Manager Small Business Policy

4 August 2015

Ms Barbara Cullen

Department of Economic Development, Jobs, Transport and Resources

Via email:

Dear Ms Cullen,

RE: Regulatory Impact Statement on two proposed new public holidays in Victoria

I submit a response to the Regulatory Impact Statement for the proposed public holidays in Victoria.

Bentleigh Bayside Community Health is a not for profit, registered community health service.

We provide primary health services with priority access for the marginalised and at risk members of the community; group activity andill health prevention education to the residents in the City of Bayside and the southern part of the City of Glen Eira. Some of our services and programs have a much larger geographic catchment such as the Gamblers Help Southern Program that extends from Port Phillip to the Mornington Peninsula, Casey, Cardinia and Greater Dandenong.

The majority of our revenue is received through state and federal government contracts and service agreements.

Our workforce is predominately made up of health professionals, support staff and a small management and administrative component. Staff are paid under six separate Enterprise Bargaining Agreements.

While Bentleigh Bayside Community Health acknowledges the intent of the additional public holidays as outlined in the Report prepared by Price Waterhouse Coopers Australia dated July 2015; the introduction of two additional public holidays have created a financial impost to our organisation as follows;

Under the Hospital Scientists Award we are obliged to pay dietitians and psychologists for the Easter Sunday public holiday despite the fact they are not rostered to work on a Sunday and we are no open for business on this day. This cost was $2,600.
Under the various Enterprise Bargaining Agreements we are obliged to pay staff for the Grand Final Eve public holiday and in some cases a penalty loading will also be payable. The estimated cost of wages is $41,500.
These additional wages costs are unfunded by government.
We have estimated a loss of client co-payment fees for the Grand Final Eve public holiday of approximately $6,000.
The Grand Final Eve Public Holiday will also place a higher productivity requirement on the workforce to deliver the same contracted hours of service or output/outcome measures outlined in our many contracts and service agreements to achieve target levels and avoid further financial penalty.

In summary Bentleigh Bayside Community Health estimates an increased unfunded liability of $50,000 per annum for these two additional public holidays. As a not for profit organisation there is very little opportunity to offset the cost of this increase without impacting on service delivered to our community.

Yours sincerely

Amanda Murphy

Chief Executive Officer

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