| Response to National Mental Health & Disability Employment Strategy |
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DRAFT submission to the National Mental Health and Disability Employment Strategy 1. Employers – Barriers What are the barriers to recruiting, retaining and assisting in the career development of people with disability and/or mental illness? a) Relevance (also known as WILL) Members of the Australian Employers’ Network on Disability are exceptional employers who have made a public commitment to enhancing career opportunities for people with disability. These organisations are leaders in their fields, and are taking steps to become more disability confident businesses. Our members demonstrate a willingness to include people with disability and it is our experience that willingness often mitigates cost. The organisations that have the best performance are those that have ‘top level’ support, i.e. people from the top management team championing the inclusion of people with disability. That said; inclusion of individuals with disability should be cost neutral to business. Despite this, for most Australian businesses the recruitment of people with disability is an invisible issue. They are unconsciously unskilled in making workplace adjustments that are often required to accommodate people with disability. Whilst most large Australian organisations have a budget to assist in attracting and retaining diversity groups such as women, indigenous Australians and people from culturally and linguistically diverse backgrounds, it is rare for an organisation to have a budget or a focus on inclusion of people with disability. Many APS agencies claim not to have a budget to remove barriers to people with disability. When Government is purchasing services, there is no requirement to report on inclusion of people with disability. There is, however, an expectation that tenderers will report on gender and indigenous diversity. This further highlights the ‘invisible’ nature of disability. Those organisations that do have an obligation to report on employment performance, such as APS or State Public Sector, experience no consequence for not making progress, giving the impression that inclusion of people with disability, while somewhat desirable, is not a business imperative. A review of recent articles in the press, industry magazines and business publications (such as BRW May 21 08) demonstrates that 457 visas, mature age workers and women returning to work are identified as groups which can contribute to Australia’s skills shortage. Tapping into the talented pool of people with disability is not commonly seen as an answer to the skills shortage. Indeed, when the Employers’ Network on Disability recently called a large multi-national corporation, we were advised by their Human Resources Department that they were ‘personally and professionally sympathetic but unable to “help”’. This clearly demonstrates that people with disability are not considered viable employees, and in fact are still seen from a charity perspective. Another significant issue is the (perceived and actual) fact that people with disability do not have the skills that employers are seeking. While sometimes based on misconceptions and stereotypes, in reality, many people with disability have not been afforded the opportunity to develop relevant, desirable and valued skills. A ‘work first’ employment policy pursued by the previous Government resulted in people with disability being placed into employment with skill levels that will leave them at risk of losing employment or being at the margins of employment. Employers recruit for skills. If people with disability do not have an opportunity to develop their skills, escaping poverty and sharing in the wealth of Australia becomes a distant dream. Business commentary on the skills shortage does not identify people with disability as a potential labour source. A lack of perceived relevance to business is a major barrier to employers recruiting people with disability. When a large business embarks on developing a proactive disability employment strategy, gaining internal support can be very challenging. This is generally because people with disability are perceived to be the responsibility of either Government or charity, rather than as viable candidates for the workplace. Employers and co-workers perceptions of people with disability often mirror community perceptions. In Australia today, there remains a lack of understanding of the diversity of people with disability and their capacity to contribute to our economic and social wellbeing. b) Health and Safety concerns Despite the research undertaken by the Australian Safety and Compensation Council –‘ Are People with Disability at Risk at Work?’, many employers still perceive people with disability to be at additional risk in the workplace. Perception is more powerful than fact. Additionally, employers are concerned that they are not sufficiently trained to appropriately assess the risks associated with employees with disability in their workforce and this acts as an powerful recruitment barrier. c) Costs – both real and perceived Discussions regarding costs associated with employing people with disability often focus on the costs of workplace adjustments. Whilst employers do have some concern about the direct costs of recruiting people with disability, a substantial concern relates to indirect costs. These indirect costs arise from time spent in negotiating, coordinating and organising workplace adjustments or changes to duties that may be necessary. Employers are also concerned that if the placement is not successful there will be a substantial amount of time and energy required to resolve the situation. d) Recruitment systems There is currently no system for large national employers to attract a diverse range of candidates with disability. The Australian Jobsearch site does not offer employers an opportunity to indicate they would welcome applications from candidates with disability. The site offers employers an opportunity to encourage applications from jobseekers who are indigenous and of mature age. Recently, when we were contacted by the Pet Industry Association, whose members are experiencing labour shortages, the only suggestion we could make was to refer their members to the JobAccess website. This is not an elegant and cost effective solution. There needs to be a mechanism for a coordinated approach. In assisting Insolvency Trustee Services Australia (ITSA) with a targeted vacancy for a jobseeker with disability, it was found that the funded National Disability Coordinator would not distribute the vacancy. As we understand it, a Memorandum of Understanding is required and the Department of Education, Employment and Workplace Relations (DEEWR) has restricted access to a free service. Currently, jobseekers are in silos. There are the Disability Employment Network Services, the Job Network Services and the Vocational Rehabilitation Services as well as injured workers. Placing jobseekers in silos without any linkage is a barrier to employers recruiting people with disability. It is simply impossible to overcome this barrier. Furthermore, unlike indigenous labour market programs, there is no labour market program that assists an organisation to develop a comprehensive business case for inclusion of people with disability. This is because any incentive or subsidy is entirely related to the individual or the discretion of the employment support service. A program similar to the STEP program for Indigenous Australians would assist an organisation to develop a business case and build their internal capacity. e) Retention Currently, the support provided by the providers of Government employment services is time limited. Some employees need long-term assistance and this support should be available to both the jobseeker and the employer. Furthermore, when the support is no longer funded, although the employer can claim ‘job in jeopardy’ in order to get the support required, this can result in the employee and their family becoming alarmed and defensive. Complexity is compounded for employers who require immediate assistance for employees with mental illness by the different support procedures across States. For example, in Queensland, if the Crisis Team is required to support an employee with a mental illness in the workplace, the police need to be called. This puts both employer and employee in an extremely difficult position for ongoing employment. The requirement of Crisis Team support should not necessitate an employer calling the police to assist with their employee. Often, the only way to achieve support is to leave a job and become unemployed. This is not helpful for either employers or people with disability. 2. Goals of strategy What does the Strategy need to achieve to help make progress in recruiting, retaining and assisting with career development of people with disability and/or mental illness?
Companies such as IBM and Benbro Electronics (a small business of 20 employees) review their performance and inclusion of people with disability and specific accountabilities are in place. Whilst the APS and State Public Services are required to report on their performance in relation to inclusion of people with disability, there seems to be no accountability for poor results, and no strategies in place to improve these results. Our experience in speaking with some APS agencies, is that despite the Management Advisory Committee Report No 6 on the Inclusion of People with Disability in APS Agencies, and their subsequent reporting obligations, they have stated that they will not be developing a strategy to meet those requirements. If the policy-making arm of Government is serious about employers including people with disability then they must also become serious as employers across portfolios. RECOMMENDATION 2: Government departments’ or agencies’ performance in relation to inclusion of people with disability should have direct accountability to an individual and be part of their performance evaluation with consequences arising from poor performance. RECOMMENDATION 3: Providers of goods and services to all levels of Government should outline their performance on including people with disability. Additionally, providers should warrant that the goods and services provided are designed to be barrier free to people with disability.
Building relevance to business of people with disability as employees and customers is the foundation to achieving success of the strategy. A social change strategy is required with a medium to long term focus that underscores the message that Australians with disability are valuable citizens. A social change strategy should build awareness of the diversity of people with disability and their contribution to Australian society. As well as the social change strategy outlined above, businesses will benefit from the articulation of an Australian business case for inclusion of people with disability as customers and employees. The Australian Employers’ Network on Disability is currently working with our members and Government to sponsor the development of a booklet that will increase knowledge and promote better understanding of relevance to business of people with disability. This will also be supported by a comprehensive website providing examples and case studies. Health and Safety An efficient solution to overcoming employer perception in relation to additional workplace risks would be for the Commonwealth to purchase a Group Workers’ Compensation Scheme that would provide insurance coverage for employees with disability for their first year of employment with an organisation. Given the data from the ASCC research report, a scheme such as this should be relatively easy to cost and fund. Additional benefits could be achieved from such a scheme if a procedure was introduced that outlined the risks specific to the workplace and then considered whether there were additional risks evident associated with the employee’s disability. A checklist could ‘sign off’ how the employee with disability can follow all safety procedures. This procedure would develop further knowledge about health and safety procedures in relation to people with disability as well as mitigate the risk for Government as funder of the insurance scheme. RECOMMENDATION 5: Commonwealth Government negotiates a ‘group’ Workers’ Compensation Insurance policy to cover eligible employees with disability for their first year of employment with a specific employer. A condition of eligibility of the group scheme could be that the workplace risks are identified and ‘signed off’ in relation to the employee with disability. Cost For large organisations, substantial internal resources need to be deployed to assist the organisation adapt their recruitment procedures, develop reasonable adjustment policies and procedures, provide education sessions to hiring managers and recruiters, develop their internet resources, communicate across the organisaton and to ensure appropriate support networks are in place. Previously, Government funded a Special Employment Placement Officers program which assisted companies such as Telstra, IBM and Qantas commence their journey to becoming barrier free organisations, and these organisations have continued (at their own cost) to make progress in relation to the recruitment and retention of people with disability. RECOMMENDATION 6: Funding should be available for large organisations, to develop a Structured Training and Employment Program for people with disability. This would allow large organisations to employ ‘diversity specialists’ to make progress on including people with disability. Additionally, industry organisations should also be eligible to apply to have ‘diversity specialists’ funded to meet the needs of their small and medium enterprise members. However, when people with disability do have the skills required, state-based payroll tax is a substantial disincentive for businesses to employ more people. Eliminating the salary of employees with disability from payroll tax liability would be an efficient and effective way of increasing employment participation of people with disability. This puts the focus on the company’s inclusion rather than subsidies associated with individuals. People with disability who are employed utilise less state-funded services than people with disability who are unemployed. Payroll tax exemption for people with disability may be palatable for State Governments, easy to administer and benefit employers. RECOMMENDATION 7: Commonwealth Government assist State Government with the modeling of costs and benefits to exempt the salaries of eligible employees with disability from State payroll tax. Subsidies associated with recruiting individuals provide a ‘mixed message’ in relation to the skills of the individual. Research undertaken by Graffam et al, showed that offering financial subsidies linked to the recruitment of an individual did not impact on an employer’s decision to hire. Recruitment systems Currently there is no Government strategy for large businesses to develop proactive strategies for recruiting people with disability. The ‘Corporate Leaders for Indigenous Employment’ program has been adopted by many of our members, and consultations indicate that a similar program would be effective for large organisations developing recruitment strategies for people with disability. The Department of Education, Employment and Workplace Relations provides a flexible package of funding to Corporate Leader organisations. This funding is tailored to business needs and assists with the development and implementation of strategies that may include assistance for pre-employment training, mentoring and/or cross-cultural awareness training. Coherent labour market programs that build capacity for employers and people with disability need to be developed and continued until substantial progress is made. Employers need to be confident that participation in a labour market program will be sustainable and durable. Currently there is no consistent subsidy or offering to employers to offset the any costs associated with additional time they may need to provide to recruiting and retaining a jobseeker with disability. Subsidies are offered at the discretion of individual Disability Employment Network Services. RECOMMENDATION 8: Reliable subsidies are available to small businesses that do not have payroll tax liability. RECOMMENDATION 9: An efficient and effective mechanism be available to employers to recruit from the entire talent pool. Whilst the focus on this consultation is specifically on people who have barriers as a result of mental health or disability, it must be remembered that employers recruit for skills. Retention and Career Planning The current focus is solely on placing a person with disability in a job. This needs to be broadened substantially to skills acquisition prior to employment as well as supporting learning and development throughout employment. The funding model for supporting people with disability in employment needs to accommodate changes in technology and workplace changes to ensure relevancy and currency of skills. Lifecycle needs must be taken into consideration in relation to people with degenerative conditions. Support needs to be provided, when appropriate, to assist a person with disability to reduce their working hours. As the capacity to work decreases, a disability support financial safety net needs to be available. RECOMMENDATION 10: Assistance should be provided by career coaches to assist people with disability and their employers with career development, skills development and indeed ‘downshifting’ and leaving the workplace if required. Additional suggestions a. What specific actions could be taken by Employers? Employers would benefit from increasing their understanding of the intersection between their specific business and people with disability as customers, employers, shareholders and suppliers. Ideally, employers will take action to ensure they have accessible premises, have barrier free recruitment processes, ensure their goods and services are accessible to people with disability, and that their suppliers also provide barrier free products and services. b. What specific actions could be taken by Government? In addition to overcoming the barriers outlined above, the Federal Government needs to asses whether the regulatory system is sufficiently effective to create equal opportunities for people with disability in Australia. Government needs to reward employers in both the public and private sector who make solid progress on becoming disability confident organisations. Most importantly, Government needs to implement significant reforms to the Disability Support Pension scheme, and ensure there is no financial disincentive to employment. The Welfare to Work policy created a great deal of fear and uncertainty for people with disability in relation to loss of benefits and entitlements. The Disability Support Pension might keep people close to poverty, but it is at least reliable. We need a system for payments of benefits that is flexible and provides safety net provision for people with disability to enter, leave and re-enter the workforce, work part-time and/or combine work with study. The current arrangements are punitive for many people, especially for people with degenerative conditions who need to reduce their working hours, and students who receive the Disability Support Pension but run the risk of losing their eligibility if they undertake course-related work experience placements. We recommend that all steps are taken to ‘pull’ people into participation and that we take active steps to increase the aspirations of people with disability. Remove all benefit related barriers to skill development and employment for a short time and learn more about what it will take to achieve increased participation in education, employment and the community for people with disability. The previous Government’s focus on ‘work first’ resulted in an inadequate ‘fit’ between the skills that employers are seeking and the skills of unemployed people with disability. In summary, take away the fear, provide people with training opportunities, make it easy for people to enter or stay in the workforce and make it flexible. RECOMMENDATION 11: A long-term career approach to employment for people with disability needs to be adopted. During the transition from school education to employment, serious consideration needs to be given to how the individual can be best supported to gain skills and knowledge that will assist them have long term fulfilling employment. c. What specific actions could be taken by Service providers It would be more helpful to employers if service providers were able to work in a cooperative rather than competitive environment. Ideally, service providers would recognise employers as valued stakeholders and would be more effective in highlighting their jobseekers’ specific skills and attributes. Service providers need to be able to clearly articulate how they will support the jobseeker and the duration of support.
Conclusion For the National Mental Health and Disability Employment Strategy to achieve increased employment participation by people with mental health challenges and/or disability, there needs to be greater attention given to employers as valued stakeholders. There also needs to be more focus on the skills of individuals rather than on their disability. It is helpful to view the strategy as a ‘capacity building’ process, and acknowledge that there is much to be done by all stakeholders to develop a sustainable employment system that accommodates people with disability in a seamless way. Against a backdrop of barriers and challenges, members of the Australian Employers Network on Disability have demonstrated their willingness to take a leadership role in including people with disability as employees and customers. Imagine the potential that could be achieved with a relevant and effective National Mental Health and Disability Employment Strategy. |
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