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Gathering and substantiating information when investigating debts

From the Gathering and substantiating information when investigating debts 107-02040010 page on the Department of Human Services website:

This document outlines information on gathering and recording evidence when investigating debts. This document is not intended to provide assistance for what is required in reviews and appeals. That information is in the procedure About Review of decision and appeals.

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Investigating the debt

When investigating a possible debt, there must be evidence to substantiate a debt exists. Staff must examine the available evidence, determine if an overpayment has occurred, and whether a recoverable debt exists under the relevant legislation.

A full investigation of the customer's circumstances must be undertaken to ensure that the debt is raised for the correct amount, period and reason. This includes following up any debt related triggers that might indicate the debt could be for a longer period or a larger amount. The only exception to this rule is the agreed guidelines for Service Updates. The procedure, Raising and attribution of Service Update debts, contains further information.

When assessing a debt shell activity, staff should examine the initial period of the debt as indicated by ADEX (debt explanation).

Three results can arise from an initial investigation:

  • no recoverable debt
  • recoverable debt raised or
  • recoverable debt raised and waived


Substantiate the debt

To substantiate a debt there must be supporting evidence. Supporting evidence could be in the form of:

  • verbal confirmation of information, documented on the system
  • electronic copies of the DOC and the debt calculations, (the electronic record is permanent and constitutes legal evidence) or
  • employers' reports (Q146 or SU11 etc.), letter from employer on official letterhead, payslips, tax returns etc. or
  • the Debt Calculator submission

Note: if there is no evidence, there can be no debt.


Evidence of a debt

Enough evidence also needs to be gathered to decide what further action needs to be taken:

  • check the system to establish payment history
  • ensure that there is sufficient verification of the facts
  • determine whether the customer has complied with the notification provisions, and
  • determine whether relevant protocols have been followed

When raising the debt, it is not necessary to gather paper copies of evidence where the paper evidence has already been sighted, recorded and scanned correctly by another staff member. The electronic record indicates where the paper copies are stored for retrieval if needed.

Screen dumps should not be printed and placed on file as this information is available on the electronic record. The only exception to this may be in some cases where it is specifically requested as part of a submission to the Administrative Appeals Tribunal (AAT).


Investigating undetermined debts

There are a few basic points to follow:

  • When investigating a debt, staff should investigate the initial period of the debt as indicated by ADEX. If there are any triggers to indicate the debt period extends beyond that of the original debt tag, these must be investigated.
  • If there are no triggers and the debt is correct, it can be raised.
  • If the debt is the result of the customer updating their details - the information is accepted to raise the debt unless there is evidence or triggers which may make the information incorrect.
  • There is no expectation that staff go 'searching' for further debts on a customer's record, or to conduct a full review since date of grant, unless investigation of the debt leads them to believe that the debt would exist from this date.
  • If a debt is raised without verification, the customer can provide further information to request a review of decision, and the debt be recalculated.


Conducting the investigation - service centre or DMB

Once the debt shell activity is created, it becomes the responsibility of the Debt Management Branch (DMB). DMB will conduct an investigation when raising a debt, to ensure that the correct decision is made.

For example, a customer attends a service centre with his last three payslips from one of his three employers. The service centre codes the payslips on the customer’s record, which creates a debt. The debt is sent to the DMB, who will conduct any investigation for that activity. This could include contacting the customer for further details. If the customer is not able to assist, advise that a Q146 will be sent to their employer and/or all of their employers, depending on the periods the customer has worked. If the periods of employment overlap between employers and the period of the debt, sending Q146s to all employers should be considered.

The only exception is when the service centre has not coded the information the customer has provided. This needs to be updated on the customer's record to ensure they are receiving the correct rate of payment. Team Leaders should be consulted regarding what local arrangements are in place for these cases.


Document standards

A customer record is made up of paper file(s), off-file documents and an electronic record.

Each customer record is identified by a unique Customer Reference Number (CRN). A customer has only one record which may be receiving several different payments or services. Every customer has their own record (including their own separate file), regardless of their relationship status and any payment or service received by their partner.

DOCs should provide a concise history of a customer’s interactions and enough information to support a decision which affects, or could affect, the customer. Contact, through any channel, (telephone, face to face, post or email) should be recorded on a DOC.

According to the Records Management Policy, debt calculations and supporting documentation are to be stored on the customer's file. All staff processing debts should be aware of, and comply with, the Records Management Unit (RMU) requirements and place independent evidence to substantiate a debt on each customer record. This evidence can be electronic or paper. See the Resources page for a link to the Records Management Policy.

Information about DOC minimum standards, can be found in the procedure, Getting It Right (GIR).


Electronic vs paper storage

If the debt has been raised using a system calculation, and the DOC contains all details of any related activities or other adjustments taken into account in calculating the debt, there is no need to place paper copies of the calculations on file. This is because Debt Explanation (ADEX) and the debt DOC remain permanently available in an electronic form. However, where paper documents were used as evidence to support the debt, they must be scanned to the record.

If the debt has been calculated on MultiCal or by using another calculation method - a DOC explaining why the system calculation could not be used as well as a detailed account of how the debt arose and was calculated must be written for the electronic record and this or the Debt Calculator submission must be scanned to the customer’s record, along with any other calculations.

Whenever paper copies of supporting evidence are required to raise and substantiate a debt, they must be scanned to the customer's record, regardless of the method of calculation used.

For issues regarding a customer, see the Resources page for the Records Management Policy.


Debts generated at a different location from where the debt has been raised

There is no need for paperwork associated with debts to be sent to DMB or other designated debt raising officers.

Verification documents used to create the debt shell (copies of payslips/employer information) can be scanned onto the record.

If paperwork is not provided, the debt shell should be accompanied by comprehensive DOCs which should include any additional information that explains the circumstances, (for example, customer did not work from dd/mm/yy (date) to dd/mm/yy (date)).