With twelve months since the introduction of the Child Care Subsidy (CCS) System, we can certainly say that it has been a bumpy ride for Approved Providers, Nominated Supervisors and families as we navigate the range of challenges that change of such a significant scale can cause.

Some of the difficulties are coming to grips with a new policy setting with different outcomes from the old regime, along with a range of technical difficulties that have caused problems, both major and minor, for us to try to resolve.

In my discussions with members all around the country, there is a range of responses as to the impact of the CCS on our sector and our families. Some service providers have experienced little or no concern with the implementation and management of CCS at a service or family level with others completely overwhelmed and struggling to make sense of some of the outcomes along the way.

In this context ACA, through my ongoing involvement with the Federal Department of Education and Training (DET)'s Implementation and Transition Reference Group, has been able to raise issues at both a macro and micro level. In some cases, we have been able to resolve hundreds of individual cases for members and their families and we have also been able to help inform the future direction of policy.

This is not to say that we have been able to assist in resolving each case bought to our attention but we endeavour to do our best at facilitating good outcomes for members and their families.

When governments implement such significant change, there will always be some policy details which in practice do not deliver on their stated objective. The challenge, however, is as they are enshrined in legislation, rectifying those situations is not a simple process.

Some of the more significant issues we continue to push for change on includes:

• The 8 Week Rule
• Cessation of Care
• Back payments to Families
• ACCS requirements
• Enrolment/CWA Requirements
• Enrolment/Fee Disputes by Families
• Access for all Children

Known issues

These policy issues sit separately to known issues, including unexplained retrospective adjustments to already paid CCS. This has been a major concern for services to try to problem solve or has left them in a position where they may need to recover debt from families who in some cases may no longer attend their service. This has been our most significant piece of work where there is no simple answer that applies in every case.

Through all of my discussions when presenting examples of these adjustments, it is clear that there may be a whole range of triggers which may have caused these changes ... which makes the situation as clear as mud! What we do know however is that the legislation only allows for minimal change to already paid CCS payments at a service level and that if the parent does have a debt then the owed amount should be settled directly from the family/individual.

It is fair to say that the experiences with these adjustments have promoted fear about the impact of the upcoming reconciliation process on families, but more importantly whether the reconciliation may result in retrospective adjustments of CCS already paid to services. Whilst the legislation does not allow for historical adjustments to CCS, ACA has heard the concerns of our members and I have spent much of the last month working with DET on ensuring they provide some information to service providers on how this process will work.

Balancing Process (ie "reconciliation")

CCS balancing (also referred to as ‘reconciliation’ or ‘income review’ process) is a process that occurs after the end of each financial year whereby the Federal Department of Human Services compares families’ income estimates with their actual adjusted taxable income to ensure families have received their correct CCS entitlement.

Whilst families who qualified for Child Care Benefits (CCB) and Child Care Rebate (CCR) combined under the old regime were familiar with this process, this is a new experience for those families who only qualified for CCR and I am sure as service providers you will be asked questions from your families as they come to grips with something new. Whilst it is impossible to predict how accurately families have estimated their income it is likely that there are a group of families who may have underestimated and as a result incur a debt. We also don’t know whether the 5% withholding adequately covers most debt and it will be interesting to observe the trends when this reconciliation process concludes. I am in no doubt that this will occupy much of ACA’s time when this process begins from July 29, 2019.

I am pleased to say that as a result of working with DET on this matter, DET and the Federal Department of Human Services has organised a webinar to clarify the circumstances of reconciliation and give service providers a clear understanding of how the reconciliation process works and who is responsible for any debt as a result of this process.

Upcoming Webinars

I strongly encourage you to subscribe to these webinars so that you have the knowledge to answer any questions that may come your way.

• Monday 15 July 2019 from 12:00 pm - 1:00 pm (AEST); and
• Tuesday 16 July 2019 from 6:30 pm - 7:30 pm (AEST).

To register for the webcast click here.

Any ongoing CCS issues

Some of the more complex cases can be difficult for service providers to determine how to resolve problems with families payments. As previously discussed, ACA has acted on behalf of individual members in bringing more complex situations to DET in order to try to facilitate a resolution.

One of the challenges often faced is bringing together the right information in order to improve the chances of a swift response from DET.

We have therefore created a one-page step-by-step guide on how to deal with any CCS issues, and how to escalate them if they remain unresolved after a reasonable amount of time has passed since you raised the issue with the Department.

You can access this guide here.

It is, of course, hoped that once you raise these issues, they will be quickly resolved.

However if after exhausting all the formal channels available to you, the problem hasn't been resolved, ACA is happy to continue to support members in escalating these issues, on the basis that we have all the relevant information.

Paul Mondo
National President, Australian Childcare Alliance

PUBLISHED: 1 JULY 2019