The audit objective was to assess the effectiveness of CRS Australia’s delivery of Disability Management Services. In assessing CRS Australia’s performance, the ANAO examined whether:

  • services are delivered in accordance with CRS Australia’s operating procedures, which incorporate the Disability Services Standards and the requirements of the DEEWR MOU;
  • CRS Australia has an effective client feedback (including complaints) system, which is used to identify and address business risks and areas for improving service delivery; and
  • sound governance arrangements (including performance monitoring and reporting) are in place to monitor service delivery.

The audit did not specifically examine issues and information relating to the commercial nature of the business, such as profitability levels and competitive neutrality arrangements.



1. CRS Australia began operating in 1941[1] and provides vocational rehabilitation and employment­related services to the Australian Government and the private sector. CRS Australia is a division of the Department of Human Services (DHS), a Financial Management and Accountability Act 1997 (FMA Act) agency. Although part of an FMA Act agency, CRS Australia does not receive direct Budget funding; instead, it funds its operations through the payments received for services delivered.

2. In 2009–10, CRS Australia had a workforce of over 2000 staff who provided vocational rehabilitation and employment­related services to some 57 000 clients from 185 sites and 140 visiting (outreach) services around Australia. From the delivery of these services, CRS Australia earned $197 million in revenue, of which $154 million was received from its service delivery arrangements with the Department of Education, Employment and Workplace Relations (DEEWR) for Disability Management Services within the Disability Employment Services program.[2]

Disability Employment Services

3. The Australian Government’s social inclusion agenda aims to make sure every Australian has the ‘capability, opportunity and resources to participate in the economy and their community while taking responsibility for shaping their own lives.’[3] Disability employment services providers assist people with disabilities to improve their opportunities for employment so they can achieve greater social inclusion, usually through gaining employment in the ‘open’ labour market with remuneration at standard award rates.

4. The Disability Employment Services program[4] has two streams: Disability Management Services[5] and Employment Support Services.[6] Disability Management Services assist job seekers with a disability, injury or health condition who require the assistance of a disability employment service but are not expected to need ongoing support in the workplace. Employment Support Services assist job seekers with a permanent disability who have an assessed need for more long-term, regular support in the workplace.

Disability Management Services provider arrangements

5. The Disability Management Services Program is managed by DEEWR under contractual or like arrangements. CRS Australia is one of 66 providers of such services. As CRS Australia is part of the Australian Government, it has a Memorandum of Understanding (MOU) with DEEWR for the provision of Disability Management Services. In essence, the MOU is the same as the contract with private sector providers.

6. Through the contract (or MOU), DEEWR sets out the services to be provided, the eligibility for the services, the manner in which they are to be provided and the fees it will pay. To provide incentives for the desired policy outcomes, DEEWR has developed a fee schedule that rewards the achievement of employment milestones in its contract arrangements.

7. The payment model is only one of the means DEEWR uses to influence service providers’ behaviour and to monitor performance. In 2008, DEEWR implemented a system of star ratings for each service delivery site operated by a provider. These ratings provide for a comparative assessment of sites against peers operating in the same area.

8. The star ratings system is based on a scale of one to five, with a star rating of one indicating a comparatively lower performing site and a star rating of five indicating that the site is comparatively high performing. Following the new contractual arrangements for disability employment services providers introduced in March 2010, an updated star rating system has been developed, with the star ratings to be made public on a six-monthly basis from August 2011.

Legislation and standards

9. The Disability Services Act 1986 (Cth) (the Act) was introduced to ensure people with disabilities were provided with services to a certain standard and to ‘assist persons with disabilities to receive services necessary to enable them to work towards full participation as members of the community'.[7] The Act includes the Disability Services Standards, which outline 12 service quality standards that are supported by 26 key performance indicators.

10. The Act specifies that a service provider must be independently assessed and certified against the Disability Services Standards in order to receive government funding.[8] The Quality Strategy for Disability Employment and Rehabilitation Services[9], introduced in 2002, provides guidance for all Disability Employment Services program providers on how to meet, as a minimum, the Disability Services Standards.

Accessing Disability Employment Services

11. The most common way[10] that clients can access the Disability Employment Services program is through a referral via a Job Capacity Assessment (JCA).[11] Centrelink, on behalf of DEEWR, identifies that a job seeker requires an assessment of their work capacity and an evaluation of any barriers preventing them from gaining employment. The job seeker is sent for a JCA where the assessor uses medical and other information to make the assessment and may then refer the job seeker to a Disability Employment Services provider.

CRS Australia’s services

12. Prior to 1 July 2007, CRS Australia was the sole service provider of Australian Government funded vocational rehabilitation services. Since that time, the Australian Government has progressively implemented a suite of reforms to the sector, including the introduction of private sector competition within the market. As a result, CRS Australia now has approximately 55 per cent of the market share for Disability Management Services.

13. To undertake vocational rehabilitation, CRS Australia assesses a client’s medical issues and other barriers to employment, and prepares a plan to support them to maintain or obtain employment. A vocational rehabilitation plan (such as the Employment Pathway Plan) may contain interventions such as counselling, training, job preparation and allied health services.

14. CRS Australia also delivers other services, which include conducting JCAs on behalf of DEEWR and providing workplace assessments, injury prevention services and return to work programs for a range of private sector employers and insurers.

Audit objective, criteria and scope

15. The audit objective was to assess the effectiveness of CRS Australia’s delivery of Disability Management Services. In assessing CRS Australia’s performance, the ANAO examined whether:

  • services are delivered in accordance with CRS Australia’s operating procedures, which incorporate the Disability Services Standards and the requirements of the DEEWR MOU;
  • CRS Australia has an effective client feedback (including complaints) system, which is used to identify and address business risks and areas for improving service delivery; and
  • sound governance arrangements (including performance monitoring and reporting) are in place to monitor service delivery.

16. The audit did not specifically examine issues and information relating to the commercial nature of the business, such as profitability levels and competitive neutrality arrangements.

Overall conclusion

17. For some 70 years, CRS Australia has been providing vocational rehabilitation and employment-related services to help people with a disability, injury or health condition obtain and/or maintain sustainable employment. In recent years, the Australian Government has implemented a suite of reforms to the disability employment sector, including the introduction of competition. This has resulted in CRS Australia moving from being the sole provider of vocational rehabilitation services to being one of 66 providers of Disability Management Services, with approximately 55 per cent of the market share during the period 2010–12. The diminishing level of ‘guaranteed’ work and corresponding requirement to compete with a range of providers, has meant that CRS Australia has needed to be flexible in its operations while maintaining a high level of customer service that provides employment outcomes for clients.

18. As the major provider of Disability Management Services, CRS Australia’s operational processes and service delivery model allow it to effectively deliver services in accordance with the Disability Services Standards and requirements of the DEEWR MOU. In doing this, CRS Australia has regularly met key service delivery milestones while also achieving an operating surplus. At the centre of CRS Australia’s business is its quality management system. Through the quality management system, service standards are established, roles and responsibilities are articulated, guidance and training activities are made available to staff, and quality assurance processes that allow management to monitor service delivery are adopted. Complementing the internal quality management system are external quality assessments, including the annual independent accreditation audits, DEEWR compliance audits, and DEEWR’s star ratings system.

19. As disability services providers are required to have an internal feedback system, including for complaints, CRS Australia has processes in place to obtain client feedback and to address client complaints. These include providing information to clients on internal and external complaint mechanisms, having available a range of methods to obtain feedback and adopting a tiered system for recording and responding to complaints. CRS Australia’s internally conducted end of program client feedback surveys show a high level of client satisfaction with the services being provided. Over the period 1 July 2008 to 30 June 2010, 90 per cent of respondents indicated that they were satisfied or very satisfied with the support received from CRS Australia. An external survey conducted in 2007, which included DEEWR job seekers, provided an overall satisfaction rating of 79.2, the high end of the moderate satisfaction scale.

20. Supporting the delivery of services, CRS Australia’s planning and monitoring framework encompasses all levels of its operations with business plans and risk registers being maintained across the business. CRS Australia has a robust internal reporting framework, particularly performance reporting against the achievement of financial and service delivery targets. In 2009–10, CRS Australia reported placing 11 859 job seekers in employment, with 7527 clients remaining in employment for 13 weeks and 5851 clients remaining in employment for 26 weeks.[12]

21. Notwithstanding the effectiveness of CRS Australia’s overall performance, there are areas where enhancements to existing practices could improve onsite quality assurance, client feedback processes, including complaints, and performance reporting.

22. At service delivery sites, senior rehabilitation consultants (SRCs) perform essential onsite quality assurance, particularly client case reviews. However, following organisational changes that included clarifying the role and responsibilities of SRCs, the varying workload demands, at times, limit the ability of SRCs to adequately perform the quality assurance role. This was evident through the observed variation in the methodology and process for completing case reviews and some case files containing no indication that a review had been conducted. Given the revised SRC role has now been in place for over 18 months, this provides an opportunity to undertake a post-implementation assessment of the changes to ensure the expected outcomes are being achieved. CRS Australia advised that it commenced a review in January 2011, which was completed in March 2011.

23. CRS Australia’s internally conducted end of program client feedback surveys show a high level of client satisfaction. However, a low and decreasing survey return rate (12.5 per cent in 2009–10) limits the level of assurance that can be placed on the results from a business-wide perspective. CRS Australia could complement and improve the existing client feedback mechanisms by: seeking feedback from clients while they are receiving services; more regularly commissioning externally conducted surveys (that include DEEWR job seeker clients) to balance the potential non-response bias from internally conducted surveys; and implementing a dedicated client feedback (including complaints) form on the CRS Australia website to improve the ease with which clients can provide feedback.

24. While complaint numbers are relatively small (295 recorded complaints in 2009–10), there were indications that, at some sites, staff awareness of the complaints management system was low and/or some complaints were not being recorded in the database. CRS Australia encourages clients to address internal complaints to staff at local sites in the first instance. However, not all staff working at local sites, such as administrative staff, receive training on how to recognise, respond to and deal with a complaint. Therefore, broadening the scope of the existing complaints management training to all service delivery staff could assist with increasing awareness, and promote the recording of all complaints in the database. This in turn would provide management with greater information on clients’ views on the services they have received.

25. External reporting is maintained through the DHS annual report. In recent years the key performance indicators used have changed, limiting the ability of stakeholders to form a view of performance over time. Using consistent indicators, which demonstrate performance outcomes (such as the proportion of clients achieving 13 week and 26 week employment outcomes), would give greater insight to CRS Australia’s performance.

26. To assist CRS Australia to build on its business practices and engagement with clients, the ANAO has made three recommendations aimed at improving the capture and analysis of client feedback and complaints, and the level and consistency of public performance reporting.

Key findings

Service Delivery (Chapter 2)

27. To help deliver its services in accordance with the Disability Services Standards and the DEEWR MOU, CRS Australia has:

  • defined staff roles and the required skills;
  • produced and disseminated operational guidelines;
  • provided training opportunities; and
  • implemented an onsite quality assurance program.

28. CRS Australia employs a mix of allied health professionals[13], employment service specialists and administrative staff across its service delivery sites. Staff are broadly classified in one of five roles for which CRS Australia has defined the relevant responsibilities and necessary skills.

29. Through CRSnet, an Intranet-based repository of information and guidelines, CRS Australia provides extensive guidance on all aspects of service delivery and a reference library. These guidelines are designed to ensure that service delivery staff meet the minimum standards set out in the Disability Services Standards and comply with the requirements of the DEEWR MOU. In addition, CRS Australia provides induction training for all new staff with additional role specific training and commencement plans for service delivery staff.

30. To monitor and support service delivery within and across sites, CRS Australia has developed the senior rehabilitation consultant (SRC) role. Among other tasks, SRCs perform a quality assurance role, principally through client case file reviews[14], which are central to maintaining a consistent approach to service delivery. Some case files examined, however, did not indicate whether the required case reviews had been undertaken. CRS Australia has specifically designed the SRC role to allow for flexibility in the tasks undertaken. While this allows regions to tailor the working arrangements to suit the operational environment, it has meant that in some cases this impacts on the quality assurance role of the SRC.

31. The new SRC role has been in place for over 18 months. This provides a timely opportunity to review the changes and assess whether the expected outcomes of, and support for, the SRC role (particularly quality assurance), are being achieved. CRS Australia advised that it commenced a review in January 2011, which was completed in March 2011.

Quality Management (Chapter 3)

Internal quality management

32. CRS Australia has a quality management system designed to align with the Disability Services Standards and the Quality Strategy for Disability Employment and Rehabilitation Services, and also to meet the requirements of the DEEWR MOU.

33. A key component of the quality management system is Quest for quality, which measures the quality of service delivery through six-monthly regional manager self-assessments and quarterly team self-assessments. The regional managers’ self-assessment checklist aims to assess the broad business aspects of CRS Australia’s service delivery operations against the Disability Services Standards. Team self-assessments use a checklist designed to assess the quality of selected individual client case files and, therefore, more directly evaluate service delivery to individual clients.

34. The results from the self-assessments are used to determine if national and local benchmarks have been achieved.[15] Given the self-assessment nature of both types of Quest for quality reviews, and the observed variability in the way they are undertaken, CRS Australia could improve the level of assurance it gains by introducing a process to periodically check the results from a sub­sample of reviews. CRS Australia could also examine the guidance provided to staff to ensure that it sufficiently covers the expectations of how a review is to be conducted.

External quality assessment

35. In addition to the internal quality management system, CRS Australia is also subject to external monitoring arrangements. External accreditation audit arrangements regularly examine key quality and service delivery processes. CRS Australia has maintained accreditation against the Disability Services Standards since 2004.

36. DEEWR also undertakes routine performance monitoring using a system of star ratings allocated to each site. Prior to 1 March 2010, CRS Australia’s service delivery sites ranged in star ratings from one to five, with a network wide mean rating of 3.1.[16] DEEWR also regularly visits sites to perform compliance audits. Forty-one CRS Australia site visits were conducted during 2009.

37. CRS Australia has used the results of these audits, in conjunction with its other internal quality assessment tools, to identify and examine issues that have broader implications across the whole network.

Client Feedback Including Complaints (Chapter 4)


38. CRS Australia uses a range of feedback mechanisms to obtain clients’ views on service delivery. A challenge for CRS Australia is to coordinate these mechanisms so that information can be gathered to assess performance and improve service delivery outcomes for clients.

39. The primary means of gathering client feedback is through the end of program feedback form. While results in recent years have shown a high rate of client satisfaction, the conclusions that can be drawn are limited by the low response rate (12.5 per cent in 2009–10). A low response rate can introduce elements of non-response bias[17] in the results, which effectively skews the result to clients who were happy with the service.

40. Obtaining feedback while the client is receiving services is optional and not commonly used by sites. This limits the ability of CRS Australia to address service delivery issues as they arise. Ensuring feedback options are available to clients while they are receiving services would allow service delivery issues to be addressed promptly. Other opportunities for improving client feedback mechanisms exist in relation to:

  • undertaking research on the effectiveness of feedback forms from the client’s perspective and, where appropriate, updating the forms; and
  • making the feedback options available to clients on the CRS Australia website clearer, and including a dedicated client feedback form.

41. Further, to provide a more objective assessment of performance and mitigate the risks of misstatement from the end of program feedback form due to the low response rate, CRS Australia could consider adopting an externally conducted survey[18] that includes job seeker clients who have exited the program.

42. High-level analysis of client feedback data is undertaken and reported to the executive. Reporting is limited to analysis of quantitative responses as the information gathered through free-text client comments is not systematically reviewed. This presents the risk that customer insights accompanying quantitative responses are missed, or trends that can be recognised are not brought to the executive’s attention. A level of national reporting that includes an analysis of client comments could help ensure systemic issues and information about service delivery are captured and, where appropriate, action taken.


43. CRS Australia has an established complaints management process with accompanying guidance, training and executive support for acknowledging and dealing with complaints. In 2009–10, CRS Australia recorded receiving 295 complaints, a relatively low level representing less than one per cent of clients exiting the program in the year.

44. CRS Australia could improve the complaint and feedback mechanisms available to clients by providing the ‘We’re Listening’ handout[19] as part of the introductory information given to clients; and developing a dedicated complaints form for its website, with a corresponding link clearly identified on the website homepage.

45. Despite having an established framework, the internal complaints process and guidance are not commonly understood by staff. This lack of common understanding impacts on the reliability of complaints data, including the number of total complaints. CRS Australia encourages clients to address complaints to staff at local sites. However, not all staff at service delivery sites have received training in how to recognise, respond to and document a complaint. To help ensure all complaints are recognised and captured, CRS Australia could develop and implement a complaints awareness training module for all service delivery staff.

46. CRS Australia uses its complaints database to undertake high-level analysis that is largely based on the numbers and classifications of complaints. This analysis does not generally include information on the causes of complaints and how they were resolved. A stronger link to how systemic issues with service delivery and personnel behaviour are addressed as a result of a complaint would assist to inform management of how risks are being managed and services are being improved.

Planning, Performance Monitoring and Reporting (Chapter 5)

47. CRS Australia’s planning and monitoring framework encompasses all levels of the business operations. Business plans have clear descriptions of roles, targets, activities and measures to be reported against. Risk management is also included in the planning framework and risk registers and risk management plans are updated as appropriate.

Internal reporting

48. CRS Australia endorses a sound approach to performance management and reporting that has a focus on financial viability, service delivery and quality. The focus on financial viability and achievement of service delivery targets is present in all aspects of internal management reporting, in particular Disability Management Services, which generated 78 per cent of CRS Australia’s total revenue in2009–10.[20]

49. While reports containing quality aspects are presented to the Strategic Business Group, (including complaints information, reports on internal reviews and annual quality reports), quality does not have the same focus within the reports as financial viability and service delivery achievements. Reporting against a range of quality key performance indicators from the regions would allow CRS Australia to focus on quality initiatives and monitor their implementation and results.

50. As a division of DHS, CRS Australia provides monthly reports to the DHS Management Board. This reporting is based on four key results areas and shows that a broad range of indicators are used to track performance in service delivery, personnel, finance and quality accreditation.

External reporting

51. CRS Australia’s key performance indicators are set out in the Human Services Portfolio Budget Statements and performance against these indicators is included in the DHS Annual Report. The key performance indicators published in the DHS Annual Report have changed over time making it difficult for stakeholders to assess CRS Australia’s performance across years.

52. CRS Australia regularly monitors a range of key performance information as part of its internal reporting. In particular, it budgets and reports on: commencements; job placements; and 13 and 26 week employment outcomes. In order to provide a more complete assessment of CRS Australia’s performance to stakeholders, consideration should be given to establishing a consistent set of key performance indicators that provides information on both overall performance outcomes and the quality of services being delivered.

Summary of agency response

53. The Department of Human Services welcomes this report and considers that implementation of its recommendations will further enhance the effectiveness of service delivery by CRS Australia.

54. The Department of Human Services agrees with the recommendations in the report.


[1] In 1941, the Vocational Training Scheme for Invalid Pensioners commenced. In 1948, it became the Commonwealth Rehabilitation Service and underwent a name change to CRS Australia in 1998.

[2] In 2009–10, the program funding was received from Vocational Rehabilitation Services until 28 February 2010 and, with the introduction of the new program, from Disability Management Services from 1 March 2010.

[3] Australian Government, Department of the Prime Minister and Cabinet, A Stronger, Fairer Australia―A National Statement on Social Inclusion, PM&C Canberra, 2009, p.iii.

[4] Temporary and permanent disabilities and health conditions encompassed by disability employment services include: physical, such as back injuries, muscle and joint problems; visual impairment; communication and hearing disorders; mental health, such as depression, anxiety, schizophrenia; and acquired brain injury.

[5] Prior to 1 March 2010 called Vocational Rehabilitation Services.

[6 ]Prior to 1 March 2010 called the Disability Employment Network.

[7] Disability Services Act 1986 (Cth) s1B.

[8] ibid., s5, s5A and s10.

[9] Department of Families, Housing, Community Services and Indigenous Affairs, Quality Strategy for Disability Employment and Rehabilitation Services, FaHCSIA [Internet] Canberra, 2002, available from<> [accessed 26 October 2010].

[10] Clients can also access Disability Employment Services through the Job in Jeopardy scheme and direct referral (including eligible school leavers).

[11] Job Capacity Assessments (JCAs) are a tool used to assess a job seeker’s capacity for work and to identify areas where existing barriers to gaining employment can be overcome. A JCA also identifies the current and future work capacity, that is, the number of hours a job seeker has to work to reach their benchmark.

[12] Under the DEEWR MOU, the 13 week (durable) and 26 week (sustained) employment outcomes are classified as milestones. Note as the Disability Management programs run for up to 78 weeks, there are timing differences that affect the job placement results from year to year.

[13] Allied health providers include health professionals with qualifications in occupational therapy, physiotherapy, psychology, rehabilitation, speech pathology and social work.

[14] A case review is where a client’s progress, case notes and vocational rehabilitation plan are assessed.

[15] The benchmark is set at 85 per cent for all key performance indicators.

[16] The new star ratings are to be publicly released by DEEWR on a six-monthly basis from August 2011.

[17] Some people are more (or less) likely to respond to surveys and this may induce bias in surveys. This can be more pronounced when there is a low response rate to surveys. National Statistical Service, [Internet] Statistical Clearing House Seminar Series, Drawing Conclusion from Surveys with a Low Response Rate, NSS, 2004, available from <$FILE/Low%20response%20rates%20-%2026%20November%202004.pdf> [accessed on 13 September 2010].

[18] CRS Australia commissioned two external stakeholder surveys in 2007 and 2008, however, DEEWR job seeker clients were not included in the 2008 survey.

[19] The ‘We’re Listening’ handout is an existing CRS Australia publication.

[20] The remainder of CRS Australia’s revenue is largely derived from numerous contracts with the private sector and other government agencies for injury management, vocational rehabilitation and business wage assessment services.