The PPL scheme presented challenges in relation to determining eligibility and processing claims. The complex nature of the PPL scheme, derived from its significant interactions with existing tax, welfare and employment provisions, means there have been some intricate issues to address regarding both eligibility criteria and the processing of claims. See chapter 2 for a discussion of the scheme itself.
3.7.1 Determining eligibility
Parents are eligible for PLP if they:• Are the primary caregivers of a newborn or recently adopted child; and • Are an Australian resident; and
• Have met the PPL work test before the birth or adoption occurs; and
• Have received an individual adjusted taxable income of $150,000 or less in the financial year before the date of birth or adoption, or date of claim, whichever is earlier; and
• Are not working, from when they become the child’s primary carer until the end of the PPL period.
Full-time, part-time, casual, seasonal, contract, and self-employed workers are eligible for the scheme (Department of Human Services 2012).
In the first year of the scheme’s operation, some complexities in determining eligibility have arisen in cases involving secondary and tertiary claimant eligibility. The vast majority of applicants are mothers (see chapter 4). However, there are situations where the applicant is not the biological birth mother, for example, cases involving adoption, surrogacy or fathers taking PPL. Such cases can result in a lengthier claim process as processing staff may require more information than with standard claims.
3.7.2 Processing claims
Individuals can only be paid PLP once Centrelink has made a ‘payability’ determination, i.e., determining that PLP is indeed payable to that person. Individuals can lodge claims for PLP either pre-birth or post-birth. Pre-birth claims involve a two- stage determination process. The claim can be lodged up to three months prior to the expected date of birth or adoption and a claimant can be determined to be initially eligible. Following the birth or adoption, proof of birth or entry into care must then be provided at which point Centrelink will determine if the person is entitled to receive PLP. Individuals can also claim PLP post-birth by lodging a claim for payment and their proof of birth form at around the same time. The two stage eligibility and payability determination processes that occur at different times for pre-birth claims, usually occur at the same time for post-birth claims.
PLP claims can be submitted either electronically, or in paper form at a Centrelink office. Prior to 1 July 2012, paper claim forms could be lodged at Family Assistance Offices located in Centrelink and Medicare offices. According to MoPE data, the majority of PLP claims are made through on-line applications (85%; see chapter 4).
45 Customers who opt to submit a paper claim form do so for a variety of reasons, for example, their language background, inability to submit it on-line, not having the appropriate facilities at home or not having access to the internet. Customers who submit either an online or a paper claim are advised in the claim about any other information they need to provide, for example, residency requirements such as passport or citizenship papers, and proof of birth. The processing team follows up on any information required that is not provided at around the time of the claim. Payments will not commence until all the requested information, including proof of birth or entry into care, is provided.
The PI study shows that in the first months of operation, staff noted a number of issues in processing claims, primarily relating to confusion about proof of birth, the timing of payments and eligibility issues. Staff discerned that some confusion existed amongst claimants about pre-birth claims, which could be lodged up to three months before the expected date of birth or adoption. Some customers believed that by submitting a claim pre-birth they could request PLP payments prior to the birth. However, individuals cannot receive PLP until after a birth or adoption and only after proof of birth or entry into care has been provided and a ‘payability’ determination has been made.
The interviews with staff also revealed that claimants felt they were asked to provide information twice — during the pre-birth claim or post birth claim for payment and once again when providing proof of birth. Another area identified as creating confusion amongst potential PLP claimants was the need to decide whether to apply for BB or PPL. When staff were questioned about a potential claimant being eligible for both payments, they would direct them to the on-line estimator to assess which entitlement would be most beneficial for their particular circumstances.
A further issue with the initial processing of claims relates to the training provided to processing staff. Interviews with staff responsible for processing claims revealed that staff felt the processing of PLP claims took place on “an ongoing learning curve”, partly owing to the short period of training before the entitlements began and in part concerning the actual training received. Although some staff felt only minimal training was provided, training was generally considered to be adequate. Training materials were also provided in the form of electronic reference material, which described the procedures that staff needed to follow, both in terms of system procedures and in terms of explaining how the policy is implemented. These training materials, as well as system support and the availability of advisory staff with substantive expertise, helped the processing staff address some of the complexities they faced in processing claims. Moreover, many staff involved in processing PLP claims have extensive experience in processing similar claims such as BB and FTB, making them familiar with the ‘customer base’.
At least three factors impacted on the processing of PLP claims and the timeliness of claim processing during the initial year of operation. One factor was the use and popularity of the electronic claim form. The on-line claim form was considered by the implementation department to be more effective than the hard copy claim form as irrelevant sections of the form are avoided automatically, making the process more efficient. While the availability of an on-line claim form positively impacted the processing of PLP claims, two unrelated factors have caused various delays in claim processing.
46 Firstly, any necessary changes in on-line forms require a major systems release from Centrelink, which occurs every three months and have a long lead time and limited capacity for system changes. Time and money are needed to carry out these system updates, which can negatively impact the processing of PLP claims in the meantime. Secondly, an external factor which impacted on the timeliness of processing PLP claims was the series of natural disasters that occurred in Queensland in early 2011, specifically Cyclone Yasi and the Queensland floods. These natural disasters caused Centrelink to divert large sections of their processing capacity to process and deliver the Australian Government disaster recovery payments. This diversion of resources impacted on the processing of all Centrelink payments and services. In particular, family assistance claims were affected because they require staff with specialised skills to process them. The transfer of PLP processing staff to disaster recovery payment assessments in January 2011 had a direct influence on the processing teams as there was a lapse of three months between learning from the training that had been provided in December 2010 and their applied work when staff actually started to assess the bulk of PLP payments in March 2011. The situation was further amplified by the fact that the natural disasters occurred early in the year when staff numbers are traditionally lower owing to staff being on Christmas and New Year holidays. These factors led to the creation of a backlog of PLP claims, which meant that many claimants did not have their paperwork processed and claims verified within the usual 21 day timeliness standards. Staff reported that the delay in processing claims resulted in an increase in complaints from PLP claimants.
To address this issue, staff worked overtime on the backlog and extra staff were brought in to focus on Family Assistance payments. In September 2011, when processing staff were interviewed, the 21 day standard was still not being reached. However, by September 2011, processing staff reported that PLP claims were being prioritised ahead of other DHS claims. To achieve more processing within the 21 day standard, proof of birth forms were also given a higher priority during this time because payability determinations could not be made on claims until proof of birth and other necessary information was received.