Services Australia should ensure that for any cohort of recipients that is intended to be excluded from a compliance process or activity, there is clear documentation of the exclusion criteria, and, unless there is a technical reason it cannot be, the mechanism by which that is to occur should be reflected in the relevant technical specification documents.
The Government accepts this recommendation.
The Government supports the need for clear documentation that specifies the circumstances when an individual may be excluded from a compliance process.
Services Australia will produce clear documentation for any exclusion criteria when any cohort of recipients is intended to be excluded from compliance or debt related activities. This includes recording any associated exclusions within any compliance activity business process specifications and compliance program documents.
Services Australia should ensure that its processes and policies in relation to the identification of potential vulnerabilities extend to the identification of circumstances affecting a recipient's capacity to engage with any form of compliance activity. To this end, circumstances likely to affect a recipient's capacity to engage with compliance activities should be recorded on their file regardless of whether they are in receipt of a payment that gives rise to mutual obligations.
The Government accepts this recommendation.
The Government agrees that individual circumstances that might impact on an individual's capacity to engage with government services, or reviews of payments and services, should be taken into account during service delivery and customer engagements.
Disclosure of individual circumstances is voluntary in most cases, particularly when this detail may not be required to establish an entitlement to a payment or service. Noting this, in some circumstances it may not be possible for delivery agencies to proactively identify all circumstances that might affect a person's ability to engage with a compliance activity.
In recognition, Services Australia has developed internal guidance to support staff to engage with customers, build the agency's capability to identify customers experiencing vulnerability, and support customers to safely disclose their circumstances and access appropriate information, services and support. Issued in July 2021, the 'Our vulnerability strategy' is being implemented across Services Australia.
