Submission - Victorian Labour Hire Licensing Exposure Draft Regulations Prepared by: Christopher Hampton / Aged and Community Services Australia (ACSA) Mutual recognition Is the prescription of the laws and scheme set out above appropriate? Yes. The prescription of the laws and scheme set out above is appropriate. Are there any other laws or schemes that you believe should be prescribed in the Regulations for the purposes of section 111 of the Act? No. There are no other laws or schemes we believe should be prescribed in the Regulations for the purposes of section 111 of the Act. Treatment of businesses as ‘separate’ for the purposes of the scheme Separate recognition of businesses would allow one business to continue operating if a second business to which they may be related lost or surrendered their licence. What is the nature of your company structure and what impact would separate recognition of businesses have on your business? Not applicable. We are submitting as the national peak body representing our members as aged care organisations – providing both residential and in-home aged care services Clauses 3, 8, 16 and 19 of the exposure draft Regulations establish the fee structure for the labour hire licensing scheme as well as the amounts payable for application and renewal fees and annual licence fees. Do you have any comments about the nature of the fee structure? We were unable to find the relevant information on the fee structure
Submission - Victorian Labour Hire Licensing Exposure Draft Regulations Prepared by: Christopher Hampton / Aged and Community Services Australia (ACSA) Mutual recognition Is the prescription of the laws and scheme set out above appropriate? Yes. The prescription of the laws and scheme set out above is appropriate. Are there any other laws or schemes that you believe should be prescribed in the Regulations for the purposes of section 111 of the Act? No. There are no other laws or schemes we believe should be prescribed in the Regulations for the purposes of section 111 of the Act. Treatment of businesses as ‘separate’ for the purposes of the scheme Separate recognition of businesses would allow one business to continue operating if a second business to which they may be related lost or surrendered their licence. What is the nature of your company structure and what impact would separate recognition of businesses have on your business? Not applicable. We are submitting as the national peak body representing our members as aged care organisations – providing both residential and in-home aged care services Clauses 3, 8, 16 and 19 of the exposure draft Regulations establish the fee structure for the labour hire licensing scheme as well as the amounts payable for application and renewal fees and annual licence fees. Do you have any comments about the nature of the fee structure? We were unable to find the relevant information on the fee structure
Submission-36-ACSA.DOCX