Complexity as a barrier to work

7.24 In this section, the ALRC recommends that DHS should evaluate the effectiveness of its methods for communicating information about social security payments and entitlements to mature age persons.

7.25 The income support payment system in Australia is highly targeted. It achieves this through making distinctions between payment categories—such as for carers, people with disability and those unemployed—and by means testing of payments.[31] The object is to direct payments to those most in need and to maintain the sustainability of the system.[32] The result is ‘the most targeted system of cash transfers in the OECD’.[33]

7.26 A corollary of targeting is complexity. Submissions to this Inquiry suggested that this complexity itself is a barrier to work.[34] Without large-scale reform of the social security system, which is beyond the Terms of Reference for this Inquiry, this complexity will remain. It is therefore important to ensure that information about social security payments is as clear and accessible as possible, to assist individuals to manage this complexity.

Information provision

7.27 DHS utilises a range of methods to provide information about income support payment eligibility, conditions and the effect of work upon payments. This includes advice to mature age persons on application for income support.[35] Information is also provided: online; in print, through letters and publications including the News for Seniors Magazine; as well as by telephone. DHS has emphasised its commitment to improving the way it communicates information, submitting that it

endeavours to display information to the public in a simple, logical manner and recently became the first government department to achieve a gold level certification for the use of plain language on the Human Services website from the Plain English Foundation.[36]

7.28 However, the ALRC has heard that mature age persons find information about social security difficult to understand and navigate. A number of submissions identified access to information about income support payments as a problem for mature age persons.[37]

7.29 The increasing emphasis on providing information online was also identified as a potential problem for mature age persons, whose access to and familiarity with information technology may be limited.[38] Research conducted in 2011 by DHS suggested that a range of communication methods are appropriate for mature age persons. This research found that mature age job seekers utilise the DHS website, but also value ‘direct contact with staff members as part of ongoing support’.[39] Self-funded retirees were found to be relatively more ‘comfortable with online channels, while … most aged pensioners preferred printed and face-to-face communication’.[40]

7.30 Mature age persons from culturally and linguistically diverse (CALD) backgrounds may find it particularly difficult to access social security information. The Federation of Ethnic Communities Councils of Australia (FECCA) noted that:

Unfamiliarity with concepts such as social welfare, communication issues and lack of knowledge restricts older CALD people’s ability to understand and access many mechanisms that established Australians take for granted, including a full understanding of social security entitlements.[41]

7.31 In addition to ensuring that information is accessible, stakeholders emphasised that such information must be easy to understand. A number of stakeholders suggested that mature age persons currently find information about social security difficult to comprehend.[42]

7.32 NWRN submitted that activity test requirements were poorly understood by mature age job seekers. It argued that many mature age job seekers were concerned about the impact of ill health on their ability to comply with the conditions of their income support payment:

Welfare Rights Centres … receive many enquiries from recipients of activity-tested payments not yet 55 years of age who suffer from a range of health problems … It is our experience that the activity testing obligations and the consequences for a person not able to comply can be daunting for an older person in poor health.[43]

7.33 Other submissions suggested that mature age persons find it difficult to understand the effect of paid work upon income support payments. For example, the Australian Chamber of Commerce and Industry (ACCI) commented that ‘there are generally no problems with accessibility to information but the areas of concern involve the complexity of eligibility arrangements and the consequences of altered circumstances’.[44] National Seniors commented that:

Older Australians continue to report a lack of knowledge and a high level of confusion regarding the eligibility for income support payments and work incentives. There is also fear about the potential loss of concessions and support payments if seniors undertake additional paid work.[45]

7.34 Some stakeholders argued that information about incentives to take up paid work is not effectively communicated to mature age income support recipients. For example, in relation to the Age Pension, COTA noted that ‘there is not a good understanding of how the Work Bonus operates … It needs to be promoted more widely’.[46]

7.35 Difficulty in accessing and comprehending information about income support payments, as well as the effect of employment income upon these payments, appears to act as an impediment to mature age income support recipients’ willingness to engage in employment. The ALRC recommends that the DHS should evaluate how it could communicate this information to mature age persons more effectively.

7.36 DEEWR, DHS and FaHCSIA agreed that ‘it would be feasible for DHS to undertake targeted evaluation of its methods for communication information to mature age persons about social security, contingent on funding and resources’.[47]

Recommendation 7–1 The Department of Human Services should evaluate the effectiveness of communication of information to mature age persons about social security. In its evaluation, it should consider the communication of information about:

(a) eligibility for income support payments;

(b) participation obligations for activity-tested payments, including possible exemptions from the activity test;

(c) how to calculate the effect of taking up paid work on income support payments; and

(d) incentives to take up paid work, for example through Working Credit, Work Bonus, the employment income nil rate period and retention of concession cards.

[31] The Treasury, Australia’s Future Tax System: Final Report (2010), 494.

[32] Ibid, 489.

[33] P Whiteford, ‘Transfer Issues and Directions for Reform: Australian Transfer Policy in Comparative Perspective’ in Melbourne Institute—Australia’s Future Tax and Transfer Policy Conference Proceedings of a Conference (2010) 20, 20.

[34] Australian Institute of Superannuation Trustees, Submission 47; J Willis, Submission 42; Queensland Tourism Industry Council, Submission 28; National Seniors Australia, Submission 27; Olderworkers, Submission 22.

[35] DEEWR, DHS and FaHCSIA, Submission 101.

[36] Ibid.

[37] Australian Chamber of Commerce and Industry, Submission 85; COTA, Submission 51; L Masters, Submission 36; National Seniors Australia, Submission 27; J Walker, Submission 20; Commonwealth Ombudsman Office, Submission 16; My Longevity Pty Limited, Submission 15; L Gabor, Submission 05; W Trinder, Submission 01.

[38] National Seniors Australia, Submission 92; L Masters, Submission 36; National Seniors Australia, Submission 27; Commonwealth Ombudsman Office, Submission 16.

[39] DEEWR, DHS and FaHCSIA, Submission 101.

[40] Ibid.

[41] Federation of Ethnic Communities’ Council of Australia (FECCA), Submission 80.

[42] COTA, Submission 51; National Welfare Rights Network, Submission 50; Australian Institute of Superannuation Trustees, Submission 47; Australian Chamber of Commerce and Industry, Submission 44; J Willis, Submission 42; L Masters, Submission 36; Olderworkers, Submission 22; My Longevity Pty Limited, Submission 15; L Gabor, Submission 05.

[43] National Welfare Rights Network, Submission 50.

[44] Australian Chamber of Commerce and Industry, Submission 44.

[45] National Seniors Australia, Submission 92.

[46] COTA, Submission 51.

[47] DEEWR, DHS and FaHCSIA, Submission 101.