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HRDC, MAETT and MHR have established a variety of mechanisms to assist with joint planning, decision-making and program delivery. These are discussed in this chapter. A. Joint Planning An enormous amount of effort and time has gone into joint planning, especially at the local level. A high degree of co-operation was observed to exist at upper levels (but below the executive level) of the organizations involved. Most government interviewees considered planning to be among the best elements of the LMDA activities to date. The Agreement calls for: An annual plan prepared by the Management Committee outlining the policy objectives to be attained, the employment benefits and support measures to be delivered, priority clients and programs and services to be offered by HRDC, notional funding allocations to each program and service, and mechanisms and strategies to be used in the implementation of the EBSMs and performance targets and measurement of results. No separate annual plan was prepared for 1997-98. The Agreement, signed after the beginning of the fiscal year and with targets for 1997-98, was felt to adequately meet the requirement for an annual plan. Work on the 1998-99 annual plan began in the fall of 1997 and a first draft was presented to the Planning/Operations Working Group on November 28, 1997. However, to date, the province-wide annual plan has not been signed because of the disagreement over IA savings outlined in the previous chapter. While this has not prevented those in the field from moving ahead on their own plans, it did result in their planning being conducted in a vacuum. Further, it provided an unfortunate signal to many trying to work co-operatively on their own planning exercise. Also, some groups obtained copies of the draft provincial plan-some did not. This caused problems at the local level, especially when those who saw the draft were from MHR (whose Deputy Minister declined to sign) and those who did not were from HRDC and MAETT (both of whose Management Committee members were willing to sign). Fourteen sub-provincial plans were developed locally and reviewed centrally. The process to develop joint sub-provincial plans was assisted by a Co-management Planning Conference (November 13 and 14, 1997) attended by more than 150 delegates from HRDC, MAETT and MHR. A framework (template) for joint sub-provincial plans was prepared. Submitted plans were reviewed centrally and only 2 of 14 were judged to require revisions. Despite this co-ordination, we observed a significant level of variation among the jointly-developed sub-provincial plans we reviewed. This may be an indication of the flexibility of the LMDA or a limitation of the framework or review process. The three sub-provincial plans reviewed by the evaluation are deficient in a number of key areas:
B. Community Input The level of community input into LMDA business planning varies enormously from area to area. However, in all cases it seems that only a limited group in the community was involved. To date, it appears that community input is limited to third party service providers. In interviews with staff of HRDC, MAETT and MHR, we were often told that there was some or a lot of community input. But when we asked for persons in the community (other than service providers) for interview or focus group purposes, very few, and in some cases none, could be identified. Third party service providers also commented on lack of community input at some sites. In addition, the community consultation framework prepared in April 1998 by the Communications Working Group has not been fully implemented in all areas. Insufficient time is the prime reason cited for the lack of community input. In the first year of implementation, staff of both levels of government have focused primarily on service to clients and on co-management issues. In one of the case study sites visited we were told that staff listen, seek input from the community, and their business plan records some community forums last year and plans for more in the coming year. Community input appears to have resulted in a smoother-running operation. In another site visited, the community (primarily third party service providers) reported that typically consultation consisted of government telling them over two hours what was happening and then allowing 15 minutes for 17 service providers to make their comments. Service providers note that their input was ignored and their concerns were not addressed. Lack of community input has resulted in the service providers forming their own group and pressuring government to listen to them. This wastes time, energy and is a disservice to clients, who ultimately suffer from the friction between service providers and government staff. Less formal community consultation is happening in some cases. Some individual project officers maintain regular and often frequent contact with third party service providers so that concerns can be addressed and programming changes can be made in a timely way. C. Local Decision-Making Almost all interviewees report that there is sufficient flexibility at the local level and that the flexibility has been used effectively to respond to local needs. We encountered numerous examples of local variation in interpretation to meet specific requirements. For example:
A minority suggested that there may be too much local flexibility and autonomy. However, a high level of local autonomy does have some drawbacks. For example:
D. Target Setting Targets for the number of participants, the proportions who are active versus reach-back, the number of all participants returning to work and unpaid benefits by current claimants who return to work are set by NHQ of HRDC. Targets for mutual clients are negotiated within B.C. Mutual client targets exist at the HRCC level and at the sub-HRCC level (MHR regions). This level of detail is not always contained in sub-provincial plans. The sub-provincial plans reviewed generally did not state how many clients are to receive which EBSMs, nor why. Local targets appear to be based on past experience. While no set targets are provided for each EBSM, HRCCs use last year's numbers as a rule of thumb for planning and setting targets for the current year. In general, targets are not internally consistent. There is no link between the types of clients targeted (imposed by NHQ or negotiated), demand for EBSMs (determined by the mix of clients and their needs) and the supply of EBSMs (estimated using last year's numbers). As well, concerns were voiced in all three regions about the lack of follow-up regarding whether or not mutual clients actually receive services. E. Client Flow Client flow is another area where local autonomy has been used successfully. In one site, all unemployed (EI-eligible, uninsured participants and IA clients) are streamed through ARCs for unassisted (labour market information (LMI), access to equipment) or assisted (RTWAP, referrals to other service providers) services. This centralized help should facilitate client flow. Another example of good use of centralized services is the centre established for all French language services in the Lower Mainland. Even in the best situations, client flow for mutual clients has been problematic. Each area, and in some situations sub-area, has developed its own process. Virtually all interviewees who addressed this question noted significant problems in client flows and a need to refine the process. However, most also felt that client flow has improved recently. Mutual client flow starts with the Program Referral Officer (PRO), an MHR staff person. This is a new position created for the LMDA and staff had to learn their role on-the-job. A Mutual Client Plan Review Report by the Achieving Results Working Group (attached to a Management Committee memorandum (dated September 25, 1997) expressed concern about delays caused by the hiring process. At one site visited, the PRO was not in place until mid-June 1998. Such delays may have resulted in services to fewer than the targeted mutual clients Only 12% of clients in 1997-98 have been mutual clients, versus the 38% identified in the targets established for the LMDA. Data from our profile of clients indicates that the proportion of mutual clients has been increasing. By quarter, the proportion of mutual clients is:
The proportion of mutual clients, although growing over time, remains significantly below the targeted percentage and is unlikely to reach its target level in the near term. As well, data on mutual clients does not get distributed because of system problems. Service providers have client-level data, but it does not flow well to local offices nor to the provincial/federal level. One site visit site is still tracking mutual clients manually. To overcome system problems which limit the distribution of client information, a plan under consideration at the time of our field work would see 75 to 80 co-ordinators faxing their lists to the HRCC weekly. F. Contracting Process The contracting process is one of the most frequently cited areas of discontent. The two cultures of the federal and provincial governments are poles apart with respect to contracting, and merging them has proved a major stumbling block. Issues include the level of decentralization and local signing authority, the amounts of money available for funding services and, thus, ownership of programming, the different approaches toward accountability and different time frames. To add to the difficulties, some within MAETT, and particularly MHR (because it does not have direct program funding), feel they are not "equal partners" in the joint contracting process. Most of the contractors that we spoke with have had contracts with HRDC for some years. HRCCs usually award contracts based on previous experience. This has been raised as an issue of concern. In one site, the direct award of one contract that included an agency having no prior experience created discontent in the community. Such practice is also seen as HRCC favouring one service provider over others by some. HRDC is highly decentralized. HRCCs have authority to directly award contracts of a significant size. Staff of the provincial government have lower spending authorizations. Provincial contracts are awarded using a more formal competitive bid process. The result is that there have been no joint contracts due to financial and legal difficulties. In some situations the federal and provincial government may contract with the same organization. However, they use two separate or "parallel" contracts. Each contract will typically share common start and end dates but will vary in terms of value and possibly services contracted for. Some sites provide examples of HRDC and MAETT working together to provide a "one stop" service for both EI and IA clients. However, although there may be one contractor involved, there continues to be two separate contracts for the service with the federal and provincial governments due to impediments to joint-contracting. Contracts generally contain a clear statement of performance expectations (e.g., targets, follow-up requirements). Few contractors felt that their roles and responsibilities were not clearly set out. However, at one site there was a problem regarding Contact IV (an HRDC software program used by third party service providers). At first it was not understood that use of Contact IV was mandatory. G. Data Collection, Monitoring, Tracking There is an Information Sharing Agreement in place between the two governments. It came somewhat late in the process of LMDA implementation and its absence in the early months caused problems. There still appears to be some differences in the way the Agreement is interpreted and some fear that mutual clients who decline to sign the information release form may be denied services. Our participant survey did not find any support for this concern. Only one mutual client reported that they did not qualify or were turned down for support under an EBSM. However, our comparison group survey did not ask for similar information. We are not able to assess whether eligible non-participants have been turned down. The lack of an interface between the computer systems of the two governments/three departments causes additional problems in sharing information. Information gathering has improved over time. It appears that all government staff and contractors are now aware that use of Contact IV by contractors is mandatory. At the onset, a major expense for contractors was new computers. Contractors have now upgraded their equipment to handle Contact IV so that most technology problems have reportedly been overcome, and contract staff have been or are being trained by HRCC staff in the use of Contact IV. Increased familiarity with Contact IV has resulted in improved information gathering. Nevertheless, there are still some manual systems in place to overcome some system connectivity problems. There is still concern regarding the completeness, reliability and accuracy of some data. For example, there is no agreement or consistency in terms of the unit of measurement to be used (intervention/client), nor are there definitions for specific units (e.g., what constitutes a contact-telephone call/in-person contact). There are also still some major problems with systems. These have frequently been highlighted by staff and contractors and are well known. For example, systems are being used to do things they were not designed for such as to "communicate" with each other. There are also insufficient fields and procedural problems with the sequencing of inputs (some things need to be done before others can be done). Reporting is still a problem. The software in use does not produce the reports that some managers need for day-to-day management. Other reports are produced by NHQ but are not timely. Their accuracy is questioned by some. HRDC's ongoing management and performance data do not allow it to identify how many/which clients are receiving which EBSM. Thus, without a major effort such as a survey, it is not possible to evaluate the effectiveness of these measures as determined by outcomes. H. Program Delivery Partnerships exist at various levels among the co-management partners-at the senior management level, through the joint structures and locally. Also at the local level, community partnerships may exist with employers and community groups. At the senior level there are problems among all three co-management partners-not just federal/provincial but intra-provincially as well. The joint structures are variable in terms of the effectiveness of partnering. For example, the Achieving Results Working Group worked well, but others do not-for reasons which include inadequate resources and frequently changing memberships. In terms of co-operation and partnerships among co-managers at the local level:
Co-operation with employers at the local level in the form of community partnerships are not common and seem to depend largely on relationships between individual staff persons and employers. Employers are not automatically brought into the consultation and decision-making loop. Co-operation with community groups in the form of community partnerships is happening to some extent. However, it varies from area to area. Most of the community groups involved in consultation and partnerships to date appear to be either the same as, or closely allied with, third party service providers. Community groups, such as chambers of commerce and city staff, are not regularly incorporated in consultation and decision-making processes. Processes to support community partnerships vary from area to area, as do their effectiveness. Processes include:
LLMPs provide encouragement and financial support to establish community partnerships among local HRCCs and community groups. These partnerships may address issues such as community economic development and local labour market adjustment. Partnerships under an LLMP are established in one of two ways:
I. Third Party Service Providers Program delivery is primarily by third party service providers. Some of these are for-profit, some not-for-profit. Issues expressed by third party service providers include:
In the three field sites, virtually all programs are delivered through third party service providers. HRCCs have downsized. The counselling units that used to exist have become responsible for contract management. Third party service providers have become the delivery arm. Some EAS services are still delivered by internal HRDC staff. However, most are delivered by third party service providers. In our survey, 63% of participants said they accessed their EBSM through an HRCC, 31% identified a third party service provider and 6% did not know whether it was a government or third party service provider. By area, those from the North (69%), including Terrace (67%), were more likely to identify services being accessed from an HRCC. By EBSM, an HRCC was identified for 73% of TP, 65% for EAS, 52% for SE, 46% for TWS and 41% for JCP. This perception by clients does not align well with observations in our site visits. Potentially, clients are not able to perceive differences (nor do not care) between government and third party service providers. Another possibility is that clients go to HRCCs and are referred to services of third party service providers. As observed in one case study site , they may not realize that service providers are not part of the government. Some contracts with third party service providers target services to specific groups including those with special needs. In some areas, service providers are required to provide services for all clients. When more than one service provider competes for the same client base, there is the potential that money will be spent on advertising to attract clients instead of to assist clients to get back to work. Linkages have been established between service providers in some areas to better handle flows of clients among them. In one study site, third party service providers have formed a group to focus and address their concerns about the local co-management of the LMDA. J. Duplication/Overlap Overall, the level of duplication may be slightly less or at least the same as the situation prior to the LMDA. There are three potential areas of duplication/overlap with the LMDA. The potential for duplication exists:
There has also been an increase in the number of LMDA-related meetings and co-ordinating/co-management activities that staff have to get involved in. This is particularly the case where boundaries between the various offices do not coincide. Thus, for instance, staff in one MHR office are obliged to deal with three HRCC offices. MAETT and MHR boundaries are also not aligned leading to further co-ordination effort. This lack of commonality across organizations creates a large amount of extra "non-productive" work on top of regular work loads. K. Clients The EBSMs collectively offer a broad range of RTW activities. In addition, there is a significant level of flexibility at the local level in interpreting how these EBSMs are applied to meet local needs. The qualitative data suggest that the EBSMs are highly relevant to the employment needs of clients. From the profile, 15% of the 25,752 clients had received multiple interventions between April 25, 1997 and March 31, 1998. This includes 14% who participated in two interventions, 1% in three and less than 1% in four or five interventions. Combinations may include activities such as counselling and referral (EAS) to a training program, the training program itself, and then perhaps a return to EAS for a job finding club or résumé preparation. We were advised that most multiple interventions are sequential, as described above. We did not find any instances of a client concurrently receiving, say, TWS and TP. The only aspects of multiple interventions that may not be efficient are referral from one agency to another for services, and case management by an agency other than the one providing the service. (We were advised that some for-profit agencies get not-for-profit agencies to do the case management.) However, without having each agency provide all services (which would result in increased duplication), inefficiency will remain. Some HRCCs, such as Coquitlam, have a case management centre that case manages all of the HRCC's clients. This may have benefits (e.g., it may be more efficient and less confusing for service providers and clients). However, some interviewees who work with Coquitlam and other Lower Mainland HRCCs suggested clients are less well served and are less likely to receive EBSMs other than EAS. Without reviewing this type of case, we are unable to comment on benefits, disadvantages and efficiency issues. L. Employers The lack of community consultation extends to employers in the community. We found that employers in our focus group sessions were not well informed about the LMDA or about co-management. Although we did not contact employers who were not involved in the LMDA, we suspect that lack of awareness and not the characteristics of EBSMs is the factor limiting participation most. Those who participated in the focus groups generally felt that TWS met their needs. All employers knew that TWS implied an obligation for continuing work after the completion of the subsidy; however, some treated it as an opportunity to hire staff on a short-term, subsidized basis. Employers emphasized that the subsidy allowed them to train staff without having to pay the full salary during that period. A number of employers noted that in some industries it takes far longer to train a staff person than is implied by the average length of a TWS. However, TWS is intended to provide an incentive to train not to displace full training costs. M. Information and Communications 1. Labour Market Information Used By Participants The unemployed have a variety of employment resources available to them. In our survey we asked whether participants had made use of these resources on their own (i.e., on a self-serve basis). Eighty-two per cent had. The most frequent resources used by these participants were newspapers (66%), job banks at HRCCs (62%) and the Internet (42%) (see Exhibit 3).
Internet Resources More detail was sought from the 42% of participants who identified using the Internet. A higher proportion of those using the Internet had the following characteristics-they had a disability (63%), were still involved with their program (56%) or were from the Lower Mainland (53%). The Internet resources most frequently accessed by those individuals who used the Internet were BC Work InfoNet (37%), job listings (other than Electronic Labour Exchange) or résumé posting services (31%) and the Electronic Labour Exchange (24%). Those using printed or on-line (Canada WorkInfoNet or BC Work InfoNet) career and work search information were also asked for their opinions on the quality and ease of use of these sources. Ease of use was assessed on a scale of one to seven, where one was "not at all easy" and seven was "very easy." The average score was 5.3. Printed Career And Work Search Information More detail was also sought from the 14% who identified using printed career and work search information. Those using this printed material were more likely to have a post-secondary education (18%) and to have a household income between $20,000 to $40,000 (18%). Principal items searched by those using printed career and work search information were Work Futures/Job Futures (38%), The Job Guide (32%) and Career Paths (22%). In addition, 22% were not able to identify specific titles searched. Those using printed career and work search information accessed it from a variety of sites. However, fully two-thirds (68%) report obtaining this information from an HRCC. Technology Provided For Use More detail was also sought from the 15% of participants who identified using technology provided for them by the HRCC/service provider. Those more likely to use the technology which was provided had the following characteristics-they were mutual clients (22%), 35 to 44 years of age (19%) and were of Aboriginal descent (18%). The technologies used most frequently were computers (90%), telephones (51%), fax machines (49%) and printers (42%). Satisfaction with the quality of self-service tools was rated on a scale of one to seven, where one was "not at all satisfied" and seven was "very satisfied." The average score was 4.9. Most (55%) had used these products within three months of the survey-73% had used them in the last six months. Users were also asked if they would use the tool again. Ninety-three per cent said they would. 2. Significant Differences in Labour Market Information Use by Participants We asked a more limited set of questions on the employment resources used by comparison group members. We then assessed differences between participants and comparison group members in terms of their use of LMI through regression techniques. Regression models controlled for potential differences in the demographic and other characteristics between participants and comparison group individuals. Using regression techniques, we found a significant difference2 in the use of: We asked a more limited set of questions on the employment resources used by comparison group members. We then assessed differences between participants and comparison group members in terms of their use of LMI through regression techniques. Regression models controlled for potential differences in the demographic and other characteristics between participants and comparison group individuals. Using regression techniques, we found a significant difference in the use of:
Participation may be responsible for these differences. Alternatively, some other unmeasured factor, such as motivation, may account for both higher use and participation in an EBSM. 3. Communication with Community, Employers, Clients Section 13 of the LMDA notes that Canada and British Columbia agree to work jointly on preparing public information material and organizing related public announcements; as well as developing mechanisms to inform Canadians of the activities undertaken and the results achieved in the context of the Agreement. As noted earlier, there has been limited communication with community groups. In our focus groups, most employers knew about EBSMs through word-of-mouth. Other sources included potential employees who knew of the programs, advertisements in local newspapers, information at trade shows and from third party service providers. Employers in focus groups say that some of the best ways to communicate with them are by advertisements and articles in local newspapers, information sessions held by HRCCs, and through unemployed individuals who visit them. Generally speaking, employers do not want telephone calls or television advertisements. Many do not belong to industry associations eliminating this as a useful avenue to approach non-associated employers. To communicate with clients or prospective clients, a wide variety of communication tools are used, including posters, EI cheque inserts, advertisements in newspapers, posters in public places and on the Internet. From our survey of participants, a wide variety of sources of information were identified:
Respondents rated the information they had received highly. Sixty-six per cent found it very useful and a further 25% somewhat useful. There was little difference in the positive responses given across location or client characteristics. Those who participated in TP or SE rated the information they had received slightly more positively. Those who received EAS or JCP rated the information received slightly less positively. For clients in our focus groups, the majority claimed that they initially heard of EBSMs through word-of-mouth; others heard through personal investigation, school, another referring agency and the Internet. An HRCC was not mentioned as the initial source of information. Clients interviewed in the focus groups noted the following as the best means for communicating with them:
Most clients in the focus groups felt that they had enough of the necessary and appropriate information they needed. However, while we had a mix of active, reach-back and mutual client participants in the focus groups, we note that:
Thus, the focus groups did not provide information on clients who do not speak English, clients whose mother tongue is French, clients with low education levels and clients who cannot read. Interviewees suggested that some clients may not be able to access the information they need. However, efforts are made to accommodate such clients. For example, information sessions are held, where much of the information is in oral form, sometimes in a language other than English or French. French-speaking clients are referred in the Lower Mainland to 10th Avenue, which provides services in French for all Lower Mainland HRCCs. In some cases, clients from non-English/French speaking groups are referred to service providers who provide services in languages such as Mandarin, Cantonese or Spanish. N. Case Management There appear to be different definitions of what constitutes case management. For example, some see it as a means to ensure interventions are client-driven; others use it for follow-up and reporting purposes. Despite the differences in interpretation, case management is widely used, primarily by third party service providers. Not all clients are case-managed-some, particularly those going through short interventions, are not. Usually, however, those going through longer, more complex, or multiple interventions that involve an action plan are case-managed. The agency that provides the intervention is not necessarily the agency that does the case management. This may result in some duplication. Some expressed concern that for-profit service providers were relying on not-for-profit groups to do their case management. Clients in the SE program use their business plans as action plans. They are reviewed regularly and provide a basis for progress reporting and feedback. O. Negotiated Financial Assistance Clients are expected to contribute to their RTWAP if they are able. NFA is the process whereby staff or a third party service provider identify the client's resources and the cost of the RTWAP and then negotiate a sharing of these costs, if appropriate. The extent to which NFA is used varies by area, HRCC, third party service provider and even within each specific contract. The amount of knowledge of NFA also varies. Many, but not all, third party service providers have received training or assistance on NFA from their HRCC staff. The amount and depth of training varies significantly. At least one service provider interviewed had requested but had not received NFA training. At least one more had never heard of NFA. At least one HRCC held a session with some third party service providers to ensure some consistency in the application of NFA. However, we note some remaining inconsistency in our qualitative interviews. What people include in NFA differs. For example, some say having a family member baby-sit would be counted; others suggest this would not be applicable. Some interviewees note that NFA does not apply to mutual clients. However, this interpretation is not universal. We think this lack of consistency may be in part as a result of the flexibility available to staff and delivery agents. There is no recording of the savings realized through the application of NFA. In particular, neither third party service providers nor HRCCs capture information related to in-kind savings realized. We asked specific questions about the sharing of costs of their intervention with the 251 TP participants in our survey. Seventeen per cent were not able to say who paid. A further 1% identified no costs. It is possible that NFA was not conducted with either group. The responses of this minority are excluded in the following discussion related to NFA. Five per cent of the participants under TP said they paid all of the costs of their training. A further 46% said they paid part of the costs, while 49% identified paying nothing. Those most likely to contribute to their training costs were those 45 years of age or older (76%), those with household incomes of more than $40,000 (74%) and those with a grade 12 education (68%). These groups are apparently better able to contribute to their RTWAP. Ninety-three per cent of those who reported paying part or none of the costs of their training said they would have been unable to take the training without this support. The proportion was highest for those with less than a grade 12 education (100%), mutual clients (100%), members of an under-represented group other than females (100%), those under 35 years of age (97%), reach-back clients (97%) and those with household income under $20,000 (96%). The proportion was lowest for those 35 to 44 years of age (86%), those who had taken training more than one year ago (88%) and those with household income of $20,000 to $40,000 (88%). The 78 comparison group members who had taken a training course since April 1997 were asked whether they had paid all, part or none of the costs of training. Eight per cent said there were no costs and were excluded from the following analysis. Forty-two per cent said they had paid all, 8% said part and 50% said they paid none of the cost of their training. Comparable numbers for participants were 5%, 44% and 51% respectively. Although those who reported paying none of the costs of training are almost identical across the two groups, participants appear to share the costs of their training in much higher numbers. NFA appears to result in a sharing of training costs. Seventy-four per cent of those who received funding support for their training say they would have been unable to participate in the training without this support. Participants receiving partial or total support under NFA more often (94%) said they would have been unable to participate without support. This suggests that NFA has been successful at assessing ability to pay for training. However, it is also possible that participants were less inclined to admit they could have undertaken training without support in a survey to evaluate the LMDA. P. Efficiency And Effectiveness Some interviewees noted efficiencies through the LMDA. Parallel contracting, where HRDC and MAETT contract with the same contractor for complementary services over a similar time frame, should result in some efficiencies. Some interviewees feel there are too many third party service providers available. Fewer contracts would reduce contract management activities, reduce overheads and may offer a better service at less cost. Contractors say that they now have to compete with each other through advertising to maintain their share of a finite client base, rather than spending that money on clients. This tends to increase costs with no benefit to clients. Short contract lengths, possibly as a result of uncertainties related to the future of the LMDA, have meant that contractors are forced into shorter term and more expensive leases and rental agreements for equipment. Another problem is the uncertainty it creates for staff-many of whom may leave in search of more secure positions. Some contractors would prefer to focus on one specific group of clients; but HRCC staff have "forced" them to bid on providing services to all clients. This is inefficient as it forces contractors to deliver services at higher costs to a client group for which it does not have a comparative advantage. It appears most HRCCs do not make any special distinctions for under-represented groups. One case study site, for example, used to have a contract especially for persons with disabilities, but it was not renewed this year. It appears to be left to the third party service providers to accommodate the special needs and requirements of under-represented groups.
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