PO Box 6886
Marion Square, Wellington
Tel: 04 284 2000
www.inclusivenz.org.nz
EMPLOYMENT, PARTICIPATION AND INCLUSION SERVICES: DRAFT PROPOSALS FOR
CHANGE
Submission from Inclusive NZ
24 April 2015
About Inclusive NZ
Inclusive NZ is a federation of organisations providing employment and community support services
for disabled people. We represent 70 member organisations throughout Aotearoa/New Zealand.
The majority of our members provide a range of support services and are contracted by a range of
funders, including Ministry of Social Development, Ministry of Health, ACC, Ministry of Education
and District Health Boards.
In compiling this feedback we have consulted widely with our members. The proposals were
discussed at our Forum on 25 March and those who could not attend the Forum also had
opportunity to provide written feedback, both on the discussion document and our draft
submission. Members have been consistent in their comments and the issues they identified.
We have discussed the proposals with our colleagues in the sector, including other provider
networks and Disabled People’s Organisations. We support and endorse many of the issues raised in
the submission from the Disability Employment Forum, and support the submissions of our member
organisations, such as Workbridge, who have provided valuable feedback about how the proposals
will impact on them.
This submission looks at each of the five proposals outlined in the Discussion Document. Our
intention is to be constructive and to seek better outcomes for disabled people, while also ensuring
that support services have the capacity and capability to ensure these outcomes can be met.
1. The Need for Change
The Discussion Document outlines the need for change and the purpose and scope of the proposals
for change. These include:
 Improving the effectiveness of existing services
 Alignment with Enabling Good Lives and Welfare Reforms
 Applying an investment approach
 Managing within on-going budget constraints.
There is also reference to the Improving Existing Employment Services Working Group being
involved in the development of these proposals.
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We recognise that MSD must work within the parameters set out by the Government but we
challenge some of the processes and assumptions that underpin this document:
a) There is no evidence or explanation of how the effectiveness of existing services needs to be
improved. The document outlines issues with the current arrangements, but these are
largely based on anecdotal feedback and assumptions. Most of the barriers that our
members, and the people they serve, experience are not described. These include:
 Lack of easily accessible information on how to access the support system for people
and families.
 Meeting disabled people’s expectations for personalised supports within a contributory
funding system created for centre-based supports that has not had an increase for
between 8 – 10 years.
 Providing adequate support for people as they age.
 Managing the constraints on people’s choices which arise because of misalignment with
other contracted services, e.g. Ministry of Health funded day and residential services
and Ministry of Education ORS criteria.
 Continuing to find jobs for people within a changing labour market.
 Addressing the attitudes of communities and employers towards the inclusion of
disabled people.
 Disincentives within the benefit system that discourage people from working, including
abatement levels and people’s fear of Work and Income.
b) The demonstration projects for Enabling Good Lives are still in their early days and it seems
premature to try and align contracts and funding processes before the Demonstrations have
been completed and evaluated. We do not see how the proposals align with the EGL
principles, especially in relation to:
 Self-determination and people having choice and control over their own lives. In fact,
the proposals give Work and Income more power and control over a person’s life
through a more prescriptive referral process and only allowing people to access one
funded service at a time.
 A person-centred and whole of life approach. The proposals are about Work and
Income processes and have a single focus on work. They ignore the realities and
complexities of people’s lives and reinforce the siloed approach we are trying to move
away from.
 Being easy to use. Rather than streamlining the existing system the proposals are likely
to make the disability support system harder to understand and negotiate. There will be
extra levels of referral and assessment and there is no clarity about how the Work and
Income outcome assessment will align with the planning work undertaken by EGL
Navigators.
c) We understand that Work and Income is required to implement the investment approach
adopted by this Government. The proposals, however, take a narrow view of an investment
approach by only considering the cost savings associated with moving people off benefit and
into work. They do not take into account the economic benefits of people working fewer
than 15 hours per week. In many cases this type of employment improves wellness and
overall wellbeing, which in turn reduces the incidence of people requiring interventions from
other government funded agencies, such as the health and justice systems.
d) The processes for engaging the disability community in the development of these proposals
have been poor. When we have been invited to provide feedback it has often been at short
notice, within the parameters of pre-determined questions and without the benefit of fully
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understanding the context or being able to consult with our members. In most situations
we have been able to offer little more than reaction and the process has, therefore, not
been informed by considered responses.
e) It is unrealistic to expect that the sector can support and implement changes of this
significance within existing funding parameters, especially when current funding is already
inadequate to achieve what is expected now. It is dishonest of Government to increase the
expectations of disabled people in terms of policy direction when it is not prepared to
provide the necessary investment.
f)
The main driver for these proposals appears to be welfare reform. The Disability
Employment Forum has consistently outlined the need for an over-arching, crossgovernment, employment strategy to improve employment outcomes for disabled people.
Without this government agencies continue to take a siloed and piecemeal approach that
will not affect the change that we have all agreed we would like to see.
2. Proposal 1: Introduce a new Outcomes Framework
a) We support the development of an outcomes framework and the focus on supporting
people to find and stay in employment. We are also pleased that the Outcomes Framework
demonstrates an understanding that the pathway to employment is not a linear one for
many disabled people and allows them to move back and forwards between outcomes as
their circumstances dictate. We are also pleased that the disabled people’s right to have
access to specialist employment services is acknowledged.
b) It is not clear what type of support that a person on a Pathway to Sustainable Employment
might be able to access, and from whom.
c) We understand the logic behind funding support for people to achieve one outcome at a
time, but this does not reflect the reality for many people, particularly those on a Pathway
to Sustainable Employment. People in this circumstance may have complex needs and
require support from a Participation and Inclusion service when they are not involved in
training or other skill-building activities.
d) We are unclear about how the Outcome Setting Decision Support Tool will be developed
and used. Any tool and/or process that is developed must be strengths-based, support a
person’s goals and aspirations and identify how a person’s circumstances impact on how and
when these goals might be achieved. We are concerned that the proposed tool will only be
used to restrict eligibility to services based on a person’s perceived ‘level of disability’.
At present employment and participation and inclusion services are required to develop
personal plans with each person to ensure that their goals and aspirations are articulated
and inform service delivery. EGL Navigators are also undertaking planning and matching
with participants in the Demonstrations. The Work and Income tool will add yet another
planning and assessment process to people’s lives.
Recommendation 1: We would like to suggest that we take this opportunity to review and
align the various planning and assessment processes across agencies. This may identify a
more stream-lined and less intrusive approach that ultimately costs the government less
money than every agency undertaking its own assessment processes. There is considerable
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experience and knowledge about strengths-based planning processes among providers and
we are happy to contribute to this work.
e) There is a high level of concern amongst our members about the increased power and
control Work and Income will have over both disabled people and service providers. They
will effectively be acting as gate-keepers to services by controlling the outcomes setting and
service matching process.
f)
The feedback from our members is that many of the people they support are confused
about their benefit status, including what benefit they are on, and are anxious about their
interactions with Work and Income. This has been compounded by the increased security
measures at Work and Income offices. It is important that people have access to advocacy
support during the transition process. It should be noted that providers are not funded to
provide this level of advocacy but are frequently required to do so because they have a
trusted relationship with the person and know their circumstances.
g) Currently Work and Income front-line staff do not have a good knowledge of employment,
participation and inclusion services in their areas. Our members do not have confidence in
their ability to refer people to the appropriate services.
h) We would like to know in what circumstances Work and Income would not accept the
results of an assessment and who in Work and Income will be reviewing and accepting
assessments? Our experience of Work and Income front-line staff is that they do not have
the skills, experience and time to undertake this work. We would also like to know what
redress a person will have if they are unhappy with Work and Income’s decisions.
3. Proposal 2: Improve Support for people to get and stay in work
a) We do not believe that the investment approach taken in the proposals is being effectively
applied in relation to employment, participation and inclusion services. In reality it will
result in the people requiring the greatest levels of support receiving less, and is highly likely
to cause a balloon effect in other parts of the system, e.g. health and justice.
b)
The investment approach does not align with our commitments under the UN Convention
on the Rights of Persons with Disabilities, Enabling Good Lives or the Disability Strategy.
Recommendation 2: We suggest that it is more appropriate to take a whole of life and whole
of government approach to employment, participation and inclusion services for disabled
people and recommend that this is put to the Work and Income Board for consideration.
c) We acknowledge the work that is being undertaken through the Disability Action Plan,
particularly in relation to building employer confidence. This work, however, is still in
development and employment services are dealing with the realities of the labour market
and employer attitudes.
Feedback from our members indicates that few employers are prepared to offer work for
more than 15 hours per week at the outset, but this can change once they have taken
someone on. The proposals for improving support for employment may actually result in
fewer employment opportunities because the criteria are unrealistic. We are also
concerned that providers will have to deliver on unrealistic outcomes and will be penalised if
they fail to meet them.
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d) At our recent Forum, Inclusive NZ members were unanimously opposed to milestone, or
outcomes-based, payment structures. Our experience is that they do not provide any
incentives for providers. They are highly likely to:
 Result in ‘cherry-picking’, where providers are incentivised to work with those
people who are likely to achieve outcomes and to avoid working with people who
face greater barriers.
 Increase competitive behaviour between providers and dis-incentivise collaboration.
 Destabilise the financial viability of organisations and disadvantage those who do
not have financial reserves to draw on. We would like to point out that many
organisations, small and large, are currently in this position as a result of the
compounding effects of increased costs and no funding increase for 8-10 years.
 Cause providers to opt-out of contracts creating a service delivery vacuum.
Recommendation 3: we strongly recommend a review of funding for employment,
participation and inclusion services and that Work and Income requests and works with
providers and their national networks to develop a fairer and more sustainable funding
model.
4. Proposal 3: Improve support for people to participate and be included in
employment and their communities
a) We are heartened to see that the hard work providers have put in to adapt their services to
achieve greater inclusion for disabled people is acknowledged in the Discussion Document.
Our members want to provide services that are more person-directed, support people into
employment and to be included in their communities.
b) It is important to note, however, that providers are hampered in their efforts to achieve
these outcomes by the current funding levels, which MSD has always stated were
contributory rather than meeting the true cost of service provision. Most providers receive
a contribution of between $3,500 - $5,500 per person, per year. This equates to between
$13.40 - $21.00 per person, per day. It is simply not possible to provide all people with
personalised supports in the community at these funding levels.
c) If Work and Income is going to change service specifications and require organisations to
meet increased outcome expectations as part of their contract obligations then it must
provide the funding to match.
Recommendation 4: We recommend that no changes to contracts are introduced until Work
and Income is able to support the increased expectations with increased funding.
d) There can be an inherent conflict between contract outcomes and person-directed services
when a person does not wish to work or be more active in his/her community. This can be
the case for a variety of reasons, but particularly as the result of conditions related to early
aging and illness.
e) We are concerned that providers will be penalised if they are unable to meet contract
obligations for these reasons and would like greater clarity about how their performance will
be evaluated and what sort of contract accountability measures will be required.
f)
In consultation meetings about the proposed changes we were repeatedly assured that
Work and Income staff would be up-skilled so that their knowledge and the culture of their
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workplaces would enable them to meet the increased expectations outlined in the
proposals. We ask that the same opportunity for development is offered to provider
organisations, as it was when Pathways to Inclusion was introduced. Internationally, we are
not aware of any jurisdiction that has expected service providers to move to personalisation
without significant investment in staff training and organisational development.
Inclusive NZ has documented what we have learned through administering the Training and
Workforce Development Fund, providing forums for our members and working with
organisations through our organisational development service, One Fish Solutions. We are
happy to share this and work with Work and Income to develop an Organisational and
Workforce Development Strategy.
Recommendation 5: Develop an Organisational and Workforce Development Strategy to
ensure that provider organisations have the skills and capabilities to implement the changes
required in the proposals.
5. Proposal 4: Ensure services are accessed by the people for whom they are
intended, and the available funding is used more fairly.
a. The Discussion Document does not adequately outline how existing services are not being
accessed by those for whom they are intended and, most importantly, by those who need
them. The driver for change seems to be that demand for services is outstripping the
funding available, making it necessary to restrict eligibility criteria. We do not find this an
acceptable rationale for change.
b. We are concerned about the proposal to restrict eligibility for Participation and Inclusion
support to those who are receiving Supported Living Payment. Our members have a number
of examples of people who have been put into the JobSeeker benefit category but who
require significant daily support. In many situations people are not aware of their benefit
category and struggle to communicate their circumstances to Work and Income staff and
their GPs.
c. The definition of open employment does not appear to be well understood by Work and
Income staff or GPs.
d. The proposals make the assumption that the 18 percent of people currently accessing
Participation and Inclusion services who are not on Supported Living Payment will need to
be transitioned to another service. We suspect that many of these people will apply for a
case-by-case review and that the likely outcome is that it will be determined that they are
unable to work 15 hours or more per week in open (i.e. without support) employment for
two years or more.
e. People who are currently working fewer than 15 hours per week are likely to be transitioned
from specialist employment services to Participation and Inclusion services. It will require
the new service to establish a relationship with the person’s employer in order to ensure
that their job is secure and they are not worse off. Participation and Inclusion services have
indicated that they are concerned about their capacity to take on more people and to
provide them with the type of support they require. There is also no indication in the
Discussion Document of how many people will be affected by this change, and what funding
will be attached to them.
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f.
The proposals assume that there are services available to transition people to, and that
these services have the capacity to take more people. This is not necessarily true, especially
in rural areas.
Recommendation 6: We recommend that more time is taken to better understand the
population of people who may need to be transitioned, and the capacity and availability of
services to transition them to, and that proposals for any changes required are developed in
response to this.
g. The proposal to restrict people to accessing one funded Participation and Inclusion place at a
time is at odds with the principles of Enabling Good Lives, the expectations of disabled
people and their families and Better Public Service targets asking providers to collaborate
more. It also poses a risk of provider capture, which is something that the sector has been
trying to overcome for some years. Providers are increasingly working with people and
families who want to select a suite of supports. This is challenging within the existing
contracting and funding arrangements due to the low levels of funding involved and the
administrative complexity of trying to make this work.
Recommendation 7: We strongly recommend that proposal four is dropped and that we
await the findings from the EGL Demonstration Projects to see how we can best support
greater client choice, increased personalisation and better collaboration between providers.
6. Proposal 5: A trial of Work and Income matching people to employment services
a. We acknowledge that there are issues with how people currently access employment,
participation and inclusion services. Disabled people and their families frequently share
their frustration about how difficult it is to find out what supports and services are available
and how to access them. We are not aware of any people or families raising concerns about
self-referral.
b. We are pleased that people matched to a Participation and Inclusion service will be able to
choose their own service provider. This acknowledges the importance of self-determination
and establishing a relationship of trust between services and the people they serve.
c. The proposed trial places Work and Income in a gate-keeping role with a high degree of
control over both disabled people and providers. Work and Income offices currently have
little awareness of what providers offer and we are not confident in their ability to make
assessments about disabled people and match them to the appropriate supports.
d. The Enabling Good Lives Demonstrations are also looking at the role of Navigators to better
connect people with appropriate supports. It is not clear how, or if, the two approaches will
be evaluated and compared.
Recommendation 8: It would seem a better use of resources and a better alignment with
Enabling Good Lives principles if assessment and referral processes were streamlined.
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Summary of Recommendations
While this submission focuses specifically on the proposals outlined in the Discussion Document we
believe that there should be a much more focused, over-arching employment strategy for disabled
people, rather than the welfare strategy that currently exists. We would like to see government
agencies, disabled people and providers working in partnership to develop this, and a long-term
commitment to its implementation.
Recommendation 1: We would like to suggest that we take this opportunity to review and align the
various planning and assessment processes across agencies. This may identify a more stream-lined
and less intrusive approach that ultimately costs the government less money than every agency
undertaking its own assessment processes. There is considerable experience and knowledge about
strengths-based planning processes among providers and we are happy to contribute to this work.
Recommendation 2: We suggest that it is more appropriate to take a whole of life and whole of
government approach to employment, participation and inclusion services for disabled people and
recommend that this is put to the Work and Income Board for consideration.
Recommendation 3: We strongly recommend a review of funding for employment, participation and
inclusion services and that Work and Income requests and works with providers and their national
networks to develop a fairer and more sustainable funding model.
Recommendation 4: We recommend that no changes to contracts are introduced until Work and
Income is able to support the increased expectations with increased funding.
Recommendation 5: Develop an Organisational and Workforce Development Strategy to ensure that
provider organisations have the skills and capabilities to implement the changes required in the
proposals.
Recommendation 6: We recommend that more time is taken to better understand the population of
people who may need to be transitioned, and the capacity and availability of services to transition
them to, and that proposals for any changes required are developed in response to this.
Recommendation 7: We strongly recommend that proposal four is dropped and that we await the
findings from the EGL Demonstration Projects to see how we can best support greater client choice,
increased personalisation and better collaboration between providers.
Recommendation 8: It would seem a better use of resources and a better alignment with Enabling
Good Lives principles if assessment and referral processes were streamlined.
John Grant
President
Email: [email protected]
Tess Casey
Chief Executive Officer
Email: [email protected]
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