters when developing the Plan, including barriers to social and economic participation, capacity to engage with the program, and individual circumstances (including gender, language, experience of domestic and family violence, and access to transport and childcare).[76]

3.82In practice, Participation Plans must also be sufficiently flexible to account for the unpredictability of parenting of young children, with providers ready to adjust requirements to account for changes to participants’ circumstances.[77]

3.83Evidence from providers indicated that many ensure Participation Plans are tailored to the goals and circumstances of participants.[78] However, whether the Plan is properly tailored to the participant continues to depend on staff who understand and are empathetic to the participants’ circumstances and—critically—who are connected with local services and supports.[79]

3.84The Committee also heard that in some cases the Participation Plan has become little more than a compliance tool. Evidence on this issue was linked to broader concerns about the compulsory nature of ParentsNext. For example, Goodstart Early Learning stated:

ParentsNext does not give participants a sense of agency; rather it obliges them to participate in a program and compels them to nominate activities they may not consider to be helpful or relevant to them to be put into a document referred to as a 'plan' but that is more akin to a contract. Then, it penalises participants for not meeting the activities in the 'plan' by suspending their payments, pushing them further into the disadvantage and vulnerability the program seeks to overcome.[80]

3.85The Committee also heard that the lack of tailoring in some Participation Plans may be a consequence of a lack of funding. For example, Dr Nevile stated:

If service providers are not funded to do more than just have a tick-and-flick initial meeting, [P]articipation [P]lans will not be individually appropriate for each participant. Probably they will just get a set of things: 'This is what you can choose from, and just hurry up and choose.'[81]

3.86Compounding this issue is the requirement for Participation Plans to be developed and agreed within 20 business days of the participant’s initial appointment with their provider (30 days if the participant makes use of their ‘think time’). Evidence indicated that this timeframe would not allow the provider to get to know the participant and identify their education and employment goals.[82]

3.87During the Committee’s site visits, several providers and frontline staff indicated that funding can be a barrier to ensuring that Participation Plans are tailored to the needs of participants and capture all their needs. This was of particular relevance to First Nations participants, who may benefit from having measures to support family and community engagement in their Plans, as well as more activities which support progress towards individual goals.

Appropriateness of the activities in the Participation Plan

3.88Another concern associated with the Participation Plan was the inclusion of activities which are not appropriate for the participant, and which are unlikely to enable the participant to reach their education and employment goals.

3.89For example, the Committee heard that activities associated with parenting and social inclusion (such as playgroups or swimming lessons) are considered unnecessary or superfluous.[83] In addition, evidence indicated that making such activities compulsory contributes to a perception that participants are incapable of caring for their children or participating in society without government intervention.[84] In this regard, the National Women’s Safety Alliance stated:

ParentsNext plans developed by service providers... mandate attendance at playgroups or children’s swim classes, which single mothers had been undertaking prior to being assigned to the program. For many this created the spectre of surveillance over routine parenting activities that were now perceived by authorities as being ‘jobready’ activities, draining the enjoyment a parent may otherwise have derived from participating in activities with their children.[85]

3.90Participants who shared their experiences with the Committee echoed this view. They indicated that while they derive some benefits from social activities such as playgroups, these benefits—and participants’ enjoyment—can be undermined by requirements to report attendance.

3.91The Committee also heard that the link between activities in Participation Plans and participants’ education and employment goals is not always clear. For example, EJA observed that some participants view activities in their plans as mere ‘busy work’.[86]

3.92Volunteering Australia stated that while volunteering is a key pathway to employment and enhances social connectedness, volunteering activities should not be included as ‘compulsory activities’ in the Participation Plan. Participants should be enabled to engage in volunteering as part of their pathway to education or employment.[87]

Funding and investment

3.93As of the 2022–23 Budget, the total estimated expenditure on ParentsNext over the forward estimates is projected to be $484million.[88] The following is a detailed breakdown of anticipated expenditure.

• Around 86 per cent ($414.9 million) is spent on service fees. A provider is paid a service fee of $626.40 every 6 months for each participant on their caseload.
• Around 13 per cent ($63.3 million) is spent on the Participation Fund. When a participant commences in the program, their provider receives a $600 notional credit to the Fund. This may be spent on resources to support the participant to achieve their education and employment goals.
• Around one per cent ($5.5 million) is spent on outcome payments. Providers receive outcome payments of $313.20 for each employment outcome (12 weeks of work) or education outcome (completing a Certificate III or higher qualification, Skills for Education and Employment or Year 12) achieved by the participant.
• The remainder ($0.3 million) is spent on evaluation.[89]
  94. Funding for ParentsNext is lower than for mainstream employment services such as Workforce Australia. Estimates suggest that funding per ParentsNext participant is around 10 per cent of that for Workforce Australia.[90]
  95. Some providers called for additional investment in ParentsNext, noting substantial increases to their caseloads since the introduction of the new program contracts. For example, Mission Australia stated:

The number of participants in our ParentsNext services has skyrocketed since the introduction of the new contract in July 2021. At the same time, program funding is low compared with other employment programs, which limits our ability to provide tailored, meaningful support.[91]

3.96The BSL similarly emphasised the importance of investment in the program, noting that to deliver high-quality services providers need funding to employ suitably qualified staff and to ensure that staff caseloads do not become unmanageable.[92]

3.97The importance of sufficient investment in ParentsNext was also highlighted during the Committee’s site visits, with several providers noting that more funding would allow them to employ the numbers of staff necessary to respond to a growing caseload. This was particularly important for providers with higher numbers of First Nations participants, given the importance of tailored support and family and community involvement to supporting most First Nations peoples.

Outcome payments

3.98Some submitters and witnesses questioned whether outcome payments are an appropriate means of compensating providers and encouraging them to deliver quality supports to participants. The key concern was that outcome payments are unduly focused on education and employment, and do not recognise the progress made by participants toward non-vocational goals.

3.99Noting these and related concerns, Mission Australia recommended changes to the program outcomes to better acknowledge the circumstances of participants and their journey to becoming job ready, as well as making payments to providers for activities related to community engagement and collaboration.[93]

3.100Metro Assist stated that current outcome fees do not reflect the time and work that providers and employment consultants invest in ensuring that participants achieve employment and education outcomes. Metro Assist noted that while it would make more financial sense for providers to simply keep participants on their caseload and collect service fees, providers and employment consultants spend a huge amount of time and effort working with participants and acting as their mentors.[94]

3.101atWork Australia similarly indicated that there would be value in introducing progress fees, noting that such fees—and additional investment in ParentsNext more generally—would further support increased workforce participation.[95]

3.102NESA similarly observed that ParentsNext should take a ‘holistic’ view of outcomes, and that this should be reflected in the program’s design and implementation, stating:

ParentsNext... is a pre-employment program... when we're talking about outcomes, we're talking about not necessarily just employment or education but a whole lot of human capital development increasing those networks.[96]

3.103Providers to whom the Committee spoke during its program of site visits also supported a payment structure with a greater focus on participants’ progress toward outcomes (as well as achievement of outcomes), and on incentives for providers which take account of non-vocational barriers to social and economic participation.

Participation Fund

3.104The Participation Fund is a flexible pool of funds that providers may use to help participants prepare for employment. As funds are pooled, a provider may spend more than $600 on a participant and may use funds on activities which support all participants on the provider’s caseload.[97]

3.105Where a provider purchases resources or supports for a participant, they may claim reimbursement from DEWR. A provider will obtain reimbursement where the purchase meets the Participation Fund principles, is not prohibited, and satisfies any specific Participation Fund category requirements.[98]

3.106DEWR advised that while it has encouraged providers to make greater use of the Participation Fund, as of 30 September 2022 only around 25 per cent of all credits had been spent.[99]

3.107Notwithstanding this underspend, some submitters and witnesses indicated that the current amount of credit per participant in the Participation Fund may be insufficient and called for the credit amount to be increased.[100] For example, NESA stated:

[Our members are] reporting that the decision by the government of the day... to effectively halve the fund when they merged the streams for those who require the most intensive support has meant that there are constraints on the amount of funding there is now and that there are also cost-of-living impacts which are having knock-on effects across a range of services and supports.[101]

3.108The CSMC similarly noted that credits to the Participation Fund are too low for many of the courses that mothers may wish to study while supporting a young child.[102]

3.109Low awareness of the Participation Fund among participants was also raised as a concern, with some submitters noting that this may be a reason for the Fund being underutilised.[103]

3.110The Committee also heard that participants and providers have difficulty accessing the funding due to the rules which govern its use. This included concern that certain resources and activities are not funded, and that reimbursements are not processed in a timely manner.[104] For example, ACOSS observed that:

[W]hile some providers allow parents to make practical purchases like computers to help with study, there are too many limitations on the kind of study that can be supported, such as requirements to enrol only in JobTrainer eligible courses.[105]

3.111Accordingly, submitters and witnesses called for increased flexibility in how the Participation Fund can be used—particularly so that providers have the resources to design and implement innovative programs to support participants.[106] For example, Women’s Health and Family Services (WHFS) stated:

[T]he evidence that we need to ask a client to provide is really challenging at times—documents, things that need to be scanned that we need to send back. So if we did have some of the participation fund sectioned off for something like driving lessons, which we know is used very often, we could have a far simpler process with some set providers that the participants could go to and it could be a very simple process, but that becomes quite onerous on us as a provider and on the participants having to constantly provide that evidence.[107]

3.112Other submitters asserted that the Fund should be made more flexible around access to crisis support, including domestic violence and mental health services, and—in certain cases—rental assistance to prevent eviction. Others suggested that the Fund could be used to meet childcare costs.[108]

3.113However, the Committee heard that increased flexibility in how the Fund may be used may result in an increase in providers using the Fund on in-house services which may introduce perverse incentives and not represent the best value to the participant.[109]

3.114The Committee also heard that additional credits to the Participation Fund could be used as an incentive to participation in ParentsNext—particularly if those credits were directed towards training and education.[110] For example, NESA agreed that there would be value in incentivising participation by covering additional costs associated with education, such as textbooks and course fees.[111]

Supporting participants to obtain driver licences

3.115Several submitters and witnesses noted that whether a person has a driver licence and access to a vehicle is a key determinant of their engagement in education or employment. This is particularly the case in regional, rural, and remote areas which frequently lack reliable public transport networks.[112]

3.116The lack of public transport options, and long wait lists for driver education, are key challenges in the majority of Employment Regions—particularly those which cover large or geographically isolated areas.[113]

3.117Current ParentsNext Guidelines expressly contemplate using the Participation Fund to support participants to gain car and motorcycle licences. This type of assistance falls within the ‘participant support’ category:

This category is used to purchase assistance to gain a driver’s licence including lessons, driving licence test and licence fees. Where a Provider is claiming for assistance given to a Participant to regain their driver’s licence after loss due to driving offences, this assistance is limited to one claim per Participant. Exceptions are listed in the Prohibited Purchases section of this guideline.[114]

3.118DEWR noted that approximately half of all expenditure from the Participation Fund is used for items in this category.[115]

3.119However, the Committee heard that the Participation Fund may not be appropriately adapted to enable participants to obtain licences (both in terms of the rules governing the Fund and the resources available), and that providers may not be making effective use of the Fund for this purpose.[116]

3.120For example, WHFS stated that the current $600 credit per participant is often insufficient to enable participants to meet the costs of lessons and licensing fees. WHFS recommended increasing credits to the Fund or establishing an additional fund specifically for lessons and licenses.[117]

3.121Some providers stated that they use the Participation Fund to support participants to obtain driver licences. However, evidence indicated that this is not universal. In this respect, Dr Vincent drew attention to the testimony of a participant she interviewed:

One interviewee, who started a family young and whose partner was doing an apprenticeship, asked her caseworker to help pay for the costs of driving lessons so she could gain her licence, which would have made an appreciable different to her employment prospects. The caseworker agreed to this request but was quickly replaced with another caseworker who reversed the decision.[118]

3.122The Committee met with representatives of local government and regional business during its site visits, all of whom stated that driver licences and access to a reliable vehicle have significant impacts on engagement with education and employment, particularly in regional, rural, and remote areas. The Committee heard that many individuals and families are unable to afford the administrative costs associated with obtaining a licence and lack the time to meet legal requirements such as minimum practice hours. Driving lessons can also be prohibitively expensive, and while a person is not required to have formal instruction to obtain a licence, lessons can substantially increase a driver’s confidence and skill level.

3.123Stakeholders strongly recommended that there be additional funding dedicated to enabling people in regional, rural, and remote areas to obtain driver licences, and that access to this funding should be framed as an entitlement.

3.124Providers with whom the Committee spoke during its site visits agreed that the Participation Fund should be used to support participants to obtain driver licences and access lessons. Those providers often indicated that they used the Fund for these purposes. However, providers also noted that additional funding is of little use in areas where there is limited or no licensing infrastructure or where qualified instructors are not available. Accordingly, providers stated that there must be greater investment in licensing infrastructure in regional, rural, and remote areas, including support for partnerships between providers and driving schools.

Committee view

3.125In recommending that the current ParentsNext program be abolished at the end of the current contract and replaced with a new supportive service developed through a comprehensive co-design process, the Committee proposes draft eligibility and design criteria in this report via a series of findings and recommendations.

3.126Every parent and carer is unique, with different goals, priorities and needs. Some may be seeking pre-vocational support, while others may want help finding and keeping work over the short, medium, and long term. Others may not need support from a pre-vocational or pre-employment service as they have comprehensive work histories, high levels of educational attainment, or strong support networks. Many parents have also made a conscious decision not to enter or re-enter the workforce and have chosen to focus entirely on parenting their child. For some single parents this may not even be a choice: all children are different, and some are ‘difficult’ and require more care than the average. All these circumstances and decisions are valid and should be respected.

3.127Current eligibility criteria for ParentsNext, while broadly appropriate, too often fail to distinguish between prospective participants based on their individual needs and circumstances. This leads to parents and carers being referred to the program despite having little to no capacity to benefit, which is a waste of taxpayers' money. For these parents it’s like entering a black hole that they can’t escape from, and they have to hope they are with a provider who uses the flexibility within the program.

3.128The Committee considers that front-line discretion should be implemented so that each of Services Australia and providers are able to exempt a parent from ParentsNext and any replacement service where it is considered that the parent has little or no capacity to benefit. Sensible guidelines should be developed to assist in these decisions, but the principle of common-sense front-line discretion should be implemented. The Parliament or bureaucrats in Canberra are not best placed to set rules that codify a judgement appropriate for every individual person and situation. In addition, a review of the criteria for exemptions should be undertaken as part of the (co-)design process for a replacement service for ParentsNext, and then on an ongoing basis, to determine whether the exemptions framework remains effective and appropriate.

3.129Current eligibility rules also appear to exclude those who might benefit from a pre-vocational or pre-employment program and who may wish to participate, such as disadvantaged parents on Carer Payment or low-income parents seeking assistance. Subject to budget considerations, the Committee would welcome a broadening of eligibility for voluntary participation so that a wider range of people, including those who are not in receipt of Parenting Payment but who may still benefit from services and supports, could choose to access the pre-vocational service that replaces ParentsNext. Over time, eligibility criteria could be further expanded to include all low-income parents, including those who do not receive either Parenting Payment or Carer Payment.

3.130Ensuring participants receive effective, tailored support also requires re‑imagining the process by which eligibility criteria and participation requirements are applied and how participants are referred. The current Services Australia practice of using outsourced call centres to refer participants to ParentsNext and inform them of their obligations is often unsuitable for parents. This is particularly the case for more vulnerable cohorts for whom effective intervention requires understanding a range of risk factors including family violence, financial hardship, mental health concerns and housing insecurity. The Committee is also concerned that the language used in letters informing parents that they will be ParentsNext participants is not appropriate, and that Services Australia’s practice of texting participants from an unknown number to inform them that an interview will be conducted creates undue stress and anxiety.

3.131As foreshadowed in the Submission Guide[111] for the broader Workforce Australia component of this inquiry, the Committee is reviewing the assessment process and typology of participants across all employment services. This may have consequences for the assessment of participants in ParentsNext and the service recommended to replace it.

3.132Notwithstanding the Committee’s final recommendations, Services Australia must review and reframe the way that it contacts parents to refer them to services (including ParentsNext and any replacement service). This should include:

• adjusting the language used in letters, to ensure participants have accurate information about the program or service, its function, and potential benefits;
• ensuring that text messages to parents (if they are deemed an appropriate means of contact) are unambiguous as to the purpose of the contact and the subsequent interview, including clarifying that the recipient is not being contacted as the result of some wrongdoing;
• exploring whether it is possible to have outbound calls show a dedicated phone number so participants know who it is from, while acknowledging there may be concerns regarding spoofing, spam and fraud that make this impractical at present; and
• ensuring that initial interviews conducted by Services Australia explain the purpose and benefits of the program, and accurately and comprehensively assess the participant’s needs and circumstances.
  133. The Committee’s strong preference is that the initial interview in a replacement service be face-to-face with the participant and be conducted by a skilled Services Australia employee, with a social worker available to meet with the most vulnerable people whenever required. Interviews should be undertaken within a framework which enables the staff member to identify risk factors such as mental health issues, family violence, and housing insecurity, and refer the participant to appropriate supports. The Committee appreciates that requiring face-to-face interviews will have resource and budgetary implications. Accordingly, this proposal may either require additional resources for the program or service or adjusting eligibility and participation requirements. The priority must be to provide a quality service—albeit to fewer people if necessary.

3.134The Committee recommends that the co-design process for the service to replace ParentsNext expressly consider eligibility criteria that:

• capture the needs of parents and carers, and ensure that parents and carers are not referred to the program where they have no capacity to benefit; and
• enable opt-in (voluntary) participation in the program by individuals who are not in receipt of Parenting Payment, such as:
  • individuals in receipt of Carer Payment; and
  • over time, low income or unemployed parents who are not in receipt of either Parenting Payment or Carer Payment.

3.135The Committee recommends that Services Australia immediately reframe its initial contact with prospective participants, so when people are referred to ParentsNext they understand the objectives, role and benefits of the program and do not suffer undue stress and anxiety. This should include ensuring that:

• letters to prospective participants clearly set out the reason for the contact and explain the role, function, and benefits of the program;
• text messages to parents notifying an interview with Services Australia are unambiguous as to the reason for the contact and explain the purpose of the interview;
• if possible, outbound calls show a dedicated phone number, so that the recipient knows who it is from, acknowledging that there may be concerns regarding spoofing, spam and fraud that make this impractical at present; and
• the initial interview conducted by Services Australia explains the purpose and benefits of ParentsNext, and accurately and comprehensively assess the participant’s needs and circumstances.

3.136The Committee recommends that the Australian Government amend the criteria for exemptions from ParentsNext, to provide a broad discretion to both Services Australia and providers to exempt a person from the program if is determined that they have no capacity to benefit. Providers and Services Australia should also provide additional training to their frontline staff to ensure that this discretion is exercised appropriately and effectively.

3.137The issue of participation requirements in ParentsNext continues to be the most contested element of the program and was the issue with which the Committee grappled the most during this inquiry. There is no perfect answer.

3.138It is clear that current participation requirements are far too onerous for many parents. The Committee is convinced that requiring participants to complete and report on activities is unreasonable, often does little to support engagement with ParentNext or to improve social or economic participation, and overall does more harm than good. The Committee’s view on this matter is reinforced by evidence indicating that many of the benefits of ParentsNext or a replacement service could be realised under a voluntary model.

3.139However, there is also compelling evidence that without participation requirements, many of the most vulnerable parents would not engage with ParentsNext and may be at greater risk of long-term unemployment and poverty including later in life. Common reasons for non-engagement include severe social isolation, anxiety, long-term disengagement from the workforce, family violence and coercive control, and cultural and gender-based norms.

3.140The Committee has concluded that significantly reduced participation requirements will continue to be necessary for the service which replaces ParentsNext, but only if major changes are implemented in relation to the activities which participants are expected to complete and report on, when and how participation requirements are applied, and the associated compliance regime.

3.141The Committee considers that forcing parents to participate in ParentsNext when their youngest child reaches nine months of age is completely unreasonable and that there is no evidence to support this arbitrary rule. This requirement is not appropriate for many parents, and particularly for those who wish to focus solely on caring for their child rather than on preparing to enter or re-enter the workforce. Parents should have the right to actively parent their very young children if they choose to do so, and the decision to focus on caring for young children without the State imposing requirements must not be limited to the wealthy, noting the Committee’s additional recommendations regarding very young parents. Several stakeholders have also pointed to evidence of the benefits of active involvement by all parents in the very early stages of their children’s lives.

3.142In addition, a parent’s capacity to engage with a pre-employment or pre-vocational program will vary considerably as their child ages. Parents with a child aged nine months are likely to have materially different capacities than parents with an older child who may be ready to start structured learning. ParentsNext does not account for these variations.

3.143The eligibility criteria for a service to replace ParentsNext must capture the specific needs of parents and children at different life stages, to ensure the program is appropriately adapted to participants’ needs and enables parents to focus solely on caring for their children should they choose to do so. In the Committee’s view, this necessitates a graduated approach to engagement that takes account of and responds to both the general support for appointments between participants and providers and the widespread concern relating to the requirement to complete and report on mandatory activities.

3.144The Committee considers that in the service which replaces ParentsNext, the ‘Participation Plan’ should be reimagined and reframed as a genuine roadmap to achieving individual goals, rather as than a compliance tool. This is likely to necessitate a change to its name, which has become a source of concern for some stakeholders. The Committee is attracted to a name such as ‘My Future Plan’.

3.145In addition, neither ParentsNext participants nor participants in the service which replaces ParentsNext should be required to undertake or report on activities in their Participation Plan (or its replacement). Current activity and reporting requirements should be adjusted as soon as possible. The Committee is strongly of the view that participants should only be expected to attend regular appointments with their providers, develop and agree on a plan and participate ‘meaningfully’ in ParentsNext or in the services which replaces that program.

3.146‘Meaningful participation’ is intended to restore common sense front-line discretion to workers and to remove anxiety associated with compliance requirements. Simple guidelines could also be developed in the co-design process for a new service that acknowledge the realities of parenting children and make clear that parents may have a variety of legitimate reasons for not achieving all of the goals in their plan or things they had hoped to do in set timeframes or between appointments. The power for providers to affect a person’s payment is also proposed to be removed.

3.147Both in relation to the current ParentsNext program and in relation to any service which replaces it, the Committee strongly encourages all providers to work with participants to ensure that the Participation Plan reflects the individual goals of the participant and sets out a pathway to achieve them. This includes goals that are not related to education or employment.

3.148The Committee also acknowledges that many, though not all, of the concerns about participation requirements relate to the severity of the financial sanctions under the TCF. The Committee is strongly of the view that the application of the TCF to ParentsNext is unreasonably harsh and unnecessary and should be wound back as soon as possible. This is discussed in later chapters.

3.149Final eligibility criteria (including the specific points where participation is required) should be determined by government following a robust and comprehensive co-design process. The Committee proposes the following draft eligibility criteria and participation requirements for refinement:

• For parents whose youngest child is aged under two years:fully voluntary with no participation requirements. Parents and carers would be able to access the service and supports as they wish. Government agencies and providers would be able to market the program to prospective participants, subject to clear business rules (for example, to prevent spamming and inappropriate incentives). Incentives would also be available to encourage participation in the program.
• For parents whose youngest child is aged between two and three years: fully voluntary with no requirement to participate in the service. When a person’s child is approximately two years old (or in the few months thereafter), Services Australia would arrange an interview with the person to check in, discuss future goals, and promote available services. Parents would eventually be required to attend this interview but with significant flexibility as to timing and location.

Services Australia would inform the parent of participation requirements service once their child reaches three years of age, properly explain the function and benefits of the program, explain available incentives and screen for domestic and family violence and other risk factors. The Committee’s strong preference is for these interviews to be conducted in-person. However, it is acknowledged that in some cases an in-person interview would not be feasible. In those cases, an online interview may be undertaken.

• For parents whose youngest child is three years or older (aligning with the starting age for pre-school and kindergarten in most States and Territories): participation requirements—attend regular appointments and participate meaningfully—begin to apply. Specific activities are not mandated to be undertaken or reported upon.

If participation requirements are not met, eventually a small financial sanction may be applied by Services Australia under a significantly revised compliance framework. This is outlined in Chapter 4.

3.150The exception to these criteria would be young and teenage parents who may require more active support from government. Those parents would be captured by a separate program (or a separate ‘stream’ of the service which replaces ParentsNext), based on the former Helping Young Parents program. This is discussed in Chapter 2.

3.151A key feature of the approach above is the greater use of incentives to participate. These might include subsidised childcare; modest cash payments before a youngest child is three years of age (for example, $100 to assist with any costs incurred in attending a first appointment and see what the service can offer); dedicated funding for education and training; or incentive payments for those participants who complete formal qualifications. There may be value in trialling different incentives in different Employment Regions to evaluate and determine which represents the best value and the greatest benefit to participants.

3.152In particular, the Committee suggests a higher priority be placed on supporting participants to develop skills to achieve their future goals and to reduce the risk of long-term unemployment and economic insecurity later in life. The Committee proposes that a ‘Skills Passport’ be considered as part of the service which replaces ParentsNext. This would be tied to the individual participant (not pooled) and given on a ‘use it or lose it’ basis. An annual credit (for example, $500 to $1,000) could be used to assist out-of-pocket expenses such as fees, books, and licences essential to the attainment of skills. This Skills Passport should value and support the attainment of pre-vocational soft-skills, completion of intensive support programs delivered by not-for-profit providers, and formal qualifications. The design of the Skills Passport and associated funding arrangements should form part of the co-design process for a service to replace ParentsNext.

3.153The Committee recommends that the service which replaces ParentsNext include graduated requirements depending on the age of the participant’s youngest child. The Committee proposes the following draft design components for refinement:

• Participation in the service be fully voluntary for parents with young children under a specified age (such as three years old).
• Participation requirements for parents with a youngest child aged three years or over should simply be to:
  • attend regular appointments; and
  • participate meaningfully in the program.
• Services Australia conduct an interview with a parent around six to 12 months before participation requirements begin to apply, to explain the service and its benefits, promote the incentives and supports which are available, and screen for key risk factors.

3.154The Committee recommends that the development of a ‘Skills Passport’ be considered as part of the service which replaces ParentsNext. This ‘Skills Passport’ should be tied to the individual participant (not pooled) and given on a ‘use it or lose it’ basis. The ‘Skills Passport’ should be an annual credit, for example $500-$1,000, which could be used to assist with out-of-pocket expenses such as fees, books, and licences essential to the attainment of skills, including soft-skills and formal qualifications.

3.155Any pre-employment or pre-vocational program must provide adequately resources so that service providers and support agencies (including Services Australia) can provide a quality service and support participants to reach their goals. The Committee has made clear that priority must be given to ensuring a quality service in accordance with key principles, even at the expense of broader eligibility.

3.156Noting questions raised by submitters as to whether the payment structure for ParentsNext is appropriate for a pre-vocational program, payment structures should be reviewed as part of the co-design process for a replacement service.

3.157A flexible Participation Fund (or a similar fund) should be retained, including in any service that replaces ParentsNext. While the Committee is concerned by evidence of a significant and persistent underspend of the current Participation Fund, the Committee does not see it as a priority that the Fund be increased at this time. Rather, providers should actively consider where participants could be better supported and should consider measures to increase participants’ awareness of the Fund and how it can be used to support their education and employment goals. In addition, the rules around how the fund may be used should be reviewed in the immediate to short term to ensure they are not acting as impediments to securing resources for participants. Consideration of rules governing the Participation Fund should also form part of the co-design process for a new service.

3.158In every site visit and discussion with providers and participants, as well as in discussions with employers and local government, the Committee heard that one of the most common barriers to education, employment, and even social participation (especially in regional areas) is the enormous difficulty for disadvantaged people in obtaining a driver licence, particularly noting issues such as high mandated minimum hours for learner drivers imposed by State and Territory Governments. While this issue is especially pernicious for young people from rural and regional areas, First Nations communities, people from refugee backgrounds, single parent families, families experiencing intergenerational unemployment, it affects untold thousands of people. The current cost of living crisis is exacerbating but not causing these problems.

3.159Challenges obtaining a driver licence, and broader concerns regarding any kind of access to reliable, affordable transport, are serious issues that have impacts well beyond ParentsNext. The Committee heard evidence of numerous ‘pilots’, ‘trials’ and ‘community solutions’ during its inquiry. However, the Committee considers that these amount to little more than band-aid and sticky-tape responses and fail to recognise the systemic nature of the problem and the response which is necessary.

3.160The Committee considers it urgent that participants can access more and dedicated support to obtaining a driver licence, including the cost of lessons and licensing fees. As an interim response, this may form part of the existing Participation Fund or be via additional financial support. The Committee also strongly encourages all providers to work with participants to ensure that participants are supported to obtain driver licences and have access to sufficient resources to meet the associated costs. In some cases, this may require providers to engage proactively with participants about their transport needs.

3.161The Committee acknowledges however that clarifying the ability to fund the attainment of a driver licence from the Participation Fund is only a partial response. The issue requires systemic action by State and Territory Governments, including implementation of measures to ensure that rules governing minimum practice hours for Learner drivers do not act as a barrier to disadvantaged people having access to reliable transport. The Commonwealth will need to pursue this with vigour and demand action. However, responsibility must rest with the States and Territories.

3.162Greater controls should be put in place over the use of the Participation Fund on related entity funding. While acknowledging that there may be some circumstances where own-entity funding is appropriate, the Committee has broad concerns as to the appropriateness and efficacy of assistance being funded and delivered through related entities and the extent to which these meet the needs of participants. The Committee considers that a clear default principle must be established that providers should not be permitted to use the Participation Fund to pay for services provided by their own organisation or by a related entity except where DEWR approves this in advance. The Committee considers that clear guidelines should be developed as to when such approvals may be given to support both decision-makers and providers.

3.163The Committee recommends that funding and payment structures be reviewed as part of the co-design process for a service to replace ParentsNext, to ensure they represent appropriate incentives for a pre-vocational program.

3.164The Committee recommends that the rules governing the Participation Fund be reviewed to ensure they are not acting as a barrier to participants accessing necessary resources.

3.165The Committee recommends the Australian Government urgently pursue systemic action by State and Territory Governments so that the varying rules requiring minimum hours for Learner drivers stop being a barrier for disadvantaged people.

3.166The Committee recommends that a clear default principle be established that providers are not permitted to use the Participation Fund to pay for activities, services, or programs that they deliver, or which are delivered by a related entity, except with express approval from the department. Guidelines should also be developed to clarify the circumstances in which approvals may be given.

Footnotes

[1]Mr Jonathon Thorpe, Deputy Chief Executive Officer (A/g)—Customer Service Design, Services Australia, Proof Committee Hansard, 18 January 2023, p. 20. See also Department of Employment and Workplace Relations (DEWR), Submission 77, p. 9.

[2]See DEWR, Delivering ParentsNext Guideline, pages 13–14, https://www.dewr.gov.au/parentsnext/resources/delivering-parentsnext-guideline, viewed 14 February 2023.; DEWR, Submission 77, p. 17. Providers may also use the JSCI to assess the participant’s needs and determine key risk factors.

[3]See, for example, Roseberry (Roseberry) Qld, Submission 71, p.1; Australian Council of Social Service (ACOSS), Submission 62, p. 8. ACOSS highlighted the impact referral letters from Services Australia have on parents’ mental health, particularly for parents experiencing housing insecurity.

[4]Angela, private capacity, Committee Hansard, 7 December 2022, p. 1.

[5]CVGT Employment (CVGT), Submission 22, p.4.

[6]SYC Ltd (SYC), Submission 44, p.7.

[7]National Employment Services Association (NESA), Submission 83, p.6.

[8]Experiences shared by participants and providers were reflected in evidence. See, for example,Ms Sally Sinclair, Chief Executive Officer, NESA, Proof Committee Hansard, 18 January 2023, p. 15.

[9]Ms Linda Forbes, Law Reform Officer, Economic Justice Australia (EJA), Committee Hansard, 11November2022, p.25.

[10]EJA, Submission 11, p. [11]. EJA noted that Services Australia recognises these issues and is examining how best to address them as part of implementation of its Family and Domestic Violence Strategy 2020-23.

[11]Mr Eric Harper, General Manager (A/g)—Working Age Programs, Services Australia, Committee Hansard, 11November2022, p.38.

[12]Mr Thorpe, Services Australia, Proof Committee Hansard, 18 January 2023, p. 20.

[13]Ms Melissa Ryan, Deputy Secretary (A/g)—Employment and Workforce, DEWR, Proof Committee Hansard, 18 January 2023, p. 23; Mr Thorpe, Services Australia, Proof Committee Hansard, 18January 2023, p. 23.

[14]Mr Thorpe, Services Australia, Proof Committee Hansard, 18 January 2023, p. 23.

[15]See, for example, Workskil Australia (Workskil), Submission 21, pages2, 4; EJA, Submission11, p.[5]; Wesley Mission, Submission 55, p.[6]; ACOSS, Submission 62, p. 8. Stakeholders also commented on eligibility criteria relating to the age of the youngest child. These comments were largely made in the context of compulsory participation for parents with very young children and are discussed later in this chapter.

[16]Council of Single Mothers and their Children (CSMC), Submission 25, p.[6].

[17]Workways Australia Ltd (Workways) Submission 54, p. [3].

[18]Workways, Submission 54, p. [3].

[19]NESA, Submission 83, p. 8. See also EJA, Submission 11, p.[5].

[20]ACOSS, Submission 62, p. 5.

[21]Mr Simon (Sam) Tracy, Practice Director, Basic Rights Queensland, Committee Hansard, 11November2022, p. 25. A similar experience was recounted by the Brotherhood of St Laurence (BSL). See DrDina Bowman, Principal Research Fellow—Work and Economic Security, BSL, Committee Hansard, 11 November 2022, p.25.

[22]yourtown, Submission 36, p.6.

[23]See, for example, EJA, Submission 11, p.[5]; Name Withheld, Submission 66, p.[1].

[24]Workways, Submission 54, p.3.

[25]Wesley Mission, Submission 55, p. [6].

[26]Metro Assist, Submission 73, p. [4].

[27]See, for example, Associate Professor Elise Klein OAM, Submission 6, p. 2; EJA, Submission 11, p.[12]; CSMC, Submission 25, p. [6]; Australian Research Alliance for Children and Youth (ARACY), Submission 37, pages2–3; ACOSS, Submission 62, p. 6; Australian Women Against Violence Alliance (AWAVA), Submission 3, p. [1].

[28]Ms Terese Edwards, Chief Executive Officer, NCSMC, Committee Hansard, 6 December 2022, pages 1–2.

[29]Dr Eve Vincent, Submission 10, p. 3.

[30]This was also reflected in written evidence. See, for example, Name Withheld, Submission 9, p. [1].

[31]Associate Professor Elise Klein OAM, Submission 6, p. 2.

[32]BSL, Submission 59, p.10. See also Dr Anne Nevile, Submission 14, p. 2, ACOSS, Submission 62, p. 6.

[33]Dr Janet Ramsey, Submission 17, p. 2; Dr Katherine Curchin, Submission 26, p. 5.

[34]See, for example, Australian Human Rights Commission (AHRC), Submission 24, p. 2; Professor Beth Goldblatt, Submission 4, p. 5, Equality Rights Alliance (ERA), Submission 19, pages 2–4; Change the Record, Submission 103, pages 3–4. This issue is compounded in the case of vulnerable cohorts of participants such as First Nations peoples and victim-survivors of domestic violence — particularly where financial sanctions result in a parent or child not being able to meet their immediate basic needs.

[35]See, for example, YFS Limited (YFS), Submission 31, p.3; yourtown, Submission 36, p.5; MAX Solutions, Submission 40, p.[2]; Salvation Army Employment Plus (SAEP), Submission 48, p.7. Those stakeholders did not all support compulsion across all elements of the program. Some, for example, only expressed direct support for compulsory appointments.

[36]Mission Australia, Submission 76, p.5. See also Sarina Russo Job Access (SRJA), Submission 23, p.7.

[37]Family and Relationship Services Australia (FRSA), Submission 60, p. 7.

[38]FRSA, Submission 60, p. 7.

[39]OCTEC Limited (OCTEC), Submission 53, p.3. See also YFS, Submission 31, p.2; Uniting SA, Submission 32, p.4; MAX Solutions, Submission 40, p.[2].

[40]Settlement Council of Australia (SCA), Submission 85, p. [2]. SCA also emphasised that whether compulsory participation will lead to positive outcomes is heavily dependent on the quality of the relevant provider. Moreover, while SCA did not oppose compulsory participation in relation to any element of the program, it only expressly supported compulsory participation for the first few appointments.

[41]Metro Assist, Submission 73, p. [4].

[42]Ms Benedikte Jensen, First Assistant Secretary—Employment Policy and Analytics Division, DEWR, Committee Hansard, 11November2022, p.31.

[43]See, for example, CSMC, Submission 25, p.[6]; Dr Ann Nevile, Submission 14, p.4; SAEP, Submission 48, pages 6, 9; NESA, Submission 83, p.6. This issue was typically raised in the context of compulsory participation. However, it also reflected broader concerns about the importance of parental involvement in the early years of a child’s life and the need to place greater value on parenting and caring as a form of work.

[44]See, for example, Associate Professor Elise Klein OAM, Submission 6, p. 2; National Women’s Safety Alliance (NWSA), Submission 27, p.[3]; Women’s Health and Family Services (WHFS), Submission 45, p.[2]; BSL, Submission 59, p.6.

[45]Dr Katherine Curchin Senior Lecturer, Centre for Social Research and Methods, Australian National University (ANU), Committee Hansard, 11November2022, p.9.

[46]See, for example, Settlement Services International (SSI), Submission 16, p. [3]; Workskil, Submission 21, p.2; My Pathway, Submission35, p. 5; MAX Solutions, Submission 40, p.[2].

[47]See, for example, Brave Foundation, Submission 56, p.5; Ms Jenny Davidson, Chief Executive Officer, CSMC, Committee Hansard, 6December2022, p. 3.

[48]Centre for Excellence in Child and Family Welfare (CECFW), Submission 74, p. 5.

[49]CSMC, Submission 25, p. [6]. It is noted that pre‑school does not begin at this age in all Australian jurisdictions. See Ms Sinclair, NESA, Proof Committee Hansard, 18 January 2023, p. 17.

[50]See Australian Institute of Health and Welfare, Early childhood education and care, https://www.aihw.gov.au/reports/children-youth/australias-children/contents/education/early-childhood-education-and-care, viewed 14February 2023.

[51]See Hon Daniel Andrews, ‘Free Kindergarten For Thousands of Victorian Children’, Media Release, 10 August 2022, https://www.premier.vic.gov.au/free-kindergarten-thousands-victorian-children, viewed 14 February 2023, Victorian Government, When to start Three and Four-Year-Old Kindergarten, https://www.vic.gov.au/give-your-child-the-best-start-in-life#when-to-start-three-and-four-year-old-kindergarten, viewed 14 February 2023.

[52]Djerriwarrh Community & Education Services (Djerriwarrh), Submission 28, p. 4.

[53]Ms Jensen, DEWR, Committee Hansard, 11November2022, p.34.

[54]See, for example, Per Capita, Submission 83, p. 5; SCA, Submission 85, p. [2].

[55]See, for example, Jobfind Centres Australia Pty Ltd (Jobfind), Submission 50, p.3; Wesley Mission, Submission 55, p.[6]; FRSA, Submission 60, p.7; Mission Australia, Submission 76, p.3.

[56]See, for example, EJA, Submission 11, p.[9]; SSI, Submission 16, p.[3]; Roseberry, Submission 71, p.2.

[57]DEWR, Submission 77, p. 10. See also DEWR, Submission 77 (Attachment 2), p. 29.In the 2021–22 financial year, 27,791 exemptions were granted to 23,580 participants. The most common exemptions are for pregnancy or birth of a child, having a large family with 4 or more children, and temporary medical incapacity.

[58]YFS, Submission 31, p.2.

[59]DEWR, ParentsNext Guideline, pages 106–107.

[60]Ms Renata Field, Team Manager—Policy, Advocacy and Research, Domestic Violence New South Wales (DVNSW), Committee Hansard, 7December2022, p.19.

[61]See Ms Forbes, EJA, Committee Hansard, 11November2022, p.22; NCSMC, Submission 5, p.4; Angela, private capacity, Committee Hansard, 7December2022, p.2.

[62]See, for example, EJA, Submission 11, p. [4]; CECFW, Submission 74, p. 3.

[63]Per Capita, Submission 87, p.14.

[64]See, for example, Professor Beth Goldblatt, Submission 4, pages7,9; CVGT, Submission 22, p.4; Campbell Page, Submission 57, pages[4, 6]; BSL, Submission 59, p.13. The AHRC indicated that using incentives instead of sanctions would assist the compatibility of the program with international human rights law. See Emeritus Professor Rosalind Croucher, President, AHRC, Committee Hansard, 7 December 2022, p. 11.

[65]SRJA, Submission 23, p.8.

[66]See, for example, Jobfind, Submission 50, p.6; Campbell Page, Submission 57, p.[6]; BSL, Submission 59, p.13; GoodStart Early Learning (Goodstart), Submission 75, p.5.

[67]Ms Sinclair, NESA, Proof Committee Hansard, 18 January 2023, p. 14; Mr Brian McCormick, Senior Advisor—Government Policy, Jobs Australia, Proof Committee Hansard, 18 January 2023, p. 10.

[68]See, for example, Uniting SA, Submission 32, p.4; SYC, Submission 44, p.10; Jobfind, Submission50, p.[6].

[69]See Social Security Act 1991, s. 500(1)(ca), Social Security (Administration) Act 1999, ss. 40A, 40D. In the applicable legislation, the Participation Plan is referred to as an ‘employment pathway plan’.

[70]DEWR, Delivery ParentsNext Guideline, pages 18–20, 24.

[71]See, for example, EJA, Submission 11, pages[4, 9]; SSI, Submission 16, p.[3]; BSL, Submission 59, p. 13.

[72]Dr Ann Nevile, Honorary Associate Professor, Centre for Social Research and Methods, ANU, Committee Hansard, 11 November 2022, p. 1.

[73]Dr Katherine Curchin, Submission 26, p.3.

[74]Ms Ella Buckland, private capacity, Committee Hansard, 7 December 2022, p. 8. Ms Buckland asserted that government ‘doesn’t have a handle’ on those providers who are engaging in intimidatory behaviour towards participants.

[75]Dr Nevile, Committee Hansard, 11 November 2022, p. 1. Reflecting on similar concerns, the Senate Community Affairs Committee found in its inquiry into ParentsNext that few participants are made aware of the ‘think time’ available to them to consider and agree to the Participation Plan. See Senate Community Affairs References Committee, ParentsNext, including its trial and subsequent national rollout, pages10–11.

[76]DEWR, Delivery ParentsNext Guideline, p. 22.

[77]See, for example, EJA, Submission 11, p. [4]; SSI, Submission 16, p. [3].

[78]See, for example, YFS, Submission 31, p. 3; APM, Submission 42, p. 8; Ms April Pan, Manager—Settlement and Employment Programs, Metro Assist, Committee Hansard, 7 December 2022, p. 22.

[79]EJA, Submission 11, p. [6].

[80]Goodstart, Submission 75, p. 4.

[81]Dr Nevile, Committee Hansard, 11 November 2022, p. 1.

[82]See, for example, Dr Ann Nevile, Submission 14, p. 1; Dr Katherine Curchin, Submission 26, p. 6; Wesley Mission, Submission 55, p. [9].

[83]See, for example, CORE Community Services (CORE), Submission 33, p. [3]; Australia’s National Research Organisation for Women’s Safety (ANROWS), Submission88, p.6.

[84]See, for example, Name Withheld, Submission 18, p. [1]; Playgroup Australia, Submission 79, p. 4.

[85]NWSA, Submission 27, p. 3.

[86]EJA, Submission 11, p. [9].

[87]Volunteering Australia, Submission 82, p. 3.

[88]DEWR, Submission 77, p.16.

[89]DEWR, Submission 77, p. 16.

[90]Employment Services Information, Advice provided by the Parliamentary Budget Office to the Select Committee on Workforce Australia Employment Services, 13 January 2023, p. 5, https://www.aph.gov.au/Parliamentary_Business/Committees/House/Workforce_Australia_Employment_Services/WorkforceAustralia/Additional_Documents.

[91]Mission Australia, Submission 76, p. 9.

[92]BSL, Submission 59, p.14.

[93]Mission Australia, Submission 76, pages3, 10.

[94]Metro Assist, Submission 73, p. 6.

[95]atWork Australia (atWork), Submission 34, p. 3.

[96]Ms Annette Gill, Principal Policy Advisor, NESA, Committee Hansard, 18 January 2023, p. 13.

[97]DEWR, ParentsNext Guideline, p. 76.

[98]DEWR, ParentsNext Guideline, pages 76–77. The principles include that the purchase supports education and employment goals, provides value for money, and will not bring ParentsNext or the government into disrepute. Prohibited purchases include those for which a provider is already entitled to payment from department, those which are already funded through other programs or grants, and the provider’s personal and business costs.

[99]Ms Samantha Robertson, Assistant Secretary—Employment Services Programs, DEWR, Proof Committee Hansard, 18January2023, p. 32.

[100]See, for example, WHFS, Submission 45, p. [3]; NESA, Submission 83, p. 13.

[101]Ms Sinclair, NESA, Proof Committee Hansard, 18 January 2023, p. 13.

[102]CSMC, Submission 25, p. [9].

[103]See, for example, NCSMC, Submission 5, p. 5; Dr Eve Vincent, Submission 10, p. 7.

[104]See, for example, Dr Eve Vincent, Submission 10, p. 5; Angela, private capacity, Committee Hansard, 7December2022, p. 2; Melissa, private capacity, Committee Hansard, 7December2022, p. 6.

[105]ACOSS, Submission 62, p. 12.

[106]See, for SSI, Submission 16, p. [4]; CORE, Submission 33, p. [3]; Mission Australia, Submission 76, p. 9; Jobs Australia, Submission 80, p. 4; NESA, Submission 82, p. 4.

[107]Ms Emma Morris, Executive Manager—Client Support Services, WHFS, Proof Committee Hansard, 1 February 2023, p. 6.

[108]See, for example, Djerriwarrh, Submission 28, p. 4; My Pathway, Submission 35, p. 5.

[109]See Per Capita, Submission 78, pages 19, 21. Per Capita recommended that providers not be permitted to refer participants to in-house courses and other supports.

[110]See, for example, CORE, Submission 33, p. [3]; My Pathway Submission 35, p. 5.

[111]Ms Sinclair, NESA, Proof Committee Hansard, 18 January 2023, p. 14.

[112]See, for example, EJA, Submission 11, p. [8]; My Pathway, Submission 35, p. 6; BSL, Submission 59, p. 14.

[113]See, for example, DEWR, Local Jobs Plan: South Coast of Victoria, p. [1]; https://www.dewr.gov.au/local-jobs/resources/south-coast-victoria-local-jobs-plan, viewed 14 February 2023; Local Jobs Plan: Great Southern – Wheatbelt, p. [1], https://www.dewr.gov.au/local-jobs/resources/great-southern-wheatbelt-local-jobs-plan, viewed 14 February 2023; Local Jobs Plan: Far West Orana, p. [1], https://www.dewr.gov.au/local-jobs/resources/far-west-orana-local-jobs-plan, viewed 14 February 2023.

[114]DEWR, Delivering ParentsNext Guideline, p. 117.

[115]DEWR, Submission 77, pp. 17.

[116]See, for example, EJA, Submission 11, p. [9]; NWSA, Submission 27, p. [3]; WHFS, Submission 45, p. [3].

[117]WHFS, Submission 45, p. [3].

[118]Dr Eve Vincent, Submission 10, p. 5. Dr Vincent observed that high staff turnover is a feature of the sector.

[111]Select Committee on Workforce Australia Employment Services, Submission Guide, pages 18–20. www.aph.gov.au/Parliamentary_Business/Committees/House/Workforce_Australia_Employment_Services/WorkforceAustralia/Submission_Guide