If not delivered return to PO Box 7820 Canberra BC ACT 2610
30 June 2025
Our reference: LEX 84899
Kathleen Madgwick
Only by email:
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Kathleen
Decision on your Freedom of Information Request
I refer to your request received by Services Australia (the Agency) on 29 April 2025 and revised
on 20 May 2025 for access under the
Freedom of Information Act 1982 (the FOI Act) to the
following documents:
I wish to request the following information relating to the Robodebt scheme:
1. I seek to obtain a copy of the Risk Matrix carried out before the Robodebt
Scheme. In particular, I am seeking a document containing the following:
a. A description of how the system would detect overpayments due to
administrative error, averaged debts, and double-up of employers' income.
b. How the system detected, recorded and handled administrative errors
2. I seek to obtain a copy of the Risk Matrix carried out during the Robodebt
Scheme. In particular, I am seeking documents which display the following:
• How the Robodebt system detected, recorded and handled staff errors
that resulted in overpayments.
3. I seek to obtain a copy of the Risk Matrix carried after the cessation of the
Robodebt Scheme. In particular, I am seeking documents which display the
following:
a. How administrative errors resulting from overpayments are detected,
recorded, and dealt with now.
4. Additionally, I am seeking data on the percentage of overpayments that resulted
from administrative errors (outside of the Robodebt scheme). The scope of the
information I seek includes:
a. Annual data on overpayments that were waived due to administrative
errors detected by staff annually from 2010 to 2016.
b. Overpayments due to administrative errors, where a debt was raised and
overturned at the Administration Appeals Tribunal, annually from 2010 to
2019.
When I refer to Robodebt, I am referring to the following programs:
PAGE 1 OF 10
• PAYG Manual Compliance Intervention program: From July 1, 2015 to July 1,
2016
• Online Compliance Intervention: From July 1, 2016 to February 10, 2017
• Employment Income Confirmation: From February 11, 2017 to September 30,
2018
• Check and Update Past Income: From September 30, 2018 to May 29, 2020
• Income Compliance Program: Also known as Robodebt, this program ended
in November 2019
To my understanding, prior to the Robodebt program, compliance staff manually
detected these overpayments. The issues mentioned above were considered before
raising a debt, and these portions of overpayments were partially or fully waived. I
assume that data collection on administrative errors was recorded, and risk
assessments were carried out prior to the Robodebt program.
Please note I have numbered your request for ease of reference.
Publicly available documents
The relevant business area has provided the following documents in scope of your request
that are publicly available from the Royal Commission into the Robodebt Scheme website:
•
Online Compliance Interventions Risk Management Plan (Exhibit 4-6529) •
Risk Management Plan – Employment Income Matching (Exhibit 4-6528) •
Employment Income Matching (Exhibit 4-6522) •
Employment Income Matching Risk Management Plan V1.0 (Exhibit 4-6518)
In addition to the above, I was advised by several business areas the Agency does not hold
any data on the percentage of overpayments that resulted from administrative errors in any
existing reports or documents as you requested (Point 4 of your request). However, the Agency
has arrangements in place for the purchase of statistical information and data.
On 13 June 2025 I wrote to you regarding the arrangements for the purchase of statistical
information and data and advised you to make a request by contacting the External Information
Release Team at:
xxxxxxxx.xxxxxxxxxxx.xxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx.
You acknowledged my email on 17 June 2025.
As a result, and in accordance with section 12(1)(c) of the FOI Act, you are not entitled to
request access to the documents under the FOI Act and Point 4 of your request for data is
taken to be withdrawn.
My decision
In addition to the publicly available information listed above, the Agency holds 6 documents
(totalling 97 pages) relevant to your request.
I have decided to:
• grant you
full access to 6 documents (Documents 1 to 6), and
•
refuse access to parts of your request, in particular parts of Point 1(a), parts of 1(b)
and Point 2, under section 24A of the FOI Act on the basis that all reasonable steps
PAGE 2 OF 10
have been taken to locate the documents you have requested, and I am satisfied they
do not exist.
Please see
Attachment A for a schedule of the documents being released.
Please see the schedule at
Attachment A to this letter for a description of the documents and
the reasons for my decision, including the relevant sections of the FOI Act.
How we wil send the documents to you
The documents are attached.
You can ask for a review of our decision
If you disagree with any part of the decision, you can ask for a review. There are two ways you
can do this. You can ask for an internal review from within the Agency, or an external review
by the Of ice of the Australian Information Commissioner. See
Attachment B for more
information about how to request a review.
Further assistance
If you have any questions, please ema
il xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx. Yours sincerely
Leanne
Authorised FOI Decision Maker
Freedom of Information Team
FOI and Reviews Branch | Legal Services Division
Services Australia
PAGE 3 OF 10
If not delivered return to PO Box 7820 Canberra BC ACT 2610
REASONS FOR DECISION
What you requested
By the Freedom of Information Act 1982 (FOI Act), I wish to request the following
information relating to the Robodebt scheme: I seek to obtain any risk matrix that was
in place before, at commencement, and during the Robodebt scheme, upon the release
of Robodebt and what risk matrix has been in place since its cessation.
When I refer to Robodebt, I am referring to the following programs;
• PAYG Manual Compliance Intervention program: From July 1, 2015 to July 1,
2016
• Online Compliance Intervention: From July 1, 2016 to February 10, 2017
• Employment Income Confirmation: From February 11, 2017 to September 30,
2018
• Check and Update Past Income: From September 30, 2018 to May 29, 2020
• Income Compliance Program: Also known as Robodebt, this program ended in
November 2019
Additionally, I am requesting statistics on the number of debts raised by defective
administration and how this was detected and managed prior to and during the
Robodebt Scheme.
On 8 May 2025, my colleague wrote to you about your original request. You revised your
request, and this was confirmed by email on 10 May 2025.
Your revised request was:
I wish to request the following information relating to the Robodebt scheme:
I seek to obtain a copy of the Risk Matrix carried out before the Robodebt Scheme. In
particular, I am seeking a document containing the following:
• A description of how the system would detect overpayments due to
administrative error, averaged debts, and double-up of employers' income.
• How the system detected, recorded and handled administrative errors
I seek to obtain a copy of the Risk Matrix carried out during the Robodebt Scheme. In
particular, I am seeking documents which display the following:
• How the Robodebt system detected, recorded and handled staff errors that
resulted in overpayments.
I seek to obtain a copy of the Risk Matrix carried after the cessation of the Robodebt
Scheme. In particular, I am seeking documents which display the following:
• How administrative errors resulting from overpayments are detected, recorded,
and dealt with now.
PAGE 6 OF 10
Additionally, I am seeking data on the percentage of overpayments that resulted from
administrative errors (outside of the Robodebt scheme). The scope of the information
I seek includes:
• Annual data on overpayments that were waived due to administrative errors
detected by staff annually from 2010 to 2016.
• Overpayments due to administrative errors, where a debt was raised and
overturned at the Administration Appeals Tribunal, annually from 2010 to 2019.
When I refer to Robodebt, I am referring to the following programs:
• PAYG Manual Compliance Intervention program: From July 1, 2015 to July 1,
2016
• Online Compliance Intervention: From July 1, 2016 to February 10, 2017
• Employment Income Confirmation: From February 11, 2017 to September 30,
2018
• Check and Update Past Income: From September 30, 2018 to May 29, 2020
• Income Compliance Program: Also known as Robodebt, this program ended
in November 2019
To my understanding, prior to the Robodebt program, compliance staff manually
detected these overpayments. The issues mentioned above were considered before
raising a debt, and these portions of overpayments were partially or fully waived. I
assume that data collection on administrative errors was recorded, and risk
assessments were carried out prior to the Robodebt program.
On 29 April 2025 the Agency auto acknowledged your original request. You consented to
exclude personal details about our staff (such as their names) therefore, staff details have
been redacted in accordance with section 22(1) of the FOI Act. In addition, you provided an
upfront agreement to a 30 day extension of time, making the new due date 30 June 2025. The
Of ice of the Australian Information Commissioner was advised of the extension.
What I took into account
In reaching my decision I took into account:
• your original request dated 29 April 2025
• your revised request on 10 May 2025
• other discussions and correspondence with you
• the documents which fall within the scope of your request
• whether the release of material is in the public interest
• consultations with Agency officers about:
o the nature of the documents
o the Agency's operating environment and functions
• guidelines issued by the Australian Information Commissioner under section 93A of
the FOI Act (the Guidelines), and
• the FOI Act.
PAGE 7 OF 10
Reasons for my decision
I am authorised to make decisions under section 23(1) of the FOI Act.
Section 24A of the FOI Act
Section 24A of the FOI Act allows the Agency to refuse a request for access to a document if
all reasonable steps have been taken to find the document, and the Agency is satisfied that it
cannot be located or does not exist.
The Data and Analytics Division and the Payment Assurance Program and Appeals Division
(the Divisions) conducted searches of the Agency’s electronic systems. I am satisfied they are
the appropriate areas of the Agency to undertake searches for the types of documents you
have requested.
The Divisions did not identify any documents relating to parts of Point 1(a), parts of Point 1(b)
and Point 2 of your request.
In relation to parts of Point 1(a) and 1(b), of your request, in particular ‘the system detecting
administrative errors’, the Division advised the Administration Error Waiver decision is made
by a staf member. There are no User Specifications that describes how the system detects
overpayments due to administration error. A staff member would make a decision to apply an
administration error waiver once they have followed the correct process and considered the
relevant criteria.
In relation to Point 2 of your request, the Division advised the Robodebt system did not detect,
record or handle staff errors resulting from overpayments, as such no documents exist for this
point of your request.
Based on the searches undertaken, I am satisfied that in accordance with section 24A of the
FOI Act al reasonable steps have been taken to find the documents, and the documents do
not exist.
Conclusion
In summary, I have decided to:
• release 6 documents to you in full, and
• refuse access to parts of your request under section 24A of the FOI Act on the basis
that all reasonable steps have been taken to locate the documents you have requested,
and I am satisfied they do not exist.
PAGE 8 OF 10
If not delivered return to PO Box 7820 Canberra BC ACT 2610
Attachment B
INFORMATION ON RIGHTS OF REVIEW
FREEDOM OF INFORMATION ACT 1982
Requesting a ful explanation of a Freedom of Information (FOI) decision
Before you ask for a formal review of a FOI decision, you can contact us to discuss your
request. We wil explain the decision to you. This allows you to correct any misunderstandings.
Requesting a formal review of a FOI decision
If you consider the decision is incorrect, you have the right to apply for a review under sections
54 and 54L of the
Freedom of Information Act 1982 (the FOI Act).
You can apply for:
1. an
internal review by an Internal Review Of icer of Services Australia (the agency),
and/or
2. an
external review by the Australian Information Commissioner.
Applying for an internal review by an Internal Review Officer
In an internal review, a different decision maker to the Agency delegate who made the original
decision wil carry out the review. The Internal Review Of icer wil make a fresh decision on
your request and wil consider all aspects of the original decision and identify any relevant
additional factors.
An application for an internal review must be:
• made in writing
• made within 30 days of receiving this letter
• sent to the address at the top of the first page of this letter, or by email to
xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx
Note: You do not need to fil in a form. However, it is a good idea to set out any relevant
submissions you would like the Internal Review Officer to further consider, and your reasons
for disagreeing with the decision.
Applying for external review by the Australian Information Commissioner
If you disagree with the original or internal review decision, or if you have not received a
decision within 30 days of applying for an internal review, you will have 60 days to apply in
writing for a review by the Australian Information Commissioner.
Note: The Australian Information Commissioner generally prefers FOI applicants to seek an
internal review before applying for an external review.
PAGE 9 OF 10
You can lodge your application:
Online:
www.oaic.gov.au
Post:
Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Email:
xxxxx@xxxx.xxx.xx
Important:
• If you are applying online, the application form the FOI Review Form is available at
Information Commissioner Review Application form
• If you have one, you should include with your application a copy of the Agency's
original and internal review decisions on your FOI request
• Include your contact details
• Set out your reasons for objecting to the Agency's decision.
Complaints to the Australian Information Commissioner and Commonwealth
Ombudsman
Australian Information Commissioner
You may complain to the Australian Information Commissioner concerning action taken by an
agency in the exercise of powers or the performance of functions under the FOI Act. There is
no fee for making a complaint. A complaint to the Australian Information Commissioner must
be made in writing. The Australian Information Commissioner's contact details are:
Telephone: 1300 363 992
Website:
www.oaic.gov.au
Smart Form:
FOI Complaint Form
Commonwealth Ombudsman
You may also complain to the Commonwealth Ombudsman concerning action taken by an
agency in the exercise of powers or the performance of functions under the FOI Act. There is
no fee for making a complaint. A complaint to the Commonwealth Ombudsman may be made
in person, by telephone or in writing. The Commonwealth Ombudsman's contact details are:
Phone:
1300 362 072
Website:
www.ombudsman.gov.au
The Commonwealth Ombudsman generally prefers applicants to seek review before
complaining about a decision.
PAGE 10 OF 10
