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Interview: Gillian Mitchell talks about the CCS implementation
Jason Roberts
Sep 24, 2018
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The Sector Founder Jason Roberts sat down with the Department of Education’s Group Manager of Transition and Engagement Gillian Mitchell to discuss the Australian Government’s approach to the planning and implementation of the Jobs for Families Child Care Subsidy.
Interviewee: Gillian Mitchell – Group Manager Transition and EngagementOrganisation: Department of Education Date: 30 August 2018Topic: CCS transitionJason: Good morning. Thank you very much for joining me today. We’re going to talk about the CCS transition from the Department of Education’s perspective. So, as a team, as a department, how soon after the legislation passing did you start to put together project plans, ideas as to how you’re going to engage with the sector and roll out this transition?
Gillian: So, we were planning simultaneously because the legislation as you know went into parliament three times before it was finally passed and you can’t just wait for something like that to happen and not have planned and be ready. We follow normal standard project management arrangements and so we had project plans in place, risk plans in place and we would just keep adjusting them while we were working through the legislative process. Jason: I see. So, once the legislative process was completed the project plans would kick in and at that stage, were you actually engaging with the sector? Gillian: Yes. Jason: Post the legislation? So that would be an important period. Gillian: So, we were engaging with the sector prior to the legislation. Jason: Right. Gillian: So, the Abbott Government when it first come in, in 2013, created a whole lot of ministerial councils. So, we had a ministerial council on early childhood education and care (ECEC) which had members from key peaks and other organisations such as Goodstart for example. The Minister met with them regularly as did we and we used them to consult on elements of the package and of course the legislation. Jason: I see. Gillian: So, government processes require you to do things such as a regulation impact statement for example and when you release a regulation impact statement you are required to consult. Jason: I see. Gillian: So, we were already talking with the sector and getting their input into the development of the package. That regulation impact statement then formed part of the final legislation package and it is then tabled with the package of legislation. It had been public for some time before the legislation was tabled of course. So, we had constant engagement with the sector throughout the whole development of the legislation. Jason: I see. Gillian: Then once the legislation was passed we just ramped up a notch really. We moved into what we call the implementation phase and when the terms of the appointment for the ministerial council finished, []we actually moved to our current implementation and transition reference group. Jason: Ok, I see. When was that Gillian? Gillian: That was July 2017.
Jason: So basically, this time last year?
Gillian: Yes. We were moving into full blown implementation phase and really, we needed a group we could work with that was close to the sector. So it was the same – almost the same membership, expanded slightly to make sure that we had covered all elements of the childcare sector, chaired by our Deputy Secretary. And we used them quite constantly throughout Jason: I see. And you would meet regularly? Gillian: Yes. We would meet every four to six weeks. But sitting underneath the implementation and transition reference group were three working groups. Jason: I see. Gillian: We had the communications working group, we had an IT working group and when we needed it we convened a ministers’ rules working group which we used to consult on the subordinate legislation. Jason: Okay, I’ve got it. Gillian: We used the communications working group to test our communications products all throughout implementation. So, they tested the revamp of the departments’ website that we did. They tested some of our fact sheets and various other communications’ products mostly focussing on readability and accessibility for the sector and getting feedback from users before we went more broadly to the whole sector. Jason: Yes, right. Gillian: Then the IT working group met with a similar cadence, so every six to eight weeks, and talked through issues to do with the development of the new IT system that they got to see some demonstrations as we were going along and give us some feedback and reactions to how it was looking. We also engaged in the co-design process with the third party software providers. Jason: I see. Okay. And there was a third working group.
Gillian: Yes, the minister’s rules as well. We convened the minister’s rules working group when we needed to consult on the rules. So again, it’s all part of the legislative process. It’s important to consult to make sure that we understand the practical side of things and the operationalisation of what’s going to be in legislation. So, we brought that group together and we worked through the ministers’ draft, the ministers’ rules, page by page before we put them to the Minister and recommended it. Jason: Forgive me but could you explain what is meant by the ministers’ rules? Gillian: So the primary legislation basically sets out how the system will work. The framework mainly. And then sitting underneath that we have ministers’ rules and secretary’s rules. They really are about the administrative aspects of the framework. So how it’s actually going to work. The ministers’ rules are about policy matters and the secretary’s rules are generally very administrative about delegations and authority. Jason: Thank you. So, the working group would have been made up of representatives from your team and then representatives from the sector. Gillian: That’s correct. Jason: Would it be the same representatives that were on the implementation and transition working group? Gillian: No. Those on the overarching body nominated people to be on the working groups. Jason: I see. Gillian: So, we had practitioners at the working group level. So, the overarching bodies are almost like your peak bodies if you will and then the working groups were centre directors and the like. Jason: I understand. So just focusing back on that how receptive were you to the feedback from the sector that was materialising in those working groups? Gillian: So, I think we were very receptive. We’ve always been receptive and this is evidenced by elements of the childcare package that have changed based on feedback from the sector. Jason: Can you share with me a couple of examples? Gillian: Gee… Jason: I might have one I could volunteer. Would the delay of the mandatory signing in and signing out be an example? Gillian: So that’s not an example because - well, it’s an implementation example. Jason: Right. Gillian: That was more about feedback from the sector regarding the volume of change happening on the second of July. Where there were things that we could delay that would not impact on the payment of the new subsidies just to give the sector a little bit more time to adjust. So that was one. Jason: I understand. Gillian: But there were things that we changed along the way. So, a good reference is probably the RIS, the Regulation Impact Statement because you’ll see when you do a RIS, you have to ask your impacted sectors a series of questions. Should it be this or should it be that? Jason: Right. Gillian: And you get all the feedback from it. So, we adjusted our policies based on the answers to that. In terms of the ministers’ rules one really good example might be vacancy reporting. Jason: Right. Gillian: So, reporting vacancies and fees to the government each week is something that the sector is obliged to do and we use it to put on to the MyChild website and it’s replacement that is soon to be launched called the Childcare Finder. So, we worked really closely with the sector and listened to their feedback about how they should report and what they should report. So, it is now set out in the rules that what they report in terms of vacancies is whether they have one or not rather than saying that I have a vacancy in the baby room and the vacancy it’s just high level. It’s just a yes or a no, I have a vacancy and then please contact the centre for more information. That made sense to us because vacancies can vary from centre to centre and really what the sector was saying to us, is we would really like to have the conversation with the parents about what they’re looking for. Jason: I understand. So, when was the last ministers’ rules working group? Gillian: December. Jason: So, the key was to have much of this back and forward addressed prior to heading into 2018? Gillian: We possibly consulted with them early this year on a couple of issues. So, we had to put in place some specific rules for transition, such as how the compliant written arrangements are done and giving the sector a little bit of extra time. So, we would have held a couple of specific teleconferences with the rules working group. The other one of course is in home care so because the new in home care program wasn’t settled until earlier this year so we convened the ministers’ rules working group to go through the specific rules for in-home care. Jason: I see. Gillian: But the bulk of them, yes, would have been addressed by December last year. Jason: Yes, understood. So the first real hard deadline for the sector was the PRODA registration requirements. Gillian: So PRODA is a digital authentication tool and most government websites require some kind of digital authentication so that we know that the people that we’re interacting with, you know, are who they say they are. Jason: I see. Gillian: So we already had that arrangement in place with AUSkey for the inclusion support program. Jason: Yes, understood. Gillian: So PRODA is just like AUSkey except that the Department of Human Services uses PRODA. Jason: I see. Gillian: So, it really was about those people who are going to be interacting with the government system for the purposes of getting childcare subsidy and ensuring they have been authorised in terms of their bona fides in terms of they are who they say they are. Jason: I understand. You mentioned the Department of Human Services. It seems to me that, although you were leading this project, they were very much involved as well? Gillian: Yes, we were partners. Jason: I see. Gillian: This has been very much a partnership and I mean, it is the Commonwealth and the Department of Human Services or Centrelink is responsible for making payments to families. They have always been involved in the work that we do. The payments of CCB and CCR and family entitlements were managed by the Department of Human Services previously. Jason: Right. Gillian: So it’s no different now. They’re just administering the childcare subsidy on our behalf instead of the childcare benefit and the childcare rebate. The difference is that the government took a decision that this was an opportunity to build a more up to date IT system than the one we had previously. The CCMS was built by the Department of Social Services and we worked really closely with them on that build. Our new IT system was basically built on the SAP platform within the Department of Human Services and it was all about bringing payments to families into one central location and instead of having data sweeping between us (DE), DSS and DHS we just brought it all together in one place. Jason: Yes, I see. In so doing allowing the different departments to unify their systems and become more efficient, is that right? Gillian: It was certainly an opportunity to have an IT system that brought everything together in one place. Jason: Understood, yes.
Gillian: It was also an opportunity for us to also look at how we could update our systems and bring them more into the 21st century in terms of the way we do our reporting, the way we monitor payments. Under family assistance law, we are responsible for payment integrity. So it is important that we are sure the childcare subsidy is being paid to the people to which it should be paid. Jason: Understood. Gillian: So by upgrading the systems we have another opportunity to strengthen our payment integrity role. Jason: Understood. So, timing wise we are now post PRODA and into April. We’ve got three months to go. From a third party software providers perspective this is a critical time. I would suspect those larger players to some degree were taking a lead with regards engaging with you and building out the systems. Is that a fair conclusion? Gillian: So, what we did was we entered into a co-design process with them. So, DHS took the lead, and we and DSS worked really closely with the 27 that they were – they are now 16. We brought them together in a series of co-design workshops as one big group. Jason: I see. Gillian: Yes, and no one necessarily took the lead. They are, as you would know, they’re all competitors in a market. Jason: Yes, that’s right. Gillian: So, they actually – and they are used to participating as a group. So even previously, when they’re registered for CCMS, we had an arrangement with them where we would always give them six months’ notice if there were any policy changes coming that would interact with their IT systems. So, if there were a policy change coming that meant we had to upgrade our IT system, that they then had to upgrade their IT system. So we’ve always worked with them in that way. Jason: Right. Gillian: So we would have started that process with them. Again, we had to wait until legislation have passed because they gave us authority. They knew that it was coming; it’s not that we had silent on it. Jason: I see. Gillian: We engaged very heavily with them once the legislation had passed and brought them together. We made sure that we always ran – every time we ran a codesign workshop, we ran the same workshop twice, once in Brisbane and once in Melbourne to give them maximum opportunity to get there depending on their geographic location. Some of them chose to go to both workshops each time. We also brought them together here in Canberra as well. It was truly a co-design process and we did make changes to our intended build based on feedback from them. Jason: Understood. The fact that they’ve gone from 27 to 16 that will be in response to perhaps the complexities or the nature of the transition from the old system to the new system and some of the smaller players is just saying, “I can’t do it.” Is that a fair conclusion? Gillian: I think you’d have to ask them that. They made their own business decisions about whether they wanted to stay in the market or not. Jason: Ok noted. So, following on from that, as we approach the 2nd of July, I guess the next thing to think about is that some CCMS providers were probably a bit readier than others. Were you monitoring that readiness? Gillian: Absolutely we were. Yes, so they have to register. They have to register their products with us and pass a whole bunch of tests to show to us that they have built to specifications and they can deliver. Jason: Right. Gillian: So, we had a two-phase registration process. Jason: Right. Gillian: The first phase was pre-April so that we knew that they were ready for that transition phase and the second phase was in the lead up to the 2nd of July so that we knew that they were ready to receive and submit session reports and payments and the like. There’s still some functionality that they had to have in place to pass registration for that is still – So there’s still functionality yet to be rolled out in the build. And so every time we roll out functionality that is part of their interface, they will go through that registration process. ,How they rolled it out and the time frames that they do that in were really business decisions that they took. Jason: Right, understood. Gillian: Each of them had a different roll out schedule but they all had to be ready for the 2nd of July. Jason: Yes, understood. Gillian: We have the Provider Entry Point. It was a part of our build and allows childcare providers to submit session reports to us for payment. It basically provides them with the barest minimum of functionality to meet the requirements under Family Assistance law. Jason: Got it. Gillian: It does not provide all the other functionality that the third party software providers have like, booking systems, rostering systems, financial systems and the like. Jason: I understand. Gillian: So, it was there as a contingency. Jason: I understand. Gillian: And there are a very, very small number who have elected to use it. At the same time, we were bringing into the childcare, the mainstream childcare market if you like, the former budget based funding services in regional and remote areas who never had to use third party software previously. Jason: Right. Gillian: So, some of them may have chosen to use the provider entry point to begin with as they work out which third party software provider they want to use. Jason: I see. Thank you for mentioning that. That’s helpful. So as at the 2nd of July you as a department are comfortable that those providers were where they needed to be. Gillian: So there was a team in DHS, a team staffed jointly by our department and the Department of Human Services that was monitoring them very, very closely. Jason: Right. Gillian: They all passed registration and they were all ready for the 2nd July. Jason: Ok noted. In terms of what’s happening on the ground, if I was one of the CCMS providers and I was struggling, could I pick up the phone to you and say "look I'm struggling I need help?" Gillian: Yes, so we had account managers for each of them. And the team was talking with them daily. Jason: Ok I see. Then behind that account manager, there'll be expertise in the coding and the interface, and all the rest. Gillian: Correct. Yes. Jason: Okay. What about the operators before we transition? Where were they seeking their information from? How were they being supported? Gillian: So, we had a very comprehensive communication strategy for the childcare centres. We had run a series of roadshows over the life of the implementation, including before the legislation was even passed, and we ramped that up once legislation was passed. We went out and ran information sessions and training sessions for centre directors. We ran webinars for them as well as an alternative to coming face to face. We had a special transition web page on the website which walked them through the PRODA process and then the transition process and we put up a series of fact sheets for them. We developed the childcare handbook which we have online now. We have received great feedback about how user friendly the online version of that handbook is. Jason: I see. Gillian: We made sure that we did printed copies for those people in remote areas where internet connectivity might be an issue and made sure that we actually got hard copies out to people. We have a helpdesk. That used to be the CCMS helpdesk. We're changing the name now to CCS helpdesk. We extended our hours for that helpdesk including to the weekend before Go live. So, we made ourselves available as much as we possibly could. At its peak, that helpdesk was taking about a 1,000 calls a day. Jason: How many on the team? Gillian: About 25. Jason: I see. Gillian: The calls have dropped down now to a constant about 600 calls a day. So, we've always had that help desk and they have been there to work really closely with centre directors to step them through processes. We have email inquiries as well that we reply to. And we will continue, that education process is not over. Jason: Of course. Yes. Gillian: It continues and we're now getting ready to look at Version 2 of the handbook. Jason: Okay. Gillian: So, well, now that CCS is implemented, it's time to update it based on how the implementation has gone. Jason: So, this might be a bit specific but all those 1,000 calls that you are getting a day, what was the primary root of them? What was the main type of question coming up? Gillian: It went through a cycle, so we started with, "How do I transition? What do I have to do?" Jason: Okay, yes. Gillian: That phase included lots of questions about PRODA as you would expect and also about how they activate their new third party software. Then there was “how do I submit session reports” because that was the next thing they had to do. Things like “When will I see the payment in the bank account? What will it look like?” And now we're getting back to the normal, “how does this work, how does that work?” Mostly they are policy-related questions, they're not system based. Jason: I see. Gillian: Even from the beginning these were questions based more on policy. Mostly the third party software providers operated their own helpdesks. Jason: Yes, both of you would be working together, basically. Gillian: That's correct, yes. Jason: Were there some instances where you would say, "Thank you very much for your call. This is a CCMS related issue. Why don't you ring your provider?" Gillian: Yes, we would do that. Jason: Yes, and I suspect they would have done the same. Gillian: Absolutely. Jason: Yes, yes. And Centrelink, I suspect would be the other player. Gillian: So we all refer calls to each other, depending on the nature of the call. But to the extent that we can solve a family issue for a provider, we try and do that without the family then having to actually go and ring Centrelink. But I suspect that some people would say they feel like they've been ping ponged a bit between each of the different helpdesks and that's just part of the whole kind of bedding down process. Jason: Yes, yes. I suspect the families predominant their interaction with the centre director and then centre director would have referred them to Centrelink. I suspect that's the main dynamic going on there. Gillian: Yes. I think there was a huge campaign for families. So, all of the families who had an enrollment, a current enrollment on the 1st of April, were required to do a transition process as well, the “call to action.” They needed to go online and do their income estimate for this financial year which is something they do every year but they also for the first time had to give activity test details. We ran family webinars jointly with the Department of Human Services and they were incredibly popular. We had thousands of people registering for those webinars, and those webinars basically talked families through each of the screens that they needed to complete in their MyGov account and we have continued to talk with families via their preferred communication channels. So, when you sign up for your MyGov account, you let Centrelink know how you would like to be contacted by the government: email, SMS, et cetera. And DHS uses those channels to reach out to families to remind them to do their “call to action” or to get online and give us their data. Jason: I see. So, on the morning after Go everybody's probably holding their breath a little bit. How did it go? Gillian: You know, I think that is a misunderstanding Jason, because the government pays childcare subsidies in arrears to providers and they are paid in arrears the week after the week in which care occurred. So, the first payment running the new system was not until the 9th of July and it was released into bank accounts on the 11th of July. So, during that first week, what we were doing was making sure the system was behaving the way it was intended. We worked with a couple of providers to run live tests of the submission of session reports to make sure we are ready for the Friday afternoon when we expected the bulk of that week’s session reports to come in. Jason: I see. Gillian: So, you could almost say that the 2nd of July was a bit of an anti-climax. Jason: Yes, understood. But very valuable to have that week to get things right. So, the real Go Live then would be that Friday? Gillian: Yes, that's exactly right. So everyone submitted their session reports and I think on that first weekend we processed maybe 500,000 session reports and the payments were made. The payments were made on time on the 11th of July and the system has continued to make payments every single day – every single weekday thereafter based on the submission of session reports. Jason: So, every session report that was submitted was paid. Gillian: Correct. Jason: Yes. But there were instances where session reports weren't submitted for reasons that could be connected to the family not doing what they need to do on Centrelink or to a lack of understanding on behalf of the centre director or a challenge with the CCMS system but they would be specific issues outside of the basic functionality of the interface. Gillian: That's correct. Jason: So, they would all have to be fixed and then resubmitted and then they'll be paid. Gillian: That's correct. Jason: Interesting. I suspect that during that transition period, I suspect the calls would have ramped and people would be looking for you to solve problems which you just couldn't solve. Gillian: So, some of the problems were easy to solve. So, for example, a lot of the calls were about pending eligibility. So, everybody's ringing up saying, “Why does it say pending eligibility next to a family’s name?” The answer to that was, the family had not completed the “call to action” and confirmed the child's enrollment. We would then say please tell the family to do that. The minute the family does that and then it's all good to go. Jason: I see. Gillian: Yes, that's a very simple one. For the more complex ones we had a command centre in place between ourselves, DHS and DSS. That command centre was stood up two weeks before Go Live and it stayed in place for three weeks post. We were co-located and we had daily telephone calls and issues were raised and resolved on a real time cadence. Jason: How many people were there in this command centre? Gillian: I think it was probably about 10 people together but then everybody, you know, everybody else in the background. Jason: I see. And you would have had specialists in place? Gillian: We had a communications specialist, we had an IT specialist, we had a PRODA specialist, we had a CCS policy specialist and all of that. Jason: I see. So just to be clear, calls would come in, they would get forwarded to the command centre and they would be allocated to the specialist. They would then be addressed and then it goes back to the family or director. Gillian: Yes, pretty much. It was very successful. And, yes, that was necessary when you got so many moving parts to keep tracking them all. The key was that families and services really just wanted their subsidy and we had to do our best to provide it. Jason: Yes, understood. Talking about money that's another thing that I was thinking about. There was a significant cost burden for some of these CCMS providers to transition effectively and possibly costs incurred by the centres and the operators in engaging with Centrelink et cetera outside of the normal course of business. Now, was there any consideration over the course of this transition from the government level that there would be a recognition of additional costs being borne by the sector to transition by way of a compensation mechanism? Gillian: Yes… There is a recognition. I mean, we've heard the same comment. But the third party providers operate as a business and the cost of transition were business expenses. We did nothing different this time from the way we did things when that NQF was rolled out or when we switched from the system they had before CCMS came into being. So, it was a business cost. Certainly, there is recognition that there has been costs for the sector, but as someone in the sector described it to me is that “It is a short-term cost for a long-term gain.” Jason: I see. Thank you for sharing that. Okay, so we're through go live, we've done our first payment, the bulk of the system appears to be working well. Out at the margin though there were some challenges with a couple of subordinate subsidies CCS and pre-school exemption. Gillian: Yes, that right. Jason: I was wondering from your perspective was the priority to get the core of the CCS over the line and then once that's bedded down address associated subsidies? Gillian: So, we knew that the preschool exception and ACCS would come into play on the 2nd of July. So, we scoped and built the system for all of the payments not just for the CCS. The way that the preschool exemption has rolled out is very new so it has taken a period of adjustment for the sector to understand how that preschool exemption works. In the first couple of weeks based on the feedback from the sector, we identified a defect in the system which we are working to fix where the 36 hours did not display against the child's record. Jason: From Centrelink or on the letter? Gillian: On MyGov. Jason: I see. Gillian: Yes. So, we are absolutely rectifying that. It is a system defect but we're just going to fix it. But, so long as everyone has done the right thing in terms of the parent telling us when the child is due to start school and the service is ticking the preschool exemption box on the session report, the preschool exemption is paying. It was a visibility issue in terms of information for parents and services about eligibility. And it's a very different exemption from our other exemptions. It's a child-based exemption whereas all our other exemptions are family based exemption. So, there has certainly been a period of adjustment for the sector to understand how the preschool exemption works and certainly, the implementation has not been perfect. Jason: Yes, understood. Gillian: That being said, it is working in terms of paying. Payments are flowing. The ACCS is also another change in terms of process for the sector and that has taken some getting used to. We have found some small defects in the system. Nothing catastrophic because the payments are paying but in terms of making it easier for people to manage document evidence we are doing some system fixes along the way or some system enhancements if you like. Jason: Yes, understood. Family day care how have they absorbed this change? Gillian: The same as everybody else I think. You know, they operate as everybody else in terms of submitting session reports. I think there have been some particular challenges for the family day care sector but that seems to have petered out now. Jason: I see. Gillian: I think what people have had to get used to is – the system pays in arrears. CCB/CCR were also paid arrears but if you enrolled in care on a Monday or Tuesday and that was it for the rest of the week and you submitted your session report you could get picked up in a payment run that same week. So, you could get paid in the same week. But for CCS you cannot. And so, there was a bit of a panic there, I think but the system is working and payments being made etc.
Jason: Understood. Gillian: So, maybe there was a bit of a communication gap from our part in terms of letting people know when the first payment would hit their bank account. Jason: Yes understood. Ok, so now we are nearly two months from Go Live. How are things now? Gillian: Well I think that the implementation has been a success and I think all who have been involved would say that. I've heard similar sentiments from the sector. We had an implementation transition reference group this week and they were very complimentary about how the switch over had gone. Jason: I see. Gillian: Yes. And the issues that you picked up on – the preschool exemption and the additional childcare subsidy – are issues that they have raised as well but they continue to be very engaged with us. They are genuinely working with us to identify issues and then we are working to fix them, if they need fixing, or to clarify our advice to the sector. And that's the other good thing about how we work with the sector is that if they don't understand the advice we're giving they let us know and we can change it.
Jason: Great, so, what's next? Gillian: Well, what's next is to bed it down basically and make sure that everything is going the way it's meant to go. Our key priority is to continue to support the sector as they understand the new arrangements. And beyond that, what's next in the policy sense is really up to the Government. Jason: I see. Gillian: But our focus is about making sure that this continues to be successful and the sector is getting the support that they need. Jason: Well, thank you so much. It has been a terrific discussion.
Gillian: My pleasure Jason. [ENDS]
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