Chapter 3
Household assessments
3.1
Submitters to the inquiry raised concerns with a range of aspects of the
design, implementation and administration of the household assessments portion
of the program, including:
- the quality of assessor training;
- the number of accredited assessors;
- the process of accrediting assessors, and contracting them to the
government;
- the quality of assessments;
- problems with the assessments booking system;
- allegations of misuse of the assessment portion of the program by
companies; and
- payments to assessors.
Each of these issues
is considered below.
Quality of assessor training
3.2
One of the major concerns expressed by assessors and other stakeholders
in respect of the design and operation of the program was that the training
received by assessors was not of a sufficiently high quality to enable them to
perform high quality assessments. Evidence to the committee focussed on two aspects
of assessor training:
- the quality of training courses and training providers; and
- the lack of pre-requisites for aspiring assessors.
Training courses and providers
3.3
A significant number of assessors informed the committee that they had
received poor training which did not equip them to perform assessments. For
example, Mr Mark Walker, an assessor from NSW, submitted that:
...the 4-day training course for this program was woefully
inadequate, and the quality of training materials provided left a lot to be
desired. For example, the large ring-binder provided to me contained materials
photocopied or downloaded, was poorly organised and had neither a Table of
Contents nor page numbers, rendering it virtually useless as a reference tool.[1]
3.4
Similarly, Dr Roger Severn, an assessor from WA, commented on the lax
assessment standards to test the knowledge of newly trained assessors:
Assessment was in the form of an open book test where candidates
answered questions with no time limit and full access to the printed material used
in the course. Marking of each test was done by each candidate passing their
test answers to another candidate who marked the paper based on their own
perceptions and some key points made by the instructor as each question was
answered. Unsurprisingly, all candidates met the registration criterion even
though it was obvious that the knowledge level within the group varied
significantly.
My point is that each candidate was not tested sufficiently for
anyone to be satisfied that the knowledge required for accreditation had been
achieved.[2]
3.5
These comments regarding the poor standard of assessor training were
echoed by numerous other assessors in their submissions to the committee.[3]
3.6
However, not all assessors were dissatisfied with the quality of
training provided under the program. For example Mr Mark Clayton, an assessor
from South Australia, submitted that:
I had an advantage of a great deal of prior knowledge but
still learnt plenty during the course.[4]
3.7
Similarly, another assessor submitted that:
For the record I would like to note that outside of my
university degree Green Skills is the best training provider that I have ever
worked with. I do not believe you will find a more committed, experienced,
knowledgeable or passionate training provider in the country. Furthermore if
every training provider operated with the same level of integrity as Green Skills
does this programme would have been a huge success.[5]
3.8
Based on the evidence received by the committee, it is clear that the
quality of assessor training differed markedly between training providers. In
its submission, the Association of Building Sustainability Assessors (ABSA)
explained that one of the reasons for this was that DEWHA:
...did not require the HSAS (Home Sustainability Assessment
Scheme) training to be competency based or accredited as a short course, which
would have brought the training within the Australian Government's Australian
Quality Training Framework...rather, DEWHA signed off on the training as a
non-accredited and content, rather than competency, based short course.[6]
3.9
ABSA also explained that DEWHA did not require that training facilities
be Registered Training Organisations, which ABSA argued resulted in some of the
training being of poor quality. In September 2009, ABSA itself implemented such
a requirement as a pre-requisite for accreditation of assessors.[7]
3.10
Ms Amanda McClelland, the Chief Operating Officer of Fieldforce
Services, a key participant in the program which trained and employed over 400
assessors, argued that the quality of assessor training was 'probably the one
single big failing' of the Green Loans Program.[8]
Ms McClelland stated that:
It seemed to be that if you were an RTO [Registered Training
Organisation] you could go and train anyone. There was no governance over who
trained, what they trained and the quality of that training. There was no exam.
Basically, I could be an RTO who trained in data entry and, if I went and
developed a two-day program, I could go and get 500 immigrant taxi
drivers—which was apparently one of the things that occurred—and all of a
sudden I have trained 500 assessors, who would be accredited to do energy
assessments.[9]
3.11
Both ABSA and Fieldforce recommended to DEWHA that the standard of
training needed to be improved, and suggested that the existing Certificate IV
level program in Victoria would provide a suitable basis for training.[10]
Fieldforce made this recommendation following conducting a pilot training
course as early as November 2008.[11]
3.12
However, the committee was informed that this suggestion was not
implemented by government because of pressures to roll out the program quickly:
The concern at the time was...to have the program up and
running and to have people who were going to be able to use the assessment tool
that the government had commissioned to provide sustainability assessments to
households. I think the decision was taken at the time that having a more
extensive training schedule or training requirement would take more time.[12]
3.13
ABSA indicated to the committee that the process for nationally
endorsing the Victorian Certificate IV course has been slow because 'it is a
process of going through the state governments'.[13]
Further, Ms Carmichael, CEO of ABSA indicated that:
[I]t is a process that cannot be cut short. I did hear
Senator Wong had asked whether that could be sped up, and it is not a process
that can be.[14]
3.14
Furthermore, the government apparently had doubts as to whether the
Victorian course was appropriate. In response to a question asked at Senate
Estimates hearings in February 2010, DCCEE stated that:
The Victorian Course in Home Sustainability Assessment has a
broader approach to sustainability issues compared to the Professional Home
Sustainability Assessment course, as it incorporates ecological footprints,
waste management, garden and environs, transportation and general green living
aspects. It is the Department’s view that requiring assessors to undertake the
broader topics covered by the Victorian course may not necessarily improve the
skill sets of the Green Loans assessors as they focus only on the energy and
water efficiency performance of houses.[15]
3.15
Despite the decision not to require assessors to undergo a formal,
nationally endorsed training program—either because of timing, the suitability
of the course, or a combination of the two—a number assessors who participated
in the program had an understanding that the government intended to upgrade
their qualifications to Certificate IV level at some stage.[16]
The national accreditation body, ABSA, which was involved in the development of
the program from an early stage, has the same apprehension with respect to
DEWHA's intention to fund an upgrade in assessor training to Certificate IV.[17]
3.16
When questioned at the committee's hearing on 29 June 2010 about why the
assessor community had a widespread understanding that the government would pay
to upgrade assessor qualifications, Mr Malcolm Thompson, Deputy Secretary,
DCCEE, informed the committee:
[T]hat was never government policy and so there has never
been a position that the Australian government would pay for an upgrade of
training to cert IV for assessors.[18]
3.17
In response to a question taken on notice on the matter, DCCEE provided
an unhelpful answer, referring the committee to its response to the Hawke[19]
and Faulkner[20]
reports in which DCCEE simply stated that 'action is currently underway to
investigate potential breaches identified in this report'.[21]
3.18
However, DCCEE provided further information on this matter to the
Australian National Audit Office (ANAO). In its performance audit of the Green
Loans Program, the ANAO confirmed that email advice was sent to an assessor in
July 2009 by a DEWHA officer 'indicating that when an accredited training
course is available, assessors will be offered the necessary additional
training at no cost'.[22]
3.19
In response to questioning about how the government proposes to rectify
the misinformation given by departmental officers to assessors and ABSA on this
matter, DCCEE informed the committee that 'action is currently underway to
investigate potential breaches identified in the Faulkner report'.[23]
DCCEE stated that it would:
...conduct any necessary investigations to follow up actions
where further potential breaches of the APS Code of Conduct, the Financial
Management and Accountability Act and the Criminal Code are identified.[24]
Pre-requisites for assessor
training
3.20
Many assessors, even those satisfied with the quality of training
provided to them, commented that the training was inadequate without prior
knowledge and/or experience in a related field. For example, Mr Jeff Wormald,
an assessor from NSW, commented:
While the HSA training course that I attended was small in
number of attendees and well delivered with a very knowledgeable trainer and
quite a lot of extremely useful input from the course participants, I would be
at a complete loss if this were to be my only source of expertise to draw upon for
the purposes of conducting an assessment. The real qualifications necessary for
conducting an accurate and useful Home Sustainability Assessment may not be
extremely high, but some level of proficiency in [building design or thermal performance, with energy
efficiency, clean energy generation or home sustainability] is an
essential if this or similar types of programmes are to have any real relevance
to the house holder for use as a real and effective tool for energy efficiency
and sustainability, although the importance of people skills must never be
underestimated as this is after all an educational process.[25]
3.21
A number of submitters and witnesses indicated that at the beginning of
the program, it was understood that assessors would be required to have pre-requisite
experience and/or knowledge in addition to completing assessor training.[26]
However, the omission of such a pre-requisite was argued by some to have
undermined the quality of assessors. For example, Mr Mark Walker, an assessor
from NSW, submitted:
...the removal of the initial restriction on prior
qualifications allowed for an influx of under-qualified, uninterested,
self-focused individuals whose only real motivation was accumulating capital as
quickly as humanly possible. The lack of real regulation and lack of auditing
of so-called training organisations, made a farce of the accreditation process.[27]
3.22
Similarly, Ms Leanne McIntosh, a GLACO assessor, stated:
I have a uni degree and three trade qualifications. I
expected, when I went to training, to have a roomful of people with those sorts
of qualifications. There were nurses. There were insulation installers who just
wanted to tack on the $200 and be in and out within five minutes. They were
open about what they were doing at the training course. To me, it should have
been enforced that you had an adequate background to be able to advise people.
That was definitely one of the faults, no doubt at all.[28]
3.23
ABSA explained that requiring assessors to have experience in the
building industry was 'mooted' at the initial stages of developing the program
as originally:
...it was considered that the tool to do Green Loans was going
to be similar to what is called the NatHERS [Nationwide House Energy Rating
Scheme] tool, which is all about building fabric.[29]
3.24
However, as the program and assessment tool developed, Ms Carmichael
explained that Green Loans was quite different from NatHERS:
...in that you actually wanted people who would go into
households and engage intelligently and sensitively with householders. So just
setting a whole lot of building prerequisites became less and less appropriate
as the Green Loans Program and the tool rolled out.[30]
Committee comment
3.25
 Based on the evidence received by the committee, it is clear that there
were serious problems with the quality and regulation of assessor training.
While some assessors no doubt received excellent training by qualified and
experienced training providers, the fact that assessor training was almost
entirely unregulated meant that the government has no assurances as to the
quality and knowledge of assessors trained under the Green Loans Program.
3.26
The committee is of the view that the lack of regulation or quality
standards in relation to assessor training was largely the result of pressure
on DEWHA to roll out the program within tight deadlines.[31]
Had DEWHA been given the opportunity to wait until a national
Certificate IV level assessor training program had been developed and accredited,
these more rigorous training standards would have discouraged some of the
'sharks and shonks'[32]
from taking advantage of the program.
3.27
Furthermore, had the government allowed more time for the roll-out of
the program, it would have been clearer what skills would be required of
assessors. This would have enabled the department and other stakeholders to
better manage the expectations of assessors. The committee makes recommendations
about the necessary standards of assessor training under the Green Start
Program in chapter 7, in order to prevent the failings of the Green Loans
Program from re-occurring.
Number of accredited assessors
3.28
A common issue raised by many submitters was the number of assessors
accredited under the program. Initially, Minister Garrett indicated that there
would be 1000 assessors 'ready to begin work' from 1 July 2009.[33]
Some assessors submitted that this figure of 1000 assessors was in fact
expressed at the start of the program to be an upper limit.[34]
Other assessors claim to have had an understanding, based on information from
either their trainer, or the government's website, that there would be a cap of
1500, 2000 or 3000 assessors.[35]
3.29
In evidence to the committee, Mr Malcolm Thompson, Deputy Secretary, DCCEE
stated that:
[T]here was no expected target of 1,000... My recollection...is
that Minister Garrett had a press release that indicated we had up to 1,000
assessors ready to go in the early period just prior to the launch of the
program. There was never a statement that I am aware of from the minister or
from the government that we were aiming for a target of 1,000 assessors.[36]
3.30
However, assessors claim to have been induced into joining the program
on the basis of their understanding that there would be a cap on assessors. For
example, Mr David Cumming, an assessor from NSW, submitted:
From a personal perspective, I funded my retraining to become
a Home Sustainability Assessor on the strength of the representations made on
the Green Loans website, and in the official Green Loans Style Guide... Had I
known that ABSA and DEWHA were not managing the numbers of registered HSA’s I
certainly would not have committed myself to the program. I think it is fair to
say that many people completing their accreditation saw this as a foothold in
an ongoing (though term-limited) market with a limited supply of service
providers.[37]
3.31
Organisations involved in the program, including Fieldforce, which was
involved in the program from the outset and assisted in its development, were
under a similar apprehension about the number of assessors that would be
trained:
When the program first started, the indication—given, I
believe, to everybody—was that there was going to be no more than 1,000
assessors in the program.[38]
3.32
When pressed on where this belief came from, Ms McClelland, Fieldforce's
Chief Operating Officer stated that it came from 'conversations with the
department and ABSA'.[39]
3.33
In its submission, ABSA stated that:
At the time of DEWHA's acceptance of ABSA's application to
become an Assessor Accrediting Organisation, DEWHA estimated that the program
would attract approximately 800 assessors.[40]
3.34
When questioned, Ms Alison Carmichael, Chief Executive Officer of ABSA,
informed the committee that ABSA was never informed by DEWHA of the basis for
the figure.[41]
3.35
Ms Carmichael further informed the committee that in the initial stages
of the program:
The feeling at the time was that nobody had any idea whether
there would be any interest in this program. In fact the sense from the
department was the fear that they would not get enough people. It was kept low
and they were very hopeful that there would be 800 to 1,000 at the end of the
first year.[42]
3.36
In response to why there was a wide-spread understanding amongst
stakeholders that there would be 1,000 assessors, Mr Malcolm Thompson, Deputy
Secretary, DCCEE stated:
...it was considered at the time that 1,000 assessors would be
the minimum that the government would need to deliver this program and that is
why 1,000 became significant in that sense...
There may have been discussions with departmental officials.
I know some stakeholders have made reference to that. We, in our search of our
records, cannot find definitive evidence of that. I am not saying that it is
not the case, but if it was the case then, as far as I am aware, it was not
government policy.[43]
3.37
Yet, the independent inquiry into procurement processes and contractual
arrangements under the program by Ms Patricia Faulker, found that DEWHA had
briefed Minister Garrett in December 2008 on various options for delivery of
assessment services under the program, and in that brief indicated that 'up to
2,000 assessors were envisaged'.[44]
3.38
The difference between the figure given to the Minister in December 2008
(2000) and that given to ABSA in February 2009 (800) has not been explained by
the government. While DEWHA clearly gave thought to the number of assessors
that were required or likely to become involved in the program, the government
has not been able to explain what these estimates were based on. Yet it is evident
that different estimates were given to different stakeholders at different
times, whether officially or unofficially. These estimates naturally affected
the decisions of assessors and organisations to become involved with the
program and expend money in order to participate.
3.39
It is also clear that there was no thought given early on in the program
to the risk that many more than the projected 800 or 1000 or 2000 assessors
would train and apply for contracts under the program. ABSA submitted that:
By August 2009, ABSA was aware of 2,000 individuals who had
undertaken HSAS training seeking accreditation as HSAS assessors. ABSA
repeatedly raised its concerns with DEWHA from August 2009 regarding the number
of assessors relative to the number of funded assessments over the life of the
Green Loans program and the number of assessors originally estimated by DEWHA.[45]
3.40
In response to ABSA's concerns:
DEWHA made it clear to ABSA that it did not have a view about
how many assessors should be trained and accredited.[46]
3.41
In evidence to the committee, officers from DCCEE commented:
It certainly was the position that the government and the
department considered that this was a matter for ABSA, as the accrediting
agency, to settle. We were concerned to ensure that there were enough assessors
available to deliver the program, not only as to the total number of
assessments in a quantity sense but also to give a reasonable geographic spread
of assessments across the country.[47]
3.42
ABSA then 'decided to take the matter into its own hands' and in early
November 2009 advised DEWHA that it proposed to only accredit those who
submitted their application by 24 December 2009. ABSA submitted that
this decision led to ABSA receiving legal threats from training providers and
potential applicants. As a consequence ABSA pushed back the date at which
applications closed to 21 January 2010 for those who completed training
prior to 24 December 2009.[48]
3.43
ABSA projected that this moratorium would result in there being a total
of 4500 registered assessors (3000 who had already registered, plus 1500
registering between its announcement and 21 January 2010). However, instead of
receiving 1500 additional applications during December and January, ABSA
received 6500 applications for accreditation prior to 21 January 2010
(making a total of 9500 assessors).[49]
3.44
The almost twelve-fold difference between the number of assessors initially
projected by DEWHA versus the actual number of accredited assessors led to a
much greater number of assessments being performed in a shorter space of time
than anticipated. ABSA submitted that of the 360 000 assessments that were
intended to be funded over the 4-year life of the program, 288 170 of these had
been booked by 22 January 2010.[50]
This equates to more than 80 per cent of the entire program's allocated
assessments which were conducted in less than 15 per cent of the program's
lifespan.
3.45
A number of submitters blamed the blow-out in assessor numbers on ABSA
and/or assessor training organisations. For example, Dr Roger Severn, an
assessor from WA, submitted that:
Accreditation authority has been vested in a private
organisation. This has meant that to be accredited an individual must become a
member of that organisation paying significant fees for the privilege. In order
to protect the income earning capacity of their members it is now argued that
accreditation should be limited. It is true because of the enthusiasm of the
training contractors far too many people were encouraged to enrol in training
with unrealistic expectations of income earning.[51]
3.46
Mr Mark Walker, an assessor from NSW, argued that the oversupply
resulted from:
...less scrupulous and (comparatively) unregulated training organisations
had no vested interest in limiting the number of potential assessors trained
and so, lacking appropriate advice or regulation from Government, attracted as
many potential assessors as possible to their training courses.[52]
3.47
ABSA responded to these arguments by noting:
We wanted to shut off in August [2009]. In the end, when we
did close off, we absolutely did not want any more.[53]
3.48
According to the ANAO, a draft report by PricewaterhouseCoopers, which
the government has not yet publicly released, on ABSA's compliance with the
protocol for the Assessor Accrediting Organisation under the program found that
while ABSA had not been fully compliant with certain aspects of the protocol,
'...areas of non-compliance were primarily due to factors beyond ABSA's
control'.[54]
The PricewaterhouseCoopers report is subject to an order for the production of
documents in the Senate.[55]
3.49
Ms Amanda McClelland, Chief Operating Officer, Fieldforce, attributed
the problem to the lack of clarity between the responsibilities of ABSA and
DEWHA:
The line of responsibility between ABSA and DEWHA was
sometimes very blurred. I would talk to ABSA and they would say that it was not
their responsibility to cap the number of assessors but DEWHA's responsibility.
Then DEWHA would say that ABSA is the accrediting body. I would have assumed
that they would have ironed that out during program design.[56]
3.50
The Department of Climate Change and Energy Efficiency submitted that:
On 19 February 2010, the Government announced a cap of 5,000
on the number of assessors participating in the program. This will ensure a
sustainable level of assessment activity for contracted assessors.[57]
3.51
DCCEE's submission suggests that this cap was possible because, of the
approximately 9500 assessors who had applied to ABSA for accreditation, only
approximately 4000 had been contracted to the government to work as assessors
at that stage.[58]
3.52
The government gave no indication as to how it would decide which of
those assessors accredited by ABSA but not yet contracted to the government
would be formally contracted, and which would not. Minister Wong suspended the
issuing of new contracts to assessors in March 2010. Mr Malcolm Thompson,
Deputy Secretary, DCCEE informed the committee that Minister Wong was not going
to make a decision regarding the issuing of further contracts until the PricewaterhouseCoopers
audit of ABSA's accreditation processes and the Faulkner review of contracting
arrangements under the Green Loans Program had been considered.[59]
3.53
The committee notes that the Faulkner review was released on 8 July
2010, simultaneously with Minister Wong's announcement that the Green Loans
Program would be phased out and transition to a new Green Start Program
(discussed in chapter 7). Yet, in a media release that day, the Minister
announced that the suspension on new assessor contracts 'will continue'.[60]
The government has made it clear that some Green Loans assessors will likely be
successful in obtaining grants under the new program, and has released limited
details about a retrenchment package available to those assessors not chosen to
participate in Green Start. However questions remain about the status of
uncontracted assessors. These issues are discussed in chapter 7. Â
Committee comment
3.54
The huge blow-out in assessor numbers that occurred under the Green
Loans Program is arguably one of its most significant failings. The demand that
that blow-out created in household assessment bookings; the resulting
numbers of assessment reports; and the huge number of invoices that needed to
be processed by the departments were all significant flow on effects. DEWHA's
management systems were simply not designed to handle this huge number of
assessors and the resulting deluge of assessments. The combination of these
factors led to the program's funding being exhausted well before its planned
end date, which has left thousands of assessors without the income they had
anticipated from the program.
3.55
DCCEE has stated that the government did not, at any stage, have an
official policy on how many assessors should be contracted. Yet it is clear
that various projections of assessor numbers were given by DEWHA officers to
individuals and organisations during the course of the program. On the strength
of these representations, individuals and organisations invested substantial
resources into the program, and made business decisions on the basis of these
projections. It is the committee's firm view that members of the public should
be able to rely on information given to them by government.
3.56
Furthermore, the committee finds it unacceptable that the federal
government would embark on a program of this size and scope without having firm
projections of the number of assessors likely to be involved and clear
agreements with partner organisations as to whose responsibility it was to
ensure that sustainable numbers were not exceeded. If the government was not
going to monitor assessor numbers, it should have made it clear to ABSA that
this was part of their role, and given ABSA ownership of any related aspects of
the program.
3.57
The fact that neither ABSA nor DEWHA considered themselves responsible
for assessor numbers is another indication of the lack of planning that went into
the Green Loans Program.
3.58
The arrangements put in place once the government became aware of this
enormous problem—of capping the number of contracts at 5000 and suspending the
issue of new contracts—are simply unacceptable from the point of view of
assessors who trained under the program expecting to be contracted to the
government under the program. This decision has left over 5000 Australians in
limbo since February 2010. The committee makes various recommendations as to
how similar problems caused by a lack of communication and planning may be
avoided under the Green Start Program in chapter 7.
Accrediting and contracting assessors
3.59
A large number of assessors who submitted to the inquiry complained
about the time it took both ABSA and DEWHA to process paperwork relating to
accreditation and contracting respectively.
3.60
Some assessors claim to have waited for six months or more after
undertaking training and submitting the relevant documentation, to obtain the
accreditation and contract, without which they were not able to perform
assessments under the program. For example, Mr Mohamed Hawli, an assessor,
submitted:
Upon submitting my application to ABSA, it took approximately
10 weeks to receive the [Home Sustainability Assessor] numbers and cards. After
a long and drawn out effort to obtain the [Home Sustainability Assessor] numbers
I promptly sent off my contract to the Green Loans Program. I sent off the
contract in the first week in February [2010] and have been waiting since for
some indication but nothing has come through.[61]
3.61
A list of the periods that various assessors claim to have had to wait
for the government to approve their paperwork is at Appendix 3.
3.62
Like Mr Hawli, many other assessors complained of not yet having been
contracted to the government, despite being accredited by ABSA and having paid
the requisite training, accreditation and insurance fees. Based on DCCEE and
ABSA's submissions, there are between 5300 and 5500 assessors in this position.[62]
3.63
Based on the submissions received by the committee, the average assessor
would have spent between $2000 and $3000 on training, insurance, police checks,
ABSA fees and other costs, prior to being contracted with DEWHA and being
allowed to begin performing assessments under the program.[63]
Committee comment
3.64
As discussed above, the length of time it took for DEWHA to approve
assessors' contracts was likely to have been a flow-on effect of the lack of
projections and controls on assessor numbers.
3.65
It also reflects poor resourcing decisions by the government. In order
for an agency usually focussed on policy to undertake a project of the size and
complexity of Green Loans, it is obvious that substantial additional resources
would be required. It appears that not nearly enough resources were provided to
the team managing the project within DEWHA. Indeed, this was a finding of both
the Faulkner review and the review of the program by Resolution Consulting.[64]
3.66
In chapter 7, the committee makes recommendations about resourcing and
planning of the Green Start Program, in order to prevent the failings of the
Green Loans Program from re-occurring.
Quality of assessments
3.67
Another significant concern, raised by both assessors and participating
householders, was the quality of home sustainability assessments. Problems with
the quality of assessments are argued to have arisen as a result of the:
- quality of assessor training (discussed above at paragraph 3.2
ff);
- design of the assessment tool required to be used; and
- speed at which some assessors performed assessments.
Design of assessment tool
3.68
A number of assessors submitted that the assessment tool was flawed, and
did not account for climate variations across the country and various other
important factors in the environmental performance of a house. Ms Enga Lockey,
an assessor from Victoria submitted that:
The assessment tool has so many flaws as to make any
resultant information supplied to the homeowner worthless.[65]
3.69
Similarly, Mr Sam Tuck, another assessor from Victoria, submitted:
The assessment books were so irrelevant to the information
required by the online tool they were useless. A massive waste of resources...
The biggest reductions in energy use in homes I have assessed
would be gained from implementing draft proofing and insulation effectively –
but this is very limited in the scope of the report. There is no priority given
to measures to improve the householder’s emissions in the report, which is our
area of expertise.[66]
3.70
Mr Darryl Smith, a participating householder, analysed the report he
received under the program and found 'a significant number of issues' with it.
These 'issues' include:
- Many of the measures recommended by the report project cost and
energy savings in excess of actual expenditure. For example, Mr Smith currently
spends $104 on hot water electricity annually. The report recommends that he
purchase a solar or heat pump, and projects that he would save $190 per year if
he did so.[67]
There are a number of similar examples of both projected power and monetary
savings being above Mr Smith's current actual costs throughout his report.
- The use of incorrect tariffs in calculating the potential savings
of recommendations within the report.[68]
- Incorrect usage data being recorded on the report. For example,
the report received by Mr Smith records his annual electricity consumption as
approximately 14 680 kWh, whereas his actual electricity consumption is
13 395 kWh. Mr Smith has calculated that this error is likely to be a
result of a recording error by his assessor.[69]
- Recommendations that would increase the energy used in Mr Smith's
home, such as replacing his existing top loading washing machine with a new
front loading device, which the report states would save -8 kg (i.e. use an
additional 8 kg) of greenhouse gas equivalent per annum.[70]
- Savings figures calculated on fanciful assumptions. For example,
his report recommends that if Mr Smith installed a grey water tank, he would
only use approximately 8 litres of water per day. Mr Smith has calculated that
this figure assumes that he shower for approximately 1 minute per day and
rarely wash his clothes.[71]
- The fact that the energy savings arising from the recommendations
made in the report are not cumulative, so that a householder cannot choose to
implement all the recommendations to achieve the sum of the listed savings.[72]
3.71
Assessors argued that the time it took to complete the report did not
justify the value of the end product. For example, Mr Michael Lewin, an
assessor from Victoria, submitted:
The software tool is simplistic and perhaps has to be. Most
receivers of the report have found it hard to relate to and don’t see it as
being worth investing several hours to get.[73]
3.72
Similarly, Mr Sam Tuck, another assessor from Victoria, submitted:
The data entry for a typical household took over an hour
(much much longer initially!). Repetition, data loss etc. wasted so much of our
time. The fixes took months, and IT savvy colleagues commented on the archaic
manner the online tool operated.[74]
3.73
Assessors reported that the poor quality of reports reflected poorly on
the ability of assessors and on the program generally:
Some assessment reports were so deeply and obviously flawed
that they inevitably caused the householder to doubt the capability of the
assessor. I was embarrassed by some householder's disappointment in the
reports. Many held me responsible for the inaccurate statements/recommendations
they received. As such they would not recommend my services, or the program, to
others. My reputation in my local community, for both home assessments and any
future business, has been negatively affected by DEWHA's flawed assessment
software and slow/non-delivery of reports.[75]
3.74
The media reported on one extreme example of the failings of the
assessment tool, and the lack of even basic audit of it, involving a Brisbane
man being told he could save more than $31 million per year by installing a new
air conditioner and ceiling fans, when his quarterly power bills only totalled
$195 and he already had ceiling fans in most rooms.[76]
3.75
The software for the assessment tool was developed by RMIT, under a
contract with DEWHA. The Faulkner review of procurement practices and
contractual arrangements under the program found serious flaws with the
awarding and managing of contracts under the program.[77]
The findings of the Faulkner review are discussed in chapter 6.
3.76
A particular concern was that the tool did not take account of air
leakage. DCCEE advised the committee that:
...the tool has always included both questions relating to the
level of air leakage in the dwelling and recommendations to improve this aspect
of the dwelling as is appropriate...
Air leakage has always been considered as part of the
building thermal load calculation (heating and cooling), and this module has
been subject to upgrades during delivery of the program.[78]
3.77
The committee was also made aware of potential issues related to the
loadings given to various technologies in the assessment tool, and how
preferences for various technologies were made in the design of the tool. The
committee questioned DCCEE about whether any persons or organisations had
corresponded with either the department or RMIT about the loadings to be given
to various technologies by the tool, and was informed:
RMIT has advised that all technologies included (or not
included) in the assessment tool have been based on the available research in
the field of residential building energy use.[79]
3.78
The review of the program by Resolution Consulting Services found that:
The assessment software appears to be one of the key failures
of the system in two ways. Firstly, the development of the software appears to
have breached a number of procurement processes within the Department. Secondly
it did not work to a standard that could be expected and this was not detected until
after the trial was completed and the program had gone live.[80]
3.79
The ANAO's performance audit of the program found that a key reason for
the problems experienced with the assessment tool was the fact that it was
developed so late in the program-development phase. RMIT was only engaged three
months prior to the start date for the pilot program, and was asked to develop
an online component for the assessment tool only three weeks before the
'go-live' date for the entire program.[81]
Accordingly, the full tool was not available for the pilot program and there
was no testing phase for the assessment tool which would have enabled
modifications, which are standard on a software program of this scale and type,
to be made.[82]
Committee comment
3.80
Based on the evidence from householders, assessors and the reviews
conducted by Resolution Consulting Services and Ms Patricia Faulkner, it
appears to the committee that the tool was inappropriate, inadequate and highly
faulty. The key reason for the problems experienced with the assessment tool,
however, appears to be the fact that the developer was not given sufficient
time to develop and test it. This resulted from DEWHA's tardiness in
contracting the developer, as well as the speed at which the program was
implemented.
3.81
The committee is disappointed that the government wasted money on the
development and implementation of an assessment tool that was not able to give
constructive feedback about how householders might save energy. In the
committee's view, the provision of sub-standard assessments has undermined the
effectiveness of the Green Loans Program and nullified any benefit that it may
have had.
3.82
The committee makes a recommendation about the assessment tool to be
used in Green Start in chapter 7, in order to prevent failings that occurred in
relation to the quality of assessments in Green Loans from being repeated.
Speed of assessments
3.83
A further issue with the quality of assessments under the program
related to the time taken for assessments to be conducted. DEWHA paid assessors
$200 per assessment, and it appears from the submissions that this figure was
based on each assessment, including travel to and from the assessment by the
assessor, taking a total of two hours.[83]
The Sustainability Advice Team, an ACT company which has been conducting energy
audits and assessments of households since 2004, submitted that:
The two hour time allowed for the assessment and travel is
insufficient to do a competent and complete job of collecting and entering the
very large amount of data required by the assessment tool, except for very
small houses.[84]
3.84
Under the program, assessors were able to contract individually to
DEWHA, or conduct assessments as a nominee of their employer. The second
arrangement seems to have typically involved a company arranging and booking
assessments for assessors, in return for a portion of the assessment fee. For
example, Fieldforce entered into arrangements with assessors whereby it marketed
and booked assessments on their behalf in return for $100 of the $200
assessment payment.[85]
3.85
Mr Mark Walker, an assessor from NSW, submitted that assessors engaged
under these arrangements were routinely required to perform up to five
assessments per day.[86]
Mr Walker submits that the short timeframe this left for assessments resulted
in assessors being unable to perform thorough, high quality assessments:
It is widely known that many organisations involved actively
encouraged their employed assessors to perform in excess of 5 assessments per
day, in as little time as it was possible to do so, and claims of half hour
assessments and ‘ghost’ assessments are common.[87]
3.86
The evidence received from Mr Chorazy, a Fieldforce assessor, confirms
that:
...the Assessment scheme provided the opportunity for 5
assessments per day per assessor and Fieldforce contractors were achieving
these levels.[88]
3.87
Energy Makeovers submitted that it was not only companies encouraging
assessors to perform as many assessments as possible at the expense of quality,
but also individual assessors:
Further, there is an opportunity for unscrupulous assessors
seeking to minimise time on site (to reduce costs) to overly rely on “default
settings” at the expense of accuracy of the assessment outcome.[89]
3.88
As part of its performance audit of the program, the ANAO surveyed
householders who received assessments under the program. Almost half of those
who responded indicated that the assessment took less than an hour.[90]
Even more concerning was the small proportion of householders surveyed who
stated that they did not receive assessments under the program at all.[91]
Issues related to misuse of the program are discussed in further detail below.
3.89
Submitters argued that these practices impacted on the quality of assessments
and the integrity of the program.[92]
3.90
A number of submitters made the point that many of these issues with the
quality of assessments may have been prevented if there had been a system for
auditing assessors.[93]
3.91
In its submission, DCCEE informed the committee that it has been
directed by Minister Wong, who assumed responsibility for the program on 8
March 2010, to provide her with 'options to assure and improve the professional
standard of assessors contracted to the program'.[94]
3.92
However, the Minister's media release of 8 July 2010, announcing that
the Green Loans Program will be phased out but that assessments will continue
in the meantime, did not include any details of how these issues will be
addressed while assessments continue to be performed.[95]
Committee comment
3.93
In the committee's view, the issues relating to the quality of
assessments performed under the Green Loans Program would have been prevented
had basic processes been followed and implemented from the outset.
3.94
Like a number of the other problems with the program discussed above,
had the government not placed so much pressure on DEWHA to roll-out the program
by July 2009, RMIT would have been given more time to develop and test the
assessment tool and problems with the tool could have been ironed out prior to
the system being rolled out nationally.
3.95
The committee further considers that had DEWHA followed the proper legal
procurement procedures, it is possible that some of the issues with the
assessment tool may also have been avoided.
3.96
With respect to issues related to individual assessors performing
substandard assessments, the committee's view is that this issue would have
been avoided had adequate training and audit systems been in place.[96]
In addition to quality training, the government needed to have a system in
place whereby assessors were audited in order to ensure their quality. While
the government repeatedly promised that such an audit program would be put in
place, to date, more than 12 months after the program's commencement, and
seemingly right before its demise, no such program has eventuated. The
committee finds this unacceptable.
3.97
The committee makes a recommendation in chapter 7 on the need to
establish audit systems from the outset of the Green Start Program in order to ensure
the quality of assessments delivered under that program.
Problems with the booking system
3.98
Household assessments could be booked either by the assessor (or an
organisation acting on their behalf) or by a householder requesting an
assessment. Bookings were made through an outsourced call centre which was
managed by the Department.[97]
3.99
It was initially intended that bookings would be made online, however
the online booking portal was not developed until December 2009 to January
2010, immediately before the demise of the program, at a cost of over $1.3
million.[98]
Instead, the telephone booking system developed for the Household Insulation
Program was used throughout the Green Loans Program.
3.100
Almost every assessor who submitted to the inquiry complained about the
booking system and call centre. Predominantly, assessors were angered by the
amount of time it took them to book assessments while waiting on hold. Assessors
also noted flaws with other aspects of the booking system including its
accuracy and the lack of an online booking portal.
3.101
Assessors submitted that they waited on hold for up to three hours in
order to book assessments during December 2009 and January 2010.[99]
The Sustainability Advice Team, based in the ACT, submitted that:
Phoning to book assessments was extremely difficult. At the
worst, hold times were well over an hour. Between December [2009] and the end
of February [2010] we made a total of 201 calls, many very lengthy, to the 1800
Green Loans line in order to try and register our assessments, from which we
eventually booked about 30 assessments. From the 9th of February to
the 9th of March [2010] we made 136 calls to undertake a total of 10
assessments.[100]
3.102
The ANAO's performance audit contains details of the performance of the
call centre over the life of the program.[101]
At its peak, in January to February 2010:
- only one quarter of calls were entered into the call centre's
queue;
- three quarters of callers received a busy signal;
- only 6.3 per cent of calls from assessors were answered within
the target timeframe of 20 seconds; and
- the longest wait time was 2 hours and 35 minutes.[102]
3.103
Mr Tom Livanos, an assessor from NSW, submitted that when he called the
booking centre:
I was greeted with a message that the call centre had reached
its maximum capacity, that I should call again at another time and the call
then proceeded to an engaged tone. This is an event which is without precedent
in my life. It occurred repeatedly. When I did get through, it took over 90
minutes to speak to a call centre consultant.[103]
3.104
Ms Leanne McIntosh, a GLACO assessor, gave evidence that the long delays
experienced by assessors with the booking system were a key reason for
assessors contracting with marketing companies, including GLACO, which booked
assessments on their behalf. Ms McIntosh stated:
Seriously, three-quarters of the week was literally trying to
get the AN (Assessment Number) numbers and hit redial on the phone endlessly
and wait hours in the phone queue. If you were with GLACO they did that, so you
could be out assessing and actually working as opposed to sitting on the phone
with a sore finger.[104]
3.105
Mr David Cumming, Principal Consultant from Sustainable Evolution, an
assessor from NSW, argued that the booking system was 'emblematic of the
inefficiency of the Green Loans Program execution as a whole'.[105]
Mr Cumming explained:
In the age of the internet, online data, validation and
analytics, the Green Loans Booking Process was bizarre. No commercial
enterprise would force their field agents to phone a number in order to dictate
basic booking information to an operator to in-turn transcribe into a booking
system.[106]
3.106
In addition to long delays, assessors also complained about various
inaccuracies within the booking system:
Inadequate operation of the Department’s booking system meant
that on a number of occasions assessors did not receive email alerts of an
assessment booked by the system until the day of the booking or even, on some
occasions, after the assessment was supposed to be conducted. This made the
business delivering the assessments, and the individual assessor, look very
poor.[107]
3.107
Mr Cumming outlined various inherent problems with the booking system,
being that it was:
Slow – dictating, transcribing, correcting basic data input;
Error-prone – as operators inevitably made transcription
errors, which could subsequently impact programming invoicing and validation
procedures;
Costly – involving call costs many time more expensive than
online alternatives, and requiring the employment of a dedicated operator to
enter information that the caller could have so readily entered themselves via
an online portal;
Susceptible to Overloading – the obvious possibility of
hundreds if not thousands of assessors making multiple attempts to phone
through and then tying-up available lines while transcribing booking
information.[108]
3.108
Assessors involved since the beginning of the program informed the committee
that at the start the booking system 'seemed to be working well', and that it
was only the changes made in late 2009 plus the increasing number of assessors
using the system that led to its problems.[109]
3.109
However, the committee received evidence that certain actions by DEWHA
compounded the problems. For example, DEWHA announced as late as 24 December that
the booking line would be closed over the Christmas and New Year's period. Many
assessors were angry about this late notice. For example, Ms Larissa Nicholls,
an assessor from Victoria submitted:
On Christmas Eve assessors were given less than 2 hours by
DEWHA that the Green Loans booking line would be closed for an extended period.
Access to the assessor's online assessment bookings calendar had also been
removed. Assessors were required to lodge bookings with the call centre before
performing assessments so this unexpected closure prevented booking and working
for over 3 weeks. When the call centre reopened it was inundated. It took
several hours, or several days, of dialling and waiting on hold to book a
maximum of 5 assessments. Bookings were lost as householders were unimpressed
by the unexplainable delays.[110]
3.110
Apparently, in response to complaints about the booking system being
shut down for Christmas, DEWHA informed assessors that they should undertake
assessments and obtain booking numbers afterwards via email.[111]
However, Mr Walker, an assessor from NSW informed the committee that:
These “January email bookings” have largely been neither
recognised, nor provided with booking numbers, much less paid, leaving many
assessors seriously out of pocket for work they performed – with the best
intentions and with the Department’s tacit approval – and yet no solution has
been offered to rectify this gross oversight.[112]
3.111
With respect to these January 2010 email bookings, DCCEE informed the
committee that 'significant progress' has been made in processing them, and the
'majority of valid assessment bookings received in the period 14 January 2010
to 1 February 2010, when the temporary email booking system was in place,
have been processed'.[113]
3.112
Assessors submitted that they had great difficulty contacting DEWHA to
discuss and resolve these problems with the booking system.[114]
For example, Mr Trevor McTaggart, the director of GLACO, an
organisation which booked assessments on behalf of assessors, submitted:
We could not connect with a Manager in the [call centre].
They diverted their phones, redirected their emails or didn't bother to
respond. Complaints to the then Ministers [sic] Office bought no reply. The
Management were clearly hiding. They left the 'dirty business' to their staff.[115]
3.113
A number of assessors submitted that at the outset of the program,
assessors were led to believe that an online booking system would be
implemented.[116]
However, this online booking system never eventuated, at least for individual
assessors.
3.114
Ms Anne Leo, Acting Assistant Secretary, DCCEE, informed the committee:
I understand that the IT module to allow [online bookings] to
happen was developed, but it was ready around the same time that problems
started to emerge with the bookings over January and February [2010]. Part of
the problem at that time—what was slowing the performance of the booking
system—was releasing some of the modules. I was concerned that it would further
affect the performance of that system. Our focus at the time was on trying to
make sure we had a system whereby all assessors could make bookings quickly and
efficiently.[117]
Arrangements with Fieldforce
3.115
It has been alleged, both by assessors in their submissions,[118]
as well as in media reports,[119]
that one company, Fieldforce, was given priority access to the booking system
through an online portal.
3.116
Reports of Fieldforce's 'special treatment' angered assessors who were
forced to wait for hours on the phone to book assessments. For example, Mr
Simon Walsh, an assessor from NSW, submitted that:
Field Force being given a direct link into the Department’s
computer systems is unthinkable and highly inappropriate. While a small
business like ours was forced to endure call-waiting times in excess of 60
mins, Field Force were given special treatment and eventually siphoned away a
huge amount of the program’s allocated funds. The Department’s preferential
treatment of Field Force was unethical, highly inappropriate and I suspect it
is illegal according to laws that bind Federal Government Departments.[120]
3.117
DCCEE did not respond to this allegation in its submission. However, on
3 February 2010, Senator the Hon Joe Ludwig, then Special Minister of
State and Cabinet Secretary, informed the Senate that:
Fieldforce is the single largest operator under the Green
Loans Program, and to accommodate this, they make bulk bookings which are
processed by the Department once a week.
These bookings are subject to a weekly limit, in order to
ensure there is adequate work for all assessors.
Jobs are available to all assessors, whether they are
individuals or part of a company.
Over half the assessors contracted to the Department (59 per
cent) choose to operate as sole traders, and are provided with bookings
generated via the call centre. Work is allocated equitably.[121]
3.118
Mr Roland Chorazy, an assessor who participated in the program through
Fieldforce, outlined the benefits of working with Fieldforce. He stated that:
Press reports indicate that the committee has had many
complaints from individual assessors of ‘unfair ‘competition from Fieldforce
which has been very effective in this market. I seek to give some balance to
the committee’s evidence by presenting the experience of a Fieldforce assessor...
Fieldforce has the great advantage of a professional
marketing team and a large database freeing me from cold calling and selling.
It is no surprise to me that many independents are having difficulty.[122]
3.119
In its evidence to the committee, Fieldforce explained how they had come
to have online access to DEWHA's booking system. Ms McClelland, Chief Operating
Officer, Fieldforce, informed the committee that Fieldforce had repeatedly
raised concerns about the booking system during August and September 2009:
In September I rang the department and asked them for a
meeting. I travelled to Canberra and provided them with a large document
of issues with the program... [Officers from the department] suggested that we
start to work with them on alternative ways to redesign some of the processes.[123]
3.120
Ms McClelland told the committee that the department suggested that
Fieldforce develop a 'SOAP' interface[124]
'to interface our system into their system'.[125]
The department attempted to develop its own portal, but according to Ms
McClelland, they 'got it all wrong', and 'at that stage they decided that the
best way to do it was for us to do a B2B [business-to-business] interface via
SOAP into their system'.[126]
This involved Fieldforce implementing 'five daily file transfers' from 7
December 2009 forward.[127]
3.121
Mr Timothy Ryerson, Executive General Manager, Fieldforce, further
explained that:
...because we [Fieldforce] were so intimately involved from the
beginning—we were actively providing advice—that, when the department saw that
they were starting to have issues with their call centre and the number of people
involved in it, they actively pursued a solution which would enable the
assessors working for Fieldforce to reduce the burden on their call centre.
This is the reason why they entered into what was called a call centre
agreement, which effectively was just a file transfer of our appointments.[128]
3.122
Furthermore, Mr Ryerson gave evidence that if any other company had
approached DEWHA requesting the same arrangement as Fieldforce, Fieldforce
would not have objected as 'trying to find alternatives in any way possible at
the height of the program was probably a good idea'.[129]
Ms McClelland stated that she had assumed the department was 'talking to other
organisations about B2B interfacing between the systems'.[130]
3.123
When asked how Fieldforce came to be in the position of having this
'special arrangement' and whether they had provided any payment to DEWHA, Mr
Ryerson stated:
Fieldforce were involved in providing advice because we are
experts. We have been running these programs for 17 years, so naturally [DEWHA]
came and gravitated to us to ask for help. We have received nothing apart from
the contract that we signed [to train 300 plus assessors].[131]
3.124
Ms McClelland also informed the committee that on numerous occasions Fieldforce
offered their booking system to DEWHA free of charge:
I could have set up our system with every assessor. It would
have taken me a week and they could have gone online, typed in their HO number
and a booking. It would have fed via the five-fold transfer process that we set
up in December [2009] automatically into the DEWHA systems and we could have
solved a lot of the problems.[132]
3.125
Yet DEWHA apparently chose to ignore the solution proposed by
Fieldforce. When asked why the government did not take up Fieldforce's offer,
DCCEE advised that it does not have any record of having received such an offer
from Fieldforce.[133]
3.126
The Faulkner review of procurement processes and contractual
arrangements found no misconduct with respect to the arrangement between
Fieldforce and DEWHA. According to that review the Memorandum of Understanding (MOU)
between the organisations did not involve any financial obligations.[134]
3.127
However, regardless of the fact that no money was exchanged in return
for this special arrangement with Fieldforce, the ANAO has found that 'it
allowed Fieldforce to gain a market advantage'.[135]
Committee comment
3.128
As discussed above, the problems experienced with the booking system
were directly related to the government's lack of foresight and planning
regarding controlling assessor numbers.
3.129
Furthermore DEWHA was obviously not prepared, nor resourced, to handle
the significant escalation of the program when it occurred. According to the
Faulkner review, the contract for the call centre blew out from $770 000 to
$3.4 million.[136]
A cost blow-out of this scale clearly shows that DEWHA lacked the project
management expertise to plan for and manage a program of this nature and size.
3.130
While it is understandable, particularly from Fieldforce's perspective,
how the arrangement between Fieldforce and DEWHA came to be at a time when the
call centre was under significant pressure, the committee is not satisfied that
the arrangement was appropriate. It is possible that the arrangement reduced
the call centre constraints by diverting what would otherwise be a significant
percentage of assessment bookings. However, any small advantage this may have
provided to assessors generally, was more than offset by the disadvantage they
experienced by having to book through the inefficient call centre.
3.131
The arrangement was also far from transparent: the Faulkner review found
that the DEWHA Executive and Minister Garrett were not informed of the
arrangement;[137]
and no other assessors or assessor organisations were offered such an
arrangement. This lack of transparency casts doubt on the findings of the
Faulkner review that the agreement was reached 'in good faith'.[138]
3.132
Thus, in the committee's view, while perhaps not illegal, the entry into
a special arrangement with Fieldforce by DEWHA was grossly unfair to other
assessors and highly improper. The committee makes a recommendation to this
effect in chapter 7, in order to prevent the problems that occurred under
Green Loans from being repeated in the Green Start program.
Misuse of the program
3.133
The submissions received by the committee contain allegations of the program
being 'rorted' in various ways. These 'rorts' included:
- aggressive cold calling, and using misinformation to generate
assessments;
- certain companies using the program predominantly to promote
their products; and
- companies which employed assessors requiring them to perform five
or more assessments per day, as discussed above at paragraph 3.83 ff.
3.134
It was suggested by a number of submitters that some of the companies
which entered into 'organisation contracts' under the program and marketed and
booked assessments on behalf of their assessors, used dishonest means to urge
householders to book assessments.
3.135
For example, as the operator of the ACT home energy advisory service,
the Sustainability Advice Team received complaints about the program of:
...aggressive cold calling from lists apparently compiled as
a result of previously supplying compact fluorescent light bulbs under the NSW
Greenhouse Gas Abatement Scheme, followed by setting times against the will of
the householders (a particular concern of elderly householders).[139]
3.136
The committee also received anecdotal evidence of assessors misleading
householders into believing that if they did not agree to an assessment now,
they would be required to pay for an assessment themselves in the future:
I have heard stories of assessors door knocking, cold calling
and marketing practices in retirement villages using mandatory disclosure and a “get it done now or you’ll have to pay for it later” tactic being employed.[140]
3.137
A number of assessors also alleged that some companies which manufacture
or sell environmental products, such as solar panels or water heating systems,
became involved in the program as a means of promoting their products.[141]
For example, Dr Roger Severn, an assessor from Western Australia submitted
that:
Many of the candidates [in the Assessor training course] were
sales support employees of companies engaged in selling environmental services
such as solar panels and hot water systems.[142]
3.138
This conflict of interest is argued to have diminished the value of the
assessments performed by those companies, and to have been in contravention of
the contract that assessors signed with DEWHA.[143]
Mr Mark Walker, an assessor from NSW argued:
It is also clear that these many organisations blatantly breached
the conflict of interest provisions of the Contract by encouraging their ‘assessors’ to up-sell products and services of their own or linked businesses,
contrary to the specific terms of the Contract.[144]
3.139
Specifically, subclause 17.1 of the DEWHA assessor contract provides
that:
(a) The Assessor must act impartially at all times and provide Assessments
that are accurate, independent and free of commercial influence.[145]
3.140
Subparagraph 17.1(b)(ii) further states that Assessors must not:
...direct Householders towards a range of products or
services developed or supported by an enterprise with which the Assessor is
associated or from whom the Assessor receives a commission or other benefit.[146]
3.141
These obligations are also included in the Assessor Code of Professional
Practice.[147]
3.142
However, there was no auditing of assessors or the quality of their
assessments under the program, or of their compliance with the Code of
Professional Practice.[148]
3.143
Dr Severn submitted that he questioned DEWHA on this issue, and was told
that:
...it was alright to re-contact the householder on behalf of an
employer once the Household Assessment Report had been issued. In other words,
the information received in order to carry out the household assessment can
then be used for another purpose namely as a sales lead. This advice from DEWHA
is at odds with their own contracts and the code of practice for assessors.[149]
Committee comment
3.144
As with many of the other problems that occurred within the Green Loans
Program, the issue of misuse of the program would likely have been circumvented
had an audit system been built into the program.
3.145
In the committee's view it is unacceptable, but entirely predictable
given the lack of program regulations and controls, that such practices were
allowed to take place under a federal government program.
3.146
The committee makes a recommendation in chapter 7 about the necessity of
implementing proper audit processes in the Green Start Program right from the
outset, in order to prevent widespread misuse such as occurred under the Green
Loans Program.
Payments to assessors
3.147
Under its contract with individual assessors, DEWHA agreed to 'make
payment of a correctly rendered invoice within 30 days after receiving the
invoice'.[150]
3.148
However, according to many assessors, this did not occur. For example, Mr Shayn
Harkness, an assessor from Tasmania, submitted that he is yet to receive
payment for assessments conducted in November 2009, and 'cannot access a
responsible person by phone or email to resolve this problem'.[151]
3.149
In response to this issue, DCCEE stated in its submission that:
The 30-day timeframe for payment applies from the date at
which a complete and correct invoice is received. Some delays in relation to
the payment of invoices have been experienced by some assessors, while there
have also been problems with some assessors submitting incorrect invoices.[152]
3.150
In order to address these delays, DCCEE informed the committee:
...a template has been developed for assessors to use, along
with a step-by-step guide to filling in the template. Departmental staff have
also been contacting assessors directly if they have submitted an incorrect
invoice to explain what needs to be fixed... In addition, the Department is
allocating additional resources to invoicing. As a result, the throughput of
invoices has increased by 50 percent in recent weeks. Overtime shifts are planned
until the backlog of invoices has been cleared.[153]
3.151
At the committee's public hearing on 29 June 2010, Mr Malcolm Thompson,
Deputy Secretary, DCCEE further informed the committee that:
Correctly rendered invoiced are currently being paid within
the 30-day time frame. There has been a significant reduction in the number of
outstanding inquiries and complaints, although a reasonable number of those
remain and we are working on reducing those further.[154]
Committee comment
3.152
The committee expresses its strong disappointment with the government
not meeting its payment obligations to individual contractors. The government's
tardiness would undoubtedly have created serious cash-flow problems for many
assessors.
3.153
As with call-centre delays and delays in issuing contracts, the
government's delay in paying assessors was a direct result of the lack of
control DEWHA had over various aspects of the program, and particularly
assessor numbers. It also reflects the serious lack of project management
expertise within DEWHA.
3.154
In chapter 7, the committee makes a recommendation on payments to
assessors, in addition to recommendations about ensuring that DCCEE has
appropriate expertise within the staff managing the Green Start Program, in
order to prevent the failings of the Green Loans Program from re-occurring.
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