Generating and preparing for a Comprehensive Compliance Assessment (CCA) 001-18030212

CCAs underpin the integrity of the Job Seeker Compliance Framework by ensuring that serious failure penalties are applied appropriately in the case of persistent non-compliance, and provide the flexibility to ensure vulnerable Community Development Program (CDP) participants are appropriately supported and protected.

A CCA is generally automatically triggered by a CDP participant’s apparent persistent non-compliance but may also be used as an early intervention tool.

While the CCA is the legislated safety net to ensure serious failures are applied appropriately, the CCA is also a critical opportunity to improve a CDP participant’s likelihood of future compliance by:

• providing an opportunity to identify and/or assess issues for vulnerable CDP participants, who may be experiencing a range of complex needs, and whose circumstances affect their ability to meet their mutual obligation requirements, and
• recommending suitable alternative intervention strategies and pathways for CDP participants with vulnerabilities

A CCA is automatically triggered once the number of No Show, No Pay failures, non-attendance failures, connection or reconnection failures applied indicates a pattern of non-compliance.

CDP providers or Services Australia may also manually trigger a CCA where there are indicators that a CDP participant may have barriers to compliance.

There are no limits to the number of CCAs that can be undertaken for a CDP participant and no time frames for how often a CCA can be undertaken during a CDP participant’s period of employment assistance.

Attendance at the CCA is a compulsory requirement. CDP participants who fail to attend a CCA will be unable to report until contact occurs with a Participation Solutions Team-skilled Service Officer to discuss the CCA.

An outstanding CCA will not affect the investigation of serious failures for refusing or failing to accept a suitable offer of employment or Unemployment Non-Payment Periods (UNPP).

Each time a No Show, No Pay, non-attendance, connection or reconnection failure is applied the system checks the failure history to see if a CCA should be automatically triggered.

A CCA is automatically triggered where there are 3 applied failures of the same 'type' (that is, either 3 connection/non-attendance/reconnection failures, or 3 No Show, No Pay failures) with incident dates in either:

• the 6 month period prior to the system date, or
• since the last finalised CCA where the outcome was either to apply a serious failure or finalise without penalty

Automatic CCAs are generated as part of overnight processing.

Where a failure is applied that will result in the automatic generation of a CCA, a Participation Solutions Team (PST)-skilled Service Officer can choose to generate the CCA immediately so that the CCA can be conducted while the CDP participant is on the phone.

Note: rejected CCAs do not count as a finalised CCA. Where a CCA has been rejected, another CCA will automatically generate when a further 'triggering' failure is applied with an event date after the date the previous CCA was rejected.

A CDP participant’s serious failure penalty ends when either:

• the CDP participant has served the serious failure period in full, or
• the penalty for the serious failure has been permanently waived, which is generally when the CDP participant attends a waiver re-engagement appointment with their provider

As a result, the system will prevent either the manual or automatic generation of a CCA where the applied failures have occurred after a serious failure has been applied but the potential event date of the CCA:

• falls within a period of conditional waiver, or
• is prior to the start date of the existing serious failure period (where the CDP participant is serving the serious failure period)

In these circumstances, a new serious failure assessment period has not started.

Providers and Services Australia may manually request a CCA where there are indicators a CDP participant may have suspected circumstances impacting compliance with their mutual obligation requirements.

A pattern of non-compliance is not a pre-requisite for a manually triggered CCA. However, a manual CCA will usually be generated following one or more non-compliance events.

The aim of a manual CCA is to:

• assess the CDP participant’s capacity to comply with their mutual obligation requirements, and
• review the types of employment assistance they are receiving

A manual CCA request should contain sufficient supporting material to form the basis for initiating a CCA, including:

• why the CCA was requested, and
• a summary of any suspected barriers to employment and current personal circumstances

Service Australia generated CCAs are only generated by PST-skilled Service Officers. Before generating a manual CCA, the PST-skilled Service Officer considers whether any of the following are more appropriate:

• updating the Job Seeker Snapshot
• referring the CDP participant for an Employment Services Assessment (ESAt), or
• granting a mutual obligation exemption

A provider may request a manual CCA for a CDP participant with mutual obligation requirements. Prior to making this request, the provider is expected to consider whether the following is more appropriate:

• a Job Seeker Snapshot Change of Circumstances assessment, or
• referral to Services Australia for an exemption from mutual obligation requirements

If a manual CCA is preceded by multiple rejected Participation Reports, the provider's decision to lodge a CCA would generally be based on a belief that:

• unidentified circumstances are impacting the CDP participant’s compliance, and
• a CCA is required to uncover and assess the impacts of these barriers

A manual CCA is not appropriate when:

• it's used by the CDP provider as a means of simply attempting to contact a CDP participant who is difficult to engage, or
• the CDP provider has identified a significant change in the CDP participant’s circumstances, and consequently an assessment is required to determine the CDP participant’s participation requirements, including assessment of work capacity, barriers to employment, mutual obligation requirements and suitable employment assistance services. In this circumstance an ESAt is the correct assessment

Even though a serious failure may be an appropriate outcome, a manual CCA should not be generated as a means to determine whether a serious failure should be applied.

Note: a provider cannot manually generate a CCA where there is an outstanding ESAt.

After the generation of a CCA (either manual or automatic) PST-skilled Service Officers undertake preparatory work before transferring the CDP participant to a CCA Specialist.

CCA preparatory work involves:

• Validating the CCA
• Explaining the purpose of a CCA to the CDP participant
• Identifying the most appropriate CCA specialist
• Notifying the CDP participant of the requirement to attend the CCA
• Recording relevant information on the CCA Details page for the CCA Specialist
• Reviewing outstanding reconnection requirements and ending reconnection failure periods
• Finalising outstanding compliance actions where appropriate

PST-skilled Service Officers are responsible for determining which CCA Specialist is the most appropriate based on the CDP participant’s individual circumstances.

CCA Specialist identification

A CCA may be conducted by the following specialists (referred to as a CCA Specialist):

• a PST-skilled social worker or
• a Participation Solutions Team SO5

CCAs are conducted by PST-skilled social workers where the CCA is the participant’s first CCA, or the first CCA conducted in a twelve month period (referred to as an 'initial CCA'), and the participant:

• is in receipt of Youth Allowance (YA) or
• has a presenting or recorded current circumstance impacting compliance of either:
• medical condition - mental health
• family relationship/domestic violence, or
• is identified as being in crisis and there are exceptional circumstances identified that indicate social work assessment skills are required during the CCA

CCAs are conducted by SO5s where:

• the CCA is the second or subsequent CCA in a twelve month period (referred to as a 'review CCA'), OR
• the CCA is an initial CCA, and the participant does not meet any of the criteria above to indicate a PST-skilled social worker is the most appropriate specialist to conduct the CCA

Note: while these specialist streaming guidelines are intended to support staff to make consistent decisions regarding the most appropriate specialist to conduct the CCA, they are intended as a guide rather than a set of rules, to be used with flexibility, discretion and consideration of individual circumstances on a case-by-case basis.

A CCA may either occur via an immediate transfer or the CDP participant may be advised to contact by midday on the following business day. This is also known as a deferred contact notice.

The PST-skilled Service Officer is responsible for explaining the purpose of a CCA.

Attendance at a CCA is compulsory for CDP participant with mutual obligation requirements. As part of preparatory work, the PST-skilled Service Officer is responsible for notifying the CDP participant of the requirement to attend the CCA and the consequences of non-attendance.

Validation of a CCA will:

• finalise any outstanding NAR including any outstanding NAR reconnection requirements
• remove any outstanding reconnection requirements

When the CDP participant is formally notified of a requirement to attend a CCA, this ends any current non-attendance failure and reconnection failure periods.

Once a CCA has been generated and is determined to be valid, outstanding failures on the CDP participant’s record will automatically be finalised. Where the automatic process has not been able to occur all non-attendance failure, connection, reconnection or No Show, No Pay compliance investigations are to be rejected.

Attendance at a CCA is a compulsory mutual obligation requirement.

The requirement to attend a CCA includes:

• where a deferred notice has been issued, contacting before midday on the scheduled business day. In some cases, a CDP participant may be given longer to contact following a deferred notice being issued, and
• contacting before 5 pm on the same business day if disconnected while being transferred to a CCA Specialist or while the CCA is being conducted

Where a CDP participant fails to attend the CCA, or fails to comply with a CCA requirement by close of business of the day of the requirement, a contact trigger will be placed on the CCA. The contact trigger will prevent the CDP participant from reporting. The CDP participant will be required to contact the PST to complete the CCA before the next report can be accepted and payment made.