The Australian Greens oppose the measures contained in the Social Security (Administration) Amendment (Income Management and Cashless Welfare) Bill 2019 (Bill).
The Bill will extend the Cashless Debit Card trial in the East Kimberley, Ceduna and Goldfields trial sites to 30 June 2020. These three trial sites were due to end on 30 June 2019. This is the third extension of these trial sites. The Bill will also extend the Cape York income management program to 30 June 2020. It is currently due to end on 1 July 2019.
The Australian Greens note that this is the fourth legislation inquiry into the Cashless Debit Card and that our dissenting reports to the previous bills' inquiries continue to remain relevant.
We continue to hold significant concerns about compulsory income management and the lack of proper consultation of people affected by the card. We also continue to hold serious concerns that the Cashless Debit Card perpetuates indirect race, disability and gender discrimination. We note that the objectives of the Bill continue to be based on flawed evidence.
The Australian Greens reject the committee view in the majority report that the Cape York income management program and the Cashless Debit Card trial are having a positive impact on communities. The trial sites have clearly demonstrated compulsory income management causes unwarranted emotional, financial and psychological harm to some of the most vulnerable people in Australia.
Flawed evaluations
As noted in previous inquiries, the inquiry heard how the first evaluation of the Cashless Debit Card, known as the ORIMA evaluation, was flawed. This was supported by findings from the Australian National Audit Office's review of the ORIMA evaluation. Despite these findings, the Government continues to use the ORIMA evaluation as a justification for extending the Cashless Debit Card trials.
Several submitters highlighted the problematic nature of relying on evidence from the flawed ORIMA evaluation as a rationale for extending the trials.
The Social Services peak body ACOSS notes in its submission:
The Australian National Audit Office (ANAO)'s review of the Orima evaluation of cashless debit found that there is inadequate evidence to determine whether this policy has reduced social harm. ACOSS questions how the government could extend a policy that greatly restricts people's freedoms without any credible evidence that it is meeting its objectives.
Dr Janet Hunt from the Australian National University notes in her submission:
This poor Orima Evaluation of the Cashless Debit Card in Ceduna and the East Kimberley, is still relied on in the Explanatory Memorandum for this Legislation as justification for the extension of this trial in Ceduna and East Kimberley despite the fact that in 2018 the Australian National Audit Office itself vindicated my arguments about the poor quality of the evaluation and concluded that the Department of Social Security's "…approach to monitoring and evaluation was inadequate. As a consequence, it is difficult to conclude whether there had been a reduction in social harm and whether the card was a lower cost welfare quarantining approach."
Further, Dr Elise Klein from the University of Melbourne provided evidence about the significant problems with using evidence from the ORIMA evaluation. Dr Klein said at the hearing:
Third, I am particularly concerned at the government's evaluation processes. While the ORIMA evaluation for the East Kimberley and Ceduna has been thoroughly discredited by a number of credible academics as well as the Australian National Audit Office, the government still continues to deploy this evaluation to promote the trial for the Kalgoorlie and Hinkler regions and, again, even in the explanatory memorandum for the current bill we are discussing. This goes against the basic logic of a trial. For the cashless debit card trial to actually be a trial, it does need to be rigorously and independently evaluated, which would mean that such an evaluation of methodological and analytical quality would be completed in a timely fashion to inform deliberation into whether the trial should continue, let alone be expanded. This has not happened in the case of the cashless debit card, and now to ask for an extension without supporting evidence of its benefit can only be either ideological or illogical.
The Australian Greens have serious concerns about the Government continuing with compulsory income management on the basis of a flawed evaluation that has been widely discredited by the academic community and the Australian National Audit Office.
Inadequate baseline studies
Since the ORIMA reports, there continues to be significant issues with evaluations of the Cashless Debit Card across the three trial sites. The Government is justifying an extension of the Cashless Debit Card on the basis that it will provide enough time for findings from a second evaluation of the program to be completed. Yet the inquiry heard extensive evidence that more recent evaluations, including the Goldfields study, are repeating the same shortcomings as the ORIMA report.
Dr Shelley Bielefeld from the Australian National University notes in her submission:
The recently released Goldfields Cashless Debit Card report conducted by the University of Adelaide replicates many of the same failings in the Orima reports so justifiably critiqued by the ANAO. It provides:
no credible baseline data,
no representative sample of program participants,
no evidence of CDC program success,
numerous unsubstantiated interpretations,
numerous leading questions that pre-empt the government's desired response in the structure of the questions asked, and
much of the same waffly anecdote that has previously characterised government-commissioned research in this area.
Dr Janet Hunt explains in her submission that to be a genuine baseline study, it needs to occur before the intervention starts:
There is reference to the so-called "Baseline Study" in the Goldfields. This is not a bad qualitative study but it is not what I would consider a genuine baseline study – it was not undertaken to assess social conditions in the Goldfields before the intervention (ie CDC) was introduced. The fieldwork for this study was undertaken between June – September 2018, i.e. at least 3 months after the introduction of the CDC (which began March 2018). This may not have been the fault of the evaluation team, and they clearly tried to get a qualitative assessment of conditions before the card was introduced. However, a baseline should be undertaken prior to an intervention and subsequent evaluation undertaken after a period which is judged adequate for signs of the effects of the intervention to be evident.
The Accountable Income Management Network notes in its submission:
Further, only qualitative findings are presented, and there was no reference to supplementary administrative data. The report also notes that just over half of stakeholders interviewed were not CDC trial participants, but were instead government employees or employees of partner organisations, community organisations etc.
The Queensland Council of Social Services explains in its submission why the timing of the second evaluation does not justify the extension of the trials:
A key reason provided for extension in the Explanatory Memorandum of this Bill is to "provide sufficient time for the findings of a second evaluation of the program to be finalised". However, the Department of Social Services reported to Senate Estimates that the Impact Evaluation for the first three trial sites will be completed by June 2019. This makes this reason for the extension invalid.
The Australian Greens continue to hold serious concerns about the Government's failure to undertake rigorous evaluations of the Cashless Debit Card trials. Information from previous evaluations does not justify the punitive measures of compulsory income management.
We are also concerned that the Government is using the Goldfields study as the basis for its evaluation of that trial site. This is problematic given the Goldfields report is a perceptions study, does not provide quantitative baseline data and cannot be relied upon as a justification for extending the trials.
Continuous extensions of trial sites
The Australian Greens are concerned that this is the third extension of the Cashless Debit Card trials, resulting in an incredibly long 'trial' of the same program. The Cape York income management program has been operating for over a decade now.
The Accountable Income Management Network notes in its submission:
It is unreasonable and disingenuous of the government to conveniently frame the CDC as a trial, with the attendant room for error that this status affords.
Dr Shelley Bielefeld from the Australian National University notes in her submission:
In closing, I ask the Committee to consider 'when is a trial no longer a trial?' The CDC program – initially intended to be for a short time frame – is now proposed to be extended to five years – despite the absence of any compelling evidence that it makes a positive difference. This is deeply problematic. However, this trend is also seen in the proliferation of BasicsCard 'trials' in the Northern Territory, Place Based Income Management sites and Cape York. With more than ten years of 'trials' regarding compulsory income quarantining, this approach looks increasingly like an 'embedded' feature of Australia's social security landscape.
Dr Eve Vincent provided evidence at the hearing about the impact the continuous extensions are having on people in Ceduna trial site:
It's a mixed picture, but many of the people drawn to talk to me were drawn because they felt that they had not had a voice in the process of its implementation and the extension of this trial—so-called. People were very cynical about the notion that it was still a trial. It did not speak to their experience of an anxiety inducing dimension to their lives. They didn't know that they could depend on the card, and they felt targeted, shamed, stigmatised, identified in some way, and that that had done nothing to support or alleviate the very difficult circumstances that many of them faced—in fact, it had become another site of hardship in their lives.
The Australian National University Centre for Social Research and Methods highlights the lack of exit strategy for these trials:
A key concern which we have identified in the evaluation work we have undertaken and in reviewing other initiatives including the cashless debit card, is that of a lack of any coherent exit strategy, other than in the Cape York initiative where people are placed on income management for a defined period. As identified above these programs have a tendency to promote dependence and lock in. We further note that notwithstanding initial claims of these policies being introduced as short term measures, usually with a one or two year duration that they have rather been continually extended, most notably in the Northern Territory where the "initial period of twelve months" announced in 2007 (Brough 2007), is now into its eleventh year.
We are extremely disappointed that the Government continues to extend compulsory income management without credible evidence that the trials are meeting their stated objectives. We also wish to express our concerns about the lack of exit strategy for people on the Cashless Debit Card.
Consultation
A number of submissions note concerns about the lack of consultation and re‑engagement with communities following implementation of the Cashless Debit Card.
In its submission, the MG Corporation notes:
Prior to the implementation of the card the government was meeting with us regularly to ensure genuine partnership and co design of the implementation of the CDC. However, since the CDC was introduced there has been no transparency from those working in the space, nor honest collaboration between the government and community members. Since the card has been introduced there has been no collaboration between service providers, nor any transparency about the funding they are receiving, the programs they are providing, or how successful they have been in alleviating local people off welfare. We were promised that we would have genuine co design and development of the CDC and have a say in how it would work in our town and for our people. This unfortunately, has not happened.
At the hearing, Trevor Donaldson from the Goldfields Land and Sea Council provided the following evidence when asked if he was aware of any consultation that had been undertaken since the implementation of the Cashless Debit Card:
Not that I'm aware of. It frightens me at the minute that there's a delegation of people heading towards Warburton to discuss putting our mob up there on it. I don't know if there are any Aboriginal people on that delegation. That's scary, because we're looking at the Goldfields here at the moment, which is under the trial, [inaudible] even more so. But we should just be looking at our mob here at the moment. No, none of those other agencies have, I don't believe, consulted our mob here in a proper and fair manner.
The Accountable Income Management Network notes in its submission:
The CDC trials have been expanded and extended into community after community despite a clear lack of appropriate community consultation as well as the concern and consistent critique voiced by community members, academic experts and non-government organisations working in direct service provision.
The Australian Greens believe the Government has not undertaken sufficient consultation with communities, particularly First Nations communities, prior to or following implementation of the Cashless Debit Card and extension of the three trial sites.
The Australian Greens reject the committee view in the majority report that the Department of Social Services have continued to consult with stakeholders about the implementation and extension of the Cashless Debit Card trials.
Cape York income management
This Bill also seeks to extend the Cape York income management program to
1 July 2020. We note that income management in Cape York operates very differently to the Cashless Debit Card. Under this program, conditional income management orders are issued for a set period of time and determine what percentage of income will be quarantined.
The Australian Greens have concerns about the compulsory nature of income management in Cape York. We are also concerned by the Government's recent announcement to introduce the Cashless Debit Card in the Northern Territory and Cape York, especially given harmful effects the Cashless Debit Card has had on First Nations communities in the current trial sites.
Conclusion
We are disappointed with the Government's continued attempts to enforce compulsory income management. The evidence demonstrates compulsory income management does not work, is not meeting its stated objectives and is being extended on the basis of flawed data and ideology.
The Government's approach calls into question its ability to conduct evidence‑based evaluations of trial programs.
Compulsory Income Management in all its various forms should be abandoned and the resources invested in approaches that are therapeutic, individualised and are genuinely supported by the community.
Recommendation
The Australian Greens recommend that the Bill not be passed.