Communicating with Centrelink
I sat with my daughter—and I have worked for the public
sector for many years—and attempted to go through the questions which were in
this form with her. Some of the questions were nonsensical. I had no idea what was
being asked. You cannot progress unless you answer the question, so people are
making a guess. They are putting in whatever information in order to get the
form completed. They do not understand.
Throughout this inquiry, the committee heard wide-ranging evidence
regarding the difficulty individuals and organisations faced in communicating
with the Department of Human Services (department) to discuss online compliance
intervention (OCI) related debt matters. Communication problems included
letters not being received, trouble contacting the department via phone, difficulty
in receiving intelligible income data used to calculate purported debts, hard
to navigate online communication portals, difficult to understand
correspondence and a lack of material translated into other languages. These
were all listed as individual barriers to effective communication between the
public and the department.
However, a number of organisations raised a separate critical issue that
acts as a barrier to all forms of communication – that there is a significant
power imbalance between income payment recipients and the department, and
communication therefore does not take place on a level playing field.
When confronted with a large public entity like Centrelink, many
people feel that they simply must comply with the requests and that they have a
limited capacity to advocate for themselves and limited confidence in the
system's willingness to interact with them. I think this has been exacerbated
by the loss of human oversight of these processes.
In discussing the impacts of this power imbalance, where individuals
tend to assume 'the department is right', organisations pointed to a number of
adverse outcomes for individuals, such as people paying purported debt notices
without question and people accepting pre-filled income data that averages
their income without checking it for accuracy, leading to incorrect debt
calculations. The evidence presented to the inquiry points to a tendency among
individuals to assume the department is correct, and when a person does see an
error, they feel they do not have the power to change it.
A lot of people get one of the letters and assume that the
debt is correct, so they go into an agency and say: 'I've got this Centrelink
debt and I can't afford it. What can I do?' That is when the agency says:
'Maybe you better actually check to see whether the debt's correct. Go to the
Welfare Rights Centre.'
The Australian Council of Social Service (ACOSS) cited communication at
the commencement of the program as having created a climate of fear among debt
We also know that, because of the communications from the
responsible minister in the lead-up to this program being unleashed, there has
been a perception created that if you do not comply you may go to jail.
The Queensland Council of Social Service put forward the view that in
order to achieve procedural fairness in the OCI process, government is
responsible for ensuring that communication is clear and effective:
The government has a responsibility to provide clear and
comprehensive information to individuals affected. The government has a
responsibility to ensure that there is sufficient support for clients affected.
The government has a responsibility to provide a number of channels of support:
digital, phone or face-to-face. The government also has a responsibility to
provide a myGov website that is easy to access and navigate.
As discussed in Chapter 2, evidence from multiple submitters also points
to the shift in the onus of communicating. Where the department previously checked
income discrepancies, by communicating directly with employers, under the new
OCI system, the onus for seeking that information and communicating it to the
department in a highly proscribed form is now the responsibility of the income
In the past, DHS would investigate these discrepancies and
would seek to obtain sufficient information from the person or employer to
enable an accurate assessment to be made. Under the new
process, DHS does not seek to obtain sufficient information to enable an
accurate debt assessment to be made. It is instead used as the online platform,
which is an automated system that makes a debt assessment based on the data
match information alone if the person does not provide further information for
The outcome of this communication with the department is critical for
individuals – if they get it wrong they could incur a debt they do not owe. This
chapter will review the various challenges people find in communicating with
Centrelink, and the impact that challenges have specifically on their purported
debt matters and more broadly on their lives.
Chapter 2 provided a breakdown of the OCI process, whereby the first stage
is the data-matching process itself, and where a possible reported income
discrepancy is found, an initial letter is sent to the individual asking for
clarification around that income discrepancy.
The department provided evidence around this first stage of communicating
with people who may have an income discrepancy. Firstly, the department
explained that initial contact was not a 'debt notice.'
Instead, the department referred to this step as a 'request for clarification':
We match data with the tax office to see if there is a
difference between the information the ATO has about employment and the
information the recipient has told us. If there is a difference, we do not make
an assumption about whether that is a debt or there is no debt; we simply ask
the person to clarify the difference and provide either confirming information
or updated information.
However, the National Social Security Rights Network expressed concern
that, as individuals tend to assume the department is correct, the wording of
the letter itself could lead individuals to not provide detailed and accurate
The very first version of the letter said, 'Go online to
confirm your ATO information.' 'Confirm' is an extremely confusing word to use
because generally the ATO information is correct... A number of people simply
went online and all they did was confirm it and then averaging resulted or they
did not go online because, understandably, they said, 'It's correct. I probably
don't need to worry about this.'
People with Disability Australia were also critical of the confusing
nature of the initiating letters from the department, stating that 'We raised
concerns with the Ombudsman early on that the initial letter sent to welfare
recipients failed to include crucial information and provided information that
confused and frustrated some of the people who contacted us.'
One individual who received a letter, Michael, pointed out that the
subject line of the letter itself does not encourage people to open the
communication, because the letter 'is marked "general" in the inbox.
It is not labelled "urgent", "please respond", or "information
needed". It is labelled "general". I think that seems foolish.'
The Welfare Rights Centre, South Australia pointed to the difficulties
individuals had in responding to the letters because the person may 'lack the
internet literacy to adequately respond to the letters and some letters are
never received as the customer has moved.'
These two issues are discussed in detail below.
The Council on the Ageing Tasmania pointed out that beyond internet
literacy, general literacy levels are also a barrier to some people responding.
General and internet literacy is discussed in greater detail in the later
section on communication barriers.
The inquiry received evidence from a range of organisations relating to
the apparent lack of updated contact details held by Centrelink, which resulted
in many individuals not receiving the initial 'clarification' letters.
ACOSS estimated that this resulted in over 6 500 people hearing about their purported
debt from a debt collector rather than from Centrelink.
The department discussed this problem at the second Canberra hearing,
and outlined changes it made to the distribution of postal letters. The
department initially used the 'last known address' to post letters. Around 5
000 people did not receive initial letters as the 'last known address' was not
up to date.
The department said it now sends letters via registered post and that, after an
initial settling in period, 'the registered post system is more mature and we
are able to reach that 10 000 mark' of letters being delivered each week.
The department also acknowledged that in some cases, lack of up to date details
meant that letters were sent to deceased people.
ACOSS provided evidence that while the use of registered mail will
resolve the issue of whether initial contact can be verified, '[t]hat does not
address the matter of people who have previously been contacted under this
program, who have not received that information, and are currently trying to
address an alleged debt.'
The issue of people who first heard about a purported debt from a debt
collection agency instead of the department is discussed in further detail in
this chapter below. The process by which people challenge the estimated debt
amounts is discussed in chapter 4.
People 'not engaged'
The department discussed the difficulty they face, across many different
payment areas, in having people engage with the department's requests for
information. The department provided evidence that in one payment area, over 20
per cent of people did not respond to requests for information:
Last year we sent out about 300,000 [reminders] and, even
after we had sent reminders, still [65,000] people received a debt because they
had not updated their details, they had not engaged with us. Of those 65,000
people who had a debt, about 21,000 subsequently had the debt reduced to
zero—because they had done everything; they just had not told us. This is a
pattern that we have. We actually have to suspend a number of payments every
year from recipients who we ask for information—we ask them to update their
details; we ask them to notify us of earnings—and they do not give it to us.
After we have tried on a number of occasions, we actually have to suspend their
payments in order for them to engage with us again. So I think it is going to
be a key lesson learnt for us about just how many people are not responding to
calls for action.
The department further stated that it had underestimated 'how many
people would not clarify and would not engage'
after receiving the initial letters and claimed that much of the communication difficulties
specific to the OCI program were caused by this lack of engagement by individuals:
I think it is a problem when the recipient or the former
recipient does not engage with us. That is why the refinement has been to
ensure as best as possible that we can engage with the recipient. Sometimes we
will really struggle to engage with either a recipient or a former recipient
because they do not want to be engaged with us, or it may be that for whatever
personal reasons they do not want to engage.
Witnesses raised a number of reasons as to why many individuals do not
respond to communications from the department.
ACOSS provided evidence that often, communication with individuals is
not done through a printed letter sent to an individual's residence. Instead, a
person can be contacted via text message or email, letting them know there is a
letter from Centrelink available on their myGov account. ACOSS submitted that
in the case of the OCI, many people ignored such communications, thinking it
was not relevant because 'they no longer have anything to do with Centrelink,
and they thought they had done the right thing. They just thought it was an
Other witnesses pointed to many people's long-term reluctance to engage
with Centrelink processes:
[W]e know of many people who have received letters from
Centrelink and never open them. Clients will come in with a bundle of 10
letters from Centrelink that they have never opened. While that could be seen
as being irresponsible, for many people it is a sense of hopelessness or
helplessness in the face of a system that they often do not understand well.
The inquiry heard evidence that the timing of the department sending out
initial letters was poorly chosen. The Federation of Ethnic Communities'
Councils of Australia (FECCA) pointed out that during the Christmas period when
many people received initial letters, advocacy services for Culturally and
Linguistically Diverse (CALD) Australians were closed, leaving people to 'deal
with it on their created difficulties for individuals due to the lack of legal
advice available, but also because of the increased stress that vulnerable
individuals and families experience during Christmas. The Financial Counsellors
Association of Western Australian described a typical call for assistance:
'So I've had this letter, but I've got all these other debts.
I'm just about to start my kids at school, I've got to buy uniforms, I've got
to buy books, school fees. I've had a moratorium on my utility, I've got to now
find the money for that, I've got the credit card debt after Christmas, and now
this has come.'
Mission Australian echoed this evidence of the distress caused by the
timing of letters:
In the lead-up to Christmas Mission Australia in Tasmania
experienced a significant increase—around 20 per cent—in the number of calls
from people who were overwhelmed or traumatised by the amount of debt they owed
to the government and the urgency with which they had to pay that back. The
majority of these callers were not aware of the supports available to them or
how to challenge the claims of debt. The huge amounts of debt and the tight
time frames to respond to them left people anxious and distraught—for example,
some clients received these letters just before Christmas and did not know
whether they could afford food or last-minute gifts. Then, towards February, we
got feedback from some people that they were unable to provide school supplies
and uniforms for their children as they were paying back a debt to Centrelink.
Ms Campbell, Secretary of the department, claimed that much of the
distress was caused, not by the letters themselves, but by the media attention,
stating 'I think that in the lead-up to Christmas and into January people
became even more distressed because of the significant media attention around
these issues. I think that half of the stories that appeared in the media were
not part of this system—they were general debt matters but, because of some of
the stories in the media, there was a belief that all debts were wrong.'
The department also provided evidence that seasonal variations are taken
into account, and stated 'there was a significantly lower number of debt
assessments initiated in December, because we are aware that that is a
However, Ms Campbell, Secretary of the department went on to say:
It is a difficult management system around when you can and
cannot send out letters. If we do not send them out in November, December and
January then we have to send out letters in February, March and April, and then
people say, 'It's Easter.' It is very difficult to find a good time of year to
send a letter to someone asking them to clarify their details.
The committee notes that for the 6 500 people who did not receive their
initial letters before the department moved to using registered mail, those
people lost the opportunity to 'clarify' income data discrepancies. A
significant proportion of those 6 500 people would have had their purported
debts reduced or acknowledged as incorrect, had they had the opportunity to
provide information to the department.
The committee remains highly concerned that a proportion of this cohort appears
to have paid these purported debts without question, meaning the department was
likely recouping monies it was not owed, from people who could least afford it.
The committee notes it is clear there is a significant communication problem
when 65 000 from 300 000 people do not respond to requests from the department
to engage. When the proportion of non-respondents is so high, it is also clear
the communication problem lies not with the recipients, but with the department.
These communication problems were exacerbated under the OCI program, but are
clearly a broader systemic issue.
There is no doubt that the sending of a significant number of letters in
the period before Christmas caused additional distress to people receiving the
The inquiry heard evidence from a range of organisations and
individuals, that communication barriers experienced by people were not
adequately taken into account by the department in its communication strategy
for the OCI program. These barriers included having a vulnerability indicator,
language barriers, or a communication disability.
The department uses a system of a 'vulnerability indicator' on a
person's record to indicate a jobseeker who has a 'psychiatric problem or
illness, cognitive or neurological impairment illness or injury requiring
frequent treatment, drug/alcohol dependency, homeless, recent traumatic
relationship breakdown, significant lack of literacy and language skills or a
nationally approved vulnerability.'
The department submitted that vulnerable people are not subject to the
OCI program, including 'those who are culturally and linguistically diverse, if
the person is in a period of bereavement, affected by a natural disaster or
resides in a geographic location with limited access to digital services. The
identification of vulnerable recipients is based on the information the department
has on record.'
ACOSS noted that the OCI program would likely include some vulnerable
people who do not yet have a vulnerability flag on their record:
That may happen, for instance, where the person did not have
a vulnerability at the time they received a Centrelink payment from where the
alleged debt arose, but have subsequently acquired one—for instance, they may
be subjected to domestic violence or have depression and anxiety. Those people
may well be caught up by this program.
The National Social Security Rights Network agreed with this view, and
went further to state that this system may not be appropriately targeted because
'these indicators are applied to job seekers and, as the example below shows,
may not be applied to recipients of non-activity tested payments such as
FECCA also pointed out that while many individuals have a vulnerability
flag, and would therefore not have received letters, many vulnerable people
would still be subject to the debt-recovery program:
By definition, those receiving support from Centrelink will
likely have vulnerabilities, whether or not they are severe enough to be noted
with a vulnerability indicator in their record. That vulnerability is likely to
be compounded if you are from a CALD background.
By contrast, Basic Rights Queensland submitted that indicators aside,
most income support payment recipients are vulnerable:
Centrelink does say it has those vulnerability indicators but
then, by definition, most of the people who contact us are quite vulnerable in
one way or another—it is just that it hasn't been officially categorised as
The Tasmanian Council of Social Service (TasCOSS) agreed with this view,
stating 'any human service system we have in place in this country should
actually already acknowledge the level of need that anyone accessing a safety
net might have, rather than people having to be stereotyped or stigmatised by
having a flag next to their name.'
TasCOSS put forward the view that the reason for this, is that there are
sensitivity issues around creating those vulnerability indicators in the first
place, which may mean many vulnerable people are not identified as such:
The need for an individual or the desire of an individual to
disclose vulnerability is very personal. Many people have gone through their
whole life very carefully guarding the fact that they may be illiterate, for
example, and they become very clever at how they deal with covering that up.
Equally, someone with a mild intellectual disability will be very proud of the
fact that they fully function within the community within their capacity and do
not want to be classified as a person with a disability, and nor should they. 
TasCOSS also submitted that vulnerabilities often co-exist in areas of
socio-economic disadvantage such as Tasmania, where the impact would be felt
harder than in other regions:
It was always likely that the system would have a
particularly egregious impact in Tasmania. Tasmania has the highest rate in the
nation of children living in low-income, welfare-dependent families (30%), the
highest youth unemployment rate (16.2%), and the highest rate of female
sole-parent pensioners (5.5%). It also has high levels of inadequate adult
literacy (less than 50% of Tasmanian adults have literacy skills at or above
OECD level 3). Tasmanians, like many in rural and remote parts of Australia,
have very limited access to legal assistance services and effectively no access
to pro bono legal services.
Australia concurred with this view, and stated that 'it should not be a requirement
for Centrelink customers to disclose mental health issues for debt collection
activity to be conducted in a manner that is sensitive to their needs.' Mental
Health Australia pointed to the disbanding of mental health specific
consultative groups within the department as being a contributing factor to the
failure of the department to appropriately institute risk-mitigation processes
to support people with mental health issues.
To rectify this problem, Mental Health Australia recommended:
[T]he Department should employ a co-design methodology to
ensure that debt recovery processes, and Centrelink services more broadly, are
fit-for-purpose and have necessary protocols to protect vulnerable cohorts,
including people experiencing mental health issues. As a mechanism for
co-design, the Department should immediately reconvene the Consumer
Consultative Group, the Service Delivery Advisory Group and the Mental Health
Advisory Working Party as a core element of the Department's continuous
improvement process, which would by supported by user testing.
A common concern raised by multiple witnesses, is the level of literacy
of recipients of the departments communications, and the style of language used
by the department, which together can create a significant communication
barrier. The Law Society of South Australia noted:
The initial notices are received frequently by
poorly-educated individuals and not infrequently by individuals who have a
limited command of the English language. It is to be expected that some will
interpret the initial notice as actually being a notice of demand.
This view was echoed by #NotMyDebt, who stated 'The multistage review
process is convoluted, protractive and oppressive, especially for vulnerable
clients with low literacy, self-esteem, language skills or mental health.
The Youth Network of Tasmania agreed the communication from the
department was overly complex, and noted that in relation to younger income
[I]t is also about the
complexity of the language and complexity of the information they are required
to provide and about the understanding of the disclosures that they need to
make every step of the way.
The Launceston Community Legal Centre told the inquiry that the
complexity of language used by the department meant that in order to achieve
progress, an individual was best served by a professional who understood the
[T]he best and most helpful way for those matters to be
handled is for me or someone to assist the client to get all of their material
evidence together and get it into Centrelink. There is a particular set of
words you have to use. It is what I call Centrelink English, which is quite
different to Australian English. If you do not use the right words, you do not
always get the right outcomes.
Ms Basterfield, a consultant speech pathologist, concurred with this
view of the complexity of language used by the department, but stated she
simply referred to it as 'government English'.
TasCOSS told the inquiry that literacy can be a greater challenge,
depending on location. TasCOSS pointed to the multiple levels of intersecting
communication barriers faced in their jurisdiction:
Tasmania has the highest rate of population receiving any
kind of income support payment and across all different payments available.
Tasmania has the highest proportion of our population with a disability,
including an intellectual or a learning disability. Nearly 50 per cent of the
Tasmanian adult population has very low levels of functional literacy and
numeracy. A recent national report released by Telstra shows that Tasmania has
the lowest levels of digital access and digital capability. Tasmanians, like
many Australians living in rural and regional areas, have limited access to
legal assistance and extremely low levels of access to pro bono legal services.
So, putting aside any other issues that have occurred with this system, these
factors alone mean that dealing with any system that relies on online written
communication will be fraught with difficulty. This should have been foreseen
by the government and it should have been addressed.
English as a secondary language
A number of submitters raised concerns around Centrelink clients for
whom English is a secondary language. The Welfare Rights Centre South Australia
Another problem is that the letters go out in English,
regardless of whether the person can read English. Communicating with people
from non-English speaking backgrounds has always been problematic for
Centrelink, but even more so when the decision to communicate is made by an
automated decision-making system.'
ACOSS contended that language barriers for culturally and linguistically
diverse (CALD) people in and of themselves are often not enough to cause a
'vulnerability flag' on a person's account, but such communication barriers do
in fact often create serious disadvantages for CALD people.
FECCA also raised issues relating to the intersecting difficulties faced
by the CALD community, which went beyond simple language barriers:
Many migrants and refugees learn English as their second
language and report that, at times, they struggle to use Centrelink's automated
systems due to comprehension difficulties. Some claim that they may be entering
their details incorrectly due to a lack of understanding of the system. Clients
are exasperated at the lengthy call-wait times and the limited non-automated
support. They suggest that it is almost impossible to receive face-to-face
support from a person without waiting for significant periods of time and, once
they do, they are referred to an online form, which is no good to them. Older
clients, new migrants and refugees report that they have difficulty in
completing the online forms because they do not have a computer and the
internet, and nor do they understand how to use digital technology.
Furthermore, they do not have someone who is available on a routine basis to
provide assistance with income data reporting. Some clients have been told that
they have needed to provide pay slips, bank statements and letters from their
employers dating back to five years ago. This has proven difficult for some
clients, as their previous organisations have closed and no longer exist.
Children with Disability Australia told the committee they were not
aware of any communication assistance that had been put in place to help people
with a disability or their families in navigating the OCI system.
This evidence is supported by the personal experience of Michelle, who
provided evidence to the committee that when she attended the Centrelink office
to query her debt notice, she was directed to use the phone system, despite the
fact she is deaf and had a communications support person with her:
At first they asked me to ring and I said, 'Hang on, I'm
deaf.' My support worker was getting agitated going, 'Look, she's deaf—this
can't happen.' They tried to force her to become the contact person, and that
person did not want that; that person respects my privacy. They ended up
forcing her to ring, and she did not want to and then walked out. My carer
ended up walking out because they forced us to ring, whereas they should have
done their job and assisted me.
LawRight provided evidence relating to a client they assisted who has
'the reading age of a five- or six-year-old and the maths age of a six- or
seven-year-old.' LawRight did not specify whether this person had a
vulnerability flag, but submitted that in communicating with this person, the
department sent 'a printout of payments made to the client dating back to 2001'
but that the print out was not accompanied by any explanatory notes and was so
complicated that even the LawRight lawyer did not understand the information.
Access Easy English submitted that there is a requirement for important
information to be provided to people with a disability-related communication
barrier in an 'Easy English' format, but found that 'CentreLink complaints processes
and forms are not presented in a way these particular clients can use, to raise
their concerns about access
to written information.' To address the deficiency, Access Easy English
recommended the department implement a 'whole of CentreLink/DHS approach to
Accessible Information, in particular, Easy English.'
The committee received evidence of the impact that geographic barriers
to communication has had on individuals. In particular, the committee notes
that the need to travel long distances to Centrelink offices and/or legal
services has increased the hours individuals have spent in resolving purported
There are alleged debts that people have travelled hours to a
Centrelink office to talk to somebody about, because they could not reach
anybody through their call centre network, only to find after two visits that a
debt had not occurred. The one example that a member told me about was somebody
that had to get on a bus for an hour and 15 minutes to get to a Centrelink
office not once, not twice but three times before the matter was resolved.
The National Union of Students stated travel distances have impacted
students who tried to attend Centrelink offices to resolve their cases:
We have had students in rural
and regional areas drive out or catch the bus to be told that they could have
just done it at home and then they subsequently have had to wait even longer.
This issue was also discussed in media reports on the OCI program, with
the ABC's Background Briefing radio program outlining the case of Greg Steen,
who lives over 100 kilometres from his nearest Centrelink Office. After a
number of trips Mr Steen had travelled over 1000 kilometres to resolve his
purported debt matter.
The committee notes evidence that there is a broad systemic problem with
the way the department engages with vulnerable clients, which has been
exacerbated by the OCI system.
The committee is deeply concerned for the people in the system who have
not been properly identified as vulnerable, noting that to some extent,
everyone who uses income support payments is vulnerable in some way.
The inquiry received a range of evidence that people often first found
out about their purported debt when they received a debt notice from the
department, or when they were contacted by a debt collector. As noted earlier
in this chapter, an estimated 6 500 people did not receive the initial
letter requesting income clarification from the department, due to incorrect
addresses being used. ACOSS noted that '[w]hile Centrelink could not track down
these people to provide them with the information about a discrepancy or,
indeed, an alleged debt, debt collectors have seemingly had no trouble doing
Whether or not a person knew about the purported debt, the receipt of
the formal notification of the purported debt was noted by many individuals and
organisations as a stressful experience for people:
Life is stressful enough on Newstart, living from week to
week and trying to find work and making a better life for yourself. It is only
made worse by stressful events such as receiving a debt notice. I can only
imagine the suffering someone who received a larger debt would experience.
This experience was echoed in evidence presented by advocacy
organisations such as the Welfare Rights Centre South Australia Inc:
Many clients are extremely distressed by such letters and
believe they are being accused of cheating. I personally spoke to a young woman who suffers from anxiety,
who was extremely agitated and upset. She was crying and repeatedly told me
that she was not a cheat. She was frightened that the debt, which was $17,000,
would result in her going to jail.
Tom characterised the debt notice as a fishing expedition, stating 'the
debt notice was like a fraud; it was like a scam. You cannot send a letter
saying, 'I accuse and you are guilty.'
The inquiry also received evidence of individuals who first became aware
of a purported debt, because deductions were made from their income support
payments. In these cases, the individuals had not received any prior communication
regarding the purported debt matter. Queensland Advocacy Incorporated (QAI)
discussed the case of a client who told QAI 'she did not receive a notice or
letter, but she simply noticed that there was $86 missing from her Newstart
allowance of $536 per fortnight. This is obviously a substantial
proportion—more than 10 per cent—of the allowance.'
Financial Counselling Australia outlined its understanding of the
process for Centrelink to begin automatic deductions from income support
payments, and the impact this can have on individuals:
When the Centrelink system identifies a debt for a person
currently in receipt of Centrelink payments, this triggers automatic deductions
of 15% of that person's pension or income support as repayment. As people in
receipt of Centrelink benefits typically already live below the breadline, 15%
of income support can mean the difference between being able to afford
essentials or needing rent/food relief from an emergency relief provider.
Access to information
Throughout this inquiry, individuals and legal and advocacy
organisations from around Australia gave evidence that the department withheld
information that a debt letter recipient needed to understand how the purported
debt was calculated. This included information to enable them to work out what income
information may be incorrect and have the effect of creating an incorrect debt
amount. Many organisations stated they resorted to Freedom of Information (FOI)
requests to force the department to release information that was denied on
It seems to me to be quite ludicrous that we even have to go
to freedom of information. I used to think that the child support letters were
incredibly complex, until this started. But at least with the child support
letters, if a person who had sought our service had a difficulty, I could read
about the period over which that debt was incurred, what incomes were taken and
the percentages of shared care, and then we could work through it together.
But, as someone trying to assist, I will ask the question: 'Why do you have
that debt? How long have you had it for? What payments do you receive?' People
say, 'I don't know—I just have this debt.
Many individuals provided copies of the information they received from
the department, to show how difficult the data was to understand:
This thick wad of paper is the FOI, and it is total
gibberish. It is just rubbish. None of the income numbers in there make any
sense, and none of them correlate. I cannot make any sense of it.
Even when information was provided, individuals had difficulty in
understanding how the department had calculated a purported debt amount. Tom, a
retired Chartered Public Accountant, described the information he was provided
with as 'pure kafka' and said that as a trained financial professional, he found
the department's explanation of how the purported debt was calculated as
'crazy' and stated 'I am a practical person. I am a trained accountant. I
cannot listen to stuff like that.'
The Australian Privacy Foundation put forward a similar view, stating
that in trying to establish that a purported debt is owed, the onus of
communication sits with the department:
I use the fundamental justice principles, which are that you
either make your case for the debt being owing or you do not have a case.
Failing to provide information is a separate issue of the responsibility
obligations between the individual and Centrelink. When it comes to debt, the
justice system is quite clear. It is just that Centrelink does not want to comply
with those principles.
The Welfare Rights Centre South Australia contended that despite
requesting information to clarify an income discrepancy, in many cases that
information already sat within the department's information systems:
Some customers do not have the information necessary to
demonstrate their compliance. If, for example, a debt is raised up on the basis
of income earned seven years ago, it is unlikely the client would have the
information necessary and it is unreasonable to expect them to. The irony is
that in many of these cases Centrelink already has the information necessary on
the customer records which a human decision-maker could assess.
The difficulty in accessing appropriate information was raised by legal
services as being a key impediment to providing advice and assistance to
individuals in relation to their purported debt matter. Basic Rights Queensland
told the inquiry:
Centrelink's debt calculations are not actually freely
available to the public. There is a debt calculator on the online compliance
site where Centrelink customers can enter their figures and get an estimate,
but experience from our colleagues interstate indicate that once a person has
appealed a debt that calculator is no longer accessible. This means it is really
difficult for advocates like us to actually assist a person... The system is
failing to meet minimum requirements of procedural fairness because, despite
the fact that it is actually possible to provide the correct information, it is
not always accessible and there is insufficient information about how to use
The committee is deeply concerned with the lack of clarity in
information provided regarding individual purported debt matters. This includes
both sufficient depth of information as well information provided in an
appropriate form particularly for vulnerable people and people with
The questionable action of reversing the burden of proof onto income
payment recipients, where people are being asked to prove they do not owe a purported
debt, is discussed in great detail in chapter 4. What makes this reversal more
problematic, is the lack of information provided to individuals and their
advocates, that they need in order to prove the purported debts are not correct.
Centrelink communication channels
The department has three main communication channels for individuals to
interact with Centrelink: storefronts, online portals and via phone. The
inquiry received evidence of difficulties people faced with all three communication
The department discussed the various communication channels available to
individuals, and told the inquiry that individuals were encouraged to use phone
and online communication portals, as frontline staff at Centrelink offices have
not necessarily had the appropriate training to assist people with the OCI
We encourage staff to get recipients to go online, and one of
the main reasons for that is that, once they are online, they can also contact
the 1800 number. If you go to a Centrelink office—there are 350 throughout
Australia—it is not always likely that the person there will be deeply
experienced in these matters.
The inquiry received evidence that this encouragement of use of online
portals was not always considered by Centrelink officers to be the best way to
resolve purported debt matters. The Community and Public Sector Union told the
Frontline service officers reported when they get customer
details on the screen, when they are face-to-face with people, they would often
find errors that they would be able to correct very quickly but they were told,
quite quickly, not to do that and to push people back onto self-service portals
to get them to use the online system to correct their own details. They also reported
that people in the debt management teams were instructed only to deal with a
very small portion of the debt management process despite their experience
telling them that there were errors in other parts of the record.
Multiple witnesses to this inquiry, both individuals and organisations,
stressed the need for flexibility in the communications channels. While a large
proportion of people may find online systems convenient, many people require
telephone or face-to-face assistance for a variety of reasons. These issues are
discussed in the following section.
Centrelink online portals
As outlined in earlier this chapter, the premise of the OCI program is
to require individuals to provide detailed income data to retrospectively
verify their eligibility for income support payments. In the first instance,
the department directs people to provide this information via its OCI online
The online portals, both myGov and the OCI-specific website, were described
by many as being very difficult and complex to navigate, and 'inhibits people's
ability to provide accurate information that is very much needed when looking
at whether or not someone owes a debt.'
For many people subject to the OCI program, simply accessing the online
world is a challenge. The Legal Services Commission of South Australia told the
They do not have internet and they may not have mobile
phones, so their preference is to go personally to Centrelink and seek
assistance. It was specifically noted by her that those who have casual jobs or
intermittent positions prioritise other necessities, and the internet and
mobile phones may not necessarily be high on those lists.
This evidence was repeated by People with Disability Australia, who told
[W]e know that there is a problem with access to the
internet, generally, for a lot of people. Whether that is because of where they
live, whether that is because there is not community access in the communities
that they live in, it is definitely a problem. Having someone to call, having
someone to talk to, having a place to go and see people in person is absolutely
pointed out that although many people could access the internet through places
such as a library, there were privacy concerns for sending personal data over a
publicly accessible internet system. Susan stated that 'I could tell you a
little about having to give my bank records, which I had to do in a public
library. I was very scared someone was going to access my bank details over the
Easy English submitted that a significant proportion of the Australian
population, 52 per cent, has non-functional numerical literacy which is 'critical literacy for the correct
administration in areas such as meeting attendance, planning and time management,
adherence to conditions in CentreLink letters, to name a few.' Of greater
import, Access Easy English submitted that in testing of problem solving
technology-based information (online information), 62 per cent of users were
found to be non-functional, and furthermore, 1 in 5 households do not have
access to the internet.
Even for highly digitally literate people, communicating via the online
portal created difficulties in uploading information requested by the
department. Basic Rights outlined a process a client took to upload income data
to show there was no debt owed:
They went through an enormous process to try and address
this. They made seven separate attempts to upload the correct pay
documentation—keep bearing in mind that this is a tertiary educated person. As
they could not get this to work, they photocopied the pay slips and sent them
by registered mail on 26 October.
Conversely, Ian explained his difficulty in communicating with the
department was that while he was told he must submit information via the online
portal and not via an email, the department said it would accept information
I said, 'Yes, I'll email it to you.' They said, 'No, we don't
use email here.' I said, 'What! It's the 21st century.' They said, 'We don't
use email here.' They said, 'You could send it by myGov.' And I said, 'Well, I
don't have a myGov account.' ... The only other option they gave was to fax the
letter through to them. And, of course, who has a fax machine in their home? To
go to the post office, I think it was going to cost me $4.50 a page to send
this letter through. It was a letter of some eight or nine pages—so $40 to get
a letter to Centrelink.'
However, evidence was received that suggests the difficulties
experienced are not limited to simply accessing the online portals, but stem
from the design of the online website itself. The National Social Security
Rights Network stated the key problem was the usability of the site:
The outstanding impression I have had so far is that the
majority of people who have struggled are not people who are unwilling to use
online channels, they have just had great difficulty using this. There are some
people for whom on line is inappropriate or difficult or they do not have
access, but the main cause of problems is that DHS fundamentally underestimated
how usable their system was.
People with Disability Australia agreed the online portal was not
user-friendly and described the online portal as having 'some good features to
that but they were not easy to use, they were not easy to navigate and it was
not necessarily clear how to navigate around those. So without that guidance,
those tools may be available but they are difficult to access.'
UnitingCare Queensland noted that may of its clients required assistance
to navigate the OCI website:
However, in working with these clients, the main concern we
found was with the online service portal and having zero to minimal capacity to
navigate that system. They all stated that that caused a great deal of distress
and that that they needed help via a financial counsellor to navigate that
The usability of the OCI website formed part of the investigation of the
OCI process by the Commonwealth Ombudsman. The investigation report details
examples where the website does not provide sufficient warning that 'accepting'
the ATO annual income figure data will result in income averaged fortnightly
and a higher chance of a purported debt being calculated.
The report further expresses concern that even where people are aware
they must enter fortnightly earned income data in order to avoid a purported debt
being calculated, the OCI website itself does not provide a simple method to
insert this data. The report uses an illustrative example of a 'reasonably
well-educated' user who attempted to update her income data but 'found the
questions in the system too narrow, as they only asked her to confirm her
employers and her group certificate amount. After Ms D completed the OCI
process, the system advised her she owed a debt of $2203.24.'
The committee received evidence from the department that the OCI portal
was developed within the department, and did not receive extensive outside user
testing. The department outlined the testing process to develop the OCI portal
an internal exercise to identify if the online compliance system
was working; and
a pilot between July and September 2016 of 1 000 people selected
for intervention, with monitoring to check for any process or system generated
The department has confirmed that since the date of the above
complaints, the OCI website has been updated, in February 2017. The department
outlined the process it went through for subsequent user-testing of the updates
for the OCI website:
It was an interactive process with users. We had a range of
users we brought in to test screens with and to test explanations in the help
with. So it was an interactive process. Overall, the feedback we had was to
de-clutter the screens.
The department was asked whether the user-testing included vulnerable
people and those with communication barriers. The department confirmed only
that they used 'a broad sample of recipients and former recipients'
which included 'volunteer members of the public and departmental employees'
and that although other programs conduct testing across Australia, the subsequent
refinements to the online portal were only tested by users in Canberra.
The pages of the website were provided to the inquiry as a briefing to
the committee, and submitted in hard-copy. The updated website now includes a
warning that dates of employment will impact the debt calculation – referred to
as 'assessment of payments'. However, the warning appears at the point a person
verifies their overall start and end dates of employment. See image 3.1 below:
Department of Human Services, Submission 66.1, Attachment A Employment
Income Confirmation' 1 June 201, p. 19.
If a person simply confirms the start and end dates of employment but
does not go on to complete the fortnightly income stage of the website, they
will potentially be liable for an incorrectly calculated debt because of the
department's practice of averaging ATO annual income data.
Concern was raised by ACOSS that if the program was expanded to capture
income sources more likely to be received by the age pensioner population,
difficulties already being found with the online portals would be far greater:
If this program is expanded to income from areas other than
employment—what will mostly be the age pensioner population—there is a much
higher risk that the person will have poor digital literacy and may not even
have access to the internet. It is envisaged that this group is going to need
much more support than that received by the people affected by the current
program. There are also clear concerns about people's vulnerability. It is safe
to say that the proportion of people in the age pensioner population who have
some kind of vulnerability will be much higher than we have seen amongst the working-age
Evidence was received from a number of witnesses that individuals
subject to the OCI program were denied service at Centrelink storefronts. The
Community and Public Sector Union raised this as an issue of particular concern
for their members:
Members have been particularly disturbed by reports of
managers instructing frontline staff not to correct errors that they find and
instead to push customers onto self-service mechanisms and/or refer them to a
different part of the department—namely, the OCI teams.
However, the department discussed this issue and responded that letter
recipients were encouraged to use phone and online communication portals, as
frontline staff at Centrelink offices have not necessarily had the appropriate
training to assist people with this particular issue:
We do not have the capacity to train all our staff up to do
every element of business across the Department of Human Services, so we stream
into expert type areas. This is an expert type area, so what we wanted was for
recipients to engage with the system and then engage with the 1800 number,
which has the people who are expert on this, rather than any of our service
staff in the offices..
However FECCA pointed out that CALD community members can often have
greater difficulty communicating via phone and online than in person:
Given the reports that Centrelink staff were told not to
process debt disputes in person, if they are unaware of Centrelink's
multilingual phone service, language may discourage them from using the phone
service to challenge their debt letter. Many CALD Australians have limited
digital literacy, and FECCA has done a lot of work around this. Low levels of
English language mean they are unable to navigate government services through
online portals. So they just pay, whether or not they are liable for that debt.
Conversely, other witnesses pointed to the general inappropriateness of
having to discuss highly personal details in the Centrelink office. The
National Council of Single Mothers and their Children stated '[i]f you are
completely stressed out and go into a Centrelink office, you are publicly asked
what your issue is and someone makes a notation on a tablet if you cannot do
that yourself and then you wait in a very public space.'
Some witnesses pointed to Centrelink offices as being inappropriate
spaces for vulnerable people due to the level of aggression that can now be
found in Centrelink storefronts:
I am 67 and I am afraid to go into the Footscray Centrelink office.
The number of times that I have been in there where there has been someone who
has become so frustrated with the system that they are angry and threatening
everything from, 'If I had a bomb, I'd blow the place up,' to, 'Someone should
bring in an AKA and just shoot the place up,' means that I now do as much as
possible on the phone.
The department stated there has been no increase in aggressive behaviour
from customers at Centrelink storefronts and stated 'We do have a small number
of incidents—and those incidents occur every day—where people are aggressive
and take it out on the staff members. But we have not seen an increase in the
last few months on that issue.'
Evidence received by individuals, and backed up by organisations, points
to the incidents cited by the department above as often being used by
Centrelink staff as an excuse not to provide service to difficult people:
But there are a lot of cases where I have spoken to people
who have said, 'I just questioned the Centrelink staff member on this issue,
and the Centrelink staff member felt unsafe by being questioned'—maybe their
tone of voice was a little higher than usual because they were frustrated.
Instead of engaging with them as humans and trying to work out their problem,
the staff member says, 'I don't like the tone you're speaking to me with, and I
want you to leave.'
An example of this was provided by Michelle, who told the inquiry:
They actually ordered me out of the office and that made me
feel even worse... I was not abusive, threatening or angry. I was frustrated. I
was complaining about a letter and then I was dismissed. Sadly, it made me feel
as if I had done the wrong thing, but I had not.
Centrelink phone systems
The issue of people not being able to reach the department by phone was
a key concern raised by many witnesses and submitters throughout this inquiry.
This was exacerbated by the initial letters being sent out without the
dedicated OCI phone number being included. Although the department has since
updated the letters to include this information, the Commonwealth Ombudsman has
pointed out the number is printed on the second page of the letter and 'is not
obvious to the reader'.
The committee heard that people experienced difficulties getting through
on the phone in the first instance, as well as long wait times after the call was
first answered by Centrelink. The Community And Public Sector Union told the
More than 36 million calls to the Department of Human
Services went unanswered last year as the department is no longer able to
provide a basic level of service to Australians.
One witness, Jade, summarised the impact this can have on individuals by
stating 'The fact that it is nearly impossible for people to reach Centrelink
on the phone leads to people being more likely to accept the debt and not
The Victorian Council of Social Service quoted a complaint letter they
received which stated:
On Wednesday 22 March, I phoned 132850, 16 times between 1 pm
and 2 pm. The line was busy for the entire time. At 2.13 pm, I telephoned the
1300306325 line. I was then on hold for three hours and 12 minutes. This is
outrageous and unacceptable. I know this is not a one-off situation as a staff
member I eventually spoke to at Centrelink told me, not once but twice, that
that kind of wait time is common on this line.
The Financial Counsellors Association of Western Australia stated this
issue did not just impact individuals, but also impacted professionals who were
attempting to provide assistance on debt matters and had experienced great
difficulty in contacting Centrelink via phone when they were in a mediation
session with clients.
The department has previously provided evidence on the 'average speed of
answer' times for the debt phone lines for the period beginning July 2016 to
end January 2017. The committee notes the department's advice that the average
waiting time for the 1800 Compliance phone line was 40 seconds and two minutes
and four seconds for the Debt Recovery and Raising phone line.
IsCentrelinkDown described the call
data presented by the department as 'number-fudging' because the department does not record call
handling time at an organisational level, but instead resets the clock every
time a call is transferred.
IsCentrelinkDown developed a testing program for the phone number
given on the initial debt letter, 1800 076 072, and found that on average, a
call to this number had a 27.44 per cent chance of not being answered, which
went up to 50.0 per cent at 12.00pm when a large volume of calls were made
during people's lunch breaks.
IsCentrelinkDown noted the cost to individuals as a result of lengthy
wait times to have their questions answered:
Mobile calls to 13/1300 services are always charged with a
flag-fall and a per-minute rate, making long hold times expensive. This makes
no sense that we are lumping those with the least ability to pay for phone
calls with 13/1300 numbers including crisis services. Meanwhile the DHS 'purchasing
helpdesk' for the Dunn & Bradstreet contract is a 1800 number. This
displays poor priorities.
Once people managed to have their call answered, they reported
difficulty in having to explain a complex situation to one Centrelink officer,
only to have to repeat the same information the next time they call and speak
with a different staff member.
The National Social Security Rights Network also pointed to the
confusion created when individuals calling Centrelink are unable to find the
right section to speak with about their case:
[a] number of people have also expressed frustration and
confusion about not being able to access the right information when they have
attended a Centrelink office or called through on the general Centrelink
numbers. That reflects, of course, some poor decision making about
implementation, including not making the 1800 direct number to compliance
The key concern with the OCI process, is the outsourcing of the income
checking process to individuals. With this comes an inherent reversal of the
burden of proof – the department claims an income discrepancy and requires an
individual to seek the information required to prove the discrepancy does not
exist. If the individual fails, they will owe a debt of potentially many
thousands of dollars to the department.
The two fundamental resources a person needs to undertake this process
is a method of communicating, and once that communication channel is opened,
the receipt of information that is both comprehensive and comprehendible.
The department is clearly failing to provide those two necessary tools
to allow people to challenge the income discrepancy, and is reaping the benefit
through debt payments.
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