Department of Education, Employment and Workplace Relations

On this page:

• Client outcomes
• Support for Centrelink decision-making
• Referrals to employment services
• Communications with employment service providers
• Multiple Assessments
• JCA Guidelines and Processes
• The JCA Report
• Quality
• Regional and remote Australia
• The Job Capacity Account
• Complaints
• Governance and communications within Government

Client outcomes

Because the JCA is only one step in the process for clients seeking income support or employment assistance, it is not possible to attribute client employment or income support outcomes to the JCA itself. However, it is important to ensure that the JCA contributes to good outcomes for clients by making appropriate referrals to employment assistance and providing the right information to assist Centrelink decision-making.

DHS is currently in discussions with Centrelink about undertaking client feedback surveys later in 2008, to provide information on client perspectives.

In the interim, DEEWR has provided a graph showing outcomes for JCA clients who were on income support when they were assessed (almost all clients).  This shows that, six months after assessment, the percentage of clients on income support without earnings had fallen from 91 per cent to 76 per cent. Thirteen per cent had become self-reliant within six months while those on income support with earnings increased from 9 to 11 per cent. (Graph 1: Outcomes for Assessed Clients who were on Income Support at the time they had their JCAs).

This is a promising result, given the short time period and the nature of JCA clients: all of them have barriers to work, by definition. Around half of referrals to JCA are related to Disability Support Pension, Partial Capacity to Work and medical exemptions from activity testing of over 13 weeks’ duration. 

Graph 1: Outcomes for assessed clients who were on income support at the time they had their Job Capacity Assessments

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Support for Centrelink decision-making

About 50 per cent of assessments are undertaken to inform Centrelink decisions about Disability Support Pension, Partial Capacity to Work and exemptions from activity-testing due to medical conditions. The remainder relate to employment service referrals, including change of circumstances.

Acceptance by Centrelink

The JCA report is stored on the DEEWR EA3000 Smartclient system.  Centrelink is able to reject JCA reports and return them to the original Job Capacity Assessor through the EA3000 system. 

Of the 608,081 JCAs submitted from 1 July 2006 to 4 February 2008, only 3,109 (0.49 per cent) were returned because they were clearly unsatisfactory.  (Table 2: JCA Reports returned by Centrelink as incorrect)

This does not include reports returned for additional information to be added, or at the request of the Assessor. This result is consistent with the findings of independent quality assurance audits that only around two per cent of JCA reports were unsatisfactory (see under Quality below).  

Appropriateness

The appropriateness of JCAs to inform Centrelink decision-making is difficult to quantify; however, the available data shows that JCAs consistently inform decision-making over time.

A higher proportion of cases are referred for assessment than under the previous Better Assessment arrangements; however, the overall rate of grants and rejections has remained stable. (Graph 2: Disability Support Pension Grants. 2005-2007)

Graph 2: Disability Support Pension Grants, 2005-2007

Stakeholder views

In general, the industry considers that JCA support for Centrelink decision-making is working well.

It is the view of the industry that JCAs policy and procedure relating to the provision of recommendations and information to Centrelink to inform income support decisions in accordance with the Social Security Act is working effectively.  (NESA, response to JCA Review)

As discussed previously however, some stakeholders consider that the current arrangements do not always support the best use of medical evidence and understanding of the client’s medical conditions. This issue is addressed in Chapter 2 under Qualifications of Job Capacity Assessors.

Centrelink, in its capacity as the income-support decision-maker, considers that ‘generally, the JCA program is operating well and as expected’, butthat there is some capacity for JCAs to provide more effective support for Centrelink decision-making and the review and appeal process by improving their understanding of legislative requirements, particularly around medical conditions.

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Referrals to employment services

Increases in referrals to employment services

Referrals to employment services have increased significantly since the introduction of JCAs.  Under the Early Intervention Pilots, 48 per cent of people were referred to an employment service.  When the JCA Program commenced in July 2006, 74 per cent of completed assessments resulted in a recommended referral to an employment service, which has now risen to just on 83 per cent of completed assessments (Table 3: Referrals to Employment Services by Reason for Assessment).  Referrals are analysed in more detail in this section.

Note: Referral data for JCAs relates to recommended referrals whereas the Early Intervention Pilot data relates to actual referrals. Changes to policy and process have also affected service referrals.

Currently 83 per cent of JCAs recommend a referral to a DEEWR employment service.  Job Network is the most common referral type, accounting for 39 per cent of recommended referrals. There are no specific targets for referrals to employment services; however, DHS encourages JCA providers to refer to employment services whenever the client could benefit from employment assistance, and monitors individual providers to ensure that referral patterns are appropriate and consistent (Graph 3: Recommended Referrals by Employment Service Type, 2007-08).

Graph 3: Recommended Referrals by Employment Service Type, 2007-08

The rate of referral to employment services rose steadily from the introduction of JCAs, from under 74 per cent of referrals, peaking at 83.3 per cent in the three months September 2007.  The dip in the three months to December 2007 was due to a larger proportion of referrals related to Disability Support Pension  (Graph 4: Rate of Referrals to Employment Services, 2006-08).

Graph 4: Rate of Referrals to Employment Services, 2006-08

The mix of referrals to the various types of Employment Services has varied somewhat since the commencement of the JCA program, but has been relatively steady since January 2007 (Graph 5: Trends in Referral to Employment Service Type, 2006-08). 

Graph 5: Trends in Referral to Employment Service Type, 2006-08

Referrals for people seeking income support decisions

As outlined above, around 50 per cent of referrals for JCA are to inform Centrelink decisions related to Disability Support Pension, Partial Capacity to Work and medical exemptions from activity-testing.  Referral to employment services is not always appropriate for these clients, and some may already be working, for instance in part-time work or through the Supported Wage System.

Three-quarters of JCAs that did not result in a recommended referral to an Employment Service were for people who had a Disability Support Pension-related JCA.  The majority of other non-referrals were for people with medical certificates (Graph 6: Reason for non-referral to an Employment Service).

Graph 6: Reason for non-referral to an Employment Service

However, referrals to employment services for people seeking income support decisions have increased significantly since the JCA Program was introduced.

• 56 per cent of JCAs for Disability Support Pension claimants conducted between 1 July 2007 – 1 Feb 2008 had a recommended referral to employment services.
• Only around 8 per cent of Disability Support Pension claimants were referred to services under the previous Better Assessment arrangements.
• Only 38 per cent of Disability Support Pension claimants were referred to services under the Early Intervention and Engagement Pilot 2005-06. 
• About 50 per cent of clients seeking a temporary incapacity exemption have a recommended referral to employment assistance (referral may be deferred due to illness).
• About 39 per cent of clients seeking their second or more temporary incapacity exemption also have a recommended referral to employment assistance (referral may be deferred due to illness).

People applying for disability-related income support or out of the workforce due to illness are identified by the OECD as a high priority for assessment and support, as being as being at high risk of long term income support dependence.

In fact, the OECD recommends in its recent report that Australia introduce Job Capacity Assessments for people on extended sick leave from their employment.  This is outside the scope of the JCA Review. ⁷

Appropriateness of referrals

While taking a positive view of the effectiveness of JCAs in income support decision- making, NESA considers that:

In contrast, recommendations about service access are proving more controversial.  The current requirements for allied health professionals are supported; however policy and processes do not allow these skilled professionals adequate scope to exercise professional judgement. …

NESA has presented a number of JCA recommendation case studies to DEEWR for review.  In each case it was clear that the JCA recommendation was correct according to policy and equally clear that the service needs of the job seeker were not going to be appropriately met by the recommended service. (NESA, response to JCA Review)

In some cases, a Job Capacity Assessor refers a client to a service which is not ‘best fit’, because the client does not disclose important information. For example, they may not disclose a medical condition, or that they are already connected to an employment service provider, or have recently been with an employment service provider, who may have key information.

In some cases, an inappropriate referral can occur because the Assessor did not contact the doctor or employment service provider, or was not able to get in touch with them.  Hence the Assessor may not have all the information needed to make the right decision.

Unfortunately, some employment service providers can be inclined to blame the Job Capacity Assessor for referring clients who are not ‘best fit’, when the Assessor had no choice under current policy settings and systems. 

• This is a particular issue for clients who have significant mental or physical health problems but cannot or will not provide medical evidence.  Appropriate medical evidence is required to refer clients to Disability Employment Network or Vocational Rehabilitation Services, or to assess them as having Partial Capacity to Work and reduced participation requirements.
• These clients may be referred to Job Network with an assessed work capacity of 30 hours a week, leading to frustrations for the employment service provider and the client, as they are not ready for work and cannot meet participation requirements.

Disputed referrals

When an employment service provider disagrees with a JCA referral, they need to contact the Job Capacity Assessor as soon as possible, because the Assessment becomes ‘finalised’ on the EA3000 system after 28 days, or when Centrelink makes an income support decision if this is earlier - and it generally is. 

• After that, the JCA cannot be changed and the only option if the employment service provider cannot assist the client is to refer them for another JCA, which is time-consuming and disruptive, particularly for the client, and costly to government (see discussion about Multiple Assessments, below).

If discussions between the Assessor and the employment service provider do not resolve a dispute, the employment service provider can raise the issue with their DEEWR contract manager, who may refer it to DHS.

• Between 1 January 2007 and 20 February 2008, 39 per cent of all issues (or around 80 cases) raised by employment service providers related to appropriateness of referrals.  This was out of 204 issues. During this period, around 380,000 assessments were completed.

While NESA notes that the capacity for employment service providers to discuss and challenge referrals is a welcome feature of current arrangements, it recommends a more formal mechanism to review disputed referrals, and an extension of time in exceptional circumstances. DHS is currently working with providers and DEEWR to develop an improved process for disputed referrals.

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Communications with employment service providers

Employment service providers report that the quality of their communication with Job Capacity Assessors is mixed, with some providers having very strong relationships with particular Assessors, while finding that JCA staff turnover and time constraints on both parties can sometimes lead to failure of communication and mutual frustration. Staff turnover for employment service providers can sometimes also be an issue.

Maximum Solutions Australia reports from its perspective as both a JCA and employment service provider:

Generally the relationship between JCAs and employment service providers are very positive.  Frustration only occurs when clients are referred that are unsuitable or unable to work.  …lack of places in [employment services] also leads to many jobseekers being referred to the Job Network that really need more specialist assistance if they are to make the transition to work. (Maximus Solutions Australia, response to JCA Review) ⁸

At the extreme, ACE (the peak Disability Employment Network provider organisation) found in its State of the Sector Survey for 2008 that most Disability Employment Network providers were ‘unsatisfied’ or ‘very unsatisfied’ with the JCA process.  As noted in Chapter 2 however, Disability Employment Network providers previously direct registered clients without independent assessment, and many would prefer a return to these arrangements.

ACE notes that:

Disability Employment Network providers frequently comment on the turnover of Job Capacity Assessors in their area. Consequently they are frequently dealing with inexperienced Job Capacity Assessors. This means that Disability Employment Network providers are expending time and energy re-establishing relationships and re-educating the new Job Capacity Assessor about what the local Disability Employment Network can provide in terms of service.

It is postulated that the cause of the turnover is lack of job satisfaction, stemming from the time demands on Job Capacity Assessors but also that the rigidity of the system leads to high levels of frustration and a perceived lack of use of the Assessor’s professional skills. (ACE, response to JCA Review)

Clients already linked with an employment service provider

Job Capacity Assessors currently refer clients to a specific employment service provider (within a service stream such as Vocational Rehabilitation Services) based on a drop-down menu of available providers on the EA3000 system.

If the client does not tell the Job Capacity Assessor that they are already with a particular provider, or previously worked with that provider, they may be sent to a different provider.  The client then has to start over again with a new provider, and the first provider may then lose the client just as they were about to place them in employment and achieve an outcome payment. 

The June 2008 systems release enabled JCA providers to view employment service providers’ exit reports for the first time. Previously, there were unable to access these. While this is a significant improvement for clients who have left their employment service provider, there is currently no facility to alert Assessors that the person is still linked to an employment service provider, who may be unaware that they are having a JCA. DHS is working with DEEWR on this issue.

ACE gives an example of a client who had been with a Disability Employment Network provider for 12 months, and was transferred to a Vocational Rehabilitation Services provider following a review of her Disability Support Pension. The client then sought to return to her previous Disability Employment Network provider. In this case, the Job Capacity Assessor may not even have been aware that the client was already with a service.

Many of our participants are only now considering employment as an option because they know we have a partnership arrangement with their clinic and case manager. …This model helps to make the transition to job search … a much less daunting task for them because… we are working alongside them, and also their health professionals. When participants go through the JCA process and are not referred back to the employment provider supporting them through this process, many stop engaging in the employment process altogether. …Consideration must also be made to providers who have made the effort to source the referrals in the first place and are supporting the participant through the JCA process. (Mental Illness Fellowship Victoria, response to JCA Review).

Networks and partnerships

DHS and DEEWR strongly encourage JCA and employment service providers to improve communications by developing strong networks with each other, for example by attending local forums and conferences and taking opportunities to meet with and present to staff in other organisations.

JCA providers often have both formal and informal meeting arrangements with employment service providers, including regular forums to share information and discuss issues.  Many JCA providers and employment service providers already have strong partnerships and networks at both the organisation and practitioner level, due to a long history of working together locally to assist clients. Many JCA providers are themselves also employment service providers, which facilitates linkages and information sharing.

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Multiple Assessments

Current policy settings are that a JCA remains current for two years, unless there is a significant change in circumstances, such as significant new medical evidence. 

The JCA Program commenced in July 2006 and in the 15 months of operation to September 2007, the average number of completed assessments for each client who underwent a JCA was 1.3. 

• A total of 23.6 per cent of clients had undergone more than one JCA:
• 19.7 per cent had 2 JCAs;
• 3.5 per cent had 3 JCAs; and
• 0.4 per cent had 4 or more JCAs.

Thirty-six per cent of multiple JCAs were for clients who applied for Disability Support Pension after they had already had one or more JCAs.

• Job Capacity Assessors do not complete the Impairment Tables for a client who is not applying for Disability Support Pension, but this is a requirement for clients applying for Disability Support Pension under the Social Security Act 1991. Currently, the impairment tables do not display on the system unless the reason for referral is related to Disability Support Pension. For this reason, clients may also require a second JCA if they apply for Disability Support Pension after their first JCA has been finalised.

A further nine per cent were due to multiple medical certificates, usually for clients applying for an extended exemption from activity-testing.

As discussed above, the other main reason for repeat JCAs is that the employment service provider, or the client, considers that the current employment service referral is not working out, or that the client was not referred to the correct ‘bandwidth’ in terms of hours of work capacity.

A proportion of clients will always need a reassessment within two years due to a significant change of circumstances. However, the current rate of re-assessments could be reduced by:

• making sure the right medical information was provided at the first JCA;
• better communications between employment service providers and Job Capacity Assessors;
• better training for Assessors; and
• changes to employment service arrangements, as proposed by the Employment Services Review.

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JCA Guidelines and Processes

The current JCA Guidelines are comprehensive and supported by a number of task cards which take Job Capacity Assessors through the more complex processes step by step.

The JCA Guidelines now provide comprehensive details of the technical process required to complete a JCA. Regular updates to the Guidelines have been consolidated for service providers and have resolved a range of implementation problems…However, it has been noted that the JCA Guidelines have become increasingly prescriptive in nature… (CRS Australia, response to JCA Review)

Service providers acknowledge that the JCA Guidelines are invaluable and that individual sections are clearly written and helpful, but consider that overall the Guidelines have become too complex and prescriptive, both because they have been added to and revised frequently over the last two years, and because they set out income support and employment services arrangements, process, contract and systems requirements that are themselves complex and multi-layered.

The JCA Guidelines are highly complex in terms of policy and structure. The combined effect of this complexity has significant issues in terms of correct application of policy as well as training and retention issues.

Structurally, the information provided in the Guidelines is extremely fragmented and unwieldy in design.  …For example, to ensure a correct referral to a Disability Employment Network, an assessor would need to first consult section 2.3 to understand the nature of the service, then section 2. 9 to ensure eligibility, then sections 4.11.3 and 4.11.5 to ensure the duration and type of Support Requirements are correct, then section 9.3 and finally section 11.4.  The Guidelines need to be streamlined so that all relevant information is grouped together to assist assessors in correctly understanding complex policy.

The Guidelines have significantly increased in size to …over 300 [pages], plus guidelines on the Jobseeker Classification Instrument, vulnerability guidelines and task cards and other attachments located on the learning centre…revisions and changes have ranged in frequency from bi-monthly, to monthly, and now quarterly  arrangements have been established in consultation with DHS. (Mission Australia, response to JCA Review)

The JCA Guidelines are not currently available on line. As a downloadable document, providers report that they are difficult and time intensive to search.

Specific issues

Within the Guidelines, JCA providers, employment service providers, Centrelink and review and complaints bodies agree that there are particular issues that cause confusion and misunderstanding.

i. Permanency

The main issue causing confusion is that, in line with DEEWR policy, the word ‘permanent’ has two different definitions, depending on whether it is used in relation to qualification for Disability Support Pension or partial capacity to work and access to employment services.

Under the Social Security Act 1991, ‘permanent’ for Disability Support Pension purposes means expected to last more than two years and ‘diagnosed, treated and stabilised’.

However, for eligibility for Vocational Rehabilitation Services and Disability Employment Network, the DEEWR policy requirement is that ‘permanent’ means that the condition is diagnosed and expected to last more than two years.

This is an important distinction in practice, because it allows people to receive Disability Employment Network and Vocational Rehabilitation Services, even though their condition may not be fully treated and stabilised.

A further distinction in relation to permanence of disability is made for people with partial capacity to work. While the legislation does not use the term ‘permanent disability’, the concept is similar. For partial capacity to work, a person must have a physical, intellectually or psychiatric disability which prevents them from working 30 hours a week independent of support, or being trained for such work, within the next two years. There is no requirement for the impairment to be ‘diagnosed, treated and stabilised’.

As the Commonwealth Ombudsman has pointed out, the meaning of ‘treated and stabilised’ is itself somewhat problematic, leading to people who are very ill, or even dying, having Job Capacity Assessment appointments scheduled because their prognosis is unclear, they are under treatment and their condition is unstable. This is a particular issue for people undergoing treatment for cancer and other very serious conditions.

ii. Medical evidence

In Chapter 2, the Report discussed the issue of clients who refuse to provide medical evidence being referred to Job Network with an assessed work capacity of over 30 hours.

Equally, medical evidence requirements are frustrating, and can be perceived as insulting, for clients with stable physical disabilities which do not require treatment, such as permanent blindness or amputation.

• For example, Vision Australia reports that one client who had lost her eyeballs was required to provide medical evidence that she was permanently blind, while amputees have also been required to provide medical evidence that a limb is missing.

Stakeholders support a more sensitive and practical approach to dealing with this issue.

iii. Hours of work and temporary incapacity

Other issues relate to employment service eligibility criteria other than the client’s support needs, such as hours of work or restrictions for people on Disability Support Pension.

• An example is that current policy states that a client with a temporary work capacity of less than eight hours per week is not eligible for Vocational Rehabilitation Services, but a client with a current capacity of less than eight hours per week is eligible. Assessors are required to follow this policy, but to the employment service provider and the client, the referrals appear contradictory because two clients who ‘look’ the same can be treated differently.
• Another example is a client whose condition is ‘temporary’ because its prognosis is unclear:

To take a typical scenario, a job seeker is assessed … as requiring Vocational Rehabilitation Services [and]… has a medical diagnosis of ‘back problem’, which must be classified as a temporary condition under Social Security rules as it is not clear that the condition will last for more than two years. Given this, the jobseeker must be classified as having a ‘current and future work capacity of 30 hours + a week’ despite the fact that this supposed ‘temporary’ disability has a material impact on their work capacity. …Under the existing arrangements, the jobseeker can only be referred to a fixed (capped) Vocational Rehabilitation Services place (CRS Australia, response to JCA Review).

NESA and other stakeholders also consider that the current arrangements do not recognise the importance of factors such as client aspirations.  

• As an example, clients who have 30 hours plus assessed capacity can be very difficult to assist if they are uncooperative or lack motivation. On the other hand, people who may have a low assessed work capacity (0-7 hours) due to the severity of their condition, but are highly motivated to work, can exceed their expected capacity with the right support.

Within the current employment services framework, eligibility has been constructed around assessed work capacity and income support type.  This has created an inter-dependency which results in JCA recommendations which do not reflect ‘best fit’. A review of international streaming models demonstrates an increased move away from models which create such interdependences in acknowledgement that they are counter-productive. (NESA, response to JCA Review)

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The JCA Report

Many employment service providers note that the availability of the JCA report to the employment service provider is a substantial improvement on previous arrangements, where the employment service provider generally received very little information about the client.

It is the view of providers of employment assistance that since the introduction of JCAs there has been a significant improvement in access to and the quality of information they receive in assessment reports. (NESA, response to JCA Review)

However, some providers consider that Job Capacity Assessors are not providing sufficient information in the report. ACE has suggested that this is due to Assessors’ focus on getting the data entered during the interview ‘to save time, as they are inadequately funded’. 

In fact, the system design and processes were premised on the Job Capacity Assessor writing up the report during the interview.  As an example, they cannot refer a client to an employment service without the client agreeing to the choice of service provider, but the system does not allow them to choose the service provider until they have finished the report and referral recommendations.

In theory, this means that the client needs to wait while the Assessor writes a comprehensive report, checks the report against the client’s documentation and if necessary contacts the client’s doctor, mental health worker or employment service provider or other support person.  As this is generally impractical and inappropriate, most Assessors finish the report later and ring the client to discuss choice of employment service provider.

The report format can interfere with providing sufficient information in a logical manner. Centrelink and other JCA service providers note that some fields in the report have very limited number of characters, so that the Assessor can often not enter sufficient information to explain their findings (this has partly been addressed by the March 2008 DEEWR systems release). 

The report is divided into a series of fields which, until the June 2008 DEEWR systems release, could not be viewed at the same time or as whole, leading to disjointed reports with duplication and in some cases internal inconsistencies. Some specific issues with functionality are further discussed in Chapter 4 on Systems.

JCA providers note that the art of writing a good and comprehensive report within current systems functionality takes some time to master, so current staff turnover levels can reduce the quality of reports. 

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Quality

Many stakeholders consider that the complexity and inflexibility of current policy and program settings is adversely affecting the quality of JCAs.  

Notwithstanding these factors, reports, on the whole, appear to be of good quality. Centrelink rejects less than 0.49 per cent of reports as incorrect (see under Support for Centrelink decision-making). In addition, ongoing audits of JCA reports by independent allied health professional auditors show that 98 per cent are satisfactory or better, with only 2 per cent containing errors which could lead to incorrect outcomes. This audit process is discussed in further detail below.

JCA Reports

In January 2007, DHS engaged an organisation to conduct independent quality assurance audits of the quality of JCA reports. The allied health professional auditors are required to review the JCA report as well as the medical evidence available to the Assessor. A total of 1,012 audits were conducted in 2006-07, with another 1,301 in 2007-08.

The overall finding by external quality assurance auditors has been that around 98 per cent of JCA reports are satisfactory or better in terms of comprehensiveness, internal consistency, usability, appropriateness and sensitivity.

After the initial start up period, the auditors now provide ratings for all reports being audited. Of the 57 per cent of JCAs for which the auditors provided ratings from 1 July 2007 to 10 January 2008:

• 22.9 per cent were rated as excellent;
• 49.2 per cent were rated as good;
• 25.8 per cent were rated as satisfactory; and
• 2.1 per cent were rated as unsatisfactory (Graph 7: Quality of JCA Reports). 

Graph 7: Quality of JCA Reports

Reports are rated satisfactory if they do not contain any technical errors that are likely to affect the outcome for the client, such as through income support decisions, activity test requirements or program referrals.  Any such errors are subsequently corrected.

Qualitative feedback from the external audit team is that the overall quality of JCA reports has improved significantly over the course of the program. 

Interaction between quality and complexity

The complexity of current requirements increases the risk of an unsatisfactory report.

• For example, eligibility for Disability Employment Network and Vocational Rehabilitation Services is determined by complex combinations of checked boxes and ‘periods of support’ requirements. Sometimes these are built into the system (meaning that if the Assessor ticks the wrong box, a referral is prevented), and sometimes these are outlined in policy. 

A small audit sample was conducted recently to assess the implementation of a policy clarification around the definition of permanency, which was not only difficult to understand and administer (see above), but involved a complex manual workaround for Assessors.

• This audit showed that only 1 (0.76 per cent) of 150 clients received an incorrect partial capacity to work status, which was subsequently corrected. None of the clients had received an incorrect income support decision.

The impact of systems limitations on quality is addressed in Chapter 4 under Systems. This section also discusses recent and planned improvements to systems functionality to support more efficient and better quality assessments.

Following considerable work with JCA providers, the National Employment Services Association and other stakeholders, a new JCA quality assurance framework was introduced from 1 July 2008, with scoring and weighting against a number of key criteria, such as appropriate use of medical evidence. This will enable more rigorous assessment of the quality of reports and for a sound basis for comparative assessment of provider performance.

Other aspects of quality and performance measurement

DHS measures performance for the JCA and Job Capacity Account programs, and JCA service provider performance, against Key Performance Indicators of quality, effectiveness and timeliness/efficiency, and against other measures of quality and effectiveness discussed in this report.  Both the program and JCA service providers are performing well against these measures, as indicated by a national Performance Review conducted in 2007 with assistance from the Australian Government Solicitor.

DHS has been working with NESA and JCA providers since September 2007 to develop a more comprehensive performance measurement framework to take into account a broader and more balanced range of measures of quality, effectiveness and efficiency.

Following extensive consultations and workshops with NESA and a number of providers on 12 May and 16 June, the new performance measurement framework was introduced from 1 July 2008.

As discussed above under Client Outcomes, the new framework will include improved measurement of quality for the program as a whole, including through formal feedback processes such as client, JCA provider, employment service provider and Centrelink staff surveys.

Method of assessment

The majority of JCAs are conducted by face-to-face interview.  DHS considers that face-to-face interview is preferable unless another method is in the best interests of the client (for example, if the client is unable to travel to an assessment due to severe illness but it is not possible to postpone the assessment).  Performance measurement takes into account the percentage of face-to-face assessments.

Of the 447,158 JCAs completed from 1 July 2007 to 30 June 2008, 398,241 (89 per cent) were conducted face to face.  File assessments were conducted in 6.7 per cent of cases and telephone assessments in 4 per cent.  Other assessments are assessments conducted by video conferencing, which only account for 0.3 per cent of assessments (Table 5: Number of JCAs by Method of Assessment, 1 July 2007 to 8 February 2008).

Table 5: Number of JCAs by Method of Assessment, 1 July 2007 to 8 February 2008

This is also illustrated graphically (Graph 8: JCAs by Method of Assessment).

Graph 8: JCAs by Method of Assessment 

Telephone assessments are much more common in remote areas and are generally due to the person being assessed being unable to travel to the assessment, although some providers make exceptional effort to travel out to smaller sites to conduct face-to-face interviews.

Rules limiting travel time for Centrelink income support recipients with disabilities to sixty minutes means that the telephone is in many cases the only option for the JCA provider.  These rules also account for many of the 13,956 telephone assessments in non- remote areas, as many people in rural areas have similar travel difficulties.

While JCA providers chose whether to undertake an assessment face to face, by telephone or by video conference, they do not choose whether to undertake a JCA by file.

This decision is made by Centrelink as the referring agency. File assessments may be directed where the person being assessed is in hospital or the person has recently been assessed by a JCA for another reason but requires a new JCA. This is usually because the client:

• has decided to claim Disability Support Pension;
• is seeking a further extension of their incapacity exemption; or
• has no telephone and cannot travel to an assessment.
  

Where JCA providers chose the method of assessment, they are undertaking telephone assessments in just over 3 per cent of JCAs non- remote areas and less than 26 per cent of JCAs in remote areas.  Telephone assessments account for less than 5 per cent of JCAs where the JCA chooses the method of assessment (Graph 9: JCAs: Face to Face and Telephone).

Graph 9: JCAs: Face to Face and Telephone

Approaches to increase face-to-face assessments in remote and regional communities are discussed below.

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Regional and remote Australia

Access

The current JCA arrangements have achieved good access to JCA services in regional and remote areas, with national coverage in over 1,113 sites across Australia, many visiting services. Timeliness is close to that for metropolitan sites, with 94 per cent of remote assessments completed in 15 working days, and about 80 per cent within ten working days.

As part of the Northern Territory Emergency Response, DHS officers were outposted to Darwin to co-ordinate the JCAs required due to lifting of remote area exemptions. A total of 5,830 assessments have been conducted so far due to lifting of remote area exemptions. Feedback from clients has been positive, with many people referred to treatment and support services for the first time.

Viability

However, feedback from JCA providers is that current market share and contracting arrangements do not work well for regional and remote Australia.  While the issues are most acute in remote communities, NESA considers that this issue needs to be addressed in many regional Employment Services Areas as well.

Currently, providers receive a remote loading of around $100 for JCAs provided in remote Employment Service Areas only. They do not receive any additional funding, such as reimbursement for travel costs, either in remote or regional sites.

In addition, current market share arrangements and session booking arrangements are the same for all Employment Service Areas: service providers are required to serve all sites in every Employment Service Area in which their tender was accepted, with at least three providers represented in every Employment Service Area. In some regional sites which require travel, market share is very small, representing perhaps one assessment per month.  

…the current allocation of market share in such sites often has three or four JCA providers all delivering assessments across a remote Employment Service Area.  This approach further reduces the flow of JCA referrals and places further financial pressure on providers. (CRS Australia, response to JCA Review)

The practical impact of current contract arrangements is highlighted in a response to the JCA Review from Maximus Solutions Australia, a small private provider.

MSA has a small business share in rural sites such as Roma, Dalby and Charleville in Queensland.  …Although DHS hears [MSA’s] concerns no resolution has been found regarding the servicing of these rural sites.  MSA currently requires assessors to commute to these areas by either aeroplane or car. To increase the likelihood of MSA filling appointments in these regions, we open sessions up to two weeks in advance knowing that these will affect our timeliness Key Performance Indicator of ten days. The last two trips planned for Charleville have resulted in cancellations due to the Assessor not being filled with appointments and the cost outweighing this trip. 

A more flexible approach to timeliness and sharing of business in these areas is important to ensure jobseekers can gain appointments when they require them. Consideration may also be required for travel costs to rural locations. (Maximus Solutions Australia, response to JCA Review)

Centrelink, with 52 per cent of market share and an existing presence in remote communities throughout Australia, also reports that current arrangements are not viable.

…Centrelink endeavours to provide [face-to-face] interviews wherever possible. This involves substantial costs associated with expensive travel, time away from the office and back-filling of travelling assessors. Some remote assessments require the skills and experience of Senior Assessors – for example when conducting assessments with traditional Indigenous clients who require interpreters (Centrelink, response to JCA Review)

CRS Australia notes the current remote loading equates to 40 minutes’ travel time in terms of current allied health professional salaries, forcing providers to use phone assessments far more often than elsewhere in Australia: 36 per cent of JCAs in remote areas, excluding file assessments, compared to 4 per cent in non-remote locations.

Approaches developed with JCA providers

DHS has worked with JCA providers to address these issues, with an initial focus on remote communities, where there are the greatest challenges in providing high quality, face-to-face assessments on a financially viable basis.

Good progress was made in mid-2007 following a meeting with remote JCA providers in Alice Springs in March 2007. At this meeting and in subsequent discussions, providers agreed a number of useful approaches, particularly achieving economies of scale and more timely and effective services by combining visits to remote communities with other agencies, such as DEEWR, Centrelink and employment service providers. 

The most promising approach was for providers to work together and agree allocation of different sites within an Employment Service Area, so that each provider would only be required to visit some communities, and would have enough assessments in those communities to make the visit worthwhile. 

DHS agreed to work with providers to implement the new approaches following the 2007 national performance review and market allocation in September. This made some changes to market share which somewhat improved viability for providers in some regional and remote Employment Service Areas. 

However, work on the new approaches did not proceed, as DHS and the main remote JCA providers instead devoted the required staff and resources to undertaking Northern Territory Emergency Response JCAs.

DHS has made a commitment to work with providers and other agencies to refine these approaches in the light of experience with the Northern Territory Emergency Response.  Work with providers commenced in June 2008, focusing first on remote and regional communities where providers are experiencing particular difficulties.

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The Job Capacity Account

As set out in the Introduction, Job Capacity Assessors are reimbursed through the Job Capacity Account for purchasing short term allied health professional services, such as counselling and pain management, for people referred to Job Network who need this assistance to become work-ready.

Referrals to Job Capacity Account

In 2007-08, 33,754 referrals were made to Job Capacity Account services.

A total of 23,603 referrals were made to Job Capacity Account services in 2006-07. Although take-up was initially slow, since January 2007 it has been running at around 7.5 per cent, with expenditure in 2007-08 of around $17 million (Graph 10: Referrals to Job Capacity Account).

Graph 10: Referrals to Job Capacity Account

The majority of referrals to Job Capacity Account interventions for 2007-2008 were for counselling.  Cognitive behaviour therapy accounted for 32 per cent of referrals during this period, Other Psychological Support for 11 per cent, Pain Management for 5 per cent, Behaviour Management/Modification 5 per cent, Social Work 3 per cent, Work Conditioning 3 per cent, Other Social Work Support 2 per cent, and Other Physical Support less than 1 per cent.  There are no targets for the individual types of Job Capacity Account interventions.

Graph 11: Referrals to Job Capacity Account interventions, 2007-2008  

Effectiveness of Job Capacity Account

In their responses to the JCA Review, stakeholders including JCA providers and employment service providers were overwhelmingly positive about Job Capacity Account services.

JCA providers note that they have many ‘good news stories’ from clients who have been referred to Job Capacity Account services, some of which have been provided to DHS (see Attachment C, JCA and Job Capacity Account – Good News Stories). 

JCA providers indicate that feedback from Job Capacity Account clients is highly positive. Advanced Personnel Management provided feedback from a survey of 108 Job Capacity Account clients undertaken in October 2007 (Table 6: Client feedback on Job Capacity Account, from Advanced Personnel Management survey, October 2007).

Table 6: Client feedback on Job Capacity Account, from Advanced Personnel Management survey, October 2007

Advanced Personnel Management’s paper, Job Capacity Account – Addressing the Barriers,  also provides a number of excellent cases studies and the following quotes for clients surveyed, who felt that the Job Capacity Account provider:

• ‘has provided me with the counselling to assist me to get my life back into focus, although not completely void of all remaining issues. I feel without her assistance I would not now be in a position where I can visualise a positive future ahead.’
• ‘helped me and put positive energy into my life again. I feel more happy, confident and believe in myself, that I can do anything and I’m always smiling. Whenever I feel down I think about what [she] said to me and I smile again. I recommend this to anyone. It saved me and changed my life around and I appreciate everything.’
• ‘I found the experience rewarding. I also feel confident that my life and job prospects will be better as a result.’
• ‘After doing this course I feel 100% to what I did before. I am now back working and feel I wouldn’t be doing this without the help of [the Job Capacity Account provider]’. ⁹

Evaluating the effectiveness of Job Capacity Account is complex, because of the many other factors affecting client outcomes and the long lead times from referral to Job Capacity Account services to sustainable employment outcomes. In addition, it is difficult to track clients on the DEEWR system, which is transaction-based. Therefore only preliminary results are available. 

• Job Capacity Account is not a stand alone service: clients are only referred to Job Capacity Account services if they have a concurrent referral to Job Network, so if they later get a job, it is generally not appropriate to attribute this to the Job Capacity Account intervention alone. 
• There is also no valid ‘control’ or comparison group. Job Network clients are only referred to Job Capacity Account if they have barriers to work requiring allied health professional services such as counselling, so it would not be appropriate to compare them to other people attending Job Network.
• Job Capacity Account services are not compulsory (the Social Security Act 1991 prevents clients being compelled to undergo treatment services such as counselling). Clients who accept referrals to Job Capacity Account services and attend the services clearly have higher motivation than clients who refuse to attend.

The following graph shows that the proportion of clients referred to Job Capacity Account who were on income support fell from 82 per cent to 49 per cent in six months from referral (Graph 12: Proportion of clients on income support following Job Capacity Account services).

Graph 12: Proportion of clients on income support following Job Capacity Account services:

DHS and Centrelink have examined the first 100 referrals to Job Capacity Account, which provide a more or less random sample. While over 80 per cent were on income support with no earnings when referred to Job Capacity Account services, after 12 months, this was reduced to around 30 per cent.  By this time, around 70 per cent of clients had earnings or were no longer on benefit, presumably because they had a job (Graph 13: Outcomes for 100 Clients referred to Job Capacity Account Interventions).

Graph 13: Outcomes for first 100 Clients referred to Job Capacity Account Interventions:

Source: Centrelink files for first 100 clients referred to Job Capacity Account services from July 2006

Industry proposals

Stakeholders overwhelmingly support the Job Capacity Account. JCA providers and most employment service providers consider that it should be extended to people referred to employment services other than Job Network, and that the maximum duration should be extended from three to six months.

NESA’s words summarise the views expressed in responses from JCA providers and employment service providers:

The industry supports the initiative that the time frame for Job Capacity Account interventions should be increased to six months. 

Job Capacity Account … can enhance the capacity of the client to participate and reduce the anticipated time to achieve economic participation. The initiative also supports improved social inclusion through improving access and supporting clients to connect with services.  …It is the view of employment service providers and JCA providers that this initiative should be extended to clients being referred to other types of assistance, not only Job Network but also Vocational Rehabilitation Services and the Disability Employment Network. (NESA, response to JCA Review)

While at least one employment service provider considered that Job Capacity Account funds should be spent by the employment service provider, this would remove the advantage of having clients referred to an allied health professional service by another allied health professional, who is in the best position to judge their appropriateness and effectiveness.  As NESA says:

The Job Capacity Assessors are in a good position to exercise professional judgement if the interventions would improve outcomes for the client. (NESA, response to JCA Review)

JCA providers also consider that the contract requirement that a maximum of fifty per cent of referrals should be self-referrals makes it difficult to find appropriate allied health professional services for clients, particularly in regional Australia.  

Administrative costs for providers

JCA providers are however concerned that current arrangements only provide for reimbursement of the cost of purchasing services, not administration, monitoring or case management. 

There is no provision in the current JCA price structure that recognises the administrative impost and cost represented by referrals to Job Capacity Account. In other programs, such as DEEWR’s wage subsidy program, providers are able to levy a $100 administration fee for each wage subsidy. A similar arrangement should be considered for Job Capacity Account. (CRS Australia, response to JCA Review)

This view was strongly expressed by all JCA providers following changes to the JCA Guidelines in September 2007, to implement recommendations of an independent audit of Job Capacity Account processes. These changes were required to ensure appropriate accountability for government funding, but JCA providers considered that they added significantly to their workload. Most larger providers report that they are now employing 1-2 staff full-time to administer the Job Capacity Account.

There have been significant revisions to the guidelines… that have resulted in a considerable administrative burden… According to the guidelines, JCA providers must track instances of non-attendance, the quality and timeliness of Job Capacity Account exist report, liaise with the Job Network during and after completion of the service, monitor the quality of outcomes, ensure that the referrals are finalised appropriately, and make sure that the service is completed within 16 weeks after date of submission of the JCA report. (Mission Australia, response to JCA Review)

Accountability

Concerns were raised by the Australian Federation of Disability Organisations (AFDO) about accountability for Job Capacity Account services:

AFDO is concerned that insufficient safeguards are built in to the Job Capacity Account service model to ensure accountability, to discharge the duty of care of the government and to effectively boost the work readiness of clients. (AFDO, response to JCA Review)

The National Welfare Rights Network also raised the need to ensure the cost-effectiveness of the program and that referrals to these allied health professional services were appropriate and did not interfere with the client’s existing treatment regimes.  As allied health professionals themselves, Assessors are in the best position to ensure appropriate and effective use of allied health professional services.

DHS is working to improve arrangements for monitoring effectiveness and client outcomes.

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Complaints

JCA service providers are required to ensure that clients and other stakeholders such as employment service providers are clearly informed of JCA complaints mechanisms, including the providers’ own internal complaints handling processes and the Centrelink Customer Relations Line.

Nevertheless, the JCA program receives very few complaints.  In the 24 months from 1 July 2006 to 30 June 2008 there has been a total of 377 complaints lodged relating to JCAs. During the same period over 822,000 JCAs were completed.  This equates to less than one complaint from every 2,000 JCAs (less than 0.05 per cent). On average, DHS has received less than 16 complaints a month since 1 July 2006. 

About 70 per cent of complaints are about the conduct of the JCA or other issues that relate to the service provided, while about 30 per cent are a disagreement with the Job Capacity Assessor’s findings. In some instances this is a complaint about Government policy or legislation, and in others it is a disagreement with Centrelink’s decision: for example, the client thinks they should get Disability Support Pension, but the Job Capacity Assessor and the Centrelink decision-maker do not.

Sources of complaints

Complaints on the JCA program come from a number of different sources. 

If a client has concerns about how their assessment was conducted, they are advised to follow a three-step process:

1. Contact the Job Capacity Assessor;
2. If still concerned after doing this, they can call and lodge a complaint with the Centrelink Customer Relations Unit;
3. If they are not satisfied with Centrelink’s or the Job Capacity Assessor’s attempt to resolve the issue, they can complain to the Commonwealth Ombudsman.

The majority of complaints come to DHS via the Centrelink Customer Relations Unit or are lodged directly with the JCA providers. Complaints which are directly lodged with providers are sent to DHS as part of their quarterly reporting requirements.

Other channels in which complaints can be raised include:

• the DHS Hotline (this is managed by DHS and is available for calls from clients and employment service providers);
• through DEEWR for complaints from employment service providers;
• formal complaints to DHS (these include complaints to the Commonwealth Ombudsman and could include those from JCA providers); and
• via email to feedback@jca.gov.au (this is managed by DHS and is available predominantly for clients or other stakeholders). (Table7: Source of JCA Complaints, 2006-2008)
  

Table 7: Source of JCA Complaints, 2006-2008

Type of complaint

DHS receives complaints about a number of different issues relating to JCAs. 

Most complaints are about the conduct of the assessments.  These complaints are usually about the way that the JCA was conducted but are separate to complaints about the Assessor’s behaviour, language or presentation alone. 

Examples of complaints about conduct of assessment include ‘the Assessor wasn’t listening to me’, ‘the Assessment was too short’, and ‘the Assessor made up their own mind’.  This reason also includes some multiple complaints, particularly instances where the person is complaining about the conduct of the Assessor and also has a secondary complaint about the Assessor’s qualifications e.g. ‘the Assessor didn’t do a thorough assessment and he/she wasn’t a doctor.’ 

The second largest group of complaints relates to the appropriateness of referral by the Assessor.  These complaints, along with those relating to income support/activity test requirements which are the fifth highest category, are often complaints about payment or program eligibility, rather than the JCA itself. 

The third largest group of complaints relates to the quality of assessment services.  These types of complaints usually relate to difficulties dealing with the organisation providing the JCA.  Many of the complaints in this category are from Centrelink and employment service providers as referrers.  Examples of complaints about quality of assessment services include ‘the JCA didn’t organise an interpreter’, and ‘the JCA wouldn’t return my call about his/her recommendation’.

Complaints to the Commonwealth Ombudsman

Between 1 July 2006 and 30 June 2008, DHS received ten complaints from the Commonwealth Ombudsman.  All have been finalised and subsequently closed. 

The Commonwealth Ombudsman advised that in five cases there was an administrative deficiency recorded for DHS (this is related to the activities of DHS’s contracted service providers, not DHS staff).

In those five complaints where no further action was required:

• in three cases, the client had an issue with the Assessor determining if their condition was permanent;
• in one case, the client had an issue with the recommendation of the report; and
• in one case, there was a wrong referral code.

Of the five cases that an administrative deficiency was recorded:

• in one case, the client was not assessed for Disability Support Pension;
• in one case, the complaint was about Assessor behaviour;
• in one case, the assessment was conducted while the client was in hospital (this is not known to the Assessor when Centrelink makes the appointment); and
• in two cases, there was a claim for Disability Support Pension and there was a problem in identifying whether the condition was permanent.

In those instances where an administrative deficiency is recorded, DHS takes the appropriate action with the provider and/or makes adjustments to the JCA program to prevent a similar instance occurring in the future.  

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Governance and communications within Government

The Social Security Appeals Tribunal considers that:  

the overall administration of the programs of which the JCA assessment can be a part, seems somewhat fractured.  Responsibility for Disability Support Pension policy now resides in FaHCSIA; DEEWR remains responsible for policy for Newstart and other working age payments; the delegates making the substantive income support decision reside in Centrelink, with JCA contractual issues and training of Job Capacity Assessors being the responsibility of DHS and the assessments themselves being performed by the JCA service provider.  (Social Security Appeals Tribunal, response to JCA Review)

While these arrangements can certainly be confusing for stakeholders, in practice they work very well, due to the strong working relationships between people in these government agencies who work on JCA issues, and strong relationships between DHS and JCA providers. 

In their responses to the JCA Review, many stakeholders have strongly supported the current administrative arrangements as ensuring the integrity and independence of Job Capacity Assessment.  As outlined in Chapter 1, stakeholders who provided views about the role of DHS have been uniformly positive about the willingness of staff to listen and respond to stakeholder concerns.

⁷ Department of Employment and Workplace Relations, Job Network Disability Support Pension Pilot: Interim Evaluation Report, October 2004; Early Intervention and Engagement Pilot: Evaluation Report, September 2005.

⁸Job Capacity Assessors are required to refer people to the most appropriate service, regardless of caps and waiting lists.  The reason for inappropriate referral to Job Network is generally the client’s refusal to provide medical evidence, see JCA Guidelines and Processes, below.

⁹ Advanced Personnel Management, Job Capacity Account: Addressing the Barriers, Perth, 2008: also attached to Advanced Personnel Management’s response to the JCA Review.

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