Wednesday, 10 December 2025

Regulatory oversight and the delivery of mainstream income support

 

Through tatter'd clothes small vices do appear;

Robes and furr'd gowns hide all. Plate sin with gold,

And the strong lance of justice hurtless breaks;

Arm it in rags, a pigmy's straw does pierce it.

King Lear, Act four, Scene six.

In September the Guardian reported (link here) that some 300,000 Centrelink payment recipients had their payments unlawfully cancelled because of a glitch in the IT system that runs the mutual obligations scheme embedded within the social security system. The Guardian article stated:

The analysis from Economic Justice Australia shows about 310,000 people had their Centrelink payments unlawfully cancelled between 2020 and 2024 because they were not given enough time to reconnect to a job provider after missing a compulsory activity as part of their mutual obligations.

Jobseekers are required to meet mutual obligation requirements – such as attending meetings with an employment provider and applying for jobs – to continue to receive their payments. After jobseekers receive five demerits in the mutual obligation system, they enter what is called the “penalty zone”, where they risk having their payment completely cancelled.

The Guardian article linked to a previous report where the Commonwealth Ombudsman had found 964 persons had their payments illegally cancelled. The Employment and Workplace Relations Department (DEWR) later found additional unlawful cancellations and the mutual obligation system was placed on hold.

A second Report from the Commonwealth Ombudsman has just been issued titled Fairness in the Targeted Compliance Framework: when decisions are made beyond your control (link here) which follows up on the Ombudsman’s previous report. The Mandarin provides a short summary of the report too (link here). Both these reports deal with mainstream income support and do not apply to remote regions where the Community Development Program (CDP) administered by NIAA and DEWR operates (link here and link here). Importantly however, the same IT systems that underpin mainstream program administration are utilised for CDP.

I don’t propose to attempt to unpick the administrative detail that underpins the delivery of income support but instead point to two important elements revealed by the Ombudsman’s valuable analysis.

First, Indigenous citizens are over-represented in the unlawful cancellations. Bear in mind, these are citizens residing in urban and regional Australia, not remote communities. The Reports states (page 11; footnote removed):

Of the 985 unlawful cancellation decisions affecting 964 job seekers between 8 April 2022 and 4 July 2024 (affected job seekers), First Nations People were disproportionately represented:

·         16%:  Average number of First Nations People who accessed Workforce Australia Services between 1 October 2022 – 30 June 2024

·         46%:  First Nations People who were identified to have had their payment unlawfully cancelled between 1 April 2022 – 4 July 2024

Further, 24% of affected job seekers had one or more of the following vulnerability indicators attributed to them: • psychiatric problem or mental illness • illness or injury requiring frequent treatment • significant lack of literacy and language skills • drug or alcohol dependency which impedes compliance • recent traumatic relationship breakdown • homelessness (beyond the control of the job seeker) • cognitive or neurological impairment and • significant caring responsibilities.

I have quoted the related vulnerability indicators as Indigenous citizens are undoubtedly over-represented in many of these categories. They point to the deep systemic issues in play that point to the importance of considering issues beyond Indigenous status in seeking the causes of the underlying drivers of disadvantage.

Bearing in mind the finding by Economic Justice Australia that the total numbers of unlawful cancellations was over 300,000 between 2002 and 2024, the number of Indigenous citizens adversely affected is likely considerable, perhaps in excess of 45,000 over the relevant period.

Second, the Ombudsman’s most recent report makes a finding related to the apparent underinvestment in compliance oversight of the providers by DEWR (see pages 44-47). I have extracted four paragraphs from the report which I suggest are worth considering (emphasis added):

As discussed in Finding 5, DEWR and Services Australia are overturning provider decisions at a high rate. When incorrect decisions are being made by providers at such high percentages, we cannot be assured that DEWR’s prevention and education strategies are sufficient or should not be complemented with a more rigorous approach to deterrence and sanctions. Given the program has been active for more than 3 years, we would have expected more compliance activities against providers.

Our concerns of the lack of transparency for provider performance were heightened when we observed that there appeared to be nominal compliance actions taken against providers. A lack of provider performance transparency combined with nominal compliance actions against providers, in an environment where a high rate of provider decisions are overturned, could point to an oversight design where providers are not being held accountable for poor performance.

In comparison, job seekers are very frequently subject to potentially catastrophic penalties for perceived failures to comply with mutual obligation requirements. In 2023-24, providers issued 1,373,295 income support suspensions to 734,220 job seekers; of these, 6,895 job seekers were subject to financial penalties.

Providers are paid significant amounts by the Australian government to deliver services to job seekers. In 2024-25 DEWR spent approximately $1.256B on Workforce Australia, 74% of DEWR’s spending on employment services.

Conclusion

My own takeout from the release of this report is threefold:

First, the implementation of outsourced program delivery arrangements requires high quality and independent regulatory oversight if the public interest is going to be served. What is almost always absent in our whole of government thinking about the delivery of basic services is the quality of regulatory oversight. I do not doubt that there are downsides to excessive regulation in some policy spaces, but to the extent that the incessant and longstanding campaign against regulation is broad bush and not nuanced, it should be seen for what it often is: ideological special pleading.

Second, there is a case for our core accountability institutions to shift more attention to focussing on the issue of whether governments are under-investing in regulatory oversight across the board (rather than in focussing on whether particular programs or (worse still) program clients are involved in fraud, inefficiency or maladministration. My sense is that at least in areas where the recipients of government services are comparatively voiceless, that this regulatory underinvestment is endemic and indeed a key element in driving or exacerbating systemic (and seemingly intractable) disadvantage as appears to be the case in the income support /social security system.

Third, in terms of Indigenous policy, the mainstream policy realm matters. While the extent of disadvantage and need is arguably more intense in remote regions, the issues facing non-remote indigenous citizens are quantitatively and qualitatively significant and structurally embedded. The National Agreement on Closing the Gap includes as one of four Priority Reforms a reform focussed on the transformation of mainstream institutions (link here). However, the underpinning detail is all about the processes used by agencies to deliver mainstream programs and says nothing about the importance of high-quality mainstream regulation in ensuring Indigenous citizens access mainstream programs equitably. This may appear to be a very fine distinction, but I would argue that it is a crucial distinction that deserves more thought by the Joint Council on Closing the Gap.

 

10 December 2025

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