If not delivered return to PO Box 7820 Canberra BC ACT 2610
8 September 2025
Our reference: LEX 86718
Frank N Fearless (Right to Know)
Only by email
: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Frank N Fearless,
Decision on your Freedom of Information Request
I refer to your request dated and received by Services Australia (the Agency) on 8 August 2025
for access to the following documents under the
Freedom of Information Act 1982 (the FOI
Act):
This request relates to the Annual Payment Accuracy Review Program (PARP)
From Trimester 1, 2024-25 questions were introduced to examine the following
matters for the first time:
1. administrative error which denies a person receipt of a benefit they are
entitled to as a payment inaccuracy.
2. Recipient error cases in which a recipient does not claim a benefit to which
they are entitled, but which they would like to receive, as a payment
inaccuracy.
I seek the results document which outlines Trimester 1 PARP results for these
specific error categories - reporting on the prevalence of these errors.
I also seek the procedure document which (1) includes the specific questions used for
exploring these issues (2) the procedure for securing responses to these questions
from those undergoing the PARP review.
My decision
The Agency holds 2 documents that relate to your request.
I have decided to:
• grant you
full access to one document (Document 2), and
• grant you
part access to one document (Document 1) with some of the content
removed.
I have decided that certain parts of Document 1 are exempt under the FOI Act, as the
document includes information that if disclosed could have a substantial adverse effect on
the proper and efficient conduct of the operations of an agency (section 47E(d) conditional
exemption).
In addition, I have also decided to refuse access to the Trimester 1 PARP results data you
requested in Points 1 and 2 of your request under section 24A of the FOI Act on the basis
PAGE 1 OF 8
that all reasonable steps have been taken to locate the documents you have requested, and
I am satisfied they do not exist.
Please see the schedule at
Attachment A to this letter for a detailed list of the documents
and the reasons for my decision, including the relevant sections of the FOI Act.
Disclosure Log
Agencies and ministers must publish information that has been released in response to every
FOI request, subject to certain exceptions (s 11C). This publication is known as a ‘disclosure
log’.
The disclosure log requirement does not apply to:
• personal information about any individual, if it would be unreasonable to publish the
information (s 11C(1)(a))
• information about the business, commercial, financial or professional affairs of any
person, if publication of that information would be ‘unreasonable’ (s 11C(1)(b))
• other information of a kind determined by the Information Commissioner under s
11C(2) if publication of that information would be ‘unreasonable’ (s 11C(1)(c))
• any information if it is not reasonably practicable to publish the information because
of the extent of modifications that would need to be made to delete information
listed in one of the above dot points (s 11C(1)(d)).
I am satisfied the documents being released to you contain information that may later be
published on our disclosure log (subject to certain exceptions).
How we will send your 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 Office 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 email
xxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxxxxx.xxx.xx
Yours sincerely,
Alexander
Authorised FOI Decision Maker
Freedom of Information Team
FOI and Reviews Branch | Legal Services Division
Services Australia
PAGE 2 OF 8
If not delivered return to PO Box 7820 Canberra BC ACT 2610
REASONS FOR DECISION
What you requested
This request relates to the Annual Payment Accuracy Review Program (PARP)
From Trimester 1, 2024-25 questions were introduced to examine the following
matters for the first time:
1. administrative error which denies a person receipt of a benefit they are
entitled to as a payment inaccuracy.
2. Recipient error cases in which a recipient does not claim a benefit to which
they are entitled, but which they would like to receive, as a payment
inaccuracy.
I seek the results document which outlines Trimester 1 PARP results for these
specific error categories - reporting on the prevalence of these errors.
I also seek the procedure document which (1) includes the specific questions used for
exploring these issues (2) the procedure for securing responses to these questions
from those undergoing the PARP review.
What I took into account
In reaching my decision I took into account:
• your request dated 8 August 2025
• the documents that 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.
Reasons for my decisions
I am authorised to make decisions under section 23(1) of the FOI Act.
I have decided that parts of Document 1 that you requested are exempt under the FOI Act.
My findings of fact and reasons for deciding that the exemptions that apply to those
documents are discussed below.
Section 47E(d) of the FOI Act – Operations of the Agency
I have applied the exemption in section 47E(d) of the FOI Act to parts of Document 1.
PAGE 4 OF 8
This section of the FOI Act allows the Agency to redact material from a document if its
disclosure would have a serious or significant effect on the Agency’s ability to conduct its
operations efficiently and properly.
Document 1 is a guide for Agency staff when coding changes to customer information and
claiming errors within Payment Accuracy Reviews (PAR). I am satisfied this information is
relevant to the implementation, delivery, and management of a process administered by the
Agency and therefore is relevant to the conduct of the Agency’s operations.
I consider that providing this material to you, which is not publicly available, would negatively
affect the conduct of the Agency’s operations because it may provide insight to malicious
users about navigating the Agency’s internal systems.
While I have no reason to believe you would misuse the exempt material in this way, the FOI
Act does not control or restrict the use or dissemination of the information once released, so I
must consider actions any member of the public might take if the information is in the public
domain.
Public interest considerations
Access to conditionally exempt material must be given unless I am satisfied it would not be in
the public interest to do so.
I consider disclosure of the material would promote the objects of the FOI Act, including
increasing public participation in Government processes.
However, I also consider disclosure of the exempt material would prejudice the Agency’s
ability to properly and efficiently deliver services to the public. I consider that some of the
exempt material containing detailed system coding instructions for staff could be used as a
‘how to’ guide by a malicious user to navigate the Agency’s system and therefore presents a
cyber security risk. Disclosure of this exempt cyber material would increase the likelihood
that individuals could use process information to circumvent or manipulate steps in securing
a favourable outcome for receiving payments. This in turn would significantly prejudice the
Agency’s ability to promptly and effectively deliver services to the Australian public.
Based on these factors, I have decided that in this instance, the public interest in disclosing
the information in the above-mentioned document is outweighed by the public interest
against disclosure. Accordingly, I have decided not to release the document in full to you.
I have not taken into account any of the irrelevant factors set out in section 11B(4) of the FOI
Act in making this decision.
Conclusion
In summary, I have decided that parts of the document, as set out in the Schedule, are
conditionally exempt under section 47E(d) of the FOI Act. Furthermore, I have decided on
balance it would be contrary to the public interest to release this information. Accordingly, I
have decided not to release the document in full to you.
Furthermore, out of scope or irrelevant information has been redacted in accordance with
section 22 of the FOI Act.
PAGE 5 OF 8
Section 24A of the FOI Act - Documents do not exist
Section 24A of the FOI Act permits an Agency to refuse a request for access to documents if
all reasonable steps have been taken to find the documents, and the Agency is satisfied the
documents cannot be found or does not exist. The Agency was unable to locate the
Trimester 1 PARP results data you requested in Points 1 and 2 of your request.
In processing your request, I contacted the Payment Assurance Program and Appeals
Division (PAPAD) and asked that they conduct searches for documents related to your
request. This Division is the area of the Agency responsible for payment accuracy,
compliance assurance, debt and compensation programs, policy engagement, payment
assurance processes, and the management of customer rights to a formal review of a
decision. On this basis, I am satisfied they are the appropriate area to conduct searches for
the documents relevant to your request.
The Division advised that they conducted searches of the Agency’s payment accuracy
internal resource repositories, as well as relevant shared folders where these types of
documents would normally be located. However, PAPAD advised that no documents
currently exist which outline Trimester 1 PARP results for the error categories requested.
On the basis of the searches conducted, I am satisfied al reasonable steps have been taken
to locate the documents relevant to Points 1 and 2 of your request, and the documents do
not exist.
PAGE 6 OF 8
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 full 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 Officer 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 Officer 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 wil 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.
You can lodge your application:
PAGE 7 OF 8
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 8 OF 8
