The First Assistant Secretary
Community and Economic Development Division
Department of the Prime Minister and Cabinet
1 National Circuit Barton ACT 2600
We, the Kimberley Alliance K3 comprising three CDP providers (Kullarri Regional Communities Inc.
(KRCI), Marra Worra Worra AC and Winun Ngari AC) support the Social Security Legislation
Amendment (CDP) Bill 2015 with its key elements stipulated in the Consultation Paper as ‘payments
to be made by local providers’, ‘payments to be made weekly’ and ‘increased income thresholds',
and promote its implementation to our Region subject to the following changes applied to the
legislative instrument referred to in the Consultation Paper, which ‘will set out in detail changes to
rights, responsibilities and obligations that a remote job seeker must meet while in receipt of income
support’.
We understand that the proposed simplified compliance framework is a step in the right direction in
reducing red tape by diminishing the role of DHS, by applying ‘a no show penalty calculated based on
hourly attendance reflected in weekly payments’, and introducing a compliance review ‘where a job
seeker attends less than 25 per cent of their required hours of mutual obligations’.
However, these amendments highlight but do not eliminate the fundamental flaw of CDP and the
reason why CDP2 will eventually be less successful than CDEP. The proposed changes to CDP focus
on the administration of individual welfare payments and not on community development and
community based engagement. Albeit its name CDP2 continues to center around the fulfillment of
mutual obligations by the job seeker in work-like activities in exchange for receipt of benefit
payments termed ironically ‘work for the dole’. Consequently, the program does not build job seeker
skills incentivizing them to participate, but applies penalties for non-participation. In its current from
CDP2 would equally follow a closed and negative paradigm as the increased income thresholds in
conjunction with a mutual obligation of 25 hours for social benefit payments would de facto hardly
impact a job seeker’s income unless a job seeker would embark on an extremely well remunerated
job or work weekly hours beyond any National Employment Standards. We therefore propose an
open and positive paradigm where financial incentives for job seekers adequately reflect their
engagement in work-like activities tightly linked to community development.
Centerpiece of our proposal is a reduction of the mutual obligations to max. 15 hours weekly as in
metropolitan areas under JobActive;
Mutual obligations would be remunerated equivalent to national minimum wage levels;
Additional hours in work like activities would be remunerated on an hourly rate based on minimum
wage levels;
The compliance framework would be simple and effective based on an open and positive paradigm:
Remuneration would be reduced to basic payment for valid non-attendance (within max. 15 hours
weekly);
No show no pay for invalid non-attendance (within max. 15 hours weekly);
Persistent invalid non-attendance over 10 business days would trigger a compliance review leading
to revision of job seeker’s activities or supports, assessment of job seeker’s capacity or waiver of no
show no pay policy due to financial hardship;
Cancellation of income support would de facto take immediate effect under a no show no pay policy
for invalid non-attendance but would be formalized for invalid non-attendance over 28 days;
Given the possibilities of incentivizing work and mixed income sources we propose a mandatory
registration of all job seekers on myGov. This will safeguard the jobseeker from incorrect income
declaration with severe consequences on the part of the Australian Tax Office. The provider would
monitor the usage of myGov by the job seeker;
The provider reports on utilization of funds dedicated to program administration, work-for-the-dole
activities, training activities and remuneration in regards to job seekers fulfilling mutual obligations
and additional hours.
We believe a positive and open paradigm will increase participation of job seekers in WfD Activities,
enhance Community Development and, eventually, boost career prospects for job seekers on job
pathways.
This submission is to be regarded as a starting point in designing and drafting the legislative
instrument that ‘will set out in detail changes to rights, responsibilities and obligations that a remote
job seeker must meet while in receipt of income support’ and we as the Kimberley Alliance hereby
express our interest in working together with PM&C on this matter.
Above all, we believe that Aboriginal Corporations delivering CDP on communities successfully such
as the above mentioned members of the Kimberley Alliance need to be regarded as the partners of
choice for PM&C in rolling out the next phase of CDP2.
20 April 2016
The Kimberley Alliance K3 comprising:
Kullarri Regional Communities Inc. (KRCI)
Marra Worra Worra AC
Winun Ngari AC