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Centrelink’s Automated Debt Raising  and Recovery System 

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DHS must manually reconsider whether the application of the collection fee was appropriate, taking into account the customer's personal circumstances, including the existence of a reasonable excuse. DHS implemented a number of broader improvements to the online system and manual processes that significantly reduced the application of the collection fee. DHS no longer applies a collection fee where a customer contacts the department (online or by phone) before a debt is incurred.

Recommendation 2—Initiation letters (DHS)

It is our view that the introductory letter given to customers up until September 2018 did not clearly explain the consequences of not contacting the department. Please note that if you do not confirm or update the information within 28 days, we may use employment dates and income from the ATO for your registration. This text does not explain that the ATO income will be averaged or that this may affect the amount of any debt.

For example, if the ATO shows that you worked for 5 months, we will divide your income equally over those 5 months. If you do not check and update your details, we will use the details we already have, including ATO details. The ATO told us how much your employer paid you for the whole financial year.

If you don't tell us, we'll use the income information from the ATO and estimate it over the period you worked - which could result in a debt. If you do not confirm or update your information, we will use the amount given to you by ATO.

Recommendation 3—Online messaging (DHS)

As the image above shows, the customer is then asked if they want DHS to use the. We understand that traditional views on communication have evolved, particularly with advances in the application of behavioral insights, and that visual prompts and other tools can be more effective in communicating warnings than plain text. We therefore appreciate that pop-up screens asking people if they are sure they want to proceed without payslips or bank statements can be more effective than standard written warnings.

In any case, we are pleased that DHS has now developed clear, simple text warnings and information in CUPI screens. However, DHS states that these changes could not be implemented in less than 3-4 months, at which point there will be no customers using the EIC to complete their end-to-end reviews online.11. 11 DHS states that initiations in the EIC system ceased between mid-September 2018 and between late.

October 2018 and late November 2018, less than 40 customers completed their end-to-end reviews online (ie, without staff assistance).

Recommendation 4—Obtaining employment income evidence (DHS and  DSS)

Recommendation 5—Communication with customers and staff (DHS)

Wait times on the compliance helpline between July and November 2018 were approximately 50 seconds.14 Recommendation 5(b) states that DHS should provide comprehensive publicly available information for clients on how to use the online system. The Department's website has been updated to include more information on the use of ATO income and, from 12 August 2017, links to written and video information. The website contains comprehensive information on using the online system, a helpline number and information on obtaining proof of employment income.

Recommendation 5(c) sought to improve processes for transferring customers contacting DHS from call centers to the compliance helpline. The department's internal guidelines and intranet contain instructions to warm transfer15 callers to compliance officers. During our investigation, DHS acted on our suggestion to improve the visibility of its guidance on the use of s 192 information collection powers, entitled 'Unable to access payslips or bank statements', in its online guidance and training packs. 16.

Recommendation 5(e) sought to ensure that DHS has robust processes for capturing and recording information about complaints and internal reviews for purposes of continuous improvement. The Department also created the position of Chief Citizen Officer to capture the citizen perspective and implemented a formal continuous improvement process, including a monthly OCI feedback report.

Recommendation 6—Customers receiving staff assisted interventions (DHS)

DHS developed and provided staff training, including on-demand videos, e-learning, and facilitated learning packages—copies of which were provided to our office in September 2017. In October 2016, prior to the commencement of our original investigation, DHS added the EIC Complaint Marker to its complaint monitoring system to enable separate reporting and management of EIC complaints.

Recommendation 7—Assistance to vulnerable customers (DHS)

Recommendation 8—Future implementation (DHS)

Part 3:  C OMPLAINTS DATA

The trend in automated data matching complaints reflects a general decrease in complaints due to improvements to the system after February 2017; and a more recent increase in complaints consistent with increased DHS compliance activity, as shown in Figure 5 below. In early 2018, DHS began tracking people who received an initiation letter but did not respond or did not complete the process. This increased activity resulted in a corresponding increase in automated data linkage complaints to the Office, peaking in October 2018 with 126 complaints.

Qualitative analysis

Part 4:  C ONCLUSION AND FURTHER RECOMMENDATIONS

Conclusion

For people who were sent debt notices before May 27, 2017, we recommend that DHS include messages in its debt collection communications similar to the messages included in enhanced notice of decision letters sent since May 27, 2017. The Office believes DHS should provide a more detailed explanation of debt outcomes to customers in all compliance bonds. Within the next 12 months, DHS should provide an improved debt explanation in all compliance debt outcome letters, regardless of whether the customer completed the review online or through the assistance of a compliance officer.

DHS should take steps to ensure that CUPI initiation letters warn clients that if they do not check and update past information, DHS may use Australian Taxation Office (ATO) information to calculate any debt, which it can mean that they have to pay back more than they should. The letter itself, or in related or attached material such as a leaflet, should explain how the ATO's income averaging works and the implications this may have for calculating the debt. There may be people in this cohort who did not go online or contact the department because they did not understand the consequences of not doing so.

We therefore recommend that the Department provide information on the implications of averaging at the next key point of contact in the process – debt collection correspondence. The MDV should include clear information about the consequences of using ATO information and the options available to customers in debt collection correspondence such as liability notices and debt outcome letters.

A PPENDIX  A—R ECOMMENDATIONS FROM  A PRIL  2017  REPORT

  • Recommendation 1 — Ten per cent recovery fee
  • Recommendation 2 — Initial contact letters
  • Recommendation 3 — Messaging within the OCI
  • Recommendation 4 — Obtaining employment income evidence
  • Recommendation 5 — Communication to customers and staff
  • Recommendation 6 — Expansion of customers who are offered a staff  assisted intervention
  • Recommendation 7 — Assistance to vulnerable customers
  • Recommendation 8 — Future implementation of the OCI

Recommendation 5—Communication to clients and staff. a) ensure that its 1800 compliance helpline number continues to be adequately resourced (b) comprehensive publicly available information for customers on how to use the. OCI system, including the compliance helpline telephone number and how to obtain relevant evidence of employment income. DHS should provide additional assistance and support to vulnerable people to engage with the OCI system. a) DHS should consider making outbound calls to vulnerable clients where they do not respond to the initial or reminder letters to explain what is required and initiate the staff assistance service offering.

Before further expansion of the OCI, DHS must:. a) undertake a comprehensive evaluation of the OCI in its current form.

A PPENDIX  B—DSS  POLICY ON USE OF S  192  Social Security Guide

Confirming Employment Income

Summary

Employment income evidence

For example, the recipient could not obtain the required information because the third party was out of business, uncontactable or uncooperative. Whether the cost of obtaining the required information itself will cause financial hardship to the recipient. Whether it would be unreasonable to expect the recipient to obtain the information themselves given the nature of their particular vulnerabilities.

For example, records were destroyed in a fire or if the person claims they did not work for that employer (eg mistaken identity). Act reference: Section 79 SS(Admin)Act Determination of rate reduction, Section 80 Decision to cancel or suspend, Section 192 General power to obtain information Rule reference: SS Guide 1.1.E.102 Employment income.

RECEIVED

2 6 MAR 2019

DHS should take steps to ensure that CUPI (Check and Update Past Income) initiation letters warn customers that if they do not check and update past information, DHS may use ATO data to calculate any debt, which could mean that they have to pay back more than they have to. DHS should include clear information in compliance debt collection correspondence, such as notices to creditors and subsequent reminders to pay, about the consequences of using ATO information and options available to customers. APRIL 2017 THE OMBUDSMAN'S OWN REPORT: CENTRELINK'S AUTOMATED DEBT ENHANCEMENT AND COLLECTION SYSTEM — ORIGINAL RECOMMENDATIONS Recommendation 1— Ten percent collection fee.

We recommend that DHS reassess debts already collected by the OCI in certain circumstances when collection fees were applied automatically, including when a customer contacts DHS or a commercial agent to report a problem, seek information, or request reassessment in respect of an OCI debt that includes a collection fee (regardless of whether or not the debt has been repaid). Status: Recommendation 2(a)(b) and (d) are met. DHS has been working closely with the Office of the Ombudsman to develop a viable solution to achieve the intent of recommendation 2c) and will continue this work to improve the customer experience. DHS should include a notice in the OCI system to clarify that if the client does not enter their income information, their ATO income will be averaged evenly over the relevant period and this could result in a debt.

If these charges would put the person in financial difficulties, DHS would have to use its powers to request the evidence directly from the financial institution. Before expanding the OCI further, DHS should:. a) carry out a comprehensive evaluation of the OCI in its current form (b) reflect further on how to reduce the risk of possible over-.

CANBERRA ACT_ 2601 J.__

Australian Government

Department of Social Services

March2019

Figure

Figure 5 — Complaints about data matching 2017 – 18 

References

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