Department Of Human Services, Child Support Agency: Unreasonable Customer Conduct and ‘Write Only’
Allan Asher, The Commonwealth Ombudsman, December 2010. ISBN 978 0 9807966 8 1
The Child Support Agency (CSA) is part of the Department of Human Services and it has a unique role compared to other government agencies. For each child support case, the CSA has to respond to the needs and enquiries of two customers, whose interests are often diametrically opposed. A customer’s involvement with the CSA frequently begins at a time of recent relationship breakdown, when arrangements for children and finances are far from settled.
As a consequence, at the time customers are in contact with the CSA, they may express a range of emotions, from frustration and anger, to resignation or deep sadness. In some cases, a person’s behaviour can appear disproportionate to the child support problem they are experiencing and their conduct can become unreasonable.
Like many government agencies, the CSA had a policy of restricting a customer’s access to its services if it considered this was necessary to manage the customer’s unreasonable conduct. The CSA’s most common method of restricting access was to designate customers ‘write only’ – meaning that the agency would only engage with them in writing, not over the telephone or face-to-face.
This is a departure from its normal service delivery approach as a ‘phone first’ organisation, meaning that it prefers to deal with its customers by telephone. The ‘write only’ policy was intended to emphasise the CSA’s expectation that customers will treat its staff with appropriate levels of civility; to protect CSA staff members and other customers from possible harm. It also limited the extent to which CSA staff were unnecessarily tied up in unproductive communications.
It was evident from this investigation that CSA customers experience frustrations and problems when they have to deal with the CSA exclusively in writing. While the cases that we examined were ones where the CSA imposed this restriction in response to unreasonable conduct, we note that there are other people who have communication challenges arising from disability, geographical location, language barriers or educational disadvantage. We consider that the CSA also needs to keep these people in mind when it makes decisions about service delivery and resources, including whether to impose ‘write only’ restrictions.
At the start of this investigation, the CSA told us that it had 133 ‘write only’ customers. The majority (113 customers) had requested that the CSA not telephone them. The remaining 20 ‘write only’ customers included 17 where CSA had made the decision to impose that status and three where it was a ‘joint decision’. In those 20 cases, there was frequently no clear trail of documentation to indicate who had made the decision, the reasons for the decision, and when (or if) a review might occur. We have reservations about the completeness of the CSA’s records. Three ‘write only’ customers we identified through our own complaints and these did not appear on the CSA’s list. We consider it is likely, that of its 1.5 million customers, the CSA has restricted many more than just 20 to written communication about their child support case.
We found that the CSA did not have standardised procedures for restricting certain customer’s access to services. Our investigation also revealed that limiting customers to ‘write only’ will often inconvenience both CSA staff and customers. Imposing ‘write only’ status in one notable case, actually increased the CSA’s interaction with that customer. We also found that ‘write only’ restrictions made it more difficult for customers to communicate their concerns and could obscure a genuine customer grievance. We consider that a ‘write only’ restriction can be a significant barrier to the CSA providing good service. Accordingly, it should be used rarely and only for as long as is necessary to manage a customer’s unreasonable behaviour, with the eventual aim of reinstating access to the CSA’s usual service delivery arrangements. Most importantly, a ‘write only’ restriction should not be the CSA’s first, or only, response to unreasonable customer conduct.
To read full text, follow this link. http://www.ombudsman.gov.au/files/dhs_csa_unreasonable_customer_conduct_and_write_only_policy_14_2010.pdf