8. Recommendations
The following recommendations have been formed on the basis of findings from the research project, including background research and a broad consultative process engaging a diverse group of stakeholders.
8.1 Design of a single assessment tool
Recommendation 1
A single wage assessment tool for wage determination in Business Services should be developed on behalf of FaCS. The assessment tool should be developed in close consultation with the sector, undergo extensive testing and build on the strengths of existing assessment processes.
Recommendation 1A
In the design of the single assessment tool, the following existing assessment mechanisms should be reviewed in further detail, as these systems exhibited some sound elements:
- The SWAT
- The Greenacres tool (Wollongong, New South Wales)
- Wangarang Industries (Orange, New South Wales)
- WestCare Industries (Perth, Western Australia)
Recommendation 2
The assessment tool should combine elements of both competency and productivity assessment, which links directly to endorsed industry standards wherever practicable. The development of the assessment tool should include identifying the competencies incorporated in industry training packages that are most applicable to Business Service activities.
Recommendation 2A
The dual assessment elements should not compound reductions in wage rates. For example, an employee with 50 per cent of level x competencies working at 50 per cent of the productivity benchmark should not receive 25 per cent of the relevant award wage (that is, 50 per cent x 50 per cent). A 'sliding scale' approach should be adopted.
Recommendation 3
The preferred tool should include provisions for a minimum wage 'safety net' for employees of Business Services. Further, the minimum wage should be in the order of $50 per week, appropriately indexed to increases in award rates of payment (or the CPI). Pro-rata payment of the safety net wage is not considered appropriate.
Recommendation 4
The assessment tool should be applicable to all industry settings in which Business Services operate. This may require the conduct of an industry audit. This will enable identification of the appropriate industry training packages (and competencies) with which the assessment tool should be linked.
Recommendation 5
The assessment tool should provide a direct and rational link to appropriate awards. Current wage structures that link historical pay rates to an award by identifying a proportional award payment without a defined assessment process are not considered appropriate.
Recommendation 6
The single assessment tool should be not only a valid and appropriate assessment system, but the calculation of corresponding wage rates should also be considered. It is considered that the wage determination process should be incorporated into the assessment tool.
8.2 Implementing the assessment tool
Recommendation 7
As part of the development and trialing of a single assessment tool, comparative studies in some Business Services should be conducted to monitor the impact of implementing the new tool on the cost of wages.
Recommendation 8
Wage determination assessments should be conducted by independent assessors (endorsed by FaCS), who hold the national units of competence for conducting assessment (or equivalent), namely:
- BSZ 401A Plan Assessment
- BSZ 402A Conduct Assessment
- BSZ 403A Review Assessment.
Recommendation 9
Wage assessment should be conducted in a process that is separate to the employee's Individual Employment Plan, yet is strongly linked to goal-setting, training needs identification and career path establishment.
8.3 Additional considerations
Recommendation 10
Wage determination assessments should be closely linked to training opportunities for employees in Business Services, including both in-house (on and off-the-job) and external training (for example, involvement in TAFE courses).
Recommendation 11
‘A Guide to Good Practice Wage Determination’ should be made available to all Business Service outlets and relevant industrial relations organisations, particularly Industrial Relations Commissioners involved in the assessment of Enterprise Agreements.
Recommendation 12
Business Services should enhance links with the training sector, particularly with registered training organisations, to facilitate the achievement of recognised industry-related qualifications.
Recommendation 13
Business Services should demonstrate a commitment to the payment of superannuation for all employees, including those earning less than the superannuation guarantee threshold. This minimises discrimination on the basis of reduced capacity to earn full award wages.
Recommendation 14
The implementation of the preferred single wage assessment tool should be included as part of ongoing quality assurance monitoring.
Recommendation 15
The implementation of a single wage assessment tool for Business Services should include subsidisation from FaCS to assist in the payment of independent assessors and potential increases in administrative costs, at least during the preliminary implementation stage.
Recommendation 16
A training program for Business Service managers, Centrelink, consumers and employment agencies should be developed and implemented to address misconceptions/misinformation relating to the impact of award-linked wages on social security benefits/eligibility.
Recommendation 17
Prior to the implementation of the single assessment tool, a training program should be conducted describing the rationale for the tool, with particular emphasis on the competency-based assessment component.
9. Additional observations of the research team
The following observations by the research team represent issues that require further analysis or consideration.
- Not all Business Services are funded by the Commonwealth as section 10 services. This limits access to the SWS and influences the development and adoption of structured wage determination systems.
- The SWS was designed specifically for open employment assessments, limiting its applicability in some Business Service settings. Although the SWS is accepted in open employment, there is some debate over its applicability in Business Service settings.
- The minimum wage under the SWS of approximately $50 per week is more than a number of Business Services currently pay, or (reportedly) have the capacity to pay.
- Where the SWS is not implemented in its entirety, adaptations are occasionally made whereby assessments are conducted 'in-house' as costs of assessment using the SWAT are not subsidised by the Commonwealth.
- Some Business Services apply adapted forms of the SWAT to determine productivity-based wages for employees. These services claim that the SWAT requires amendment as its original focus was on the open employment setting.
- Findings and standards relating to the implementation of competency-based assessment for the purpose of wage determination are based on the attainment of qualifications. Competency-based pay systems without recognised qualifications are rare.
- Competency-based assessment has developed from a training paradigmhowever, formal links to training are inconsistent across the sector.
- The impact of wage earnings on social security entitlements has been identified as an issue requiring clarification for Business Service operators, workers and their advocates/families. This relates not only to the sliding scale for Disability Support Pension payments, but also retention of Pharmaceutical Allowance, Rent Assistance and health care/concession cards.
- Recommendations prescribing wage assessment processes for Business Services are likely to have a significant impact on many Business Services, particularly in relation to financial viability, cost of assessment and administrative requirements.
- Interstate variations, particularly in the determination of industrial agreements, may complicate the implementation of recommendations of this project.
- Consideration should be given to the implications of prescribing wage determination conditions that may not have been met in the negotiation of pre-existing industrial agreements. That is, what will be the impact on existing wage assessment processes and certified agreements (that have been ratified) that do not comply with refined standards/legislation?
- A number of concurrent/recent projects are likely to have a direct impact on the findings and implementation of this report, including the Case-Based Funding trial, Business Services review, SWS review, Quality Assurance trial and Award Based Wages Training. Wherever possible, the findings and recommendations of these projects have been considered.
- The research team did not review a representative sample of Business Services, and it is possible (yet considered unlikely) that alternative wage determination models are in existence.