3 Ongoing Contact and Communication with Jobseekers

Introduction

3.1. The employment services system depends heavily on effective contact and communication between the jobseeker on the one hand and Centrelink or a provider on the other. Our inquiries show that breakdowns in contact and communication account for a very large proportion of breaches. This might be because of non-receipt of a letter, inability to appreciate a letter, failure to understand the importance or relevance of information, difficulty in comprehending English, or other causes. More could be done to contact and communicate effectively with jobseekers and thereby to reduce the rate of breaching.

3.2. We have identified three principal issues which appear to be problematic:

• contacting jobseekers;

• effective communication;

• especially vulnerable jobseekers.

Contacting jobseekers

3.3. The most usual form of contacting jobseekers is by ordinary mail, using a standard form letter selected from a range of templates for different particular purposes. At the initial interview, Centrelink obtains the jobseeker's postal address and records it on their electronic file. Each fortnight, most jobseekers have to submit a continuation form in order to continue receiving their allowance. On that form, they have the opportunity to advise of a change of postal address. It seems clear that changes of address are not always recorded reliably in the jobseeker's file, let alone also being recorded in the files for other Centrelink payments that are made to that person or people associated with him or her, such as a spouse.

3.4. Our inquiries also show that the jobseeker's postal address on Centrelink's file may be different from the address known to a provider. Although jobseekers have an obligation to advise Centrelink of a change of address, they often believe that it is sufficient for that purpose to notify their provider. Conversely, they may notify Centrelink and believe that also constitutes sufficient notification to their provider. A common perception is that the "system" has been advised. This perception is compounded by the fact that most letters to the jobseeker, including most generated by the provider, are mailed by Centrelink on Centrelink letterhead. A provider is not obliged to tell Centrelink of a change in the jobseeker's address and Centrelink is not required to advise relevant providers. There is often a persistent dislocation in knowledge of the jobseeker's postal address, instead of systemic provision to ensure that changes in a jobseeker's address are known to both Centrelink and providers.

3.5. When a letter is sent to a jobseeker, Centrelink generally presumes that it is received by the jobseeker. Our inquiries indicate that it has often been very difficult to persuade Centrelink to accept that there has been non-receipt. In response to these concerns, DFACS recently issued a policy statement emphasising that a jobseeker's assertion that a letter was not received is to be accepted if there is "no valid reason to doubt it". Such reason for doubt is to be considered as existing if, for example, there has been a previous occasion of non-receipt and the jobseeker has not taken reasonable steps to prevent recurrence. This policy statement may be a useful step in the right direction but careful monitoring will be necessary to ensure that it is implemented effectively.

3.6. Even if all reasonable efforts are made to keep records of a postal address up to date, effective communication with jobseekers remains limited by heavy reliance on post. It is important that all communications which advise of, or may give rise to, obligations are made in writing to the jobseeker's primary postal address. In many instances, indeed, this is required by law. But our inquiries indicate that making greater use of additional methods of communication would significantly increase the rate of establishing contact with jobseekers. This method should be used in addition to, not instead of, written communication to the primary postal address. It may be a method for direct communication with the jobseeker or with a relative, friend, social worker or other person with whom they have reliable contact.

3.7. An additional method of communication may involve communication with another postal address, including a post office box. Some Centrelink officers are willing to act as postal collection points for jobseekers. Communication by telephone is a very useful option, especially as it can be quicker, facilitate comprehension and explanation, and, if the jobseeker has a mobile phone, reduce problems of transience or absence from home. Voicemail and SMS messaging options also strengthen its potential utility. Accordingly, Centrelink and providers should place emphasis on obtaining and updating telephone contact details.

3.8. Centrelink and providers could also assist communication by establishing facilities for jobseekers to leave and receive voicemail messages on a 1-800 freecall number with a personal identification number; developing a jobseeker website with password-protected mailbox; providing access to Internet terminals limited to a range of free email sites; and using an email program which automatically notifies senders if their message has been accessed.

3.9. Another potentially useful means by which contact could be made with a jobseeker is displaying a message on their automatic teller machine screen when they seek to withdraw the allowance from their account. Banks could program the auto-teller screens to show a message such as "Contact Centrelink office urgently or call (telephone number)" when an apparent breach of an obligation is being investigated or a breach and penalty have been imposed. Banks derive substantial financial benefits from being the conduit for social security payments. It would be reasonable to call for their cooperation in arrangements by which such brief notifications could appear when duly authorised by Centrelink. Any such system would need, of course, to comply with the proposed Privacy Code.

3.10. In order to provide greater encouragement for jobseekers to provide additional contact methods, the initial interview questionnaire system could specifically suggest some such methods rather than merely having an optional heading for "other" methods. In addition, the format of the fortnightly continuation form could be changed to place greater emphasis on the need to notify changed contact details. Indeed, the need for Centrelink to send this form to most jobseekers each fortnight, and for those jobseekers to return it to a Centrelink office (or visit the office for a replacement form), seems to provide useful opportunities that have not been sufficiently utilised in relation to contacting and communicating with jobseekers about potential breaches or impending penalties.

R6. Contacting Jobseekers

(1) Centrelink and providers should improve their arrangements for identifying and recording appropriate ways of contacting individual jobseekers.

(2) In particular, they should confirm and record at least the jobseeker's primary postal and, where available, telephone contact details at each meeting with the jobseeker and immediately notify each other if they become aware of changes in those details.

(3) They should also request jobseekers at the initial interview to provide, and to update thereafter, at least one additional contact method such as a secondary postal or telephone address, email address, or contact details for a relative or friend. These methods would be for use if the primary method has met with no response or is likely to be ineffective.

(4) Centrelink should also substantially improve its data entry and management processes for recording and using up-to-date contact details.

R7. New Options for Making ContactError! Reference source not found.

(1) Centrelink and providers should consider offering additional contact options for jobseekers such as email and voicemail services that are free and secure, and facilitating postal collection arrangements at their offices.

(2) Centrelink should also seek to establish means for communicating brief messages in some circumstances through automatic teller machine screens accessed by jobseekers.

Effective communication

3.11. Many Centrelink letters to jobseekers, such as those advising of appointments, are in simple English. But many also contain technical expressions, legislative terms of art or complex financial calculations. They have a common appearance and are generated according to a standard form or template in black type on white paper. Our inquiries show that the expression, design and format of Centrelink's written communications often restrict, sometimes very substantially, the extent to which they are understood. There is considerable scope for improvements in these respects. This is especially important, of course, when the communication relates to an obligation that may give rise to a breach and penalty in the event of non-compliance.

3.12. Use of "plain English" in standard communications should be regarded not merely as the conversion of complex wording to simpler wording but also as the reduction of text to its essential message, without marginal or extraneous material attached to it. Our inquiries show that Centrelink letters and notices to jobseekers commonly contain significantly more information than is necessary to convey the key messages and that, as a result, jobseekers often fail to understand the point of the communication.

3.13. Many jobseekers face significant barriers to understanding written correspondence. These barriers include visual impairment, a range of reading disabilities, impaired literacy, and poor English comprehension. Measures which could be taken to reduce these problems include using graphics to illustrate the essential message of the communication and incorporating red headings and watermarks in urgent notices and on envelopes as is commonly done, for example, in utility companies' payment notices. The need to highlight the importance of some correspondence is emphasised by the fact that some jobseekers may receive several letters in a week from Centrelink.

3.14. A significant proportion of jobseekers has difficulty comprehending English. Despite the extensive range of Centrelink material available in other languages, written correspondence continues to be only in English, with a supplementary message in a range of languages to contact Centrelink if assistance with translation is needed. Similarly, providers are under no obligation to write to jobseekers in languages other than English. Centrelink and providers should ascertain at their initial interviews whether a jobseeker may have difficulty in comprehending written English. If so, this should be recorded on the jobseeker's file and all subsequent letters should either be in the person's preferred language or include a brief message in that language conveying the main purpose of the letter and providing a contact number for a telephone interpreter service.

3.15. While Centrelink does produce some relatively brief brochures and other publications, there is much to be said for developing other forms of written communications that are especially succinct, clear, durable and readily accessible. This could include, for example, use of laminated, pocket-size cards or brochures, and of items such as calendars or other material which can be put in prominent places where they are more likely to have ongoing impact and accessibility.

3.16. A major problem in relation to communication between Centrelink and jobseekers is the frequency with which many staff, especially amongst those dealing directly with jobseekers, are moved to different positions. This substantially reduces the ability of many jobseekers, particularly those who are especially vulnerable, to communicate effectively with Centrelink. It is very important that jobseekers are enabled to develop a sense of personal confidence in the staff with whom they are dealing and that the need for jobseekers to keep repeating facts and explanations is reduced. It is notable in this context that, as mentioned earlier, a few categories of jobseekers are to be provided from later this year with their own Centrelink Personal Advisers in order to facilitate ongoing contact and confidence. Most jobseeksr, however, will remain without such potentially valuable assistance.

3.17. These difficulties can be aggravated by Centrelink's general policy of declining to give jobseekers the name (or at least the position title) and telephone number of a person in their Centrelink office with whom they can communicate directly. The need for staff to have personal security, and some protection from an excessive load of telephone calls, is undeniable. But the current system commonly causes considerable failures in communication, as well as exacerbating frustration, suspicion and a reluctance to cooperate. Some Centrelink offices or individual staff appear to be able to provide direct telephone contact details in this way without incurring substantial problems. There seems no good reason why their example could not be adopted more widely.

R8. Effective Communication

(1) Centrelink and providers should place greater emphasis on the use of plain English and accessible formats in their written communications. Where technical language has to be included for formal legal purposes, it should usually be put in an attachment, or on the reverse side, with its meaning being explained simply in the principal communication.

(2) Where failure to respond to a communication may lead to a reduction in payments, there should be a clear and prominent warning to that effect in the letter, possibly involving graphics, and the special importance of the letter should be emphasised in an appropriate way on the envelope.

(3) Communications with a jobseeker whose first language is not English should include a prominent message in his or her first language, mentioning the key purpose of the letter and advising how to contact Centrelink or the provider through a telephone interpreter service.

(4) Wherever possible, jobseekers should be provided with the name or position identification, and the direct phone number, of an appropriate officer with whom queries or difficulties about Centrelink communications can be discussed.

Especially vulnerable jobseekers

3.18. We have recommended earlier that all jobseekers should be requested to nominate a preferred additional method of communication. For people in the category of "especially vulnerable jobseekers" that we have described earlier, it is essential that special efforts are made to ensure that at least one such additional method is provided. These efforts should commence at the initial interview and, if necessary, continue at the special follow-up interview that we have recommended for such jobseekers and at subsequent meetings with providers. Centrelink and providers should not only record additional methods of contacting especially vulnerable jobseekers but also be required to use them unless it is clearly unnecessary or inappropriate to do so.

3.19. For especially vulnerable jobseekers, direct personal contact, preferably in a familiar environment, is often more likely to be effective than postal communications. Telephone contacts that could be recorded and used include family, friends, and frequented places such as drop-in centres, clubs and social service agencies. A list of several such contacts could be recorded for especially vulnerable jobseekers.

3.20. Many especially vulnerable jobseekers will be unable readily to nominate additional methods of contact. It may often be appropriate for Centrelink and providers to give active help in identifying and arranging effective and reliable additional means of contact. This might involve, for example, inviting a particular community agency or welfare worker to accept nomination as a contact or offering the Centrelink or provider office as a postal collection point. Centrelink's proposed new Personal Advisers could also provide assistance in this respect in relation to the categories of jobseekers whom they will be permitted to assist.

3.21. Our inquiries show that an effective method for contacting and communicating with especially vulnerable jobseekers is for Centrelink staff to go and meet them. In some cases this might mean a Centrelink officer hand-delivering a letter and being present in person to explain its contents and requirements. In a number of Centrelink regions, outreach programs operate as an effective way of contacting and communicating with jobseekers having characteristics which would bring them into our proposed category of especially vulnerable jobseekers. They often involve staff known as Centrelink Community Officers who visit places where they are likely to be able to meet jobseekers with special needs. Often the visit may be arranged on a regular basis through a community organisation that has close links with relevant types of jobseekers.

3.22. Many of these outreach programs have been implemented largely due to the initiative of particular Centrelink managers operating with localised autonomy, often in cooperation with a local community and on occasions with the support of a local funding program. A national approach should be taken to develop additional outreach programs that focus on particular groups of especially vulnerable jobseekers. Their effectiveness would be enhanced by local community consultations of the kind that we recommend later in this report.

R9. Arrangements for Especially Vulnerable Jobseekers

(1) When jobseekers have been identified by Centrelink as being especially vulnerable, they should be required to give additional contact details, wherever possible. They should be assisted in doing so by Centrelink and providers, which may sometimes involve asking another person or organisation to accept the jobseeker's nomination as a contact point for this purpose.

(2) Use of one or more such additional methods of communication, in addition to sending a written communication to the principal postal address, should be mandatory in relation to especially vulnerable jobseekers, except where it is clearly unnecessary or inappropriate to do so.

(3) Provision of direct Centrelink contact as in R8(4) above should be mandatory in relation to especially vulnerable jobseekers.

(4) Centrelink should substantially expand its outreach activities (particularly through its Community Officers), and also utilise its proposed system of Personal Advisers, in order to improve its ability to communicate effectively with especially vulnerable jobseekers.