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Administrative requirements for providers
As is clear from the preceding chapters, administrative requirements for Job Capacity Assessors and providers are complex, partly reflecting the complexity of income support and employment services policy settings, systems and processes, and partly as a result of JCA and Job Capacity Account program and contract management requirements.
Job Capacity Assessors have a complex and challenging role in assessing work capacity based on legislative requirements of the Social Security Act and determining service needs of the client. … they are inadequately resourced to fulfil all that is being asked of them particularly in the light of the increasing complexity of policy settings and administrative requirements. (NESA, submission to Employment Services Review)
JCA providers advise that they did not anticipate the administrative costs and overheads when they entered agreements to provide services, and have subsequently had to employ additional administrative staff, and spend the valuable time of allied health professionals in performing clerical duties.
The following account of administrative costs is typical for a small private JCA provider:
MSA business share for JCAs is approximately 100 JCAs per week nationally ... Property and rental costs, information technology fees, administrative and finance staff, translator fees, courier fees and recently the case management of Job Capacity Account are among some of the hidden costs in the delivery of the JCA contract.
…In all instances when a JCA is conducted by MSA, there is a [room] rental charge despite whether the client attends. …roaming internet costs…the costs of face to face translator services in some regions can escalate up to $150 an hour. Translators charge fees to MSA when clients do not attend.
In addition to the cost of professional health staff, MSA currently employs three full time equivalent administrative and finance staff to open sessions in EA3000, make reminder calls or SMS, reschedule appointments where required, claim financial information from EA3000, receive JCA referrals, internally create an invoice for Job Capacity Account, claim Job Capacity Account from EA3000, and track any outstanding ad hoc payments. It is estimated that this costs MSA approximately $120,000 a year based on the average administrative salary. (Maximus Solutions Australia, response to JCA Review)
JCA providers are accountable to the Government not only to provide high quality, effective and efficient services, but to ensure appropriate expenditure of public funds. Sound internal administrative processes are critical, particularly in the case of Job Capacity Account where JCA providers are effectively acting as the Government’s agent in purchasing services from third parties.
However, as for the guidelines, many changes to processes have been introduced since the JCA Program commenced, which have led to an accretion of additional requirements for providers. JCA providers consider that requirements could be reviewed to ensure that they are sound and necessary, to streamline processes and reduce duplication, and to replace ad hoc and manual processes wherever possible.
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Courier costs
JCA providers are responsible for collecting and returning the client’s medical information file from Centrelink. DHS does not reimburse these costs. The process is outlined in Mission Australia’s response to the JCA Review:
This process creates a significant administrative and resourcing burden on both the assessor and administrative staff. Not only does each client’s JCA report need to be checked to see if documentation is required for pick-up, a courier needs to be arranged and paid for. However, despite the procedure being not to arrange a JCA appointment without the Medical Information File being present, Centrelink often arrange the appointment before they have the documentation ready. This leads to a significant cost involving having to send couriers twice to pick up the same file …nationally, we spend between $2,000-$3,000 per week on courier charges. (HSA Group, response to JCA Review)
Once again, Maximus Solutions Australia provides a typical account from a small private JCA provider:
In some instances MSA have funded couriers up to $298 in non-metro areas to deliver overnight medical documents. The courier fees are charged to MSA when they visit Centrelink offices and medical documents are not available….The average costs of couriers for MSA in one month are $1,800 or approximately $22,000 a year. No money is recouped from DHS for courier costs. (Maximus Solutions Australia, response to JCA Review)
The information on clients’ medical information files can be substantial. Centrelink has considered scanning this information to enable it to be used more efficiently and effectively, but to date, the cost has been prohibitive. Even if Centrelink scanned the documents, a secure means of transmitting them to other JCA providers would still be needed. DHS and Centrelink are currently considering this issue.
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Access and session availability
Current diary arrangements and the requirement to complete 80 per cent of assessments within ten days of referral to meet contract Key Performance Indicators mean that JCA providers rarely open appointments on the EA3000 system more than five days in advance. Appointments can book out fast, particularly in regional areas.
The only means that providers have to manage their performance against [the current timeliness] measure is to ensure that they only make appointments available five days in advance. This issue is most critically felt in regional and remote areas where full time services may not be available or clients live considerable distances from offices and require more notice. (NESA, response to JCA Review)
In addition, market allocation arrangements mean that, if one provider has not booked enough appointments to meet their market share, other providers can be ‘locked out’ by the system and prevented from opening new appointments.
The present EA3000 diary system …does not work effectively for rural and remote servicing. Where numbers are smaller the allocation system will lock a provider out from opening further appointments when perhaps only one actual JCA appointment has been scheduled. This will continue until another JCA provider opens an appointment in the location/area. This means that the JCA provider will need to travel to the remote location, which is not currently compensated, and then only provide a reduced number of assessments because more cannot be scheduled even if there is demand. (Rehabco, response to JCA Review)
JCA providers generally manage session availability well within the current constraints, although absence of Assessors on unplanned leave and workforce shortages can cause issues particularly in regional sites. DHS notes that JCA providers have invariably been quick to open sessions when asked, usually within the next hour.
This issue could be largely resolved by changes to the session booking processes, along with adjustments to performance measurement, to enable providers to open sessions further in advance, particularly in regional sites where an Assessor might only visit every two to three weeks. DHS is working with providers and other agencies on this issue.
Choice of Assessor
In practice, the current session availability arrangements also determine which Assessor a client will see, because sessions are opened by providers based on which Assessor is available at a particular time in a particular site.
As discussed in chapter 2, this has the effect of randomly allocating clients to Assessors without regard for the individual needs of the client or the qualifications or expertise of the Assessor.
Changes to session availability arrangements could give providers more discretion to allocate clients to a particular Assessor, or combination of Assessors, based on the client’s individual needs. This would need to take account of market allocation arrangements and not place unrealistic demands on providers, given the difficulties in attracting and retaining experience allied health professional staff, particularly in regional Australia.
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Timeliness
Under the Better Assessment arrangements and the preceding regimes, there was considerable criticism of delays in income support decisions and referral to employment services in particular. Mounting Australian and international evidence of the importance of early intervention and rapid connection to services highlighted the importance of a timely and efficient assessment process.
Contract and performance management systems for the JCA program therefore had a strong emphasis on timeliness, with rapid connection to employment services as a key objective.
Rapid connection has certainly been achieved under current JCA arrangements. As noted earlier in this report, JCA providers performed consistently well against the required performance standards under the contract Key Performance Indicator (KPI) for timeliness, which from July 2007-to June 2008 were:
- 80 per cent of non-remote assessments to be completed within ten business days from referral; and
- 80 per cent of remote assessments to be completed within 15 business days from referral.
In fact, providers have consistently achieved an overall national timeliness rate of over 80 per cent, with most remote assessments also being completed within ten days.
Non-remote assessments
In total, 82.7 per cent of non-remote assessments were completed within ten business days for the period July 2007 to June 2008.
The timeliness of non-remote assessments had been steadily increasing from January 2007, peaking at 85 per cent in the 3 months to September 2007. A large increase in JCA referrals in the three months to December 2007 and the need to open appointments further into the future to accommodate these JCAs resulted in a reduction to around 77.5 per cent for that period. Timeliness increased to 83 per cent by the end of June 2008. (Graph 14: Timeliness of Non-remote Assessments, 2007-08).
Graph 14: Timeliness of Non-remote Assessments, 2007-08
Remote assessments
A total of 94.1 per cent of remote assessments were completed within 15 business days for the period July 2007 to June 2008. This KPI has consistently been met by JCA providers since the commencement of the JCA program. This is due in part to the longer period of time available but also by the higher (legitimate) use of non face-to-face assessments (Graph 15: Timeliness of Remote Assessments, 2007-08).
Graph 15: Timeliness of Remote Assessments, 2007-08
Timeliness in practice
Current provider achievements against the timeliness benchmark are particularly impressive, given the practical difficulties in achieving a ten-day turnaround, as outlined by Advanced Personnel Management in its response to the JCA Review:
APM understands the importance of early intervention and the philosophy underpinning the ten day metropolitan area timeline…APM recommends guidelines be developed to ‘pend’ the timeline in events outside of the Job Capacity Assessor’s control or critical to the assessment process. This includes:
- Clients who do not attend
- Clients rescheduling appointment
- Lack of availability of Medical Information File
- Further medical clarification required
- Lack of availability/ or non-attendance of the interpreter
- Client requires more time to engage.
In APM’s experience, the two-day turnaround of report completion, post assessment, may not always be possible when service provider contract is required. Additionally the two day turn around to reschedule [clients who do not attend] may not always be possible especially for those without telephone contact or requiring interpreters. (Advanced Personnel Management, response to JCA Review)
In theory, it would be possible to suspend assessments to allow for many of these unavoidable delays. In practice, it would be very difficult to make appropriate allowances for all the causes of delay which are outside a provider’s control through suspension periods.
There is also a real danger that the ability to suspend an assessment, or in effect freeze the clock, would remove provider incentives to keep close track of these assessments and ensuring that they are completed as soon as possible, for example by following up delays with medical evidence. A suspension approach would not improve effectiveness or quality, and would detract from efficiency.
The right balance between timeliness, quality and effectiveness may vary according to the needs of the client. Generally, the more straightforward the client’s needs, the quicker the JCA.
Achieving the right balance between timeliness and effectiveness
As set out above and in previous chapters, NESA and JCA providers consider that over-reliance on this timeliness measure in performance measurement has distorted provider behaviour and created perverse incentives which restrict client access to services, particularly in regional Australia, and can detract from quality and outcomes for clients.
Over-reliance on this measure can also detract from overall efficiency, as outlined in the section on Session Availability, above.
In the implementation of JCA there has been an over-emphasis on timeliness which in the view of industry has compromised quality and access. Current timeliness measures are creating administrative pressures and increasing the level of non-attendees. Importantly, it is the experience of providers that these measures are reducing the accessibility of appointments. (NESA, response to JCA Review)
A more balanced approach to measuring performance is provided in the new performance measurement framework developed in consultation with JCA providers and implemented on 1 July 2008.
This introduces a new measure of timeliness from date of JCA interview to date of report completion. However, DHS will continue to monitor overall timeliness from date of referral to ensure that rapid connection to employment services and the efficiency of income support decision making is not compromised by inappropriate delays in JCA appointments. The new framework also removes assessments suspended awaiting medical evidence before calculating performance against these timeliness benchmarks.
More importantly, the new framework introduces a broader and more balanced set of measures, which allow effectiveness and quality to be more effectively assessed. Measures for appointment availability and the proportion of face-to-face assessments will particularly redress the balance towards quality and effectiveness, by rewarding providers who open sessions well in advance and conduct face-to-face assessments in regional and remote communities, and whose timeliness score may therefore be lower than that of providers who place more emphasis on rapid throughput.
This performance measurement framework is underpinned by the new quality assurance framework, further improving balance between timeliness and quality by allowing rigorous comparative assessment of quality through independent allied health professional auditors.
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Systems
The JCA EA3000 system
The JCA EA3000 Smartclient system is a very small part of the huge and very complex DEEWR system which manages the DEEWR employment service network contracts and interfaces with the Centrelink system on client income support and participation requirements.
The introduction of the JCA component of the EA3000 Smartclient system was a considerable advance on previous arrangements, and significantly improved efficiency by enabling automated referral to JCAs and from JCAs to employment service providers, and by improving connections between external Assessors and Centrelink.
JCA providers rely heavily on EA3000 to manage their business and to ensure that Assessors are allocated appropriately to sites where they are most needed. Session availability information is particularly useful in enabling a quick response to any local difficulties in accessing JCAs.
DHS makes extensive use of information available from EA3000, not only to manage the program and payment arrangements, but to analyse patterns of referral and expenditure and deal with any issues as they emerge. EA3000 is a key tool for performance monitoring and review and for contract management, both for DHS and JCA providers.
Generally, the e-commerce interface works well and JCA providers rarely report problems with down time or systems connections. Access to the secure DEEWR site provides a safe way for providers to transfer the sensitive client information contained in JCA reports to Centrelink and providers.
The JCA component of the system is necessarily complex, because of all the functions it performs: among others, managing contracts, payments and market share, allocating and notifying appointments, rescheduling, writing and submitting reports, managing referrals and appointments with employment service providers, submitting reports to Centrelink and finalising them once Centrelink has made the income support decision.
Moreover, the system is complex because the employment services and income support arrangements which it is based on are complex. When JCA or employment service providers complain that the system or the JCA report is complex or inflexible, they are generally complaining about the policy and program rules, not the system itself.
Systems improvements
Limited time and funding for the initial development of the JCA system meant that, when it was introduced in July 2006, some of the specified functionality was unable to be included. Following its introduction in July 2006, further issues were identified with its practical operation, most of which have now been addressed. Since then, significant changes to processes and policy clarifications have added a further layer of complexity.
Changes to the EA3000 Smartclient system are usually costly and time consuming. They frequently also require changes to the Centrelink system.
Since the JCA program commenced in July 2006, DEEWR quarterly systems releases have made a number of key improvements to JCA functionality, particularly regarding the JCA report itself. More changes are scheduled for the September 2008 systems release.
For example, systems changes to improve JCA quality that occurred in June 2008 included:
- print preview functionality for JCA reports that are not yet submitted, so that the Assessor and their supervisor can view the whole report for consistency and quality;
- usability enhancements such as improving ability to view text as it is being entered and providing additional space for text;
- a new referral reason for Centrelink use; ‘Participation Failure Pending’ to alert Assessors, employment service providers and Centrelink staff to clients who are at risk of non-payment due to failure to meet activity-testing requirements; and
- the facility to view employment service provider exit reports for clients.
Impact on JCA providers
Job Capacity Assessors are subject to the current system limitations and must also implement a significant number of time-consuming and inefficient manual workarounds, many of which require a number of steps and for them to manually enter specific phrases in specific fields within the report. These not only affect efficiency, but as noted in Chapter 3 under Quality, also create potential for Assessor error.
Assessors are required to spend time navigating (EA3000) and gleaning bits of information (in some instances looking for only one word) from multiple screens prior to seeing the client. For example, the Assessor needs to check all of the following screens for a typical assessment: the Registration screens (there are several tabs), the Central screen, placement history, Jobseeker Classification Instrument, client profile, medical screen, and the front page of the JCA report to collect all of the information required…. A much more practical situation would be to have a central screen that all of this information is collected in…. (Mission Australia, response to JCA Review)
JCA providers report that Assessors find the system, in particular the JCA report functionality, difficult and frustrating to use.
HSA has noted common reasons why internal staff have requested moving from the JCA teams to other HSA roles. These include the increased complexity of the assessments and their difficulties with the JCA system, DEEWR EA3000 Smartclient program. (HSA Group, response to JCA Review)
The Commonwealth Ombudsman, in his response to the JCA Review and report on Implementation of Job Capacity Assessments for the Purposes of Welfare to Work Initiatives, has also raised issues with systems limitations. DHS has worked with the Ombudsman and DEEWR on these issues and a number of related systems changes were introduced from 2007. Further work is currently underway with the Ombudsman, other agencies and JCA providers.
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Issues for DHS
DHS is a small Government agency, and does not have state offices. The JCA team is located in Canberra. Currently, there are 15 full-time equivalent staff running the JCA Program and Job Capacity Account programs and managing contracts and payments. For most of the life of these programs, the number of staff was very much smaller.
The same team is responsible for JCA policy and for providing advice and briefing, undertaking research and analysis on JCA and related issues, and working with other agencies on a wide range of other matters relating to income support and employment services arrangements.
In addition, last year the same team conducted a national performance review and business reallocation, which required very detailed comparative analysis of provider performance in each of over 130 Employment Service Areas. This occurred at the same time as the Northern Territory Emergency Response, which required considerable work to develop and agree processes and funding arrangements for JCAs in the Northern Territory with agencies and JCA providers, and outposting of DHS staff to Darwin to manage these arrangements. Throughout this period, there were between 8 and 13 staff in the Branch.
Stakeholder responses to the review and meetings with stakeholders have highlighted a range of issues affecting the operation of the JCA and Job Capacity Account programs, work on which has already commenced with stakeholders and other agencies.
Considerable work is also expected to be required on changes to JCA requirements as a result of the Employment Services Review, the National Mental Health and Disability Employment Strategy, the new disability employment services arrangements currently being developed with stakeholders, and other processes. In addition, work is needed on the arrangements for the next Request for Tender.
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