Chapter 2

Aims and design

The stated aims of the Parents Next Program looked very positive to me and I looked forward to starting the program and being supported in returning to work. My experience of the program was not in line with the stated aims.1
2.1
Throughout this inquiry, the committee heard from a significant number of submitters and witnesses who broadly supported the idea of a program which assists parents to develop the skills needed to re-enter the workforce but did not support the design of ParentsNext as a compulsory program with a punitive compliance framework. Many witnesses expressed particular concerns about the human rights implications of the aims and design of ParentsNext, and whether the compulsory activities which parents are required to complete are appropriate for a pre-employment program.2
2.2
This chapter examines the development of ParentsNext, how its aims and design engage with certain human rights, the suitability of the program for vulnerable subgroups in the cohort, and best practice in pre-employment programs and activities for parents.

What came before ParentsNext?

2.3
ParentsNext is based on elements of the Helping Young Parents (HYP) and Supporting Jobless Families (SJF) measures that were introduced by the Australian Government in 2012, as part of the Building Australia's Future Workforce package in the 2011–12 Budget.3
2.4
HYP was designed to improve the education of young parents and the development outcomes of their children by providing support for parents aged 19 years or younger to undertake education or training leading to the attainment of a Year 12 or equivalent qualification. The measure also included required activities that focused on the health and early childhood development of participants' children.4
2.5
SJF was designed to assist parents to prepare to return to the workforce once their youngest child was of school age, and to help ensure their children were ready to start school. SJF targeted parents aged under 23 years or in receipt of income support for two or more years to participate in compulsory workshops when their child was four or five years old, as well as voluntary participation in employment, education, parenting and childhood development activities.5
2.6
Ten place-based trials for HYP and SJF were conducted by the then Department of Employment between January 2012 and June 2015, in:
Bankstown, Shellharbour and Wyong in New South Wales;
Logan and Rockhampton in Queensland;
Playford in South Australia;
Burnie in Tasmania;
Hume and Greater Shepparton in Victoria; and
Kwinana in Western Australia.
2.7
These trials were subject to evaluation in 2015, the report of which was published in August 2017.6 The evaluation found that HYP and SJF had 'demonstrated positive outcomes for parents through regular contact with the Department of Human Services and participation in activities'.7 As a result, the Australian Government provided funding in the 2015–16 Budget, under the Growing Jobs and Small Business Package, 'to establish projects that build on the strengths of the trials and reach a larger target group'.8 HYP and SJF trials were extended in the 10 trial sites through to March 2016, at which point they were superseded by the ParentsNext trial.9

The ParentsNext trial, evaluation and expansion

2.8
The ParentsNext trial ran from 4 April 2016 to 30 June 2018 in the 10 LGAs which had been subject to the HYP and SJF trials. During this period, participation in the program was generally compulsory for parents living in these LGAs who:
had been receiving Parenting Payment for six months or more; and
had not had any employment in the past six months; and
had a youngest child aged between six months and six years old; and
met one of following three priority criteria:
was an early school leaver (i.e. aged under 22 and not completed the final year of secondary school or an equivalent qualification);
was assessed as highly disadvantaged based on a Job Seeker Classification Instrument assessment; or
had a youngest child aged five years old.10
2.9
Participants in the ParentsNext trial were required to attend scheduled appointments with their ParentsNext provider and agree on and complete activities in a participation plan in order to receive their Parenting Payment.11

Evaluation of the trial

2.10
The Department of Jobs and Small Business conducted an evaluation of the early impact of ParentsNext in the 10 trial sites after the first 14 months of the program (i.e. for the period April 2016 to June 2017). The evaluation found that, during the trial period assessed, ParentsNext had improved parents' attitudes to workforce participation, wellbeing, and chances of studying or training. Participants in ParentsNext also appeared to demonstrate higher levels of study, training and job-seeking compared to non-participants.12
2.11
However, the evaluation of the ParentsNext trial has been subject to significant criticism. The evaluation report was not published until September 2018,13 two months after the national roll-out of the program commenced; this meant that evidence of the program's efficacy was not available before it was implemented nationally.14
2.12
Furthermore, the data which was referenced in the evaluation report was not published in a complete form – for example, it is not clear what questions were asked, how many participants or providers were surveyed, or the circumstances in which the survey was completed – and did not assess all 10 trial locations, which has raised concerns about the accuracy of the quantitative trial evaluation.15 The Australian Human Rights Commission told the committee that the successes of ParentsNext reported in the evaluation were therefore not appropriately evidence-based:
On the basis of the evaluation of the program to date, it is not possible to conclude that the program is achieving its aims or that it has had a positive effect which outweighs the detriment of undermining the right to social security.16
2.13
The committee recognises that many of these submitters have called for the full evaluation data to be made publically available to allow for greater scrutiny of the reported outcomes of the ParentsNext trial and to inform future changes to the program.17

Consultations ahead of the national expansion

2.14
Following the 2017–18 Budget announcement that ParentsNext would be expanded nationally, the then Department of Employment released a discussion paper and conducted consultations with service providers and other key stakeholders in late 2017.18 The committee heard a number of concerns about the quality of the consultations which were undertaken during this period.
2.15
The Northern Territory Government submitted that ParentsNext had been introduced in the Northern Territory with 'a lack of networking, consultation and communication' with the social and community sector.19
2.16
Others submitted that they were unaware of any consultation with affected parents, their advocates or child development experts before the development and implementation of ParentsNext.20 The Council of Single Mothers and their Children (Victoria) told the committee that:
There is no evidence of co-design, or that groups such as ourselves were ever consulted in the creation of the program. Indeed, our contributions prior to the national rollout of the program were to no avail, as the pilot program was already set to be expanded and our recommendations, (including vital improvements in the quality and training of staff, ways to improve the power imbalance, and raising the minimum age of children whose parents were to attend), were not taken up. Furthermore, there is no evidence that child development experts were consulted or asked about the possible negative impacts of compulsory participation on parental stress and the cascading impact of these on the well-being of babies, toddlers and pre-schoolers.21
2.17
Although the Department of Jobs and Small Business informed the committee that Aboriginal and Torres Strait Islander peoples had provided advice during the consultation period about the need for supports for this cohort,22 the joint submission from the Human Rights Law Centre, SNAICC and the National Family Violence Prevention Legal Services noted that:
Despite the Discussion Paper for the ParentsNext National Expansion raising concerns about the cultural competency of service providers, there is no evidence that there has been consultation with Aboriginal and Torres Strait Islander people and communities about improving the situation. In addition, the ParentsNext Evaluation Report offers limited insight into the impact of the ParentsNext program on Aboriginal and Torres Strait Islander women and more generally fails to offer a robust and/or independent assessment of the efficacy of the program.23
2.18
The issues around the suitability of ParentsNext for Aboriginal and Torres Strait Islander participants are discussed in detail later in this chapter.
2.19
The committee has also received evidence that the Australian Government did not seek the advice of human rights experts before the national rollout.24 This is particularly concerning, given the significant ways in which ParentsNext engages a number of human rights.

Expansion informed by neither evaluation nor consultation

2.20
The committee heard concerns that issues raised in the ParentsNext trial and during consultations, such as the merit of referring parents with children as young as six months old and the cultural safety of the program, had not been addressed before the national rollout.25
2.21
Additionally, the national program has some significant differences to the trial program, particularly in relation to compliance and participation requirements, which were not evaluated before their widespread implementation. Good Shepherd Australia and New Zealand told the committee:
The evaluation itself is of limited use in determining the quality of the program because it was conducted prior to the linking of ParentsNext with the targeted compliance framework.26
2.22
Settlement Services International told the committee that, in fact, evaluation of the trial had not shown a need for a more rigorous compliance framework in order to achieve the program's outcomes, explaining in its submission that:
The trial phase was successful in delivering many of the program's intended outcomes without a need for [the TCF], so the value added by implementing it is unclear to us. The evaluation of the trial phase did not recommend the introduction of a targeted compliance framework and found, in fact, in the trial phase that the compliance levels were largely appropriate.27

Committee view

2.23
The committee recognises the concerns raised by submitters about the quality of evidence included in the published evaluation of the ParentsNext trial and supports the call for the full evaluation data to be made available for public scrutiny.
2.24
The committee has serious concerns that the national rollout of ParentsNext, particularly its use of compliance mechanisms, appears not to have been informed by either the evaluation of the trial or by proper consultation with expert stakeholders.

Aims, objectives and human rights implications

2.25
As outlined in Chapter 1, the aims of ParentsNext are to reduce reliance and intergenerational dependency on social security; increase female labour force participation; and close the gap in Aboriginal and Torres Strait Islander peoples' employment. According to the Department of Jobs and Small Business, ParentsNext has been designed to meet these aims by providing pre-employment support to parents of young children while they are 'out of the workforce' through the following objectives:
targeting early intervention assistance to parents at risk of long-term social security dependency;
helping parents identify and reach their education and employment goals; and
connecting parents to local services and activities to help them meet their goals. 28
2.26
A large number of submitters and witnesses have raised concerns about how these aims and objectives, which target particular groups of parents and engage with Australia's human rights obligations, have significant unintended consequences for the wellbeing of participants and their children.29
2.27
The Statement of Compatibility with Human Rights (Statement of Compatibility) for the instrument which specified participants for the national rollout states that while ParentsNext promotes rights to work and education, it engages and limits the rights to:
social security;
an adequate standard of living; and
equality and non-discrimination. 30
2.28
ParentsNext also engages the obligation to consider the best interests of the child in all actions concerning children.31

Social security and an adequate standard of living

2.29
Article 9 of the International Covenant on Economic, Social and Cultural Rights (ICESCR), to which Australia is a party, provides that everyone has a right to social security, including social insurance.32 The Australian Human Rights Commission summarises this as follows:
The right to social security encompasses the right to access and maintain benefits in order to secure protection from social risks and contingencies. It includes the right not to be subject to arbitrary and unreasonable restrictions of existing social security coverage.33
2.30
Article 11 of the ICESCR provides that everyone has a right to an adequate standard of living for themselves and their family, including adequate food, clothing and housing.34
2.31
These rights are also provided in the Convention on the Rights of the Child.35
2.32
The Statement of Compatibility notes that compliance actions in ParentsNext, taken when a participant fails to meet their participation requirements under the TCF, impact these rights. The Statement of Compatibility contends that the use of the TCF is a reasonable limitation on these rights, describing how compliance actions lead to engagement with the program:
The risk of compliance action has proved to be effective in ensuring participants engage with providers delivering ParentsNext and similar programs, and are able to benefit from the services that they offer… Linking participation requirements to the continued receipt of income support payments also acts as a re-engagement mechanism to ensure participants continue to actively participate and are focussing on the long term outcomes for themselves and their children.
…Any limitations there may be to the right to social security and the right to an adequate standard of living, due to imposing requirements directed at overcoming barriers to employment, are reasonable and necessary in view of the evidence outlined above.36
2.33
However, submitters and witnesses have described how the conditionality placed on Parenting Payment, through the use of compulsory participation plans and the TCF in ParentsNext, breaches these rights.37 Furthermore, by placing conditions on the social security of parents and potentially reducing their income, the program does not appear to consider the best interests of children.38 The Australian Human Rights Commission summarised these concerns in its submission:
…the compulsory and punitive nature of the program breaches the right to social security. The compliance framework permits social security to be reduced below the minimum essential level for parents caring for young children. This retrogressive measure affects some of the most vulnerable families in Australia, with severe detrimental impacts on their financial security and human rights. It also risks entrenching and exacerbating poverty and inequality among program participants.39
2.34
Submitters and witnesses have argued that using a punitive compliance mechanism to meet the aims of the program is not a proportionate limitation on the rights to social security and an adequate standard of living, as there is no evidence that such a mechanism is the only way to achieve these aims.40 The Centre for Excellence in Child and Family Welfare told the committee:
It is still not clear to us why the government chose mandatory participation as an engagement mechanism…We disagree with the argument that limiting the right to social security and an adequate standard of living are necessary, as we have seen no evidence that other less restrictive and punitive alternatives have been explored…the design of ParentsNext assumes that parents are not able to decide what is best for their family, that they lack capacity and motivation and that they must be coerced in order to engage in support.41
2.35
In fact, evidence to the committee suggests that placing conditions on social security through compliance programs, such as ParentsNext, is likely to result in negative outcomes for participants.42 Good Shepherd Australia New Zealand submitted that international evidence does not support conditionality in social security as a rational method of encouraging people to participate in programs, noting that:
…longitudinal evidence collected in the United Kingdom shows that a harsh regime of welfare conditionality is largely ineffective and rarely results in shifts from income support into secure employment.43
2.36
Although there has been no evaluation of the impact of social security conditionality in the national expansion of ParentsNext to date, a survey conducted by the Centrelink and Other Info Facebook Group found that nearly 68 per cent of responding participants were 'worse off' under ParentsNext and 42 per cent reported that participating had specifically caused financial hardship.44
2.37
Because of the serious limitations on human rights and the substantial concerns about the impact of these on the wellbeing of parents and their children, advocates, human rights experts and ParentsNext providers alike have almost universally recommended to the committee that a punitive, automatic compliance mechanism like the TCF should not be attached to ParentsNext.45
2.38
Furthermore, some submitters have recommended that, rather than relying on the threat of compliance action, ParentsNext should use alternative avenues of engagement which are more appropriate to the supportive aims of the program.46 The Centre for Excellence in Child and Family Welfare told the committee:
There are many ways that engagement can be respectfully encouraged without having to resort to coercion or sanctions, including addressing the individual and structural barriers that can affect a person's ability or willingness to engage.47
2.39
The ways in which pre-employment programs can engage with participants by addressing these structural barriers to employment are explored later in this chapter.

Equality and non-discrimination

2.40
The ICESCR provides that the rights to social security and an adequate standard of living 'be exercised without discrimination of any kind as to race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status'.48
2.41
The rights to equality and non-discrimination are also protected by the International Covenant on Civil and Political Rights, the Convention of the Rights of the Child, the International Convention on all Forms of Racial Discrimination, and the Convention on the Elimination of All Forms of Discrimination against Women.49
2.42
ParentsNext impacts on the right to equality and non-discrimination as its aims specifically target women and Aboriginal and Torres Strait Islander peoples as groups in particular need of pre-employment assistance. The Statement of Compatibility maintains:
It is appropriate to restrict the eligibility for ParentsNext to particular groups of parents as the program is designed to provide those groups with support to address the specific disadvantage they face.50
2.43
Evidence received by the committee does not support this view, and is discussed below.

Indirect discrimination against women

2.44
One of the aims of ParentsNext is to increase female labour force participation. As at 31 December 2018, six months after the commencement of the national program, 95 per cent of all participants were women.51
2.45
The Department of Jobs and Small Business told the committee that Australia 'is at the lower end of OECD countries in terms of the employment rate of women aged between 25 and 54 years and of mothers with very young children',52 further stating that:
Research from the OECD notes that one of the most important factors which can contribute to child poverty is whether or not children are living with parents who are jobless.53
2.46
The Statement of Compatibility explains that the majority of parents in jobless families in Australia are women and that, therefore, ParentsNext could be considered 'indirectly discriminatory on the basis of sex, as the vast majority of those affected by the Instrument will be female'. Indirect discrimination occurs when rule or policy is the same for everyone but exclusively has an unfair effect on people with a particular personal attribute.54
2.47
The Australian Human Rights Commission has criticised whether the indirect discrimination against women is justified in ParentsNext, stating that the explanation offered in the Statement of Compatibility:
…only goes so far as to identify the disadvantage facing [women], rather than adequately justifying how the imposition of ParentsNext will resolve this disadvantage. An underlying assumption of this analysis is that the program is a net benefit to all participants and therefore selecting participants based on…sex does not amount to unlawful discrimination.
2.48
Several submitters have also noted that, in January 2018, the United Nations registered a complaint concerning Australia's treatment of single mothers in relation to Parenting Payment and that the Special Rapporteurs on extreme poverty and human rights have written to the Australian Government about cuts to Parenting Payments, noting that these are retrogressive measures that undermine women's human rights.55 Associate Professor Beth Goldblatt commented:
The ParentsNext program with its compulsory element and capacity to remove income entitlements to needy parents and their children is likely to face further criticism from UN bodies.56
2.49
Witnesses and submitters have contended that the targeted aims of ParentsNext do not represent a reasonable limitation on women's right to equality and do not take into account the reasons why women, particularly single mothers, are overrepresented in the cohort of Parenting Payment recipients and have lower labour force participation rates than men.57
2.50
In particular, many pointed to the lack of recognition of the unpaid work which is carried out by mothers of young children as a major contributing factor in labour force participation.58 The National Social Security Rights Network submitted:
Women spend 16 hours per week on housework prior to becoming a parent, which jumps to 30 hours per week when their youngest child starts school, while caring duties jump from 2 hours per week to 51 hours when a baby is born. It is unhelpful to view mothers of young children as unemployed workers when they are in fact working longer hours than men in full-time positions, but largely without remuneration.59
2.51
Furthermore, Good Shepherd Australia New Zealand submitted that the aims and design of ParentsNext assume that mothers will become dependent on social security in the long term, despite evidence that social security reliance in women is generally limited to four years or less, coinciding 'with the prime child-bearing and child-rearing years'.60
2.52
The issues of unpaid labour, assumptions about women receiving Parenting Payment and other barriers to employment faced by mothers are explored later in this chapter.

Direct discrimination against Aboriginal and Torres Strait Islander peoples

2.53
Another one of the aims of ParentsNext is to close the gap in Aboriginal and Torres Strait Islander peoples' employment. A total of 19 per cent of participants in ParentsNext identify as Aboriginal or Torres Strait Islander, 94 per cent of whom are women and 69 per cent of whom are single mothers.61
2.54
As discussed in Chapter 1, 20 of the 30 Intensive Stream locations have been selected specifically for their high rate of Aboriginal and Torres Strait Islander recipients of Parenting Payment in order to achieve this aim. The Statement of Compatibility provides a rationale for this direct discrimination on the basis of race:
Given the high level of need amongst Indigenous parents, it is appropriate that the Australian Government identify locations to deliver the Intensive Stream of ParentsNext where a high proportion of parenting payment recipients are Indigenous. This will result in Indigenous parents being more likely to receive assistance from ParentsNext, receiving that assistance sooner, and receiving a higher level of assistance than if they had been in the Targeted stream.62
2.55
The Statement of Compatibility further rationalises that direct discrimination in ParentsNext:
…is reasonable, necessary and sufficiently precise to assist those parents to improve their family wellbeing, educational attainment and employment prospects and to begin to disrupt the intergenerational disadvantage from which many suffer.63
2.56
Human rights experts do not believe that this direct discrimination, which specifically targets Aboriginal and Torres Strait Islander people to participate in a scheme which limits their rights to social security, has a rational connection to the program's aims. As with the issue of indirect discrimination against women, the Australian Human Rights Commission submitted that the Statement of Compatibility's explanation of why Aboriginal and Torres Strait Islander people had been targeted only identifies their disadvantage, but does not explain how ParentsNext will address it.64 Human rights experts noted that this direct discrimination could be permitted if it constituted a 'special measure'—that is, a positive measure introduced to achieve substantive equality—but that the Australian Government had not designed ParentsNext as such.65
2.57
Furthermore, submitters drew similarities between ParentsNext and other programs which impose social security conditionality on Aboriginal and Torres Strait Islander peoples, such as the Community Development Program and Cashless Debit Card, noting ongoing concerns about programs that undermine the autonomy of Aboriginal and Torres Strait Islander people and communities.66
2.58
Witnesses and submitters have also questioned whether ParentsNext is appropriately designed to meet the specific needs of Aboriginal and Torres Strait Islander parents, who may experience higher levels of vulnerability than other cohorts.67 Good Shephard Australia New Zealand described that:
This includes lower rates of education and literacy, higher rates of victimisation due to family violence, poorer physical and mental health and other effects of dispossession and colonisation. Caring responsibilities for Aboriginal and Torres Strait Islander people also extend beyond the nuclear family structure while cultural and community responsibilities may limit time available for compliance activities.68
2.59
While some providers have described the steps taken to ensure their provision of ParentsNext is culturally appropriate and partnered with community organisations,69 the committee has heard serious concerns that many service providers do not have an appropriate level of cultural competency or experience in working with Aboriginal and Torres Strait Islander peoples.70 The NCSMC/CSMC Survey found that only 7 per cent of Aboriginal or Torres Strait Islander respondents agreed that services suggested culturally appropriate activities and employed Indigenous case workers.71
2.60
Several submitters have recommended that the design and aims of ParentsNext be revisited to better consider the needs of Aboriginal and Torres Strait Islander people.72 Further ways in which ParentsNext could be adjusted to consider these and the specific needs of other vulnerable parents are considered in later sections of this chapter.

Targeting and the inclusion of other vulnerable populations

2.61
ParentsNext, by virtue of being a program which targets highly disadvantaged parents, also includes participants from a number of other vulnerable populations, including people with disability, people from culturally and linguistically diverse backgrounds, and people who have experienced domestic and family violence.
2.62
It is unclear how many participants in ParentsNext may experience the intersection of multiple vulnerabilities.73

People with disability

2.63
According to the Department of Jobs and Small Business, approximately 14 per cent of participants in ParentsNext are people with disability.74
2.64
The committee heard that a number of parents with disability, as well as parents of children with disability, who have been referred to ParentsNext have found that the program does not meet their needs.75 One parent commented that:
I'm a disabled single parent. They assume every parent is able bodied and don't factor in disability.76
2.65
The NCSMC/CSMC Survey found that 67 per cent of responding participants with disability did not believe that their needs and access requirements were understood and included in the service they received from their provider.77 The National Social Security Rights Network also told the committee:
…a single mother who was in receipt of Mobility Allowance for her physical disabilities and Carer Allowance in recognition of the care she provided for her severely disabled son…was made a compulsory participant of ParentsNext. She contacted our member centre when her payments were cancelled because she refused to sign her participation plan due to the plan not taking account of her physical disabilities and caring responsibilities for her child with disabilities. We were advised that the mother felt pressured into signing the participation plan.78
2.66
Meanwhile, some parents with disability, or who have children with disability, who wish to volunteer to receive pre-employment supports under ParentsNext have been unable to do so. The committee heard complaints from providers who could not assist these parents because they were receiving Disability Support Pension or Carer Payment, rather than Parenting Payment.79 The National Employment Services Association submitted that:
The…stated aims are to assist parents at risk of long-term welfare dependency. As such, it is inconsistent to exclude parents on [disability support pensions] from ParentsNext given the labour market disadvantaged faced by people with a disability, higher risk of poverty and social exclusion. ParentsNext offers a unique parent friendly and focused environment that is not available in other programs such as Disability Employment Services or jobactive.80
2.67
However, despite interest from ParentsNext providers in servicing participants with disability, it appears that there is no clear requirement for contracted providers to have expertise or training in providing these services for people with physical or mental disability.81 The Council of Single Mothers and their Children (Victoria) recommended in its submission that ParentsNext providers' staff should be trained in disability awareness and meeting the requirements of the Disability Discrimination Act 1992.82

Culturally and Linguistically Diverse groups

2.68
A number of submitters and witnesses described the challenges faced by parents from Culturally and Linguistically Diverse (CALD) backgrounds, particularly new migrants, when participating in ParentsNext. People from CALD backgrounds account for approximately 19 per cent of total participants in ParentsNext.83
2.69
Evidence received by the committee has shown that ParentsNext, particularly during its trial phase, has had positive outcomes in connecting CALD participants with important services to assist them in finding work in Australia, such as English language programs, exposure to the Australian labour force and helping them to have overseas qualifications recognised.84
2.70
However, the Federation of Ethnic Communities' Councils of Australia (FECCA) contended that these positive aspects are at risk because of the high burden of the reporting system on participants,85 as has been the experience of providers working with CALD parents in the program since the national expansion.86
2.71
Advocates explained that it can be hard for people with limited English language skills to understand what ParentsNext is and what their requirements are, and that any communications issues experienced by other participants in the program are likely to be exacerbated for people whose first language isn't English.87 The focus on self-reporting through digital technology is also a challenge for CALD people who may have limited digital literacy, or limited access to computers, phones and internet.88 FECCA submitted that the availability of translation services to address these issues is 'currently unclear and must be communicated with the participants of the program'.89
2.72
While the committee did receive evidence of some providers proactively considering the language needs of their clients, such as the Brotherhood of St Laurence employing bilingual staff to improve communication and engagement with participants, it appears that there is no funding for providers to provide translated participation plans and the TCF requires reporting to be completed in English.90

Domestic and Family Violence

2.73
With the overrepresentation of women from vulnerable backgrounds in ParentsNext comes an increased likelihood that participants have experienced domestic and family violence. According to the Australian Institute of Health and Welfare:
Some groups of people are at greater risk of family, domestic and sexual violence, particularly Indigenous women, young women, pregnant women, women separating from their partners, women with disability and women experiencing financial hardship.91
2.74
It is unclear how many people referred to ParentsNext may have experienced domestic and family violence, as participants are not required to disclose this information. However, the Department of Jobs and Small Business reported that in the first six months of the national ParentsNext program, 1805 participants (approximately 2 per cent of all participants) indicated to Centrelink or to their provider that they have experienced or are experiencing domestic violence. In total, 621 participants were temporarily exempted from the program for domestic violence or relationship breakdown, representing 4 per cent of all exemptions.92
2.75
Evidence received by the committee suggests that the number of participants who have experienced domestic and family violence is far higher than that recorded by the Department of Jobs and Small Business. The NCSMC/CSMC Survey identified that 48 per cent of respondents were affected by violence,93 while some providers had reported that up to 80 per cent of their participants were in such situations.94
2.76
Submitters have told the committee that they are seriously concerned that many ParentsNext providers do not have the specialised training or experience to work with this cohort.95 The Australian Unemployed Workers Union summarised that:
Private ParentsNext providers are not social workers or violence counsellors; they are not equipped to deal with the incredibly complex issues surrounding family violence. ParentsNext providers are not appropriately placed or trained to engage with women fleeing violence, and compliance activities can create more danger for participants and their families.96
2.77
The committee heard that the way ParentsNext is conducted by providers who do not have proper training and experience in this area can be re-traumatising or potentially dangerous for participants who have experienced or are currently experiencing domestic and family violence.97 In particular, the committee heard several reports that providers have required participants to retell their experience to multiple officers, often in front of their children, in order to receive exemption, which is not necessarily granted.98
2.78
The committee notes that while some ParentsNext providers, particularly those already working in social services and domestic and family violence support spaces, do have the expertise and experience to service this cohort,99 there are still inherent structural issues within the program which may have negative impacts on parents who have experienced violence. The committee heard:
domestic and family violence can be a barrier to meeting compliance requirements under the program, which may increase the likelihood of payments being suspended;100
reporting compliance with activities in order to receive Parenting Payment may feel similar to controlling and coercive behaviour, such as economic abuse, that participants have experienced from ex-partners;101
experiencing financial sanctions may make escaping violent situations more difficult for participants;102 and
concerns about privacy, including that ex-partners may be able to track a participant's whereabouts based on their requirement to be at certain places at certain times to meet their participation plan.103
2.79
Many have also submitted that ParentsNext is not addressing how domestic and family violence can be a structural barrier to education, training and workforce participation.104 Structural barriers to workforce participation are discussed in further detail below.
2.80
The committee notes evidence received that some parents experiencing domestic and family violence may find benefits from ParentsNext,105 including providers reporting that they have been able to link parents who have disclosed domestic violence (including those with exemptions) into specialist support programs.106 Some providers have argued that ParentsNext may even offer an opportunity to assist participants out of domestic violence situations.107
2.81
Submitters and witnesses have recommended that the design and aims of ParentsNext be revisited to have greater sensitivity for the complexity of domestic and family violence experienced by recipients of Parenting Payment and how this may impact their work-readiness and their ability to participate in pre-employment activities.108

Committee view

2.82
The committee has serious concerns about the human rights implications of ParentsNext due to its compliance mechanism and its discrimination against some of the most vulnerable people in our community.
2.83
The committee considers that placing overly onerous limitations on the rights to social security and an adequate standard of living for parents and their young children is unacceptable. No parent should need to live in fear of being unable to feed their baby because of potential compliance actions against them.
2.84
The committee notes the overwhelming recommendation from witnesses and submitters that the Targeted Compliance Framework should be removed from ParentsNext, thereby removing these limitations on human rights.
2.85
The committee also has serious concerns about the high number of participants who are experiencing or have experienced domestic and family violence that have been referred to ParentsNext despite their eligibility for exemption from the program. The committee received substantial evidence that the program is re-traumatising for victims and that most providers have little to no expertise in meeting the needs of these vulnerable parents. The committee notes that several providers have presented stories about how ParentsNext has assisted people in domestic and family situations.
2.86
No matter the vulnerable group in question, the clear message received by the committee was that many ParentsNext providers do not have the kind of specialist knowledge and training to provide services which are safe and supportive for these people. Rather than helping parents, untrained providers risk harming parents and further entrenching their disadvantage.

The efficacy of ParentsNext as a pre-employment program

ParentsNext is neither an employment agency, training centre, nor a parenting program, despite claiming to facilitate all three.109
2.87
The committee has received evidence from witnesses and submitters that there is broad support for pre-employment programs which support and assist parents in achieving their educational and employment goals as a pathway to long-term economic security.110 Mission Australia submitted that:
Effective pre-employment skills development strategies and programs are critical in preparing individuals with relevant labour market skills and competencies. Pre-employment programs can incorporate networking, education, work placements and career planning in supporting individuals to build confidence, relevant employment networks and qualifications for future employment.111
2.88
However, many submitters have contended that the pre-employment goals of ParentsNext have been confused and overshadowed by the program's measurement of success through employment outcomes and use of parenting-focused activities in compulsory participation plans.112
2.89
Furthermore, witnesses and submitters highlighted that ParentsNext is failing to address the structural barriers to employment which affect parents, particularly single mothers and people from vulnerable populations, who receive income support.113

A program with a confused focus

2.90
The Department of Jobs and Small Business submitted that, as a pre-employment program:
ParentsNext was designed and implemented with a focus on meeting the needs of parents. It is flexible, recognises parents' caring responsibilities, does not require them to look for work, and incorporates family friendly sites and activities.114
2.91
The activities included in a participation plan for ParentsNext are intended to 'help parents overcome barriers to gaining employment, build work readiness115 and meet their goals'.116 ParentsNext providers are required to ensure that participants undertake activities which 'help [them] achieve their education and employment goals' and 'take into account their individual and family circumstances'.117
2.92
The Department of Jobs and Small Business reported that the most common activities included in ParentsNext participation plans are:
non-vocational assistance, such as career counselling, interpersonal skills development, parenting courses and personal development (a total of 7004 placements);
child playgroup (6729 placements);
accredited education and training (6017 placements); and
non-accredited education and training (3618 placements).118
2.93
Evidence received by the committee showed that many parents are confused about how the assistance offered by ParentsNext will help them to overcome the barriers to employment and are dissatisfied with the quality and appropriateness of the activities included in their plan. Many reported that they feel forced to undertake activities which do not meet their pre-employment objectives or their personal needs.119 This section addresses these concerns.

Is ParentsNext an employment or pre-employment program?

2.94
Although ParentsNext is not an employment program and therefore does not require parents to look for work, the committee received evidence from participants and providers alike that this message has not been clearly articulated by the Department of Jobs and Small Business, Centrelink and some ParentsNext providers. The National Employment Services Association submitted that:
…many participants report they were advised [by Centrelink] ParentsNext was an employment program, rather than pre-employment preparation resulting in their assumption they needed to find a job.120
2.95
Settlement Services International, a ParentsNext provider involved in both the trial and the national program, also described how:
Our experience shows that the changes in the move to the national rollout shift ParentsNext away from its original focus as a pre-employment program designed to support disadvantaged parents of young children, mostly women, to engage in pre-employment activities and make social ties in their local communities. We see it as having created an implied expectation of an employment outcome as the primary valued outcome rather than the pre-employment and social connection focus.121
2.96
The committee received comments from several participants who felt that they were being forced by their providers to look for work, or to work towards returning to full-time work even if that did not suit their personal situation.122 The Human Rights Law Centre provided the following case study of one parent referred to the program (emphasis added):
She had to attend an appointment and was told that she had to start looking for work again because her baby is more than 6 months old. She was told that she should keep looking for work up until 6 weeks before the due date for her second pregnancy.123
2.97
The way ParentsNext has been designed and implemented may be exacerbating this perception. Witnesses and submitters pointed to several aspects of the ParentsNext program as evidence that the program has placed employment, rather than pre-employment, at its focus:
The ParentsNext trial evaluation report includes a comment that 'given the study period, it was probably too soon to expect participants would have moved off income support'. This has been interpreted by advocates that participants are expected to move off income support and into employment while engaged in ParentsNext.124
ParentsNext offers financial incentives in the Intensive Stream for employment outcomes, including wage subsidies to increase employment prospects for parents who choose to return to work and outcome payments to providers who help parents find and retain a job.125
Co-location with jobactive, an employment program that requires compulsory job search, attendance and compliance activities, has led to some employment service providers operating ParentsNext in a similar fashion rather than focusing on pre-employment.126
The use of the WorkStar work readiness assessment tool, described by one provider as 'very employment focused' and creating 'the impression to the Participant that the program is about finding work'.127
The use of the TCF, which was designed for jobactive and other employment programs and is accessed through the jobactive mobile app and website, also creates an impression that ParentsNext is an employment program.128
The only exit criteria for ParentsNext compulsory participants, other than no longer being eligible, is achieving stable employment of 15 hours per week or 30 hours per fortnight for at least 12 weeks, which a provider expects to be ongoing.129
2.98
There is no way to exit people from ParentsNext if they are assessed by their provider as not needing pre-employment assistance. These parents may include those on parental leave who are due to return to work on a set date, those who are currently employed fewer than 15 hours per week due to their caring responsibilities, or those who are highly qualified and have clear plans to re-enter the workforce when their children return to school.130 A representative from the Personnel Group, a ParentsNext provider based in Canberra and the surrounding regions, told the committee that nearly one third of referred participants to their centres did not need pre-employment assistance:
Something we certainly know is that, being in Canberra, we've got participants who are starting a PhD who are on a parenting payment while they're raising their children. We look at some of them and go, 'Well, you're more qualified to help yourself than we ever could be.' … [A third of participants] are well on their way themselves and don't need our support.131
2.99
The Department of Jobs and Small Business explained to the committee that:
Having qualifications and searching for work are not grounds for an exemption. However, if a participant wants to search for work and does not need additional support from their provider to improve their work readiness or find employment, they can have their job search counted as their ParentsNext activity.132
2.100
The committee is of the view that mandating job search as an activity further contradicts the pre-employment focus of the program.
2.101
Submitters and witnesses have also raised concerns that ParentsNext appears to push parents into insecure, low-paying work rather than developing their ability to secure longer term employment.133 Uniting Vic.Tas submitted that, due to the need for flexibility in working hours to accommodate caring responsibilities, 'many participants are forced to accept casual jobs lacking security, adequate pay, or a long-term career pathway'.134
2.102
The joint submission from the Human Rights Law Centre, SNAICC and the National Family Violence Prevention Legal Services pointed to evidence from the United Kingdom that welfare conditionality was more likely to result in 'recurrent movements between one short-term, low-paid, insecure job to another' rather than facilitating the long-term workforce participation that is the aim of ParentsNext.135

Is it a parenting program?

2.103
In contrast to evidence which contends that ParentsNext has an employment focus, advocates have also submitted that ParentsNext, whether intended or not, appears to have developed a focus on improving parenting skills, which have no bearing on labour market outcomes or work readiness.136 The National Social Security Rights Network observed that:
If ParentsNext is intended to be a pre-employment program, participation plans should only contain activities related to enhancing employment prospects.137
2.104
As noted in Chapter 1, parents participating in the program have reported that providers have required them to attend activities, such as swimming lessons, playgroup or library sessions. Many of these parents were already undertaking these kinds of activities with their children and did not feel that this would help them to become work ready.138
2.105
While the Department of Jobs and Small Business explained in its submission that activities such as playgroup 'can help parents who have experienced social isolation to build core soft skills, such as communication, socialisation and self-confidence',139 the Brotherhood of St Laurence submitted that, for families that do not require targeted family or parenting supports, making these activities compulsory is intrusive and has left parents feeling 'unduly controlled, monitored and degraded' in their parenting.140
2.106
Submitters have proposed that, for parents who do request assistance with their parenting, or who require support with socialisation and self-confidence, these activities should not be included as compulsory pre-employment activities but rather those parents should be referred to existing social services programs which address those needs, such as the Home Interaction Program for Parents and Youngsters (HIPPY) funded by the Department of Social Services.141

Is it an education and training program?

2.107
As noted above, accredited and non-accredited education and training account for a significant number of activities included in ParentsNext participation plans.
2.108
As discussed in Chapter 1, many parents were already undertaking education and training activities before they were referred to ParentsNext and have not found any benefit to the program.142 The National Council of Single Mothers and their Children told the committee that ParentsNext represented a major change in the way parents undertaking education receive social security:
Before July 2018, if you were in receipt of the pension education supplement you didn't even have to connect with ParentsNext providers. Now, not only do you have to connect with them but also you have to respond to the reporting as determined by them.143
2.109
Furthermore, despite the objective of ParentsNext to help 'parents identify and reach their education and employment goals', advocates and providers have noted that there is no financial support available to assist parents in the Targeted Stream who undertake education and training activities as part of their participation plan, such as assistance with course fees or childcare costs.144
2.110
For those in the Intensive Stream, many participants reported that they were not aware that any financial assistance was available to them and what financial assistance is available appears to be insufficient to meet their educational or training needs.145 In the words of Ms Davidson from the Council of Single Mothers and their Children (Victoria): 'There is not even enough money for TAFE courses, let alone a Bachelor of Arts'.146
2.111
The lack of an across-the-board participation fund has been considered by a number of witnesses and submitters as ones of the major failings in the ParentsNext program, as is fails to recognise that any parent assessed as eligible for the program is unlikely to have the additional resources to fund their own compulsory pre-employment activities.147 Jobs Australia told the committee:
…there needs to be more equitable availability of funding so that, for participants in all the streams of the program, there can be better investment in skills and training so that they can be looking further ahead into their careers and developing a long-term pathway into a sustainable career when they're ready to enter the labour force and employment.148
2.112
The lack of financial resources for education and training is only one of many barriers faced by parents seeking to re-enter the workforce after caring for young children.

Addressing the structural barriers to employment

2.113
An ongoing theme in evidence received by the committee was the concern that ParentsNext, in focusing on the completion of discrete tasks by individuals to meet 'mutual obligations' under a compliance model, is failing to address the systemic, structural barriers which face this cohort in entering, or re-entering, the workforce after the birth of a child.149 The Centre for Excellence in Child and Family Welfare submitted that:
The design of ParentsNext assumes that individual behaviour is the source of a family's often complex problems, ignoring structural barriers such as family breakdown and the child support system, and more urgent systemic concerns such as child poverty and homelessness.150
2.114
Some of the key structural barriers raised by submitters and witnesses include:
the significant, unpaid work required to care for very young children, particularly for single parents who do not have additional support from a partner;151
situations such as intergenerational trauma, domestic and family violence (both current and past), relationship breakdowns, child custody negotiations, homelessness or unstable accommodation;152
cultural and language barriers, and racial discrimination;153
the costs of undertaking training, education or employment, such as fees, child care and transport;154
lack of affordable child care;155
lack of suitable, flexible and stable employment for people with caring responsibilities;156 and
discrimination against parents, particularly single mothers, in the workplace.157
2.115
Submitters and witnesses have recommended that, rather than punishing parents who are unable to engage in employment, ParentsNext should be refocused to acknowledge and address these structural barriers.158 For example, the Brotherhood of St Laurence submitted that the program should be considered:
…as part of a broader National Employment Strategy to align efforts and resources to address structural barriers to economic participation of mothers with young children including access to early learning and care; employment practices; parental leave policies and tax.159
2.116
The committee was also presented with a number of recommendations on how ParentsNext could be redesigned or refocused to address these barriers, meet the individual needs of parents, and have a better focus on positive, long-term outcomes:
Compulsory reporting using the TCF should be removed, allowing parents to engage with the program in a flexible way which meets their pre-employment goals and the needs of their family.160
Engagement with the program should be voluntary. Parents who have complex barriers to their participation or who do not require pre-employment support should not be forced to participate in a program which does not meet their needs.161
The program's participation planning and goal-setting should respect the decisions of parents to provide full-time care for their young children and note that taking time out of the workforce does not mean that parents are incapable of planning for their future or making pre-employment decisions that suit the needs of their family.162
The program should be person-centred and participation plans should meet the needs of the individual, only including activities which are genuinely supportive of their pre-employment goals; plans should only contain activities related to parenting if requested by the participant.163
Adjustments to the participation fund and other incentive funding should be considered, such as:
providing greater assistance for the out-of-pocket costs of participating in ParentsNext;164
removing the funding distinction between the two streams altogether, as disadvantage is not restricted by postcode and some participants in the Targeted Stream may require as much assistance as those in Intensive Stream areas;165 and
making incentive funding available directly to participants, rather than to providers.166
There should be better linkages between ParentsNext and existing, specialist programs and services which meet the varied, complex needs of participants.167
ParentsNext could be replaced with a voluntary pre-employment program not only for parents but also for other highly disadvantaged groups receiving social security and in need of pre-employment training and assistance, such as carers, people with disability, or older workers.168
2.117
The committee has considered these recommendations, among others, in Chapter 4 of this report.

Committee view

2.118
ParentsNext, despite its pre-employment aims, is a program with a confused set of goals. It appears to be dually focussed on parenting skills and employment outcomes, and what little support there is for education and training is insufficient and inappropriate for those parents who wish to access it.
2.119
The committee is of the view that ParentsNext is not an appropriate setting in which to mandate parenting-related activities, as the methods by which parents raise their children have no direct bearing on work-readiness. The social activities which a parent undertakes with their children should not be used as a measure of that parent's work readiness and should not be subject to punitive compliance requirements.
2.120
Receiving social security in the form of Parenting Payment should not call into question the quality of a recipient's parenting. ParentsNext providers and the Australian Government need to trust that parents know what is best for their children. The committee notes that there are established programs and pathways for social service intervention where there is evidence that a parent needs help with their parenting.
2.121
The committee strongly considers that, if ParentsNext is designed to be a pre-employment program, its activities and incentives should not be geared solely towards employment outcomes. The committee holds serious concerns about the number of aspects of the program, intended or not, which suggest to participants and providers that ParentsNext is about seeking employment.
2.122
The committee also questions why parents who are engaged in education or training or have clear plans to return to the workforce and who are not in need of additional support are required to participate in ParentsNext.
2.123
The committee considers that any pre-employment program for parents should be flexible and meet the education, training and pre-employment needs of the individual parent, while being respectful and considerate of the complexities and responsibilities that come with caring for young children.
2.124
The committee is especially worried about how the implementation of ParentsNext by the Department of Jobs and Small Business, the Department of Human Services and contracted service providers has exacerbated some of the more problematic aspects of the program's designs and aims. These issues are discussed in next chapter.

  • 1
    Name withheld, Submission 45, [p. 3].
  • 2
    See, for example: Australian Human Rights Commission, Submission 16; Human Rights Law Centre, SNAICC – National Voice for our Children and National Family Violence Prevention Legal Services (HLRC/SNAICC/NFVPLS), Submission 29.1; National Council of Single Mothers and their Children, Submission 20; Good Shepherd Australia New Zealand, Submission 15.
  • 3
    Department of Employment, Answer to Question on Notice EMSQ17-004079, 29 May 2017, Senate Education and Employment Budget Estimates 2017–18; Department of Employment, Helping Young Parents and Supporting Jobless Families Research Report, 2015, p. 2.
  • 4
    Department of Employment, Helping Young Parents and Supporting Jobless Families Research Report, 2015, pp. 3–4.
  • 5
    Department of Employment, Helping Young Parents and Supporting Jobless Families Research Report, 2015, pp. 3–4.
  • 6
    Department of Employment, Helping Young Parents and Supporting Jobless Families Research Report, 2015.
  • 7
    Department of Employment, Grant Guidelines for ParentsNext, January 2016, p. 2.
  • 8
    Department of Employment, Grant Guidelines for ParentsNext, January 2016, p. 2.
  • 9
    Department of Employment, Helping Young Parents and Supporting Jobless Families Research Report, 2015, p. 3.
  • 10
    Department of Jobs and Small Business, ParentsNext Evaluation Report, 2018, pp. 9, 11, 22.
  • 11
    Department of Jobs and Small Business, ParentsNext Evaluation Report, 2018, p. 22.
  • 12
    Department of Jobs and Small Business, ParentsNext Evaluation Report, 2018, pp. 12–13.
  • 13
    Department of Jobs and Small Business, ParentsNext Evaluation Report, 2018.
  • 14
    See, for example: Ms Stella Avramopoulos, Chief Executive Officer, Good Shepherd Australia New Zealand, Committee Hansard, 27 February 2019, p. 4; Dr Sarah Squire, Head of Women's Research, Advocacy and Policy Centre, Good Shepherd Australia New Zealand, Committee Hansard, 27 February 2019, p. 9; Centre for Excellence in Child and Family Welfare, Submission 23, p. 6.
  • 15
    See, for example: Australian Human Rights Commission, Submission 16, p. 5; Centre for Excellence in Child and Family Welfare, Submission 23, p. 6; Jobs Australia, Submission 35, p. 8; Dr Squire, Good Shepherd Australia New Zealand, Committee Hansard, 27 February 2019, p. 9.
  • 16
    Emeritus Professor Rosalind Croucher, AM, President, Australian Human Rights Commission, Committee Hansard, 27 February 2019, p. 21.
  • 17
    See, for example: Australian Human Rights Commission, Submission 16, p. 5.
  • 18
    Department of Employment, Discussion Paper for ParentsNext National Expansion, 2017. See also: Department of Jobs and Small Business, answers to written questions on notice (received 26 March 2019).
  • 19
    Northern Territory Government, Submission 27, p. 3.
  • 20
    HLRC/SNAICC/NFVPLS, Submission 29.1, p. 9; Uniting Communities, Submission 57, p. 4; FamilyCare, Submission 65, p. 2; Women's Legal Service NSW, Submission 66, p. 3.
  • 21
    Council of Single Mothers and their Children, Submission 25, p. 9.
  • 22
    Mr Nathan Smyth, Deputy Secretary, Employment, Department of Jobs and Small Business, Committee Hansard, 27 February 2019, p. 58.
  • 23
    HLRC/SNAICC/NFVPLS, Submission 29.1, pp. 14–15.
  • 24
    Ms Antoinette Braybrook, National Convenor, National Family Violence Prevention Legal Services Forum; Ms Adrienne Walters, Senior Lawyer, Human Rights Law Centre; Professor Croucher, Australian Human Rights Commission; and Associate Professor Beth Goldblatt, Private capacity, Committee Hansard, 27 February 2019, pp. 24–25.
  • 25
    Ms Kelly Bowey, Senior Policy and Research Officer, Centre for Excellence in Child and Family Welfare, Committee Hansard, 27 February 2019, p. 10. See also: Centre for Excellence in Child and Family Welfare, Submission 23, p. 6; Settlement Services International, Submission 31, pp. 4, 6; FamilyCare, Submission 65, pp. 5–6.
  • 26
    Ms Avramopoulos, Good Shepherd Australia New Zealand, Committee Hansard, 27 February 2019, p. 4. See also: Mission Australia, Submission 60, p. 11.
  • 27
    Ms Karen Bevan, General Manager, Service Delivery, Community, Settlement Services International, Committee Hansard, 27 February 2019, p. 47.
  • 28
    Department of Jobs and Small Business, Submission 67, pp. 2–3.
  • 29
    See, for example: Australian Human Rights Commission, Submission 16; HLRC/SNAICC/NFVPLS, Submission 29.1; National Council of Single Mothers and their Children, Submission 20; Good Shepherd Australia New Zealand, Submission 15.
  • 30
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, p. 8.
  • 31
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, p. 8.
  • 32
    International Covenant on Economic, Social and Cultural Rights, 16 December 1966, entry into force 3 January 1976, Part 1, Article 9.
  • 33
    Australian Human Rights Commission, Submission 16, p. 12.
  • 34
    International Covenant on Economic, Social and Cultural Rights, 16 December 1966, entry into force 3 January 1976, Part 1, Article 11.
  • 35
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, p. 8.
  • 36
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, pp. 9–10.
  • 37
    See, for example: Australian Human Rights Commission, Submission 16; Associate Professor Beth Goldblatt, Submission 3, p. 2; Playgroup Australia, Submission 13, [p. 6]; Jobs Australia, Submission 35, pp. 9–10; Equality Rights Alliance, Submission 36, [p. 3]; Accountable Income Management Network, Submission 37, [p. 10]; Brotherhood of St Laurence, Submission 63, pp. 13–14.
  • 38
    Women's Legal Service NSW, Submission 66, p. 3; Associate Professor Beth Goldblatt, Submission 3, p. 3.
  • 39
    Australian Human Rights Commission, Submission 16, p. 3.
  • 40
    See, for example: HLRC/SNAICC/NFVPLS, Submission 29.1, p. 9; Women's Legal Service NSW, Submission 66, p. 3; Associate Professor Beth Goldblatt, Submission 3, pp. 2–3; Ms Jenny Davidson, Chief Executive Officer, Council of Single Mothers and their Children, Committee Hansard, 27 February 2019, p. 3; National Council of Single Mothers and their Children, Submission 20, p. 15.
  • 41
    Ms Bowey, Centre for Excellence in Child and Family Welfare, Committee Hansard, 27 February 2019, p. 3.
  • 42
    HLRC/SNAICC/NFVPLS, Submission 29.1, pp. 9–10; Associate Professor Beth Goldblatt, Submission 3, pp. 2–3; Good Shepherd Australia New Zealand, Submission 15, p. 29.
  • 43
    Good Shepherd Australia New Zealand, Submission 15, p. 29.
  • 44
    Centrelink and Other Info Facebook Group, Submission 54, [p. 3].
  • 45
    See, for example: Brotherhood of St Laurence, Submission 63, p. 5; Australian Unemployed Workers Union, Submission 70, p. 6; YFS Ltd, Submission 5, [p. 3]; National Social Security Rights Network, Submission 14, p. 2; Good Shepherd Australia New Zealand, Submission 15, pp. 6–7; Australian Human Rights Commission, Submission 16, p. 4; National Council of Single Mothers and their Children, Submission 20, p. 3; CatholicCare Sandhurst, Submission 24, [p. 3]; Council of Single Mothers and their Children, Submission 25, p. 4; HLRC/SNAICC/NFVPLS, Submission 29, p. 6; Settlement Services International, Submission 31, p. 1; Anglicare Australia, Submission 33, p. 5; Jobs Australia, Submission 35, p. 4; Australian Council of Social Service, Submission 38, p. 4; Volunteering Australia, Submission 39, p. 2; Ms Ella Buckland, Submission 52, p. 2; Goodstart Early Learning, Submission 58, [p. 3]; Mission Australia, Submission 60, p. 2.
  • 46
    See, for example: YFS Ltd, Submission 5, [pp. 1–2]; Uniting Vic.Tas, Submission 8, [p. 2]; Wesley Mission, Submission 12, [p. 5]; Playgroup Australia, Submission 13, [p. 6]; Centre for Excellence in Child and Family Welfare, Submission 23, p. 8; CatholicCare Sandhurst, Submission 24, [p. 3]; Settlement Services International, Submission 31, p. 1; Uniting Communities, Submission 57, p. 5.
  • 47
    Ms Bowey, Centre for Excellence in Child and Family Welfare, Committee Hansard, 27 February 2019, p. 3.
  • 48
    International Covenant on Economic, Social and Cultural Rights, 16 December 1966, entry into force 3 January 1976, Part 1, Article 2.
  • 49
    See: Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, p. 8; Australian Human Rights Commission, Submission 16, p. 30.
  • 50
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, p. 12.
  • 51
    Department of Jobs and Small Business, answers to questions on notice, 27 February 2019 (received 8 March 2019).
  • 52
    Mr Smyth, Department of Jobs and Small Business, Committee Hansard, 27 February 2019, p. 57.
  • 53
    Mr Smyth, Department of Jobs and Small Business, Committee Hansard, 27 February 2019, p. 57.
  • 54
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, pp. 11–12. See also: Australian Human Rights Commission, Quick Guide: Indirect Discrimination, https://www.humanrights.gov.au/quick-guide/12049 (accessed 15 March 2019).
  • 55
    National Council of Single Mothers and their Children, Submission 20, p. 16; Associate Professor Beth Goldblatt, Submission 3, p. 3; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 10.
  • 56
    Associate Professor Beth Goldblatt, Submission 3, p. 3.
  • 57
    See, for example: Australian Human Rights Commission, Submission 16; HLRC/SNAICC/NFVPLS, Submission 29.1; National Council of Single Mothers and their Children, Submission 20.
  • 58
    See, for example: Equality Rights Alliance, Submission 36; Associate Professor Beth Goldblatt, Submission 3; Australian Unemployed Workers Union, Submission 70; National Social Security Rights Network, Submission 14; Good Shepherd Australia New Zealand, Submission 15; National Council of Single Mothers and their Children, Submission 20.
  • 59
    National Social Security Rights Network, Submission 14, p. 3. See also: Good Shepherd Australia New Zealand, Submission 15, p. 9.
  • 60
    Good Shepherd Australia New Zealand, Submission 15, p. 10.
  • 61
    Department of Jobs and Small Business, answers to questions on notice, 27 February 2019 (received 8 March 2019).
  • 62
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, p. 13.
  • 63
    Social Security (Parenting payment participation requirements – classes of persons) Instrument 2018, Attachment A: Statement of Compatibility with Human Rights, p. 13.
  • 64
    Australian Human Rights Commission, Submission 16, pp. 32–33.
  • 65
    Australian Human Rights Commission, Submission 16, p. 34; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 9.
  • 66
    Good Shepherd Australia New Zealand, Submission 15, p. 18; Domestic Violence Victoria, Submission 21, [p. 2]; Jobs Australia, Submission 35, p. 8; Accountable Income Management Network, Submission 37, p. 8. See also, Northern Territory Government, Submission 27; Kimberley Community Legal Services, Submission 72.
  • 67
    See, for example: Kimberley Community Legal Services, Submission 72; CatholicCare Sandhurst, Submission 24; Jobs Australia, Submission 35.
  • 68
    Good Shepherd Australia New Zealand, Submission 15, p. 25.
  • 69
    Wesley Mission, Submission 12, [p. 7]; Uniting SA, Submission 18, p. 8; CatholicCare Sandhurst, Submission 24, [pp. 1–2]; National Employment Services Association, Submission 30, p. 10.
  • 70
    Benevolent Society, Submission 19, p. 3; Ms Antoinette Braybrook, National Family Violence Prevention Legal Services Forum, Committee Hansard, 27 February 2019, p. 22; HLRC/SNAICC/NFVPLS, Submission 29.1, pp. 14–15.
  • 71
    National Council of Single Mothers and their Children and Council of Single Mothers and their Children (Victoria) (NCSMC/CSMC), ParentsNext Survey, January 2019, p. 9.
  • 72
    Kimberley Community Legal Services, Submission 72, pp. 9–14; Good Shepherd Australia New Zealand, Submission 15, p. 7; Australian Human Rights Commission, Submission 16, p. 5; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 6; Accountable Income Management Network, Submission 37, [p.12]; Australian Council of Social Service, Submission 38, p. 5; Mission Australia, Submission 60, p. 13.
  • 73
    See, for example: Ms Joanna Leece, Executive Officer, Kildonan and Lentara Cluster, Uniting (Victoria & Tasmania), Committee Hansard, 27 February 2019, p. 51.
  • 74
    Department of Jobs and Small Business, answers to questions on notice, 27 February 2019 (received 8 March 2019).
  • 75
    See, for example: Centrelink and Other Info Facebook Group, Submission 54, [pp. 6, 8]; Name withheld, Submission 45, [p. 2].
  • 76
    Centrelink and Other Info Facebook Group, Submission 54, [p. 8].
  • 77
    NCSMC/CSMC, ParentsNext Survey, January 2019, pp. 8–9. In: National Council of Single Mothers and their Children, Submission 20.
  • 78
    National Social Security Rights Network, Submission 14, p. 6.
  • 79
    National Employment Services Association, Submission 30, p. 4; Mission Australia, Submission 60, p. 5; Joblink Plus, Submission 53, p. 3.
  • 80
    National Employment Services Association, Submission 30, p. 4.
  • 81
    Accountable Income Management Network, Submission 37, [p. 8].
  • 82
    Council of Single Mothers and their Children, Submission 25, p. 5.
  • 83
    Department of Jobs and Small Business, answers to questions on notice, 27 February 2019 (received 8 March 2019).
  • 84
    See, for example: Ms Bevan, Settlement Services International, Committee Hansard, 27 February 2019, p. 51; Federation of Ethnic Communities' Councils of Australia, Submission 59, p. 2.
  • 85
    Federation of Ethnic Communities' Councils of Australia, Submission 59, p. 2.
  • 86
    Ms Bevan, Settlement Services International, Committee Hansard, 27 February 2019, p. 47.
  • 87
    Settlement Services International, Submission 31, p. 7; Jobs Australia, Submission 35, p. 7; Uniting Vic.Tas, Submission 8, [p. 1]; Volunteering Australia, Submission 39, p. 1; Federation of Ethnic Communities' Councils of Australia, Submission 59, p. 2; Anglicare Australia, Submission 33, p. 4.
  • 88
    Volunteering Australia, Submission 39, p. 1; Federation of Ethnic Communities' Councils of Australia, Submission 59, p. 2; Anglicare Australia, Submission 33, p. 4; Mission Australia, Submission 60, p. 15.
  • 89
    Federation of Ethnic Communities' Councils of Australia, Submission 59, p. 2.
  • 90
    Uniting SA, Submission 18, p. 9; Brotherhood of St Laurence, Submission 63, p. 14.
  • 91
    Australian Institute of Health and Welfare, Family, domestic and sexual violence in Australia, 2018, 28 February 2018, https://www.aihw.gov.au/reports/domestic-violence/family-domestic-sexual-violence-in-australia-2018/contents/summary (accessed 12 March 2019).
  • 92
    Department of Jobs and Small Business, answers to questions on notice, 27 February 2019 (received 13 March 2019). Discretion to grant exemptions under the program, such as exemptions for domestic violence or relationship breakdown, is discussed in Chapter 3.
  • 93
    NCSMC/CSMC, ParentsNext Survey, January 2019, p. 9.
  • 94
    National Employment Services Association, Submission 30, p. 9. See also: Joblink Plus, Submission 53, p. 4.
  • 95
    Good Shepherd Australia New Zealand, Submission 15, p. 24; National Council of Single Mothers and their Children, Submission 20, p. 12.
  • 96
    Australian Unemployed Workers Union, Submission 70, p. 4.
  • 97
    Good Shepherd Australia New Zealand, Submission 15, p. 26; The Hive Mount Druitt, Submission 34, p. 7; Ms Ella Buckland, Submission 52, p. 2.
  • 98
    Australian Unemployed Workers Union, Submission 70, p. 4; Good Shepherd Australia New Zealand, Submission 15, p. 24; Australian Council of Social Service, Submission 38, p. 2; Australian Motherhood Initiative for Research and Community Involvement, Submission 68, p. 1.
  • 99
    Wesley Mission, Submission 12, [pp. 6–7]; National Employment Services Association, Submission 30, pp. 10–11; Ms Laura Clarke, Advocacy and Policy Lead, yourtown, Committee Hansard, 27 February 2019, pp. 50–51.
  • 100
    Australian Unemployed Workers Union, Submission 70, p. 13; Uniting Vic.Tas, Submission 8, [p. 1]; National Social Security Rights Network, Submission 14, p. 8; Good Shepherd Australia New Zealand, Submission 15, p. 25; Domestic Violence Victoria, Submission 21, [pp. 3–4]; Anglicare Australia, Submission 33, p. 4; Jobs Australia, Submission 35, pp. 5–6; Equality Rights Alliance, Submission 36, [p. 5]; Australian Council of Social Service, Submission 38, p. 2; Brotherhood of St Laurence, Submission 63, p. 10.
  • 101
    Good Shepherd Australia New Zealand, Submission 15, p. 24; Council of Single Mothers and their Children, Submission 25, p. 10; Feminist Legal Clinic Inc, Submission 6, p. 2. See also: Centre for Excellence in Child and Family Welfare, Submission 23, p. 5.
  • 102
    HLRC/SNAICC/NFVPLS, Submission 29.1, p. 10; Anglicare Australia, Submission 33, p. 4.
  • 103
    Australian Unemployed Workers Union, Submission 70, p. 13; Good Shepherd Australia New Zealand, Submission 15, p. 30.
  • 104
    Australian Unemployed Workers Union, Submission 70, p. 10; Australian Human Rights Commission, Submission 16, p. 21; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 10.
  • 105
    Uniting SA, Submission 18, p. ??; Domestic Violence Victoria, Submission 21, [p. 5]; Federation of Ethnic Communities' Councils of Australia, Submission 59, p. 2; Ms Chelsea Fraser, ParentsNext Coordinator, The Personnel Group, Committee Hansard, 27 February 2019, p. 49.
  • 106
    Wesley Mission, Submission 12, [p. 7]; National Employment Services Association, Submission 30, p. 10. The Department of Jobs and Small Business reported that only 39 participants were referred to activities conducted by specialist services for or relating to family violence in the first six months of the program; Department of Jobs and Small Business, answers to questions on notice,
    27 February 2019 (received 13 March 2019).
  • 107
    National Employment Services Association, Submission 30, p. 11.
  • 108
    See, for example: Jobs Australia, Submission 35, p. 7; Australian Human Rights Commission, Submission 16, p. 5; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 6.
  • 109
    Good Shepherd Australia New Zealand, Submission 15, pp. 22–23.
  • 110
    See, for example: Good Shepherd Australia New Zealand, Submission 15, p. 8; Jobs Australia, Submission 35, p. 3; National Social Security Rights Network, Submission 14, p. 3; Council of Single Mothers and their Children, Submission 25, p. 4; Settlement Services International, Submission 31, p. 1.
  • 111
    Mission Australia, Submission 60, p. 3.
  • 112
    See, for example: Good Shepherd Australia New Zealand, Submission 15, p. 8; Domestic Violence Victoria, Submission 21; [p. 5].
  • 113
    See, for example: Australian Human Rights Commission, Submission 16; Domestic Violence Victoria, Submission 21; Centre for Excellence in Child and Family Welfare, Submission 23.
  • 114
    Department of Jobs and Small Business, Submission 67, p. 2.
  • 115
    Work readiness is defined as possessing the core skills and behaviours required by employers, including team work skills; communication skills and a positive attitude and work ethic, including motivation, reliability and a willingness to work. See: Department of Jobs and Small Business, answers to questions on notice, 27 February 2019 (received 8 March 2019).
  • 116
    Department of Jobs and Small Business, Submission 67, p. 6.
  • 117
    Department of Jobs and Small Business, ParentsNext Deed 2018–2021, p. 79.
  • 118
    Department of Jobs and Small Business, Submission 67, p. 6. Although it has been reported that there are over 75 000 participants in ParentsNext, it is unclear how many participants have agreed to participation plans and have been placed in activities, and therefore what proportion of participants are represented in these figures.
  • 119
    For examples, see Chapter 1, paras. 1.44–1.49.
  • 120
    National Employment Services Association, Submission 30, p. 8. See also: Mission Australia, Submission 60, p. 6.
  • 121
    Ms Bevan, Settlement Services International, Committee Hansard, 27 February 2019, p. 47.
  • 122
    See, for example: HLRC/SNAICC/NFVPLS, Submission 29.2; Name Withheld, Submission 45; Centrelink and Other Info Facebook Group, Submission 54, [pp. 4–5 and 8].
  • 123
    HLRC/SNAICC/NFVPLS, Submission 29.2, [p. 1].
  • 124
    See, for example: Centre for Excellence in Child and Family Welfare, Submission 23, p. 2.
  • 125
    Ms Avramopoulos, Good Shepherd Australia New Zealand, Committee Hansard, 27 February 2019, p. 4; Ms Ella Buckland, Private capacity, Committee Hansard, 27 February 2019, pp. 15–16.
  • 126
    Uniting SA, Submission 18, p. 5.
  • 127
    Joblink Plus, Submission 53, p. 8.
  • 128
    Mission Australia, Submission 60, p. 11; Brotherhood of St Laurence, Submission 63, p. 3; Australian Human Rights Commission, Submission 16, p. 10; Accountable Income Management Network, Submission 37, [p. 5]. See also: YFS Ltd, Submission 5, [p. 2]; Australian Council of Social Service, Submission 38, p. 8.
  • 129
    Department of Jobs and Small Business, ParentsNext Guideline: Transfers and Exits, 25 June 2018, pp. 6–7.
  • 130
    See, for example: Ms Fraser, The Personnel Group, Committee Hansard, 27 February 2019, p. 54; NCSMC/CSMC, ParentsNext Survey, January 2019, pp. 6, 15 and 16; Centrelink and Other Info Facebook Group, Submission 54, [pp. 5 and 7].
  • 131
    Ms Fraser, The Personnel Group, Committee Hansard, 27 February 2019, p. 54.
  • 132
    Department of Jobs and Small Business, answers to questions on notice, 27 February 2019 (received 13 March 2019).
  • 133
    See, for example: HLRC/SNAICC/NFVPLS, Submission 29.1, p. 13; Women's Legal Service NSW, Submission 66, p. 5; National Social Security Rights Network, Submission 14, p. 4; Equality Rights Alliance, Submission 36, [p. 2]; Uniting Communities, Submission 57, p. 4.
  • 134
    Uniting Vic.Tas, Submission 8, [p. 2].
  • 135
    HLRC/SNAICC/NFVPLS, Submission 29.1, p. 13.
  • 136
    Good Shepherd Australia New Zealand, Submission 15, p. 4.
  • 137
    National Social Security Rights Network, Submission 14, p. 6.
  • 138
    See Chapter 1, paras. 1.45–1.46.
  • 139
    Department of Jobs and Small Business, Submission 67, p. 7.
  • 140
    Brotherhood of St Laurence, Submission 63, p. 10.
  • 141
    Good Shepherd Australia New Zealand, Submission 15, p. 20; Brotherhood of St Laurence, Submission 63, p. 2; The Hive Mount Druitt, Submission 34, p. 6; Dr Peter Davidson, Senior Advisor, Australian Council of Social Service, Committee Hansard, 27 February 2019, p. 35.
  • 142
    See Chapter 1, paras. 1.47–1.49.
  • 143
    Ms Terese Edwards, Chief Executive Officer, National Council of Single Mothers and their Children, Committee Hansard, 27 February 2019, p. 8.
  • 144
    NCSMC/CSMC, ParentsNext Survey, January 2019, p. 15. See also: Uniting SA, Submission 18, p. 3; CatholicCare Sandhurst, Submission 24, [p. 4]; Settlement Services International, Submission 31, p. 1; Mission Australia, Submission 60, p. 2; Name withheld, Submission 46, [pp. 1–2].
  • 145
    Wesley Mission, Submission 12, [p. 3]. See also: Good Shepherd Australia New Zealand, Submission 15, p. 6; Council of Single Mothers and their Children, Submission 25, p. 4.
  • 146
    Ms Davidson, Council of Single Mothers and their Children, Committee Hansard, 27 February 2019, p. 9.
  • 147
    See, for example: Mr Peter Defteros, Acting Senior Policy Manager, Jobs Australia, Committee Hansard, 27 February 2019, p. 40; Ms Annette Gill, Principal Policy Adviser, National Employment Services Association, Committee Hansard, 27 February 2019, p. 40.
  • 148
    Mr Defteros, Jobs Australia, Committee Hansard, 27 February 2019, p. 40.
  • 149
    See, for example: Ms Monique Hurley, Lawyer, Human Rights Law Centre, Committee Hansard, 27 February 2019, p. 23.
  • 150
    Centre for Excellence in Child and Family Welfare, Submission 23, p. 8. See also: National Council of Single Mothers and their Children, Submission 20, p. 15.
  • 151
    See, for example: Equality Rights Alliance, Submission 36; Associate Professor Beth Goldblatt, Submission 3; Australian Unemployed Workers Union, Submission 70; National Social Security Rights Network, Submission 14; Good Shepherd Australia New Zealand, Submission 15; National Council of Single Mothers and their Children, Submission 20; Domestic Violence Victoria, Submission 21.
  • 152
    See, for example: HLRC/SNAICC/NFVPLS, Submission 29.1, p. 12; Centre for Excellence in Child and Family Welfare, Submission 23, p. 8; Domestic Violence Victoria, Submission 21, [p. 4].
  • 153
    See, for example: HLRC/SNAICC/NFVPLS, Submission 29.1, p. 11; Women's Legal Service NSW, Submission 66, p. 3; Domestic Violence Victoria, Submission 21, [p. 4]; Federation of Ethnic Communities' Councils of Australia, Submission 59, pp. 1–2.
  • 154
    See, for example: National Social Security Rights Network, Submission 14, p. 6; Good Shepherd Australia New Zealand, Submission 15, p. 12; National Council of Single Mothers and their Children, Submission 20, p. 10; Domestic Violence Victoria, Submission 21, [p. 4].
  • 155
    See, for example: National Social Security Rights Network, Submission 14, p. 4; Centre for Excellence in Child and Family Welfare, Submission 23, p. 7.
  • 156
    See, for example: National Social Security Rights Network, Submission 14, p. 4; Domestic Violence Victoria, Submission 21, [p. 4]; Uniting Vic.Tas, Submission 7, [p. 2]; Good Shepherd Australia New Zealand, Submission 15, p. 31.
  • 157
    See, for example: Australian Human Rights Commission, Submission 16, p. 25; Domestic Violence Victoria, Submission 21, [pp. 2, 4]; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 11; Accountable Income Management Network, Submission 37, [p. 9]; National Social Security Rights Network, Submission 14, p. 4.
  • 158
    See, for example: Good Shepherd Australia New Zealand, Submission 15, p. 6; Australian Human Rights Commission, Submission 16, p. 5; The Hive Mount Druitt, Submission 34, p. 1.
  • 159
    Brotherhood of St Laurence, Submission 63, p. 6.
  • 160
    Brotherhood of St Laurence, Submission 63, p. 5; Australian Unemployed Workers Union, Submission 70, p. 6; YFS Ltd, Submission 5, [p. 3]; National Social Security Rights Network, Submission 14, p. 2; Good Shepherd Australia New Zealand, Submission 15, pp. 6–7; Australian Human Rights Commission, Submission 16, p. 4; National Council of Single Mothers and their Children, Submission 20, p. 3; CatholicCare Sandhurst, Submission 24, [p. 3]; Council of Single Mothers and their Children, Submission 25, p. 4; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 6; Settlement Services International, Submission 31, p. 1; Anglicare Australia, Submission 33, p. 5; Jobs Australia, Submission 35, p. 4; Australian Council of Social Service, Submission 38, p. 4; Volunteering Australia, Submission 39, p. 2; Ms Ella Buckland, Submission 52, p. 2; Goodstart Early Learning, Submission 58, [p. 3]; Mission Australia, Submission 60, p. 2.
  • 161
    Australian Unemployed Workers Union, Submission 70, p. 5; Associate Professor Beth Goldblatt, Submission 3, p. 1; National Social Security Rights Network, Submission 14, p. 2; Good Shepherd Australia New Zealand, Submission 15, pp. 6–7; Australian Human Rights Commission, Submission 16, p. 4; Council of Single Mothers and their Children, Submission 25, p. 4; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 6; The Hive Mount Druitt, Submission 34, p. 1; Australian Council of Social Service, Submission 38, p. 4; Volunteering Australia, Submission 39, p. 2; Goodstart Early Learning, Submission 58, [p. 3]; FamilyCare, Submission 65, p. 2.
  • 162
    National Council of Single Mothers and their Children, Submission 20, p. 15; National Social Security Rights Network, Submission 14, p. 2; Good Shepherd Australia New Zealand, Submission 15, p. 6; See also CatholicCare Sandhurst, Submission 24, [p. 3]; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 6; The Hive Mount Druitt, Submission 34, p. 1; Brotherhood of St Laurence, Submission 63, p. 5; FamilyCare, Submission 65, p. 2; Australian Motherhood Initiative for Research and Community Involvement, Submission 68, p. 2.
  • 163
    National Social Security Rights Network, Submission 14, p. 2; National Council of Single Mothers and their Children, Submission 20, p. 3; Council of Single Mothers and their Children, Submission 25, pp. 4–5; HLRC/SNAICC/NFVPLS, Submission 29.1, p. 6; The Hive Mount Druitt, Submission 34, p. 1; Australian Council of Social Service, Submission 38, p. 4; See also: Good Shepherd Australia New Zealand, Submission 15, p. 6; Volunteering Australia, Submission 39, p. 2; FamilyCare, Submission 65, p. 2.
  • 164
    Good Shepherd Australia New Zealand, Submission 15, p. 6; Wesley Mission, Submission 12, [p. 3]; Council of Single Mothers and their Children, Submission 25, p. 4.
  • 165
    Uniting SA, Submission 18, p. 3; CatholicCare Sandhurst, Submission 24, [p. 4]; Settlement Services International, Submission 31, p. 1; Mission Australia, Submission 60, p. 2.
  • 166
    Australian Unemployed Workers Union, Submission 70, p. 14. See also: National Council of Single Mothers and their Children, Submission 20, p. 3.
  • 167
    Brotherhood of St Laurence, Submission 63, p. 6; Good Shepherd Australia New Zealand, Submission 15, p. 6; Settlement Services International, Submission 31, p. 1.
  • 168
    Good Shepherd Australia New Zealand, Submission 15, p. 6; Australian Human Rights Commission, Submission 16, p. 4; Australian Council of Social Service, Submission 38, p. 4; Mission Australia, Submission 60, p. 5.

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