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Managing PaTH Internships Guideline, Schemes and Mind Maps of Information Systems

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jobactive and Transition to Work Guideline Managing PaTH Internships Guideline
Effective from: 2 Dec 19 TRIM ID: D19/1854978 Page 1 of 27
Guideline:
Managing PaTH Internships
A PaTH Internship (‘internship’) gives a young person aged 1724 years (inclusive) the chance to
demonstrate their skills in the workplace to a potential employer, develop vocational skills and
improve their employment prospects.
For employers, hosting an internship is an opportunity to trial an intern in a structured work
experience placement to see if they are the right fit for their business.
Internships are available to eligible participants in jobactive, Transition to Work and Disability
Employment Services.
Each internship is voluntary and is undertaken for 30 to 50 hours per fortnight over four to
12 weeks. An internship provides financial incentives to the provider, host business and participant.
The provider, host business and participant work together to create an internship that meets the
needs of the business and suits the participants skills, experience and interests.
Before starting an internship, the provider, host business and participant must agree to the terms of
the internship and sign a PaTH Internship Agreement. The provider is also required to complete a
risk assessment for each placement before the young person commences.
Participants are not required to undertake PaTH Employability Skills Training before starting an
internship. However, Stream A job seekers who commence Employability Skills Training will
immediately be eligible to participate in a PaTH internship
This Guideline is for jobactive and Transition to Work providers who are involved in managing PaTH
internships. For detailed IT steps, providers must refer to the Managing PaTH Internships IT
Supporting Document. A separate Guideline is available for Disability Employment Services
providers, administered by the Department of Social Services.
Version: 3.1 Published on: 30 October 2019
Effective from: 2 December 2019
Changes from the previous version (Version 3.0)
Policy changes:
Nil
Wording Changes:
Example of the specific activities and learnings to be included in the Internship Agreement.
Clarity on supervision requirements for Labour Hire Organisations.
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Guideline:

Managing PaTH Internships

A PaTH Internship (‘internship’) gives a young person aged 1 7 – 24 years (inclusive) the chance to demonstrate their skills in the workplace to a potential employer, develop vocational skills and improve their employment prospects. For employers, hosting an internship is an opportunity to trial an intern in a structured work experience placement to see if they are the right fit for their business. Internships are available to eligible participants in jobactive, Transition to Work and Disability Employment Services. Each internship is voluntary and is undertaken for 30 to 50 hours per fortnight over four to 12 weeks. An internship provides financial incentives to the provider, host business and participant. The provider, host business and participant work together to create an internship that meets the needs of the business and suits the participant’s skills, experience and interests. Before starting an internship, the provider, host business and participant must agree to the terms of the internship and sign a PaTH Internship Agreement. The provider is also required to complete a risk assessment for each placement before the young person commences. Participants are not required to undertake PaTH Employability Skills Training before starting an internship. However, Stream A job seekers who commence Employability Skills Training will immediately be eligible to participate in a PaTH internship This Guideline is for jobactive and Transition to Work providers who are involved in managing PaTH internships. For detailed IT steps, providers must refer to the Managing PaTH Internships IT Supporting Document. A separate Guideline is available for Disability Employment Services providers, administered by the Department of Social Services. Version: 3. 1 Published on: 30 October 2019 Effective from: 2 December 2019 Changes from the previous version (Version 3.0) Policy changes: Nil Wording Changes: Example of the specific activities and learnings to be included in the Internship Agreement. Clarity on supervision requirements for Labour Hire Organisations.

Related documents and references:

PaTH Intern Reference Letter Template employment.gov.au jobactive.gov.au Activity Management Guideline Employment Fund General Account Guideline Managing and Monitoring Mutual Obligation Requirements Guideline Job Seeker Compliance Framework Guideline Privacy Guideline JobSearch Conditions of Use Insurance Reader’s Guide Transition to Work employment.gov.au Activity Management Guideline Insurance Reader’s Guide Privacy Guideline Transition to Work Activity Management Guideline Transition to Work Payments and Outcome Performance Target Guideline Transition to Work Providing Services to Participants and Employers and identifying Complementary and Excluded Services Transition to Work Vacancies and Outcome Guideline Transition to Work Job Plans Guideline ESS Web Summary of Changes ESS Web online support help files: Create Vacancy (Internship) Create Agreement (Internship) Update Agreement (Internship) End Agreement (Internship) Convert to Job (Internship) Reimburse Claim (Internship)

    1. Source PaTH Internships
  • Internships advertised on jobactive.gov.au by host businesses or brokers
  • Internships sourced by providers
  • Internships sourced by participants
    1. Assess eligibility
  • Assess participant eligibility
  • Assess business eligibility
    • Check a business’ previous internships
  • Collaboration with third party organisations (brokers)
  • Eligibility for internships involving Group Training Organisations
    1. Match a participant to an internship
  • Check internship details meet all requirements
  • Check the workplace is suitable
  • Check each intern will have adequate supervision
  • Insurance coverage
    1. Prepare for the internship
  • Update and sign the Job Plan
  • PaTH Internship Agreement
  • Generate the PaTH Internship Agreement
    • Sign the PaTH Internship Agreement
  • Check the participant is ready for the internship
    1. Manage a PaTH Internship
  • Confirm the internship has started
  • Pay the host business
  • Update the PaTH Internship Agreement when circumstances change
  • Recording participation against the Annual Activity Requirement (AAR) for jobactive participants
  • Exclusion from participation in the program
  • Manage participant transfers
    • Manual transfers
    • Novations
    1. End a PaTH Internship
  • Feedback on the internship
    1. Claim payments
  • Claim a reimbursement for the $1000 host business payment
  • Claim a PaTH Internship Outcome Payment
  • Tracking towards an Employment Outcome payment
  • Wage subsidy eligibility
    1. Summary of required Documentary Evidence
  • Job Plan
  • Risk assessments
  • PaTH Internship Agreement
  • Internships involving Group Training Organisations
  • Pay the host business
  • Claim a reimbursement for the $1,000 host business payment
  1. Source PaTH Internships Providers can source internships using their established business and training networks, or by connecting with businesses and brokers that have advertised opportunities directly on the jobactive website (at www.jobactive.gov.au). Before considering a participant for an internship opportunity, the provider must discuss the internship opportunity with the business. The provider must not rely solely on information in the advertisement. Internships advertised on jobactive.gov.au by host businesses or brokers Host businesses and brokers can advertise an internship opportunity on jobactive.gov.au.  A host business or broker must have a registered jobactive account to advertise an internship.  A host business or broker must engage with a provider to set up the internship before a participant can start with a business. During the advertising process, businesses and brokers are encouraged to send one or more providers an invitation to manage their internship opportunity.  The Department of Employment, Skills, Small and Family Business’ (the Department) IT Systems automatically selects the 10 closest jobactive, Transition to Work and Disability Employment Services providers for the business or broker to share their internship vacancy with.  Alternatively, the host business or broker can choose to share their internship advertisement with their preferred provider/s. Providers can view internship vacancies that businesses or brokers share via the invitations widget in ESS Web.  Providers should accept or decline the invitation within five days. After this time, the invitation will expire and the business or broker will receive a notification and be encouraged to engage with other providers.  Once a provider accepts an invitation, the provider must contact the host business or broker to gain a better understanding of the internship opportunity.  System step: The invitations widget shows providers the invitations for internships and jobs from employers. The widget is on the Dashboard screen in the Department’s IT Systems. If a business or broker has several internship opportunities and a provider cannot support all of them, the provider should contact other providers in their area that may also be able to assist the host business to meet their needs and requirements. Only participants eligible to participate in a PaTH Internship can view internship vacancies advertised by businesses and brokers on the jobactive website. A participant must be registered on the jobactive website and logged into their account to view internship opportunities.  A participant can view internship opportunities closest to their registered postcode or search for opportunities in different areas using the search function.
  1. Assess eligibility Assess participant eligibility Providers must confirm each participant is eligible to participate in an internship before entering into a PaTH Internship Agreement. To be eligible, a participant must:  be aged 17–24 years (inclusive) and,  be on income support and have mutual obligation requirements and:  be in jobactive Stream A and have participated in either block one, or block two Employability Skills Training: or  be in jobactive Stream A and have been continuously serviced in employment services from any jobactive provider, Transition to Work provider or Disability Employment Services provider for at least six months; or  be in jobactive Stream B or C, Transition to Work or Disability Employment Services.  System step: The Internship Eligibility widget displays the number of participants on a provider’s caseload who are eligible for an internship. Assess business eligibility Providers must check the business meets all eligibility requirements to host an internship before a PaTH Internship Agreement is created. An eligible business must:  have a valid ABN  have a reasonable prospect of employment, which means that the business:  has a current vacancy  will likely have a vacancy following the internship, or  has a regular pattern of recruitment for a position aligned with the participant’s interests, experience and qualifications. Eligible business types include:  for-profit organisations  not-for-profit organisations  labour hire organisations  the Provider’s Related Entity  Related Entity means those parts of the Provider, other than the part that delivers Services under the Deed.  A Related Entity can share the same ABN as the Provider.  Government departments and agencies.  Note: Commonwealth Government departments are not eligible to receive the $1,000 host payment. A host business cannot:  use the internship to displace an existing employee of the host business or reduce an employee’s hours of work, including casual or part-time workers

 be a family member of the participant, which means the host business cannot be a spouse, de facto partner, child, parent, grandparent, grandchild or sibling of the participant or their spouse/de facto partner  be the employment services provider of the participant, which means a provider cannot host a participant from their own caseload  pay the intern at any stage during the internship  provide the intern with extra hours of paid or unpaid work outside the agreed hours of the internship  receive additional labour service fees for an intern participating in an internship  have previously employed the intern  have previously hosted the intern in a work experience or voluntary work placement  have previously hosted the participant in an internship, except after written approval from the Department.  The total number of weeks of the internship and the amount of time the intern has participated will be considered.  The host business may be eligible to receive an additional $1,000 host payment. For example, if the participant falls ill and the internship ends abruptly, the participant may be able to recommence the internship with the same host business. An internship must not:  be a position, including a retail position, involving nudity or in the sex industry  involve illegal activity  involve income or funds from gambling deemed to be inappropriate by the Department, or  be a placement the Department has advised is not acceptable. (Deed reference: jobactive Deed clauses 107, 109A, 110, 111, 112 and Annexure A1 Definitions, Transition to Work Deed clauses 99, 100A, 101, 102, 103 and Annexure A1 Definitions)

Check a business’ previous internships

Providers must check that the host business has a reasonable prospect of employment by viewing details of the host business’ history with internships in ESS Web and Employment Services Reporting before placing participants into internships. Details to check include:  how many internships the business has hosted  the number of active internships the business is hosting  how many interns have been placed into paid employment with the host business  the number of internships that did not result in paid employment with the host business. Providers are encouraged to contact the host business to discuss why previous interns did not meet their needs.

 the GTO is listed on the GTO National Register (see the Australian Apprenticeships website at www.australianapprenticeships.gov.au/search-gto)  the vacancy is for a position as an apprentice or trainee  the provider receives details of the arrangement for the reasonable prospect of employment in writing and keeps this on file  the host business (not the GTO) is a party to, and signs, the Internship Agreement  supervision for the duration of the internship is provided by the host business (not the GTO)  the $1,000 host payment is paid to the host business (not the GTO). Providers must ensure supervisor requirements, work health and safety provisions and other program requirements are met in full. For example, a business can host an intern before a possible apprenticeship or traineeship where the reasonable prospect of employment is with the GTO that the host business uses to source their apprentices or trainees. Group Training Organisations may act as brokers for the host business in these cases. Note: This arrangement does not apply when businesses wish to host an internship where the potential job will be with a labour hire organisation. In this instance, the labour hire organisation must be the host business and take on all responsibilities assigned to host businesses, including direct supervision of the intern.  Documentary evidence: The provider must retain written evidence of the details of the arrangement for the reasonable prospect of employment with a GTO.

  1. Match a participant to an internship The host business or broker, participant and provider co-design an internship placement. This process is intended to help the participant to get a better understanding of the host business’ requirements and what is expected as a potential future employee. Check internship details meet all requirements Providers must ensure they co-design the internship with the participant and host business or broker to match the participant’s skills, interests and experience and meet the host business’ expectations and requirements. For example, the provider must consider the participant’s suitability for the potential job available with the host business, the activities involved and the participant’s individual circumstances such as caring responsibilities and transport arrangements. Providers should work with the host business and participant to ensure their needs are addressed and to reduce the number of unsuitable participants referred to an internship. A positive experience will increase the willingness of a host business to take on interns and engage with employment services in the future. The internship must:

 be for four to 12 weeks in duration  be for a minimum of 30 hours and a maximum of 50 hours per fortnight  not exceed a maximum of eight hours per day  not include participation on a public holiday. The internship should be for a maximum of 25 hours per week, but the host business and intern have the flexibility to manage the hours of participation over a fortnight to reflect the needs and requirements of both the intern and the host business. The provider must ensure the duration of the internship is appropriate and suitable for the participant and the nature of the job. For example, if a host business advertises an internship for 12 weeks and the provider considers the participant would not need 12 weeks to learn those skills or activities, the provider must discuss these requirements with the host business and come to an agreement to reduce the length of the internship or adapt the activities. To be as work-like as possible, interns must be provided with the same workplace conditions an employee would receive in terms of maximum shift breaks and any equipment or support. At a minimum, an intern must be provided with at least one 30 minute break every five hours. The individual circumstances of each participant should also be considered. For example, if a participant has an injury or other needs and requires a break every three hours, instead of five, the provider must ensure the host business understands these needs and agrees to allow the additional breaks. Breaks do not count towards the number of hours an intern undertakes for their internship activities. For example, if the participant’s shift was 9.00 am – 3.00 pm with a one-hour break for lunch, then the participant has participated in their internship for five hours. (Deed reference: jobactive Deed clauses 107, 109A, 110, 111 and 112, Transition to Work Deed clauses 99, 100A, 101 and 102) Check the workplace is suitable Providers must ensure the host business has a safe system of work in place for the internship, in accordance with:  work health and safety requirements under the relevant state or territory legislation  obligations relating to work health and safety under jobactive Deed clause 110. and Transition to Work Deed clause 101.1. The provider must complete a risk assessment for each participant in an internship. The provider must ensure a Competent Person conducts and documents the risk assessment. This must be done before the PaTH Internship Agreement has been signed and the internship starts. If the provider does not have a Competent Person, it must engage a Competent Person for this purpose.

Check each intern will have adequate supervision  Work Health and Safety content : Providers must ensure the host business maintains a high level of supervision to help the intern learn the requirements of the workplace. They must ensure the health, welfare and safety of each intern as well as members of the public. Providers must ensure supervisors provide guidance and support to the intern in the workplace. This includes, but is not limited to:  teaching the intern the skills required to complete tasks  adapting the activities and teaching methods to the individual intern  ensuring the intern understands what is required of them and performs tasks safely. The level of supervision must be appropriate to the requirements of the internship and take into account:  the complexity of the activities  the risk of harm to the intern and to others. The provider must ensure:  the host business provides an appropriate supervisor for each intern:,  a supervisor can be an individual who will supervise the intern at all times or a position such as a Shift Manager or Team Leader  the supervisor is employed or engaged by the host business  the supervisor has a high level of skills and knowledge relevant to the activities the intern will complete  the host business provides continuous supervision over the entire duration of the work shift where the activities involve children, the elderly or otherwise vulnerable people. The provider must ensure the host business and supervisor understand their requirements to supervise an intern at all times during the internship. For example, if there is an internship with a labour hire company, the labour hire company is considered to be the host business. The supervisor must be employed by the labour hire company and must supervise the intern at all times across all locations and sites. Providers must check if the nature of the internship requires interns and supervisors to have any checks and ensure that supervisors of interns meet the requirements of the relevant Deeds. (Deed reference: jobactive Deed clause 8, 107, 109A and 111 , Transition to Work Deed clauses 8, 99, 100A and 102 ) Insurance coverage The Department purchases personal accident insurance and combined public and/or product liability insurance to cover participants undertaking Approved Activities, including PaTH Internships.

See the Insurance Reader’s Guide for policy inclusions, exclusions and reporting requirements. Providers can deliver internships where activities are excluded under the Department’s insurance policies, if additional insurance is in place. Providers can purchase additional insurance, which must be in place before the participant can start the internship. Providers should carefully consider the suitability of the internship where it involves activities excluded under the Department’s insurance policies. This includes taking into account any associated work health and safety risks. As an alternative to purchasing additional insurance, providers could consider amending the activities in the proposed internship agreement to ensure full coverage under the Department’s insurance policy. See the Using the Employment Fund General Account Guideline for information on purchasing additional insurance for jobactive participants. (Deed reference: jobactive Deed clauses 42, 88, 107.5(c), 110.5, Transition to Work clauses 42, 99.4(c), 101.4)

  1. Prepare for the internship Update and sign the Job Plan PaTH Internships must be included in the participant’s Job Plan as a voluntary item. The Social Security Act 1991 requires Job Plans to meet specific requirements. The provider must:  update the Job Plan with the PaTH Internship activity code  provide the updated Job Plan to the participant for their agreement before creating the PaTH Internship Agreement. Providers can send the Job Plan to the participant dashboard through the jobactive website or Job Seeker App for participants to review and agree online. Providers must ensure participants have access to and are aware of how to agree to the terms of the Job Plan on their dashboard.  System step: A participant’s approved Job Plan must include the PaTH Internship Job Plan activity code (ET 67 —PaTH Internship) as a voluntary item before a provider can create a PaTH Internship Agreement for the participant.  The participant’s Job Plan must retain the PaTH Internship Job Plan activity code for the duration of their PaTH Internship.  System step: Providers must approve the updated Job Plan in the Department’s IT Systems once the participant and provider have signed the Job Plan.  System step: If the Job Plan is signed in hardcopy, the provider must enter into the Department’s IT Systems the date the Job Plan was signed and confirm the Job Plan has been approved. See Managing and Monitoring Mutual Obligation Requirements Guideline for jobactive participants regarding Job Plan requirements.

Sign the PaTH Internship Agreement

The participant, host business and provider must sign the Internship Agreement before the internship starts. The provider must:  explain the terms, conditions and requirements of the internship as set out in the Internship Agreement to both the participant and host business  provide the participant and host business with relevant contact information and insurance details  send the Internship Agreement to the host business and participant’s jobactive accounts for electronic approval or the provider can arrange for the agreement to be signed in hardcopy:  the participant can review and agree to the terms and conditions of the Internship Agreement through the Job Seeker App. When the agreement is signed in hardcopy, the provider must:  approve the Internship Agreement in the Department’s IT Systems  retain a copy for their own records  provide the participant and the host business with a copy of the signed agreement.  System step: The provider must action and approve the PaTH Internship Agreement in the Department’s IT Systems before the start of the internship. (Deed reference: jobactive Deed clause 109A.3, 109A.4, 109A.5 and 112 , Transition to Work Deed clause 100A.3, 100A.4 and 100A.5) Check the participant is ready for the internship Providers must check the host business and participant have everything they need to commence the internship. In consultation with the host business or broker, providers must identify any prerequisites of the internship (such as Employability Skills Training, white card, or responsible service of alcohol certificate) and check it is completed before the participant starts their internship. In addition, providers need to identify any assistance the participant will require to maximise the success of the internship. This may include transport, clothing and presentation, tools and equipment, work-related licencing and post-placement support. It is possible that such goods and services may be reimbursed through the Employment Fund for jobactive participants, or be funded from Upfront Payments for Transition to Work participants. Before the internship starts, providers must:  give the participant the PaTH Internship intern factsheet and contact card. These provide:  information about the participant’s rights and responsibilities during the internship  how to report concerns, complaints or issues during their internship.  give the participant the Job Seeker/Participant Insurance Guide that includes information on how to lodge a claim or report an incident

 re-confirm with the participant that participation in an internship is voluntary and they can leave an internship at any time without penalty  advise the participant to contact the provider immediately if they have any concerns, their circumstances change, they become employed or can no longer participate in the internship  ensure the participant understands all information provided and provide additional support when required For example, if the participant is from a non-English speaking background, the provider should consider providing an interpreter service to ensure the participant understands their requirements and any details associated with the internship.  re-confirm the host business has the relevant contact information for the participant, provider and the Department  ensure all parties have, or have access to, a copy of the PaTH Internship Agreement. See Using the Employment Fund General Account Guideline for information on the jobactive Employment Fund and Transition to Work Payment and Outcome Performance Target Guideline for information on Transition to Work Upfront Payments. (Deed reference: jobactive Deed clause 42, 70, 88, 109A.5 and 112, Transition to Work Deed clauses 42, 100A.5 and 106)

  1. Manage a PaTH Internship The provider must proactively manage the internship for the duration of the placement. Providers must remain in contact with the host business and intern during the internship to ensure:  they are aware of any changes in circumstances affecting the internship  the intern is attending their internship and meeting the needs of the host business and their expectations of the internship placement  the host business is meeting the terms of the Internship Agreement. The provider should discuss the preferred contact method and frequency with the participant, host business or broker to avoid disruption to the internship. The provider may use participant contacts and site visits to detect safety risks. Providers must notify the Department as soon as possible and within 24 hours of any incident involving the internship. (Deed reference: jobactive Deed clause 110.6, Transition to Work Deed clause 69.6) Confirm the internship has started Providers must confirm with the host business that the intern has commenced in the internship on the internship start date. Interns receive a $200 fortnightly payment as an incentive to participate in an internship. The payment is not to cover costs associated with the internship and is in addition to the participant’s income support payments. Costs associated with

An Internship Agreement is not required to be re-signed or re-approved in the Department’s IT Systems if there are minor changes to the following:  location  supervisor details  times of attendance, or  activities. If minor changes occur, the provider must still ensure the intern and host business agree to the changes.  Documentary evidence : The provider must keep a record of any changes to the internship, even if a new Internship Agreement is not required. Interns and host businesses have the flexibility to make minor changes to attendance times if the total fortnightly hours do not change. For example, if the intern requests to start later one day due to another appointment, the intern and host business can agree for the intern to finish later so the total hours are not affected_._ If the provider becomes aware of a change in circumstances that mean the program requirements are no longer being met, the provider must change or end the agreement. For example, if there is no longer a reasonable prospect of employment for the intern with the host business, the provider should consider ending the agreement if continuing in the internship will not develop their vocational skills or improve their employment prospects with another business.  Work Health and Safety content : The provider must consider whether the changes to the internship will require a new risk assessment.  System step: The provider must immediately update the PaTH Internship Agreement in the Department’s IT Systems. If prompted, the provider must arrange re-signing of the updated agreement with all parties and then re-approve the PaTH Internship Agreement in the Department’s IT Systems.  Documentary evidence: The provider should retain a copy of the original agreement outside the Department’s IT Systems. The host business and intern will only be able to view the latest version of their signed agreement through their jobactive account. Recording participation against the Annual Activity Requirement (AAR) for jobactive participants Where an intern has an AAR, providers must note the following:  A PaTH Internship will fully meet a participant’s AAR while they are participating in the internship, regardless of their hours of attendance. For example, a participant may attend an internship for 30 hours a fortnight. Even if the participant has a 50 hour AAR they will fully meet their AAR if they participate in a 30 hour per fortnight internship. In this example, the provider

would record the intern has undertaken 50 hours per fortnight to ensure the AAR is fully met.  Internships are voluntary and participants will not be subject to the targeted compliance framework regarding their participation in the internship.  If the participant does not participate in the internship, the provider will need to discuss with the participant another activity that could meet their Annual Activity Requirement. If recording of AAR is required for an intern, the provider must record the hours that fully meet the participant’s AAR.  If the internship has been undertaken for part of the monthly period, the AAR hours should be pro-rated. For example, if the AAR was 100 hours and the internship occurs for two weeks out of the month, 50 AAR hours should be recorded.  Provider’s must not manually indicate that the participant has met their AAR. System step: Providers must use the ‘Recording of Monthly Hours’ tab in the AAR Details screen in the Department’s IT Systems.  System step : Providers must record the total number of AAR hours for each month, within 10 business days of each month of participation. When the internship overlaps with the participant’s participation in the Work for the Dole phase, the provider can enter AAR hours for up to 10 days after the Work for the Dole (WfD) Phase end date. Participants do not have an AAR where their participation in an internship occurs outside the WfD phase. See Managing and Monitoring Mutual Obligation Requirements Guideline for information regarding AAR and Mutual Obligation Requirements. (Deed reference: jobactive Deed clauses 87, 113 and 114) Exclusion from participation in the program Where a provider identifies a host business is not meeting the terms and conditions of the PaTH Internship Agreement, they must take immediate action to rectify the situation. Providers must also inform the Department, through the relevant Account or Contract Manager, as soon as they become aware that a host business or broker may not be complying with the requirements of the program. The Department may direct the provider to take additional action to that already taken to rectify the identified issues. Provider staff may also notify the Department of issues or concerns by:  calling the National Customer Service Line on 1800 805 260 (free call from land line), or  submitting confidential feedback through the Department’s website (atwww.employment.gov.au/feedback-and-enquiry-form).