I emailed the Department of Human Services about the Centrelink #notmydebt fiasco that’s been in the news of late. The content of my emailed questions, and the DHS response are reproduced below. I’ve trimmed personal data and some header/footer guff, and played with some of the styling to make it more readable in this blog, but the content itself is verbatim.
My Initial Email
My first email of questions, sent at 10:39pm Thursday 5 Jan 2017:
Busy time, I’m sure.
I’m a contributor at Forbes.com (http://www.forbes.com/sites/justinwarren) and I’m working on a story about Centrelink/ATO data matching you’d be well aware of at the moment.
- Is the data matching system new, or an existing system that has been made ‘fully automatic’? If the latter, how much changed to make it fully automatic?
- Who developed the automated data matching software and process? Was it done in-house, by external suppliers, or some mix of the two? Which suppliers?
- What technology stack is used to underpin the data matching process? What is the main software system used, e.g. SAP?
- Is the system maintained in-house by IT within DHS/Centrelink, or are external IT suppliers used? I am thinking of the example of IBM as used by the ABS for the Australian Census.
- The false-positive rate (the rate at which debt notices are sent, yet the debts are found to be incorrect or non-existent) has been reported as at least 20%. Was this error rate known prior to going live with the more automated approach? Or did the error rate increase more recently?
- Is there an SLA or similar for the system that defines the acceptable false-positive rate? If so, what is this rate?
- The Minister is on record as saying “We’re determined to ensure welfare recipients get no more, and no less than they’re entitled to.” [emphasis mine]. Does the data matching process detect under-payment, and are people then contacted to ensure they receive any missing payments they are entitled to? Please describe the process by which this happens.
- The rate at which letters have been sent out appears to have increased over time. A total of ~169,000 have been sent, and lately at a rate of 20,000 per week. How was the sending rate increase planned: linear growth from an initial number, or a non-linear growth pattern (5% of max, 10%, then 25%, 50%, 100% kind of pattern)? I’m trying to get a sense of how much volume the system was sending each week/month from July to December.
- Does the system plan to sustain a sending rate of 20,000 letters per week indefinitely?
My deadline is 5pm Friday 6 Jan 2016, Australia/Melbourne time.
My direct number is [redacted].
I got a phone call from a DHS media staffer at 1:30pm on Friday 6 Jan 2017 explaining they were busy and I probably wouldn’t get an official response before deadline; I’d probably get an email over the weekend. I don’t do scoops, and I’m looking at this more from a “how to manage enterprise technology projects” angle, so I was okay waiting a bit for clear information.
The staffer did say a bunch of interesting things, and then, after talking to me for just on eight minutes and having said some very interesting things, he then said “That stuff was just on background. Don’t quote me.” I was very clear that I was press, what with emailing the media contact address planning to write something in Forbes.com and all.
I then sent a followup email:
Thanks for the call earlier. I’d like to confirm my understanding/clarity about the 80% real, 20% “needs more info” part of the data matching:
- Please confirm that the 20% figure refers to letters that are sent that do not result in any debt owing after people provide additional information (mostly online).
- With the 80% figure: is this letters that are completely correct and require no adjustment, or does it include a subset that do result in a debt, but not the amount matched originally? So, the letter might say “it looks like you owe us $2,500” but after they supply more info the actual debt amount is $1,000.
- What proportion of letters sent end up as “debt exists and is totally correct” versus “a debt exists, but amount is adjusted after more information supplied”?
- Of amounts adjusted, what’s the distribution of adjustment amounts (mean adjustment of $X with a variance/standard deviation of $n)?
I just got a response, at 4:20pm Monday 9 Jan, Australia/Melbourne time. Here it is:
Apologies for the delay. You may attribute the following response to Department of Human Services General Manager Hank Jongen.
We are confident in the online compliance system.
The data matching capability has been developed and is maintained internally.
The data matching software has been used by the department to successfully carry out data matching operations for a number of years.
The business rules used to identify non-compliance are well established and have not been altered in the new system.
If there is a difference in the income recorded by the ATO compared to the income reported to Centrelink for a particular time period, the department is obliged to seek clarification of the difference in the data.
This is part of ensuring the integrity of the welfare system. If someone receives benefits to which they are not entitled, the department is required by law to recover the money.
The online compliance intervention system doesn’t automate debt recovery – it is a system which automates part of the standard compliance review process. The department always provides assistance where people request it and this has not changed.
While the new online compliance system automates part of this process, it also does not change how income is assessed or how debts are calculated. The system is an easy way for people to confirm details and resolve any outstanding matters.
The first letter generated by the system is a letter advising people that there is a difference between the information reported to Centrelink and the information reported to the ATO. This is not a debt letter and simply asks them to either confirm or update the information.
At this stage of the process no assumptions about debt or no debt has been raised. No decision to raise a debt or otherwise is undertaken until the person has been provided an opportunity to confirm or update the information.
The easiest way for a person to confirm or update their information is online, through their myGov account.
The letter they receive explains how they can go online. The letter also has a number they can call if they would rather speak with someone. At any time, people can seek assistance from the department.
By going online, people can view their information including checking the dates over which their income was earned, and if necessary update any information.
People have 21 days from the date of the initial letter to go online and confirm or update their information. People who do not respond at the 14 day mark will receive a reminder.
It’s possible to go online and ask for an extension to the 21 day timeframe – this is automatically granted on the first two occasions, before a third request for extension triggers a phone call from our staff to provide assistance.
There is also the option through the system to request a phone call at any time to discuss any issues the person may have. This is a call back option and the call back will occur within 7 days.
If the employment income was earned before they began receiving or after they stopped receiving income support payments, then they will not incur a debt.
When a person completes an online intervention, the system will advise the person of the outcome. If the event that money is owing, the outcome will be explained to the person on how the debt was calculated.
If a person fails to respond to the initial request and the reminder to confirm or update the information, a debt will be raised using data from the ATO as provided to them by the employer. This is not new and is consistent with procedures which have been in place for many years.
Even after a debt has been raised the person can change their details or provide more information to have the debt reassessed or they can request to have a formal review of their case, if required.
People have further appeal rights should they disagree with the outcome of the formal review.
There is no time limit to request a review of the decision with regards to debts raised by the department.
When a debt is raised a person will receive an account payable letter advising of the debt, and provided 28 days to pay the debt in full or contact the department to discuss payment options.
Current recipients receiving a payment who have incurred a debt that has not been paid in full by the 28th day are subject to automatic withholding arrangements, which can be negotiated depending on their circumstances.
If they are not receiving a payment that is they are not a current customer and contact has not made been made after 42 days (that is 28 days plus an additional 14 days), further recovery action may apply such as referral to an external collection agent.
Since July, 169 000 reviews have been completed. In approximately 80 per cent of cases people have a debt owing to the Commonwealth. The remaining 20 per cent are instances where the customers have resolved the matter by providing updated information to clarify the difference in reported income.
Only 2.2 per cent of customers were requested to supply supporting documentation, which means 97.8 per cent did not need to supply supporting documentation.
The department is committed to ensure that people get what they are entitled to, nothing more, nothing less.
My Followup Email
I sent a followup email straight away (4.44pm on 9 Jan 2016), because DHS haven’t answered some important questions from my original email, and my post-phonecall email.
Thank you for your response.
Please clarify the following:
- When you refer to “Only 2.2 per cent of customers”, what do you mean by ‘customers’? Is this all customers of Centrelink, or something else? How many customers constitute 2.2 per cent?
I would still like an answer to the following questions:
- Does the data matching process detect under-payment, and are people then contacted to ensure they receive any missing payments they are entitled to? Please describe the process by which this happens.
- Is the plan to have the system sustain a sending rate of 20,000 letters per week indefinitely?
- For the 80% of the 169,000 reviews conducted where a debt was owed, how many cases were entirely correct, i.e. “a debt exists and no adjustment was needed to the amount”, and how many required an adjustment to the amount “a debt exists, but amount is adjusted after more information is supplied”?
- For debts that are adjusted, what is the distribution of the adjustment amount (mean adjustment of $X with a variance/standard deviation of $n)? Is the distribution statistically Normal, or skewed?