4. Compliance and enforcement

The Targeted Compliance Framework

4.1The Targeted Compliance Framework (TCF) is the current mechanism by which participants’ income support payments may be suspended or cancelled, and by which participation in ParentsNext is monitored. The TCF is administered through an electronic system. Some elements of the framework are automated.[1]

4.2Since 2018, the TCF has applied to all compulsory participants in ParentsNext. The Department of Employment and Workplace Relations (DEWR) explained that the TCF was applied to ParentsNext as part of the national rollout of the program, and that the decision to apply the TCF was based — at least in part — on evidence indicating greater engagement with ParentsNext under a compulsory model.[2]

4.3If a participant fails to comply with the mutual obligation requirements, their payments will be automatically suspended if they do not provide a valid reason for this failure or re-engage with their provider within two business days.[3]

4.4Where a participant’s income support payments are suspended, the participant may have the suspension lifted by re-engaging with their provider. If the participant does not re-engage within 28 days, their payments will be cancelled, and they will need to wait at least four weeks before they can re-apply for income support.[4]

4.5If a participant fails to comply with their mutual obligation requirements, they will also receive a demerit. Accrual of more than five demerits within a six-month period may result in the application of financial penalties, up to and including the cancellation of income support payments. Providers are the decision‑makers for the application of demerits and are responsible for reporting non-compliance with mutual obligations. Suspensions are typically applied automatically by Services Australia’s systems when a mutual obligation failure is recorded. Services Australia alone is responsible for imposing financial penalties.[5]

4.6During the 2021–22 financial year, 25,920 (22 per cent) of ParentsNext participants had their payment suspended. However, in almost all cases (97 per cent), the participant did not lose any of their payment.[6] The significant majority (82.5 per cent) of suspensions are for failing to attend an appointment with a provider, followed by failure to attend or report attendance at a compulsory activity (11.7 per cent), and failing to sign the Participation Plan (5.7 per cent).[7]

4.7Since 2018, there have been over 220,000 parents who have received assistance through ParentsNext. Only 17 participants have incurred a financial penalty.[8]

4.8According to DEWR, the TCF is designed to encourage participants to engage and connect with their service provider, take responsibility for meeting their mutual obligation requirements, and impose financial penalties on those who are persistently non‑compliant.[9]

4.9While acknowledging that participation requirements and compliance mechanisms are closely linked, the Committee considers it important to avoid conflating these issues. Accordingly, participation requirements are discussed in Chapter 3, while compliance issues including the TCF are discussed below.

Harms caused to participants

4.10Several submitters and witnesses observed that the TCF has caused and continues to cause stress and harm to participants, up to and including preventing participants from meeting their and their children’s basic needs.[10] For example, the Australian Human Rights Commission (AHRC) stated:

[T]he use of the Targeted Compliance Framework…has the effect of penalising parents, overwhelmingly mothers, if they fail to meet the program requirements. This has the potential to cause harm to children because of the extra stress experienced by parents, and the impacts on access to food, safe housing, and other basic needs.[11]

4.11In the most extreme cases, a parent may lose a child to child protection services, on the basis that the parent no longer has the means to care for that child.[12]

4.12The Committee heard that the constant threat of payment suspension or cancellation is a re‑traumatising experience for victim‑survivors of domestic and family violence, who have been subject to coercive control.[13] For example, one participant stated:

[ParentsNext] is a coercive control; I know people don't like to use it and we don't like to say it's government sanctioned abuse, but that's exactly what it is. There's no option out; you're totally controlled and there are people who don't know you and don't know your situation making decisions about whether you're allowed to pay your rent or feed your children. How is that not abuse?[14]

4.13The impacts of payment suspensions and penalties are still more pronounced for participants who are already living with disadvantage.[15] For example, Mission Australia observed:

[O]ften it is participants who are dealing with carer or parenting responsibilities, domestic and family violence, serious mental health issues, health and wellbeing concerns, and other issues who will fail to meet mutual obligations requirements. That is, people with particular vulnerabilities are more likely than others to have their income support payments suspended.[16]

4.14The Committee also heard that the TCF excessively impacts First Nations peoples. For example, DEWR noted that the most recent evaluation of ParentsNext found that First Nations participants were disproportionately subject to payment suspensions.[17]

4.15In addition, the Committee heard that the way the TCF is administered is causing undue anxiety and harm.[18] For example, the Brotherhood of St Laurence (BSL) noted that in some cases Services Australia will send a suspension notice on Friday. The participant will often be unable to contact their provider until after the weekend. The intervening period is particularly stressful.[19]

4.16Participants with whom the Committee spoke during its site visits confirmed that the application of the TCF—and particularly automated suspension notices—can create stress and anxiety for participants who are often overwhelmed with other activities.

4.17Some stakeholders also contended that sanctions (including suspensions and more significant financial penalties) are disproportionate to the non-compliance they seek to address.[20] For example, Per Capita observed that:

Despite adjustments to allow more time before automatic suspensions are applied, the punishment for not attending ongoing mandated activity requirements is clearly disproportionate to the intended benefits of the program. Various submissions to two inquiries have shown how the application – or merely the threat – of those penalties has added stress and hardship to the parents of young children it was meant to help. This is not a way to encourage them to see the value of employment and feel well supported to prepare for it.[21]

Impact on participant engagement

4.18In addition to raising concerns about the harms caused by payment suspensions and financial penalties (or the threat of such sanctions), several submitters and witnesses argued that applying the TCF is not an effective means of encouraging engagementwith ParentsNext—at least not the kind of meaningful engagement that is necessary to improve participants’ social and economic participation.[22]

4.19The Centre for Excellence in Child and Family Welfare (CECFW) asserted that there is ‘absolutely no research’ to support a claim that payment suspension (or the threat of payment suspension) is an effective incentive to single parents to gain paid work. The CECFW stated:

We often create the people that we work with by having systems and processes that harm them…These are barriers which ParentsNext does not and is not able to address. Member consultations and evidence have informed us that programs which are strengths based, voluntary and work closely with parents and children on an ongoing basis…increase confidence and workforce participation.[23]

4.20The National Employment Services Association (NESA) similarly indicated that the TCF (or compulsion generally) may not be an effective means of ensuring positive and sustained engagement. In this regard, NESA noted that when mutual obligation requirements were suspended during the COVID‑19 pandemic, participation rates only decreased from 86 per cent to 75 per cent.[24]

4.21Some submitters and witnesses asserted that the application of the TCF is not only an ineffective means of encouraging participation in ParentsNext, but actively discourages engagement with the program. The Committee heard that the threat of financial sanctions forces participants to prioritise meeting attendance and reporting requirements over activities which will have a meaningful impact on their social and economic participation.[25] For example, Settlement Services International (SSI) stated:

The implementation of the [TCF] resulted in more time-consuming administrative requirements for ParentsNext participants. Consequently, participants may focus on ensuring compliance with reporting requirements, so that their payments are not suspended. As a result, the value of activities can be a secondary priority, which impacts on quality of participation.[26]

4.22The application of the TCF may cause harm—and sometimes irreparable damage—to relationships of trust between participants and providers that are critical to meaningful engagement. This is because the TCF forces providers to support participants with their goals and aspirations while also monitoring participants’ behaviour and punishing non-compliance.[27] In this respect, Mission Australia stated:

The [application of the] TCF in its current form…results in distrustful relationships between some participants and staff, which in turn impacts on those participants’ willingness and motivation to genuinely engage and take up opportunities that will benefit them.[28]

4.23Sarina Russo Job Access (SRJA) raised similar concerns about the impact of the TCF on the relationship between the provider and the participant, arguing:

The provider must…be allowed to work cooperatively with the participant. This implies that providers should not be the helpers on the one hand (providing advice, guidance and support) and a source of difficulty (enforcement of compliance frameworks, if applied) on the other. It also means that it is important that the content and tone of communications to be used by the provider be carefully considered and well-designed in order to be influential and supportive, rather than a source of stress or apprehension.[29]

4.24Economic Justice Australia noted (EJA) that providers have difficulty administering the TCF and following its complex rules and guidelines. In some cases, this leads to providers failing to consider a participant’s circumstances and inappropriately applying demerits, suspensions, or cancellations.[30]

4.25Mission Australia raised similar concerns, noting that providers are often obliged to focus on administering an ‘excessive and burdensome’ compliance regime, rather than spending time supporting participants. This can add to the challenges of building relationships of trust and confidence that are critical to effective support.[31] BSL indicated that this has been an issue since national rollout of ParentsNext, stating:

The staff focus was around compliance because it took up a lot of time to deal with rescheduling appointments, suspending payments, the phone calls back and forward. So rather than supporting the participants, it was spent on compliance and trying to rectify what was happening there.[32]

4.26Managers and frontline staff with whom the Committee spoke during its site visits were similarly concerned about the time spent administering the TCF and were acutely aware that their role in compliance and enforcement could damage their relationship with participants. Many staff observed that they had implemented ‘work arounds’ to ensure that participants on their caseloads were not subject to demerits, suspensions or penalties (such as automatically recording that a participant has attended an activity and sorting out any issues later), and to ensure that they can dedicate as much time as possible to building relationships with participants and addressing barriers to social and economic participation.

4.27However, some providers also indicated that the use of the TCF does not damage the relationship between provider and participant, so long as the operation of the framework is carefully explained, and suspensions and other sanctions are not applied in an unreasonable manner.[33] The TCF may also enable providers to reach out to participants and conduct welfare checks. CatholicCare Wollongong stated:

We have used the compliance requirements of appointment attendance in a fashion to engage with the most vulnerable of our participants who we cannot reach by phone or mail, usually because they are homeless or experiencing domestic violence. By our staff entering non-compliance with appointment attendance, these participants are required to reach out to us to restart their payments. This instance of reengaging with clients allows us to check on the welfare and safety of participants and their families.[34]

Automation of compliance and enforcement

4.28Stakeholders also expressed strong concerns in relation to automation of payment suspensions. For example, EJA observed that automation creates significant challenges for vulnerable parents, including those who live in regional and remote areas and have limited phone and internet access. EJA further stated:

It is egregious that automatic suspensions under the TCF apply to Parenting Payment recipients, especially as those affected include single parents with infants as young as 9 months in their care, parents with disability, parents of children with disability, and sole parent families experiencing family and domestic violence. The need to ensure that vulnerable parents are not exposed to the risk of automated payment suspension is, in our view, reason enough to make Parents Next, or any replacement program, purely voluntary.[35]

4.29NESA similarly expressed concern that automated processes do not account for the circumstances of parents dealing with trauma, stating:

[Services Australia’s] IT system identifies information entered by providers…in relation to [participants’] requirements…[and] use[s] the information to commence automated trigger of a [compliance] process which can lead to demerits and income support suspension…

Once [a mutual obligation failure is recorded] …an SMS is automated advising the person that if they do not make contact within two days their income support will be suspended.…If the parent is already living with trauma and has their income support suspended, this creates significant additional stresses.[36]

4.30While not expressing direct concern about automated payment suspension, Ability Options asserted that the decision to suspend a payment should be clear, defined process that does not come as a surprise to the participant.[37]

Reducing impacts on participants

4.31Some submitters and witnesses made suggestions for improving and reducing the impact of the TCF on participants, including replacing the TCF with alternative compliance arrangements. These were generally consistent with suggestions for a ‘lighter touch’ approach to compulsory participation outlined in Chapter 3.[38]

4.32Mission Australia suggested adopting the compliance model used in the Transition to Work Program, which only mandates attendance at a first appointment between the participant and the provider. All other appointments and activities are voluntary.[39]

4.33NESA suggested that there would be value in replacing the TCF with the Job Seeker Compliance Framework (JSCF), which operates in the Community Development Program. NESA explained that the JSCF:

…does not automate suspension - decisions are made by people. An income support suspension or financial penalty only occurs when an employment consultant completes an online report detailing the circumstances and sends the report to Services Australia. The decision to submit a report is in the hands of the consultant and Services Australia review the case as opposed to an automated ‘suspend first’ approach.[40]

4.34Per Capita indicated that flexibility should be built into the current TCF to lessen impacts on participants, stating that, in relation to appointments:

Payment should not be suspended for nonattendance at the agreed time until at least a week has passed, and three attempts have been made to make contact to arrange another time or other evidence-informed modification along those lines.[41]

Reporting requirements

4.35Where a participant has compulsory activities recorded in their Participation Plan, they are required to report attendance at those activities up to each fortnight.[42] Failure to report attendance may result in suspension of income support payments.

4.36Providers are responsible for scheduling reporting dates relating to compulsory activities. DEWR encourages providers not to schedule reporting dates on the same day as participants receive their income support payments, to reduce the risk of a payment suspension resulting in an actual loss of or delay to payments.[43]

4.37The Committee heard that that activity reporting requirements, coupled with the consequences for failure to report, are too onerous for, and may cause harm to, participants.[44] For example, one participant stated:

Fortnightly reporting has been overwhelming and causes anxiety. At times in the early fortnight of reporting I would stay up just past midnight to report. Then there have been times when I had an alarm to report. But if my daughter is not coping with her feelings, has an accident or has specialist appointments then reporting has been later. If this reporting is after 10 am in South Australia it then bumps my payment from the Wednesday to the Thursday, and then I have missed payments. I've had to call companies to assure them that they will get their payment the following day. Sometimes I've had a late fee. I always think, 'Shouldn't I have been reporting when I was working? Why now?'[45]

4.38Noting the negative impacts on participants, some submitters and witnesses asserted that reporting requirements should be reduced, at least in some circumstances.[46] For example, Jobfind Centres Australia Pty Ltd stated:

Participant requirements for fortnightly mutual obligation reporting should be relaxed where participant activities extend across a number of fortnights. For example, attending weekly playgroup activities, regular driving lessons or enrolment in a course have no financial change to fortnightly payments.[47]

4.39In addition to reporting on activities, ParentsNext participants are required to report their employment income to Services Australia each fortnightly. This requirement is common to all income support payments, including Parenting Payment.[48] A person on income support is required to report even where they receive no income. Where a person fails to report, their payments may be suspended.[49]

4.40During the Committee’s site visits to ParentsNext providers, several participants told the Committee that managing the multiple reporting requirements could be stressful and time-consuming, especially where a failure to report income or attendance at an activity could result in the suspension or—in rare cases—loss of income support. Participants asserted that reducing the number and types of events that result in suspension of income support would make their lives considerably easier.

4.41Participants also questioned the utility of requiring a person to report income each fortnight when they do not and have no plans to work as they are parenting very young children. A common view was that this requirement unnecessarily burdens recipients of income support. Participants told the Committee that where a person does not plan to receive income during a reporting period, they should not be required to report. It was also acknowledged in hearings that there is a balance to be struck as regular reporting of income helps to decrease the incidence of overpayments and debts.[50]

4.42The Department of Social Services (DSS) observed that the rollout of Single Touch Payroll (STP) is having ‘very positive’ impacts on lessening the reporting burden on income support recipients and is leading to increases in payment accuracy for those who are reporting earnings. DSS also stated that reducing or eliminating income reporting for recipients of Parenting Payment may require legislative, policy, and systems change, and may have implications for other working age payments.[51]

Committee view

4.43The TCF is significantly responsible for the near unanimous view that ParentsNext has become a punitive rather than supportive program. Onerous participation and reporting requirements, coupled with the threat of financial sanctions for non-compliance, leads to significant adverse impacts on participants, up to and including poor mental health outcomes and the inability to meet immediate basic needs for the participant and their children. The application of the TCF also has a disproportionately severe impact on First Nations peoples and parents already living in situations of disadvantage.

4.44The TCF, at least in its current form, should not continue to be a part of ParentsNext or a replacement service. It should be replaced by an alternative framework which is better adapted to the needs of parents and is not unduly punitive.

4.45The loss of income support or cancellation of payments should not form part of this new framework. There is no acceptable public policy basis for these penalties on parents (overwhelmingly female single parents), and they are disproportionate to most, if not all, types of non-compliant behaviour which may occur within a pre-employment or pre-vocational program. That there have been, since 2018, only 17 instances where a participant’s payment was cancelled for persistent non-compliance further demonstrates that cancellation is not a necessary part of the compliance framework.

4.46The Committee also considers that full payment suspensions are an unnecessarily harsh blunt instrument. They should be removed from the compliance framework for ParentsNext and should not be included in any new compliance framework as soon as alternative mechanisms to encourage engagement are in place. However, the framework requires substantial change to minimise adverse impacts on participants.

4.47The Committee considers that government needs an alternative to the blunt instrument of payment cancellations or full suspensions. Legislation should be amended, and IT systems adjusted, to enable a partial payment withholding (‘holdback’) as an alternative to cancellations or suspensions. A ‘holdback’ of a small percentage (25 to 30 per cent) of a payment should become the maximum sanction available under ParentsNext or a replacement service until non-compliance is remedied.[52] A ‘holdback’ can act as an incentive to re-engage without leaving a participant with insufficient funds to meet basic needs. All holdbacks should be paid back to the participant as soon as re-engagement occurs or the participant provides a valid reason for the relevant compliance failure.

4.48Removing the risk that a participant will lose an entire payment—even for a short time—should be a priority. However, it is acknowledged that this change will take time given the need for changes to legislation and IT systems.

4.49The Committee was concerned to hear of over 1,000 cancellations where people simply stopped engaging with ParentsNext. Many will have secured work and accordingly have no need of income support; however, there were reports that people just gave up as compliance and reporting were too onerous. As a general principle, if a person has not complied with a participation or income reporting requirement for an extended period, Services Australia should be required to formally notify the person of the intention to cancel their payment. This should include a reasonable notice period (for example 28 days or more).

4.50Other changes that the Committee considers should be made as soon as practicable (acknowledging that some may not be possible until a new service is in place) include:

• Extending the time within which a participant must re-engage with their provider or provide a valid reason for their non-compliance to avoid a suspension. The current ‘grace period’ is two business days. This should be urgently extended to seven business days (i.e., always providing at least one calendar week) to better reflect the reality of caring responsibilities and the sometimes complex lives of those eligible for this program.
• Ensuring that all suspension decisions are made by a Services Australia staff member, rather than automatically by Services Australia’s systems. If a participant has failed to engage with the program by attending regular appointments without a reasonable explanation or is not meaningfully participating, the provider should be required to lodge a report with Services Australia who can talk with the participant and the provider and determine whether an exemption is warranted or if further action is required.
• Removing the power and requirement for providers to make decisions that affect people’s payments in any way. This will help to address concerns associated with providers’ dual role in helping and policing participants, allowing the provider to focus on supporting the participant to identify and achieve their goals. Removing compliance functions from the provider should also substantially reduce administrative burdens on providers and free up time to focus on helping participants.
  51. The removal of the TCF, and the replacement of the TCF with a different compliance framework, would complement significant changes to eligibility criteria and participation requirements for a service to replace ParentsNext, which would see parents only required to participate once their youngest child reaches three years of age, and participants only required to attend appointments and engage meaningfully with the program rather than regularly complete and report on activities which may be of negligible benefit to the participant’s social and economic participation.
  52. The new compliance framework should be developed as part of the co-design process for the new program, to ensure that it responds to the circumstances and needs of prospective participants, while endeavouring to make other changes as soon as practicable (discussed further in Chapter 6).

4.53The Committee recommends that the Australian Government amend legislation and adjust IT systems to enable a partial payment withholding (‘holdback’) as an alternative to the blunt instrument of harsh payment cancellations or suspensions. This ‘holdback’ should apply to only a small percentage (for example, 25 to 30 per cent) of the participant’s payment.

4.54The Committee recommends that the Australian Government:

• end automatic payment cancellations where a person has:
  • failed to re-engage with ParentsNext after their payments have been suspended (or provide a valid reason for the compliance failure); or
  • failed to meet their income reporting requirements;
• require Services Australia to formally inform the person of the intention to cancel the person’s payments, subject to a reasonable notice period (for example, 28 days); and
• retain these safeguards in the service which replaces ParentsNext.

4.55The Committee recommends that the Targeted Compliance Framework not apply to participants in the service which replaces ParentsNext. A new framework should be implemented that includes the following suggested features:

• Income support payments for parents will no longer be cancelled or suspended.
• If a participant does not meet a participation requirement, the time to re-engage be substantially longer than the current two business days (seven business days suggested).
• If a participant does not re-engage then a provider does not have the power to impact their payment. The provider will simply make a report to Services Australia.
• All decisions that affect income support payments must be made by a staff member within Services Australia, and not automatically by the system.
• A partial payment withholding (‘holdback’) of a small percentage (for example 25 to 30 per cent) of a person’s payment be the maximum sanction available to Services Australia, with the holdback paid back to the participant in full as soon as re-engagement occurs.
  56. The Committee is also concerned that participants are required to report employment income even where they do not receive any income for a reporting period. This requirement places significant burden on participants, and adds to their stress and anxiety, without delivering commensurate benefits to government.
  57. Adjusting income reporting requirements may require legislative, policy, and systems changes, and may not be feasible in the short term. Nevertheless, DSS should explore options to simplify reporting arrangements for Parenting Payment, including for current ParentsNext participants and participants in a replacement service. Options might include:

• Allowing parents to report less frequently (for example, every two or three months rather than fortnightly) if they have indicated that they are not working and have no plans to start work in the short or medium term.
• Leveraging STP information so that information about a person’s employment income is recorded in the system without that person needing to self-report or confirm. This could be applied to Parenting Payment recipients who indicate that they are not and do not propose to work, and thereafter rolled out to all working age payments.

4.58The Committee recommends that the Australian Government consider options to allow parents caring for very young children and who do not intend to work to report their employment income less frequently (for example, every two or three months rather than fortnightly).

Footnotes

[1]See Department of Employment and Workplace Relations (DEWR), Targeted Compliance Framework—Mutual Obligation Failure, pages 16–20, https://www.dewr.gov.au/parentsnext/resources/targeted-compliance-framework-mutual-obligation-failures, viewed 15 February 2023. The legal basis for the TCF is set out in Division 3AA, Part 3 of the Social Security (Administration) Act 1999.

[2]Ms Benedikte Jensen, First Assistant Secretary—Employment Policy and Analytics, DEWR, Committee Hansard, 11 November 2022, p. 31; Dr Andrew Wright, Director—Targeted Employment Policy, DEWR, Committee Hansard, 11November2022, p.31.

[3]National Employment Services Association (NESA), Submission 83, p.10. A participant may commit a mutual obligation failure in a variety of ways, including by failing to enter into a Participation Plan, failing to attend appointments, or failing to participate in a compulsory activity. For further information on mutual obligation failures and on what constitutes a reasonable excuse, see DEWR, Targeted Compliance Framework—Mutual Obligation Failure, p. 29.

[4]DEWR, Submission 77, p. 26.

[5]DEWR, Submission 77, pages 10–11.

[6]DEWR, Submission 77, p.11.

[7]DEWR, Submission 77.1, p. [15].

[8]DEWR, Submission 77, p.11.

[9]Ms Jensen, DEWR, Committee Hansard, 3 November 2022, pages 33–34.

[10]See, for example, Council of Single Mothers and their Children (CSMC), Submission 25, p. [6]; Sarina Russo Job Access (SRJA), Submission 23, p.7; Centre for Excellence in Child and Family Welfare (CECFW), Submission 74, pages1–4; Associate Professor Elise Klein OAM, Committee Hansard, 11November2022, p.2; Economic Justice Australia (EJA), Submission 11, p.[6]; Australian Council of Social Service (ACOSS), Submission 62, p. 6; Salvation Army Employment Plus (SAEP), Submission 48, p.7.

[11]Australian Human Rights Commission (AHRC), Submission 24, p. 2. The AHRC emphasised that the linking income support payments to compulsory obligations — particularly if there are significant penalties for failing to meet those obligations — is likely to be incompatible with Australia’s human rights obligations.

[12]See, for example, Ms Deb Tsorbaris, Chief Executive Officer, CECFW, Committee Hansard, 6December2022, p.17; Associate Professor Joanne Evens and Ms Jade Purtell, Submission 84, p.2.

[13]See, for example, Associate Professor Elise Klein OAM, Submission 6, p. 3; Dr Simone Casey, Senior Advisor—Employment, ACOSS, Committee Hansard, 6December2022, p.13; Ms Terese Edwards, Chief Executive Officer, National Council of Single Mothers and their Children (NCSMC), Committee Hansard, 6 December 2022, p. 2.

[14]Angela (private capacity), Committee Hansard, 7 December 2022, p. 2.

[15]See, for example, DEWR, Submission 77, p.11; DEWR, Submission 71 (Attachment 2), p.58.

[16]Mission Australia, Submission 76, p.5.

[17]DEWR, Submission 77, p. 11. DEWR’s evaluation found First Nations peoples made up 33 per cent of all payment suspensions, and 18 per cent of the total participant caseload. See also EJA, Submission 11, p. [2].

[18]See, for example, Ms Linda Forbes, Law Reform Officer, EJA, Committee Hansard, 11November2022, p.22; SRJA, Submission 23, p.7; CECFW, Submission 74, pages1–2.

[19]Mrs Penny Bohm, Project Manager, Brotherhood of St Laurence (BSL), Committee Hansard, 11November2022, p.26.

[20]See, for example, Associate Professor Elise Klein OAM, Submission 6, p. 3.

[21]Per Capita, Submission 78, p. 12.

[22]See, for example, BSL, Submission 59, p.10; CECFW, Submission 74, p.3; Goodstart Early Learning (Goodstart), Submission 75, p.4; Australian Research Alliance for Children and Youth (ARACY), Submission 37, pages 3–4.

[23]Ms Tsorbaris, CECFW, Committee Hansard, 6December2022, p.12.

[24]NESA, Submission 83, p. 9. This contrasts with evidence provided by DEWR (above) that a compulsory model generates greater levels of engagement.

[25]See, for example, Dr Ann Nevile, Submission 14, p.2; Dr Katherine Curchin, Submission 26, p.3.

[26]Settlement Services International (SSI), Submission 16, p. [4].

[27]See, for example, Dr Katherine Curchin, Submission 26, p. 3; CORE Community Services (CORE), Submission 33, p. [2]; Campbell Page, Submission 57, p. [5].

[28]Mission Australia, Submission 76, p.5.

[29]SRJA, Submission 23, p.9.

[30]EJA, Submission 11, p.[5].

[31]Mission Australia, Submission 76, p. 6.

[32]Mrs Bohm, BSL Committee Hansard, 11November2022, p.26.

[33]See, for example, APM, Submission 42, p.6; Ability Options, Submission 58, p.[3].

[34]CatholicCare Wollongong, Submission 65, p. 3. CatholicCare emphasised that since providers have ‘absolute power’ in this area, they must use the most ethical lens and application of the program to ensure that they are not exploiting or increasing participant vulnerability.

[35]EJA, Submission 11, p.[2]

[36]NESA, Submission 83, p.10.

[37]Ability Options, Submission 58, p.[3].

[38]See, for example, Family and Relationship Services Australia, Submission 60, p.7; SAEP, Submission 48, p.8; Roseberry, Submission 71, p.2.

[39]Mission Australia, Submission 76, p. 7.

[40]NESA, Submission 83, p.10

[41]Per Capita, Submission 78, p.6.

[42]DEWR, Submission 77, p.21. Parents in full-time study are not required to report attendance at activities.

[43]Ms Samantha Robertson, Assistant Secretary—Employment Services Programs Branch, DEWR, Committee Hansard, 11November2022, p.32. See also DEWR, Submission 77, p. 10. All participants are required to have at least one compulsory activity in their Participation Plan.

[44]See, for example, Associate Professor Elise Klein OAM, Submission 6, p. 2; CSMC, Submission 25, p. [6]; ACOSS, Submission 62, p. 6; Dr Cassandra Goldie, Chief Executive Office, ACOSS, Committee Hansard, 6December2022, pages14–15.

[45]Melissa (private capacity), Committee Hansard, 7December2022, p.4. Melissa’s experiences with activity reporting were reflected in participant testimony gathered by academic and policy experts. See, for example, Dr Eve Vincent, Submission 10, p.3.

[46]See, for example, Ms Kelly Millar, National Social Policy Manager, Goodstart, Committee Hansard, 11November2022, p.18, Mission Australia, Submission 76, p.7.

[47]Jobfind Centres Pty Ltd, Submission 50, p. [3].

[48]See Mr Matt Flavel, Deputy Secretary—Social Security, Department of Social Services (DSS), Proof Committee Hansard, 14 February 2023, p. 26.

[49]See DSS, How to report and manager your payment, www.servicesaustralia.gov.au/how-to-report-and-manage-your-jobseeker-payment, viewed 19 January 2023.

[50]See, for example, Proof Committee Hansard, 18 January 2023, p. 26.

[51]See Mr Flavel, DSS, Proof Committee Hansard, 18 January 2023, p. 26.

[52]At present, where payments are suspended, the participant will receive no payment until they re-engage with their provider or provide a valid excuse for the relevant non-compliance.