Services for Australian Rural and Remote Allied Health (SARRAH)

Response:

The proposed structure and arrangements for JSA appear appropriate, workable and capable of enabling the objectives set for JSA to be pursued effectively.  

The Commissioner model within a statutory body structure promotes the balance between independent authority and function, accountability and responsiveness to government and broader stakeholders.  Similar models appear to have had some success, such as the Productivity Commission. 

The incorporation of broadly constituted, advisory groups involving capable, independent and/or mixed viewpoints provides assurance and a forum for constructive debate.

We believe it is important that from formation that JSA be seen to possess a substantial body of skilled and expert staff with a culture and capacity for balanced independence, consistent with statutory body functions.  With that in mind and without meaning to impugn the Department of Employment and Workplace Relations or any individuals potentially involved in the establishment of JSA, consideration should be given to ensuring Jobs and Skills Australia is staffed by skilled people from a mix of backgrounds, without overly relying on current DEWR staffing.

We understand that one consideration would be overall APS and portfolio administrative overheads associated with the establishment of JSA.  Notwithstanding those issues, there is considerable community concern about the independence and capability of the APS and its capacity to deliver its objectives with impartiality and rigour.  These concerns are live and present a risk to the potential effective operation and success of JSA .  

Response:

SARRAH supports the principles identified to for guiding JSAs priorities and workplan development at this stage.  With regard to two of the principles, SARRAH offers the following comments/suggestions: 

Re: enhanced analysis of regional skills and labour needs:  we welcome this inclusion and note it is vital given regional differences and dynamism across Australia's industry, employment and service needs.  We strongly suggest that the analysis of regional skills and labour needs, consider not only what is current in demand (or would be if indicated by the lack of services/workforce capacity that would be expected in other locations (e.g. metro) - eg. allied health, but also whether the workforce development and pipeline supports needed to enable that workforce are available in an articulated and accessible form (e.g. if there is a local need for X workforce are the necessary VET courses (for example - and including on-the-job training capacity) available to facilitate the development of that workforce.  Frequently, in rural and remote health and social assistance (for example) vital components of the education/training/employment continuum are missing, making other investments ineffective. 
 In some cases this has presented as a lack of demand for a given training program (despite intense community need) and the withdrawal of the training, rather than an analysis to assess what other blockages / systemic gaps are preventing take-up etc. 

Re: enhanced cohort level analysis:  noting the comment above, these can be the sort of issues that impede the success of targeted programs /supports for groups who have far greater skills, workforce and earnings potential than is realised.  For example, carers returning to the paid workforce may be very well placed to fill skilled vacancies /enter career pathways is health, aged care, disability support etc (including skilled roles with pathways - such as Allied Health Assistance) - if targeted and available. The point applies equally in relation to Aboriginal and Torres Strait Islander people (whose cultural knowledge and connection (including to country) can add to the skilled attributes they bring; people with disability; and people of mature age.

Response:

As mentioned in response to the previous question, a priority for JSA will be to ensure the veracity and relevance of its work at regional as well as industry levels.  This also presents a challenge and a risk for JSA and how it is able to incorporate these aspects of their work into a workplan requiring breadth and depth.

It will mean establishing and maintaining effective, ongoing and informed consultation and information mechanisms.  Using the example provided earlier, informed information collection and analysis identifying the assets, opportunities and limitations associated with developments of key workforces in regional areas are vital inputs to the analysis and potential actions informed by and resulting from it .

Also, SARRAH strongly the Government in establishing JSA and its work agenda to incorporate significant capacity to model and develop action plans (or enable this development elsewhere) in relation to future workforce demand.  

To illustrate: some of our critical current workforce shortages have been foreshadowed and/or completely predictable for a decade or more, yet during that time mechanisms designed to identify, plan for and hep meet those demand have been dismantled. the dissolution of Health Workforce Australia (HWA) is a case The impact of COVID and workforce shortage issues highlighted by the challenge of meeting the Government's commitment to ensure registered nurses are available in aged care facilities 24X7 may have been largely addressed or ameliorated through priority work HWA had underway to build the nursing workforce;
HWA was commencing work to identify demand and distribution needs of allied health professions (AHPs) - and presumably then to develop plans to address these when it was dismantled. There are acute and chronic workforce - of increasing severity with increasing rurality/remoteness. Yet workofrce projections prepared by the National Skills Commission (2022) indicate demand for several AH professions will further increase over the next 5 years by between 20 and 35% - ie. 3 or more times that of workforce demand across the entire economy.  Despite this Australia has no allied health workforce strategy.

Instructive work into the increasing demand and demographic realities driving growth (and exacerbating shortages) in the care sector has recently been undertaken by the Human Services Skills Organisation (HSSO - The Big Care Shift report - which also exemplifies the level and focus of analysis that would contribute strongly to well informed and strategic policy setting. 

Response:

We note JSA proposes to "increase its outreach to seek feedback on and to promote
the value and benefits of its products and advice. This includes offering briefings and considering the design and development of current work and future products.

Outreach activities will be valuable, but more so if they are viewed and facilitated ads a means of gathering and incorporating detailed intelligence at a sector, regional or other level and - in the process - promote information networks.  

Response:

The collection of verified and comparable datasets, consistent with previous information holdings etc are generally seen as important and generally recognised as being so.

It is generally harder to secure the same interest and commitment to identify emerging or less quantifiable information - although this is more likely to be how emerging issues may become apparent.  

Similarly, the availability of pre-existing data collection systems and the resource commitment they represent predisposes continued reliance on them, despite the limitations that can be associated with the data - in what they collects and don't collect. 
Unfortunately, these factors can reinforce a tendency to value retrospective (and verified) data and information more than emerging information and sources, especially if they are new.  there are several risks with this:

if data has not been collected on something previously it tends to devalue the information in the present - because of the inherent view that if it wasn't collected t mustn't have been as important (even if it should have been in hindsight), involves new activities and resources and etc etc.

SARRAH encourages the Government and JSA to go beyond the collection of available data sources and investment the gaps that exist and mechanisms to identify and gather intelligence on emerging workforce.

Also - In Figure 1 (page 7), Jobs and Skills Australia operating model - we suggest adding /elaborating on the dot point in the Research element under "International experience"  with a view to identifying emerging developments and placing a greater emphasis on forward looking issues identification and potentially scenario analysis. 

Response:

Also in Figure 1 Page 7)  - under the Stakeholders element (noting this is not an exhaustive list) there may be value in explicitly adding service and workforce peak bodies as stakeholder group.  These could contribute broad, sectoral insights and knowledge, which would differ from but complement other stakeholders, such as with union, employer or direct commercial interests.

Response:

Please also refer to our response to Question 4.

Response:

No comment at this stage.

Response:

SARRAH supports the objectives and priority given to establishing JSA.  The common themes identified to date provide a good basis for developing a strong work program.

SARRAH would encourage the government and JSA to ensure the work program includes cross-cutting macro/strategic level considerations, such as:

- managing the development of workofrce development and supply across multiple (competing) employment sectors - e.g. in caring, health and building - noting the workforce implications of committing to building 1 million new dwellings over 6 years);
- regularly assessing whether emerging or potential workforces have been overlooked and/or underutilised previously;
- Enabling latent workforce capacity, notably in rural and remote Australia - for example and in mature age workers;
- Assessing alignment between (regional)  workforce demands, available potential workforce, VET training offerings and access (noting these frequently don't align).