Family assistance

Background

135. The Commonwealth has provided family allowances since 1941.[135] The current framework for family assistance comprises a range of payments and is primarily governed by two statutes: A New Tax System (Family Assistance) Act 1999 and A New Tax System (Family Assistance) (Administration) Act 1999. These Acts are referred to in this Issues Paper as the Family Assistance Act and the Family Assistance (Administration) Act respectively.

136. In replacing the previous family assistance scheme, this legislative framework aimed to ‘simplify the structure and delivery of assistance for families’[136] by establishing one body to administer a consolidated set of payments, all of which would have ‘similar eligibility rules’.[137] These payments play a significant role in supporting low-income families.[138]

137. Centrelink administers ‘family assistance payments’ on behalf of the FAO.[139] Such payments comprise a range of types, including: family tax benefit (FTB),[140] baby bonus,[141] maternity immunisation allowance,[142] child care benefit,[143] child care rebate,[144] and FTB advance.[145] As of 1 January 2011, paid parental leave is available. In addition to these payments, the FAO offers other types of support, such as rent assistance.[146]

138. The Family Assistance Guide is available online at the website of the Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA).[147] As noted above, guides, as articulations of policy, are not binding in law, but nonetheless are a relevant consideration for the decision maker.

Definition of family violence

139. Neither the Family Assistance Act nor the Family Assistance (Administration) Act provides a definition of ‘family violence’. The Family Assistance Guide also leaves the term undefined.[148]

140. As noted in the context of the discussion on child support, it may be desirable for definitions of family violence to be included in primary legislation. In ALRC Report 114 the Commissions recommended a consistent definition of family violence in state and territory family violence and criminal legislation, and the Family Law Act. As discussed above, including this definition in relevant Commonwealth laws, such as family assistance legislation, may increase clarity and certainty for victims of family violence, by ensuring that the violence they have experienced will be recognised and treated similarly across all Commonwealth laws.

Question 30 Should family assistance legislation be amended to insert a definition of family violence consistent with that recommended by the Australian Law Reform Commission and NSW Law Reform Commission in Family Violence—A National Legal Response (ALRC Report 114)?

Family Tax Benefit

141. FTB is an income-tested payment for eligible parents and carers. FTB includes 2 parts: FTB Part A and FTB Part B. FTB Part A is discussed above in relation to child support. FTB Part B is a benefit for eligible single parent families and families with one primary income earner. The rate of FTB Part B depends on the age of the youngest child and, in families with two working parents, the income of the parent who is the secondary income earner.[149]

142. FTB is paid for dependent children under the age of 16 and, in certain circumstances, for dependent children over the age of 16.[150] Parents and carers must provide at least 35% of a child’s care to receive FTB.[151] When more than one person provides care for a child, and they are not members of the same couple, FTB payments can be shared.[152]

143. The ALRC has identified several ways which FTB-related legislation and policy may affect victims of family violence, namely:

  • the methods by which the FAO determines the ‘percentage of care’ in cases where FTB is shared;

  • policies regarding the payment of FTB in cases of informal care, when a child may be at risk of harm; and

  • exemptions from tax file number requirements in cases of family violence.

Percentage of care

144. Persons who provide shared care for a child—defined as more than 35% of care[153]—may receive FTB payments. The percentage of care affects how FTB is apportioned between persons who share care of a child. It is worth noting that the percentage of care is not the same as the percentage of FTB payable to the parent or carer. As noted above, since 1 July 2010, the FAO and the CSA determine care percentages in the same way,[154] and each agency will apply a percentage of care determined by the other agency.

145. The Family Assistance Guide provides that the FAO may consider various sources in order to determine the care percentage, where parties disagree as to the arrangements that are in place. It provides that each party should be asked to provide evidence to support their claim, and lists a wide range of examples of evidence which may be taken into account.[155] In addition to parenting plans, written agreements, and court orders, the FAO will consider evidence such as:

  • confirmation of play group, kindergarten or school enrolment,

  • proof of attendance or membership of local organisations or activities,

  • receipts for expenses incurred while the child was in care,

  • confirmation of care arrangements from close family friends or relatives,

  • confirmation from professional members of the community who have regular contact with the family, such as teachers, police, ministers of religion, accountants, lawyers or doctors,

  • social worker reports, especially in cases where there may be a fear of violence if the other parent is contacted,

  • proof of travel arrangements at contact times (e.g. rail or airline tickets), and

  • records from the FAO or other government agencies which may confirm present or previous patterns of care …[156]

146. The FAO, like the CSA, will not seek verification about care from a child.[157]

147. The ALRC is interested in comment as to whether stakeholders consider the method of determining the care percentage for family assistance purposes—including in interim determinations and cases where parents dispute the care that is occurring—appropriate in cases of family violence.

Question 31 In what ways, if any, can the legislative basis for Family Assistance Office determinations about the percentage of care, be improved for victims of family violence?

Question 32 In what ways, if any, can the rules, as stated in the Family Assistance Guide, for the Family Assistance Office to verify actual care when parents dispute the care that is occurring, be improved for victims of family violence?

Children in formal and informal care

Original carer no longer has care of a child

148. FTB is paid to the person providing actual care for the child, where possible.[158] Family assistance legislation and the Family Assistance Guide set out the effect on FTB payments when there is a change in care, and a child is no longer cared for by their original carer.[159] The original carer is likely to be the child’s parent or parents.

149. Where a person no longer has care of a child, he or she is required to notify the FAO.[160] In some cases, the original carer may continue to receive FTB where the child is not in his or her care. Generally, however, the original carer should not receive FTB for more than a four-week period in these circumstances. After four weeks, the person providing informal care should receive the FTB payments.[161] However, if the original carer has legal responsibility for the child, did not consent to the change in care, and takes reasonable steps to seek the return of the child, he or she may receive FTB for up to 14 weeks.[162]

Formal and informal care

150. The Family Assistance Guide distinguishes between formal and informal care. Formal care occurs where there is a change in legal responsibility for the child, usually under state and territory care and protection legislation. People who provide formal care are generally foster carers. By contrast, informal care is ‘a private agreement between the parent and another party, where there is no change to any form of legal responsibility’.[163] Grandparents, relatives and family friends are identified as persons who usually provide informal care.[164]

151. Those with formal care of a child, like foster carers, can obtain FTB. In cases of informal care, FTB payments are contingent on the ‘nature and duration of the absence from the parent’s care’.[165]

Informal care not in child’s best interests

152. The Family Assistance Guide provides principles for dealing with cases when informal care arrangements may not be in the best interests of a child.[166] It states that a case should be referred to a social worker where:

  • the child is not a family member of the person claiming FTB or a social security payment that is dependent on the provision of care for a child, and

  • the person has not supplied documentation to support that the child is legally in his or her care, or

  • the person has previously lost care of children.[167]

153. Examples are provided of care arrangements that may not be in the child’s best interests—such as those in which the child’s well-being or daily needs are disregarded, the child is exposed to drugs or alcohol, or there is a ‘lack of guidance and oversight’.[168] Family violence is not specifically mentioned.

154. The Family Assistance Guide prescribes a broad role for Centrelink social workers in these cases. It includes obtaining information about the reason for the change in care and how long the arrangement is likely to last, contacting the original carer, and making a recommendation to the FAO about FTB and other payments. Social workers may also seek approval to disclose information to a state welfare authority.[169] The ALRC understands that Centrelink social workers may also provide support services to carers and children in these circumstances. Where the child is Indigenous or a refugee child, social workers are required to consult with ISOs and Multicultural Service Officers (MSOs).[170]

155. The Family Assistance Guide provides that where FTB to the original carer is cancelled due to a change to informal care, it should be cancelled only after the social worker has made a recommendation. The social worker’s recommendations must be given ‘due weight’.[171]

156. The ALRC is interested in whether, in practice, such cases are referred to social workers. The ALRC is also interested in the effect of cancelling FTB payments to original carers, and the effect of FTB payments to new carers, where children are at risk of, or have experienced, family violence.

Question 33 What reforms, if any, are needed to ensure that the Family Assistance Office identifies, and refers to social workers, cases in which children living in informal care may be at risk of harm because of family violence?

Question 34 What reforms, if any, are needed to improve the safety of children considered at risk of family violence, when the Family Assistance Office, due to a change in care, cancels a former carer’s Family Tax Benefit, or starts paying Family Tax Benefit to a new carer?

Exemption from Tax File Number requirements

157. An individual applying for FTB must provide both a tax file number (TFN)[172] and a TFN for his or her partner during the relevant payment period.[173] If a person either does not know his or her TFN or is currently applying for one, then the person may authorise the Commissioner of Taxation to share his or her TFN with the FAO and file a statement to that effect.[174]

158. There are limited circumstances in which an individual may qualify for an exemption from providing a partner’s TFN, including where a partner is violent, imprisoned for life, or seriously ill or disabled.[175] In particular, an indefinite exemption may be granted when the applicant has a ‘well based reason’ to believe that requesting the partner’s TFN may cause the partner to ‘become violent to the applicant or a child’ or cause ‘other concerns for the safety or the health of the applicant or a child’.[176]

159. The Family Assistance Guide provides that these cases are determined on request. Requests are referred to a social worker or an ISO for advice and assistance.[177] The ALRC is interested in whether victims of family violence are aware of, and are obtaining, exemptions from the TFN requirement, where appropriate.

Question 35 What, if any, improvements are needed to ensure that applicants for family assistance are aware of, and using, the exemption from providing their partners’ tax file numbers in cases of family violence? Should A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) expressly refer to family violence as an example of an indefinite exemption?

Baby bonus

160. The baby bonus is a flat rate payment—currently $5,294—to assist with the costs of a newborn or adopted child.[178] It is generally paid in 13 fortnightly instalments[179] to a parent of a child or a person who cares for or adopts the child.[180]

161. The Family Assistance Guide discusses the payment of the baby bonus by instalments and referrals to a social worker or a specialist officer—that is, ISOs and MSOs. The Family Assistance Guide states that young people, especially those 17 years or younger, are ‘generally inexperienced in handling large sums of money and/or may be subject to pressure to use the payment unwisely’.[181] These applicants must be referred to a social worker, ISO or MSO to discuss available services such as financial planning and support groups.[182]

162. Some applicants who are older than 17 are also referred to social workers or specialist workers. This includes applicants who have experienced family violence, have had a child subject to child protection, are considered ‘vulnerable to exploitation’, or may be ‘subject to pressure to use the payment unwisely’.[183] The social worker, ISO or MSO will assess the needs of, and the support required by the applicant, and will provide information and referrals regarding appropriate services to the applicant.[184]

163. As discussed above, family assistance legislation and the Family Assistance Guide do not contain a definition of family violence. A legislative definition of family violence that is consistent across family assistance, social security and child support legislation, may assist social workers and specialist officers in determining whether a person has been the victim of family violence. In particular, the definition’s treatment of economic abuse may assist in determining when an individual may be subject to pressure or exploitation in relation to baby bonus payments.

164. The ALRC is interested in whether, in practice, victims of family violence are referred to social workers, ISOs and MSOs, when claiming the baby bonus, particularly in light of the lack of screening for family violence by Centrelink, as discussed above.

165. The ALRC is also interested in whether these officers have sufficient access to information about family violence protection orders and child protection orders related to the baby bonus applicant. As noted above, providing social workers with access to a national register may assist them in obtaining relevant documentation to assist victims of family violence, but may also lead to privacy concerns.[185]

Question 36 What, if any, reforms are needed to ensure that baby bonus applicants who are victims of family violence are referred to social workers, Indigenous Service Officers and Multicultural Service Officers?

Question 37 What, if any, reforms are needed to ensure that social workers, Indigenous Service Officers and Multicultural Service Officers are able to access information about whether a baby bonus applicant has a protection order or a child subject to child protection?

Child Care Benefit

166. Child Care Benefit (CCB) is an income-tested payment that assists eligible parents and carers with the cost of child care. CCB is available to parents or carers responsible for child care costs where their children attend ‘approved child care services’[186]—services approved for the purposes of family assistance law.[187] The FAO website states that approved child care services meet

certain standards and requirements. This includes having a licence to operate, qualified and trained staff, being open certain hours, and meeting health, safety and other quality standards.[188]

167. The following services may provide approved care:

  • long day care services;

  • family day care services;

  • in-home care services;

  • occasional care services; and

  • outside school hours care services.[189]

168. CCB is also available where child care is provided by a person who has been approved as a registered carer by the FAO.[190] As discussed below, increased payments of CCB are available where children are at risk of ‘serious abuse’—but only where care is provided by approved child care services. The focus of this section is on whether increased payments of CCB effectively protect children who experience abuse. Therefore, CCB provided by registered carers will not be given further consideration.

169. CCB may be paid to the approved child care service and passed on to the person as a fee reduction; or the person may pay child care fees and claim CCB as a lump sum at the end of the financial year.[191] CCB only covers a limited number of hours of child care a week. A default limit of 24 hours per week applies to all eligible persons, and a limit of 50 hours per week applies where persons meet a ‘work/training/study test’,[192] or other conditions provided for in the legislation.[193]

Child at risk of serious abuse

170. Where an approved child care service considers a child is at risk of ‘serious abuse or neglect’, the FAO may grant more than 50 hours per week of approved child care,[194] or, where a 24 hour limit would have applied, raise the limit to 50 hours.[195] Additionally, the FAO may pay CCB at a higher rate.[196] The higher rate of CCB is described in the Family Assistance Guide and elsewhere—although not in the family assistance legislation—as the Special Child Care Benefit (SCCB). SCCB may be approved for up to the total amount of weekly child care fees.[197]

171. Increased weekly hour limits for CCB due to risk are sometimes also called SCCB, as on the Claim for Special Child Care Benefit and/or increased weekly limit of hours form.[198] However, the Family Assistance Guide provides that CCB for more than 50 hours of approved care due to risk is not the same as SCCB.[199]

172. If an approved service believes a child is at risk of serious abuse or neglect, it may approve SCCB or increased weekly hour limits for a maximum of 13 weeks.[200] Further periods of SCCB or increased weekly hour limits can be approved by the FAO.[201] The additional weekly hours can be paid at the SCCB rate.[202]

173. SCCB and increased weekly hour limits are available only in the form of reduced child care fees.[203] Lump sums at the end of the financial year are not available for these benefits.

Protective function

174. SCCB and increased weekly hours of child care have a protective function. The Department of Education, Employment and Workplace Relations and the Office of Early Childhood Education and Childcare state that the SCCB—including additional hours of CCB—is designed to support attendance at child care, where costs are a barrier,[204] so that:

  • the amount of time the child spends in the risk environment is reduced

  • the amount of time the child spends in a stable and developmentally beneficial environment is maintained or increased

  • the child remains ‘visible’ in the community and opportunities to link the family with other appropriate services are increased

  • the parent/carer has an opportunity for respite or to seek assistance from other agencies such as health and family support services.[205]

175. The ALRC is interested in whether an increase in the rate or weekly hour limits of CCB are accessible to child care services and families, where children are at risk of family violence. The ALRC is also interested in comment about whether the legislative requirement that a child be at ‘risk of serious abuse’ hampers accessibility to increased payments of CCB.

‘Abuse’ undefined

176. Family assistance legislation does not define ‘abuse’, and ‘serious abuse’. The Child Care Handbook directs child care services to a ‘commonly accepted definition of abuse and neglect’ in the National Child Protection Clearinghouse’s 2004 resource sheet, ‘What is Child Abuse?’.[206] Defining these terms in the Family Assistance Guide or family assistance legislation may assist parents and carers, child care services, and the FAO in considering eligibility and determining claims for SCCB and increases in weekly hours of CCB.

Question 38 Are increases in weekly Child Care Benefit hours and higher rates of Child Care Benefit sufficiently accessible in cases of family violence? What reforms, if any, are needed to improve accessibility?

Question 39 Does the legislative requirement that the child be at ‘risk of serious abuse’ serve as an unreasonable barrier to eligibility for higher rates of Child Care Benefit and increased weekly hours of Child Care Benefit?

Question 40 Should A New Tax System (Family Assistance) Act 1999 (Cth) and A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) be amended to insert definitions of ‘abuse’ or ‘serious abuse’? Should the Family Assistance Guide provide definitions of ‘abuse’ or ‘serious abuse?

Other issues

177. There may be other issues in the family assistance context which the ALRC has not identified in this Issues Paper but that are relevant to the safety of victims of family violence. The ALRC is interested in comment on any other areas of family assistance and practice that affect the safety of victims of family violence.

Question 41 Are there any other concerns about the interaction of family assistance law and practice and the protection of safety of victims of family violence? What reforms, if any, are needed to improve the safety of victims of family violence?

[135] P Whiteford and G Angenent, The Australian System of Social Protection: An Overview (2001), 12.

[136] Commonwealth, Parliamentary Debates, Senate, 24 May 1999, 5170 (I Campbell).

[137] Commonwealth, Parliamentary Debates, House of Representatives, 9 June 1999, 6417 (W Truss—Minister of Agriculture, Fisheries and Forestry).

[138] See Australian Institute of Health and Welfare, Australia’s Welfare 2005 (2005), 75.

[139] Child Support Agency, Website <http://www.csa.gov.au> at 7 March 2011.

[140]A New Tax System (Family Assistance) Act 1999 (Cth) pt 3 div 1.

[141] Ibid pt 3 div 2.

[142] Ibid pt 3 div 3.

[143] Ibid pt 3 div 4.

[144] Ibid pt 3 div 5.

[145] Ibid s 3, ‘family assistance’.

[146] Family Assistance Office, What Payments We Offer <http://www.familyassist.gov.au/payments> at 16 February 2011.

[147] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011.

[148] The Guide to Social Security Law, which is also hosted on the FAHCSIA website, does contain a definition of family violence. Department of Families, Housing, Community Services and Indigenous Affairs, Guide to Social Security Law <http://www.fahcsia.gov.au/guides_acts/> at 04 February 2011, [1.1.D.235].

[149] A New Tax System (Family Assistance) Act 1999 (Cth) sch 1 pt 4; Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov
.au/guides_acts/> at 1 March 2011, [1.1.2].

[150] FTB Part A may be paid for dependent children up to the age of 24 years old, and FTB Part B may be paid for dependent children up to the age of 18 years old. Generally, they must be in full time study. .A New Tax System (Family Assistance) Act 1999 (Cth) ss 17B, 22, sch 1 cl 29(3). Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov
.au/guides_acts/> at 1 March 2011, [2.1.1.10].

[151] A New Tax System (Family Assistance) Act 1999 (Cth) s 22(7).

[152] Ibid s 59, sch 1 cl 11.

[153] Ibid s 59(1)(b).

[154] The rules to determine the percentage of care in the Family Assistance Act reflect those in the Child Support (Assessment) Act. Ibid Part 3, div 1, subdiv D; and Child Support (Assessment) Act 1989 (Cth)pt 5 div 4 subdiv B.

[155] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.1.1.30].

[156] Ibid, [2.1.1.30].

[157] Ibid, [2.1.1.30].

[158] Ibid, [2.1.1.85].

[159] A New Tax System (Family Assistance) Act 1999 (Cth) s 22; Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov
.au/guides_acts/> at 1 March 2011, [2.1.60], [2.1.1.85].

[160] A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) s 25, Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.1.1.60].

[161] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.1.1.85].

[162] A New Tax System (Family Assistance) Act 1999 (Cth) s23; Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.
gov.au/guides_acts/> at 1 March 2011, [2.1.1.85].

[163] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.1.1.85].

[164] Ibid, [2.1.1.85].

[165] Ibid, [2.1.1.85].

[166] Ibid, [2.1.1.100].

[167] Ibid, [2.1.1.100].

[168] Ibid, [2.1.1.100].

[169] Ibid, [2.1.1.100]. A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) s 168 allows for the disclosure of information about a person in certain circumstances, including where the Secretary certifies it ‘necessary in the public interest’ in that case or class of cases; or where the person to whom the information relates authorises the information being communicated to another person.

[170] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.1.1.100].

[171] Ibid, [2.1.1.100].

[172] A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) s 7.

[173] Ibid s 3(1) (definition of ‘TFN claim person’).

[174] Ibid ss 8(4)–(5).

[175] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [4.1.1.20].

[176] Ibid, [4.1.1.20].

[177] Ibid, [4.1.1.20].

[178] Ibid, [1.2.2], [3.3].

[179] A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) s 47(1).

[180] A New Tax System (Family Assistance) Act 1999 (Cth) s 36. A person is not eligible for the baby bonus where he or she, or his or her partner, receives parental leave.

[181] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.4.3].

[182] Ibid, [2.4.3].

[183] Ibid, [2.4.3].

[184] Ibid, [2.4.3].

[185] See Question 13.

[186] This term is used in both the A New Tax System (Family Assistance) Act 1999 (Cth) and the A New Tax System (Family Assistance) (Administration) Act 1999 (Cth).

[187] A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) s 195(1). The A New Tax System (Family Assistance) Act 1999 (Cth) addresses eligibility for CCB at pt 3 div 4.

[188] Family Assistance Office, Website <http://www.familyassist.gov.au> at 16 February 2011.

[189] A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) s 194.

[190] See Ibid ss 209, 210.

[191] A New Tax System (Family Assistance) Act 1999 (Cth) ss 41(2), 43, 44; A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) ss 219B, 219BA; Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.
au/guides_acts/> at 1 March 2011, [1.2.4.].

[192] A New Tax System (Family Assistance) Act 1999 (Cth) s 54(2), (3).

[193] Ibid s 54.

[194] Ibid s 55.

[195] Ibid s 54.

[196] Ibid s 76(1). SCCB may also be available to families experiencing hardship. SCCB will only be considered in this Issues Paper in relation to children at risk of abuse.

[197] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.6.7].

[198] This form is available at Centrelink, Website <http://www.centrelink.gov.au> at 7 March 2011.

[199] Department of Families, Housing, Community Services and Indigenous Affairs, Family Assistance Guide <http://www.fahcsia.gov.au/guides_acts/> at 1 March 2011, [2.6.3.20].

[200] A New Tax System (Family Assistance) Act 1999 (Cth) ss 54, 55; s 77.

[201] Ibid ss 54, 55; s 81.

[202] Department of Education, Employment and Workplace Relations, Child Care Service Handbook, 2010–2011 (2010), 194, 196.

[203] A New Tax System (Family Assistance) Act 1999 (Cth) ss 54(10), 55(6), 73.

[204] Department of Education, Employment and Workplace Relations, Child Care Service Handbook, 2010–2011 (2010), 194, 196; Department of Education, Employment and Workplace Relations, Special Child Care Benefit for Children at Risk: Fact Sheet for Approved Child Care Services.

[205] Department of Education, Employment and Workplace Relations, Special Child Care Benefit for Children at Risk: Fact Sheet for Approved Child Care Services.

[206] Department of Education, Employment and Workplace Relations, Child Care Service Handbook, 2010–2011 (2010), 197.