Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697629933789.pdf (Australia)
Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 Submission to the Senate Community Affairs Legislation Committee 4 October 2017 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 Contents About UNICEF Australia ................................................................................................ 3 Parameters of this submission ....................................................................................... 3 Background .................................................................................................................... 6 International human rights law and social protection ...................................................... 9 The Cashless Debit Card model .................................................................................. 12 Framing income management as a child protection measure....................................... 16 Cashless Debit Card Trial research design and data gaps ........................................... 18 Concluding recommendations ...................................................................................... 24 2 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 About UNICEF Australia 1.
UNICEF is a multilateral organisation that works in over 190 countries to promote and protect the rights of children.

UNICEF supports child health and nutrition, clean water and sanitation, quality basic education for all boys and girls, and the protection of children from violence, exploitation, abuse and HIV.

UNICEF is unique among world organisations in its rights-based and participatory approach to working with children and young people.

2.
2.

UNICEF Australia is a national committee of UNICEF which advocates for the rights of all children and works to improve public and government support for child rights and international development.

Parameters of this submission 3.

UNICEF Australia welcomes the opportunity to make a submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 being undertaken by the Senate Community Affairs Legislation Committee.

4.
4.

A rights-based approach frames UNICEF’s work on social protection, focusing on the principles of universality, accountability, non-discrimination and participation.
UNICEF has experience working on social protection as part of its global mandate to advocate for the protection of children’s rights, to help meet their basic needs and to expand their opportunities to reach their full potential.1 Social protection is a strategic and essential tool in the realization of the rights of children, women and families to an adequate standard of living and essential services, and the right to the highest attainable standard of health.
UNICEF’s approach to social protection recognises the importance of public and private policies and programmes aimed at preventing, reducing and eliminating economic and social vulnerabilities to poverty, exclusion and deprivation.2 5.

The focus on economic and social vulnerability is based on an understanding of poverty and deprivation as multi-dimensional and dynamic.
UNICEF believes that social protection programmes and policies must address both social and economic 1 UNICEF, Integrated Social Protection Systems: Enhancing Equity for Children – UNICEF Social Protection Strategic Framework (2015), <https://www.unicef.org/socialpolicy/files/UNICEF_Social_Protection_Strategic_Framework_full_doc_ std.pdf> at 1.
2 UNICEF, Integrated Social Protection Systems: Enhancing Equity for Children – UNICEF Social Protection Strategic Framework (2015), <https://www.unicef.org/socialpolicy/files/UNICEF_Social_Protection_Strategic_Framework_full_doc_ std.pdf> at 1, 7-8.
3 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 vulnerabilities together, and their underlying drivers.3 In this way, social protection can be viewed as a key investment in human capital and in breaking intergenerational poverty traps.4 6.
The responsibility of governments, the private sector and civil society to create the conditions for quality employment and decent work has been recognised as a key element of the global agenda to eradicate poverty in all its forms and dimensions.
At the United Nations General Assembly in September 2015, the goal of promoting inclusive and sustainable economic growth, employment and decent work for all was identified as one of the 17 Sustainable Development Goals, and was endorsed by member states with a commitment to its full implementation by 2030.5 Increasing labour productivity, reducing the unemployment rate, especially for young people, and improving access to financial services and benefits are essential components of sustained and inclusive economic growth.6 Similarly, the International Labour Organization has identified that ‘decent work’, taking the form of stable and well-paid employment, is supported by the four pillars of employment creation, social protection, respect for rights at work, and effective social dialogue.7 7.
This submission will primarily address UNICEF Australia’s perspectives on the impacts of the Cashless Debit Card (‘CDC’) on children and families, as well as unemployed young people who are dependent on income support.

8.

UNICEF Australia recognises the particular vulnerabilities that children and families face, and the ways that social protection can impact children even when not focused on them.
While many aspects of children’s economic and social vulnerabilities are shared with their households and communities, children also face age-specific and multidimensional vulnerabilities that differ from those of adults.
Children undergo complex physical, psychological and intellectual development as they grow, and are 3 UNICEF, Integrated Social Protection Systems: Enhancing Equity for Children – UNICEF Social Protection Strategic Framework (2015), <https://www.unicef.org/socialpolicy/files/UNICEF_Social_Protection_Strategic_Framework_full_doc_ std.pdf> at 14-15.
4 DFID, HelpAge International, Hope & Homes for Children, Institute of Development Studies, International Labour Organization, Overseas Development Institute, Save the Children UK, UNDP, UNICEF and the World Bank, Joint Statement on Advancing Child-Sensitive Social Protection (2009), <https://siteresources.worldbank.org/INTCY/Resources/395766- 1187899515414/CSSP_joint_statement_8.20.09.pdf> at 1.
5 United Nations General Assembly, Resolution adopted by the General Assembly on 25 September 2015 Transforming our world: the 2030 Agenda for Sustainable Development – The Sustainable Development Goals, GA Res 70/1, 70th sess, Agenda items 15 and 116, UN Doc A/RES/70/1 (21 October 2015), at 14.

6 United Nations Sustainable Development Knowledge Platform, Progress of Goal 8 in 2017, <https://sustainabledevelopment.un.org/sdg8>.
7 International Labour Organization, Decent Work, <http://www.ilo.org/global/topics/decent-work/lang-- en/index.htm>.

4 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 also often more vulnerable to malnutrition, disease, abuse and exploitation than adults.8 9.
In addition, UNICEF Australia notes that young people in Australia are more than twice as likely as adults to be unemployed.9 For this reason, the broader implementation of a CDC will have a disproportionate impact on young people in Australia who are dependent on income support while they seek meaningful employment.

10.

UNICEF’s approaches to social protection are based on children’s rights and the principles established in international human rights law.
This submission outlines the relevance of international human rights standards to the provision of social protection at a national level, and raises UNICEF Australia’s perspectives on the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 through a child- rights framework.
This submission is informed primarily by the following:  Convention on the Rights of the Child;10  International Covenant on Economic, Social and Cultural Rights;11  United Nations Declaration on the Rights of Indigenous Peoples;12  General Comment No.

19 on The right to social security, issued by the United Nations Economic and Social Council;13  General Comment No.
23 on The right to just and favourable conditions of work, issued by the United Nations Economic and Social Council;14 8 DFID, HelpAge International, Hope & Homes for Children, Institute of Development Studies, International Labour Organization, Overseas Development Institute, Save the Children UK, UNDP, UNICEF and the World Bank, Joint Statement on Advancing Child-Sensitive Social Protection (2009), <https://siteresources.worldbank.org/INTCY/Resources/395766- 1187899515414/CSSP_joint_statement_8.20.09.pdf> at 1.
9 Brotherhood of St Laurence, Generation Stalled: Young, Underemployed and Living Precariously in Australia (2017), <http://library.bsl.org.au/jspui/bitstream/1/9409/1/BSL_Generation_stalled_young_underemployed_20 17.pdf>; Australian Bureau of Statistics, 6202.0 – Labour Force, Australia, Aug 2017 (14 September 2017), <http://www.abs.gov.au/ausstats/abs@.nsf/mf/6202.0> 10 Convention on the Rights of the Child, opened for signature 20 November 1989, 1577 UNTS 3 (entered into force 2 September 1990), ratified by Australia with effect from 16 January 1991.
11 International Covenant on Economic, Social and Cultural Rights, opened for signature 16 December 1966, 993 UNTS 3 (entered into force 3 January 1976), ratified by Australia with effect from 10 March 1976.

12 United Nations General Assembly, Resolution adopted by the General Assembly on 2 October 2007: United Nations Declaration on the Rights of Indigenous Peoples, GA Res 61/295, 61st sess, Agenda item 68, UN Doc A/RES/61/295 (2 October 2007).
13 United Nations Economic and Social Council, General Comment No.

19: The Right to Social Security, UN Doc E/C.12/GC/19 (4 February 2008).

14 United Nations Economic and Social Council, General Comment No.

23: The Right to Just and Favourable Conditions of Work, UN Doc E/C.12/GC/23 (27 April 2016).
5 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017  General Comment No.
12 on The right of the child to be heard, issued by the United Nations Committee on the Rights of the Child;15  Sustainable Development Goals 2030;16  UNICEF Social Protection Strategic Framework;17 and the  Joint statement on advancing child-sensitive social protection.18 Background 11.
UNICEF Australia is a firm advocate for inclusive social protection that is responsive to the different dimensions and manifestations of exclusion, including gender, ethnicity, and geographic location, all of which fundamentally shape the vulnerabilities of children and their families and young people in Australia.19 In addition, international law requires that the Australian Government recognises the right of every child to benefit from social security, to ensure that such measures are implemented with the best interests of the child as a paramount consideration, and that children are consulted in the design and implementation of social protection measures that affect them.
12.

UNICEF Australia supports the stated aims and positive intentions of the Australian Government’s CDC model.

These include to address excessive alcohol consumption, illicit drug use and gambling, to reduce levels of violence and harm, encourage socially responsible behaviour, and increase long-term wellbeing at an individual, family and community level.20 These aims, along with the broader commitment to 15 United Nations Committee on the Rights of the Child, General Comment No.
12: The Right of the Child to be Heard, UN Doc CDC/C/GC/12 (20 July 2009).

16 United Nations General Assembly, Resolution adopted by the General Assembly on 25 September 2015 Transforming our world: the 2030 Agenda for Sustainable Development – The Sustainable Development Goals, GA Res 70/1, 70th sess, Agenda items 15 and 116, UN Doc A/RES/70/1 (21 October 2015).
17 UNICEF, Integrated Social Protection Systems: Enhancing Equity for Children – UNICEF Social Protection Strategic Framework (2015), <https://www.unicef.org/socialpolicy/files/UNICEF_Social_Protection_Strategic_Framework_full_doc_ std.pdf>.
18 DFID, HelpAge International, Hope & Homes for Children, Institute of Development Studies, International Labour Organization, Overseas Development Institute, Save the Children UK, UNDP, UNICEF and the World Bank, Joint Statement on Advancing Child-Sensitive Social Protection (2009) <https://siteresources.worldbank.org/INTCY/Resources/395766- 1187899515414/CSSP_joint_statement_8.20.09.pdf>.
19 UNICEF, Integrated Social Protection Systems: Enhancing Equity for Children – UNICEF Social Protection Strategic Framework (2015), <https://www.unicef.org/socialpolicy/files/UNICEF_Social_Protection_Strategic_Framework_full_doc_ std.pdf> at 28.

20 Explanatory Memorandum, Social Security Legislation Amendment (Debit Card Trial) Bill 2015 (Cth); ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 11.
6 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 stabilising families and communities, are legitimate in their intent to ensure that children in Australia grow up free from violence and intergenerational poverty.

13.
13.

UNICEF Australia also recognises the significant differences in the design of the CDC as distinct from the BasicsCard, which was used to manage income support funds under the Northern Territory Emergency Response (‘NTER’).
UNICEF Australia takes this opportunity to commend the Australian Government on its efforts to develop new pilot models to enhance social protection, and welcomes the Australian Government’s commitment towards improving health, safety and welfare outcomes for children and families who are recipients of income support.
This includes the additional investment by the Australian Government into wraparound services intended to support the implementation of the CDC in Trial communities, such as additional funding to family violence services, as well as drug and alcohol counsellors.

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14.

UNICEF Australia also recognises and commends the efforts of the Australian Government to address important human rights issues affecting the full realization of the rights of children and families in the CDC Trial communities of Ceduna and the East Kimberley, including:  Safety and security (e.g.

domestic and family violence, sexual violence, assaults and harassment/intimidation);  Financial problems (e.g.
inability to pay fines, inability to fund basic living expenses for items such as food, clothing, rent and utilities);  Social problems such as family arguments/disputes, unemployment/underemployment and ‘humbugging’;  Living in overcrowded housing conditions;  Adverse impacts on the wellbeing of children as a result of poor parenting/neglect of family responsibilities and lack of engagement (e.g.

lower school attendance and engagement, poor educational outcomes and poor nutrition).21 15.
While supporting the stated aims of the CDC model, UNICEF Australia also believes in the importance of strong and credible evidence that the CDC model is effective in producing positive outcomes for children and families and young people in Australia, before extending the implementation of the CDC to further sites.

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16.

UNICEF Australia takes this opportunity to raise a number of questions about the manner in which the CDC Trial has been evaluated by ORIMA Research for the 21 ORIMA Research for Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 39.
7 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 Department of Social Services, set out in the Final Evaluation Report released in August 2017 (‘Final Report’), and its precursor, the Wave 1 Interim Evaluation Report (‘Wave 1 Report’) released in February 2017.
UNICEF Australia is of the view that there is currently insufficient evidence regarding the ability of the CDC to achieve its stated aims, particularly those relating to improving safety and wellbeing for children and families.

17.

In addition, UNICEF Australia recognises that there is no ‘one size fits all’ or ‘top down’ solution to addressing social and economic vulnerabilities.
Similarly, there are no short cuts to resolving what amount to highly complex policy issues in communities, such as intergenerational unemployment, family violence and addiction.
While recognising the importance of taking a multidisciplinary approach to addressing inequalities, UNICEF Australia notes that it is currently difficult to assess whether the additional funding invested by the Australian Government into strengthening and providing additional wraparound services in CDC Trial communities has been effective in achieving positive outcomes for children and young people.
UNICEF Australia encourages taking a robust approach in the development, implementation and evaluation of these services, to ensure that they have necessary community support, are accessible and targeted to reach their intended recipients, and as far as possible, are community-led measures that strengthen community capacity and address inequality, violence and substance abuse in communities.
This level of commitment is essential to ensuring positive outcomes in the delivery of effective social protection for children and families and young people in Australia.

18.

UNICEF Australia also takes this opportunity to note that public debate regarding social protection often focuses on the high cost of providing cash payments to working age people, such as unemployment benefits and allowances (including Newstart Allowance).
This is often accompanied by strong points of view regarding how welfare recipients should be allowed to spend their income provided in the form of unemployment benefits and allowances.

For this reason, income management in the form of a CDC may attract popular support as it seeks to restrict the ability of welfare recipients to use unemployment cash payments to purchase alcohol, illicit drugs or engage in gambling.
While acknowledging this point of view, UNICEF Australia notes that unemployment benefits and allowances only represent around 17% of total welfare expenditure as presented in the budget, and these are not the 8 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 main drivers of growth in government expenditure on social protection.22 UNICEF Australia encourages a reframing of the discussion on the CDC to ensure that the issue of how welfare recipients spend their money does not receive disproportionate attention, and risk overshadowing the more important discussion around the effectiveness of the CDC in achieving its stated aims, particularly those relevant to building positive outcomes for children and young people in Australia.
International human rights law and social protection 19.

Australia’s obligations under international human rights law are necessary considerations in shaping the policy and legislative approach to social protection.
Human rights are universal and inalienable, indivisible, interdependent and interrelated.23 All rights are ‘equal in importance and none can be fully enjoyed without the others’.24 The interrelated and equal nature of human rights must be borne in mind when determining what policy and legislative measures are appropriate to help protect children and adults, especially in the context of developing and implementing social protection measures.

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20.

Having ratified the International Covenant on Economic, Social and Cultural Rights 1966, Australia has recognised the right of everyone to social security.25 This involves a holistic consideration of the particular vulnerabilities faced by those who are most in need of social protection.

The United Nations Economic and Social Council has indicated that the right to social security involves the four key elements of availability, adequacy, affordability and accessibility.
The right to social security must be implemented through a system which ensures that benefits are provided for relevant social risks and contingencies.

Additionally, the benefits provided must be adequate in amount and duration such that everyone may realize her or his rights to family protection and assistance, an adequate standard of living and adequate access to health care.
Any direct and indirect costs and charges associated with making contributions to a social security scheme must be affordable for all and must be accessible, such that all persons are covered by the social security system, 22 Parliament of Australia, Welfare – what does it cost?, <http://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/pubs/B riefingBook45p/WelfareCost>.
23 United Nations Population Fund, Human Rights Principles (2005), <http://www.unfpa.org/resources/human-rights-principles>.

24 United Nations Population Fund, Human Rights Principles (2005), <http://www.unfpa.org/resources/human-rights-principles>.

25 Article 9, International Covenant on Economic, Social and Cultural Rights, opened for signature 16 December 1966, 993 UNTS 3 (entered into force 3 January 1976), ratified by Australia with effect from 10 March 1976.
9 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 especially individuals belonging to the most disadvantaged and marginalized groups, without discrimination.26 21.
Social protection has proven to be an effective measure for tackling disparities in income as well as empowering vulnerable populations by addressing social vulnerabilities caused by structural inequalities and inadequate protection of rights.
By reducing inequalities, social protection promotes sustainable development – it supports inclusive growth, facilitates social integration and contributes to positive environmental outcomes.27 UNICEF, the International Labour Organization and the World Bank conceptualise social protection as a key policy tool to reduce poverty and inequality, while also stimulating inclusive economic growth by boosting the health and capacity of vulnerable segments of society, increasing their productivity, supporting domestic demand, and facilitating important structural transformation of national economies.
22.
In its commentary on the right to social security, the United Nations Economic and Social Council has explained that States parties are under an obligation to guarantee that the right to social security is enjoyed without direct or indirect discrimination, either in law or in fact.28 The Council has said that in giving effect to the right to social security, ‘States parties must also pay full respect to the principle of human dignity … and the principle of non-discrimination, so as to avoid any adverse effect on the levels of benefits and the form in which they are provided’.29 The Council has also made clear the requirement of appropriate consultation, providing that, ‘The right of individuals and groups to participate in decision-making processes that may affect their exercise of the right to social security should be an integral part of any policy, programme or strategy concerning social security’.30 23.
In addition, having ratified the Convention on the Rights of the Child 1989, Australia has made a commitment to recognise the right of every child to benefit from social 26 United Nations Economic and Social Council, General Comment No.

19: The Right to Social Security, UN Doc E/C.12/GC/19 (4 February 2008); United Nations Office of the High Commissioner for Human Rights, Toolkit on the Right to Social Security, <http://www.ohchr.org/EN/Issues/RightSocialSecurity/Pages/SocialSecurity.aspx>.
27 United Nations General Assembly, Resolution adopted by the General Assembly on 25 September 2015 Transforming our world: the 2030 Agenda for Sustainable Development – The Sustainable Development Goals, GA Res 70/1, 70th sess, Agenda items 15 and 116, UN Doc A/RES/70/1 (21 October 2015).
28 Article 2(2), International Covenant on Economic, Social and Cultural Rights, opened for signature 16 December 1966, 993 UNTS 3 (entered into force 3 January 1976), ratified by Australia with effect from 10 March 1976.

29 United Nations Economic and Social Council, General Comment No.

19: The Right to Social Security, UN Doc E/C.12/GC/19 (4 February 2008), at 7.

30 United Nations Economic and Social Council, General Comment No.
19: The Right to Social Security, UN Doc E/C.12/GC/19 (4 February 2008), at 19.
10 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 security, and to take the necessary measures to achieve the full realization of this right in accordance with Australian law.31 Australia has also recognised the right of every child to a standard of living adequate for the child’s physical, mental, spiritual, moral and social development.
In doing so, Australia has made a commitment to take appropriate measures to assist parents and others responsible for children to provide material assistance and support programs to secure the conditions of living necessary for the child’s development, particularly with regard to nutrition, clothing and housing.32 24.
Australia has also agreed to be bound by the obligation to recognise the right of every child to freely express their views in all matters affecting them, and the subsequent right for those views to be given due weight according to the child’s age and maturity.33 The United Nations Committee on the Rights of the Child has stated that the right of all children to be heard and taken seriously constitutes one of the fundamental values of the Convention on the Rights of the Child 1989, alongside the right to non-discrimination, the right to life and development, and that the best interests of the child shall be a primary consideration in all actions concerning the child.34 25.
UNICEF Australia notes that a high proportion of individuals who have been subject to income management in the form of the CDC are of Indigenous descent.

In 2009, the Australian Government announced its support for the United Nations Declaration on the Rights of Indigenous Peoples, adopted by the United Nations General Assembly in 2007.

The provisions of the Declaration include that ‘Indigenous peoples have the right to self-determination.
By virtue of that right they freely determine their political status and freely pursue their economic, social and cultural development.’35 Indigenous peoples also have the right, without discrimination, to the improvement of their economic and social conditions, including in the areas of education, employment, vocational training and retraining, housing, sanitation, health and social 31 Article 26, Convention on the Rights of the Child, opened for signature 20 November 1989, 1577 UNTS 3 (entered into force 2 September 1990), ratified by Australia with effect from 16 January 1991.
32 Article 27, Convention on the Rights of the Child, opened for signature 20 November 1989, 1577 UNTS 3 (entered into force 2 September 1990), ratified by Australia with effect from 16 January 1991.

33 Article 12, Convention on the Rights of the Child, opened for signature 20 November 1989, 1577 UNTS 3 (entered into force 2 September 1990), ratified by Australia with effect from 16 January 1991.

34 United Nations Committee on the Rights of the Child, General Comment No.
12: The Right of the Child to be Heard, UN Doc CDC/C/GC/12 (20 July 2009), at 5.

35 Article 3, United Nations General Assembly, Resolution adopted by the General Assembly on 2 October 2007: United Nations Declaration on the Rights of Indigenous Peoples, GA Res 61/295, 61st sess, Agenda item 68, UN Doc A/RES/61/295 (2 October 2007).
11 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 security.36 In accord with the Declaration, States are to pay particular attention to the rights and special needs of women, youth and children, and are to take measures, in conjunction with Indigenous peoples, ‘to ensure that indigenous women and children enjoy the full protection and guarantees against all forms of violence and discrimination’.37 The Cashless Debit Card model 26.
UNICEF Australia shares the Australian Government’s commitment towards achieving better short, medium and long-term outcomes for all Australian children and young people.

UNICEF Australia has a number of concerns with the CDC model, particularly when considered from a child-rights perspective.
Compulsory income management has been trialled in similar forms across Australia, and it remains unclear whether this measure is capable of addressing the structural nature of the inequalities experienced by some children and young people in Australia.

27.

Social protection measures can be an effective tool to tackle inequalities when conceived of and implemented in a holistic way.
Inequality can be best addressed when understood as part of a broader framework – in addition to strong economic foundations, individuals need broader social, cultural and political resources to flourish and lead meaningful lives.38 Social protection measures must adequately address social as well as economic vulnerabilities.

This requires mainstreaming social inclusion into social protection programs and using a broad range of social protection instruments.39 28.
By focusing predominantly on income management, the CDC model risks failing to appropriately address or acknowledge the complexities and reinforcing dynamics of inequality, including inequalities in opportunity as well as inequalities across key population groups and communities historically evidenced as being susceptible to social exclusion in Australia.
UNICEF Australia questions whether the CDC model adequately assists in building capacity for children and families within communities 36 Article 21, United Nations General Assembly, Resolution adopted by the General Assembly on 2 October 2007: United Nations Declaration on the Rights of Indigenous Peoples, GA Res 61/295, 61st sess, Agenda item 68, UN Doc A/RES/61/295 (2 October 2007).
37 Article 22, United Nations General Assembly, Resolution adopted by the General Assembly on 2 October 2007: United Nations Declaration on the Rights of Indigenous Peoples, GA Res 61/295, 61st sess, Agenda item 68, UN Doc A/RES/61/295 (2 October 2007).
38 United Nations Economic and Social Commission for Asia and the Pacific, Time for Equality: The Role of Social Protection in Reducing Inequalities in Asia and the Pacific (2005), <https://www.unescap.org/sites/default/files/SDD%20Time%20for%20Equality%20report_final.pdf>.
39 UNICEF, Integrated Social Protection Systems: Enhancing Equity for Children – UNICEF Social Protection Strategic Framework (2015), <https://www.unicef.org/socialpolicy/files/UNICEF_Social_Protection_Strategic_Framework_full_doc_ std.pdf> at 46, 75-80.
12 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 affected by high levels of violence, unemployment, addiction, and low school attendance rates.
While noting the additional funding committed by the Australian Government towards support services in CDC Trial communities, UNICEF Australia encourages the Australian Government to invest greater attention and commitment towards more targeted services for children and young people experiencing the multidimensional and reinforcing dynamics of inequality.
This includes social services that are important to children’s survival and development, including youth suicide support or detox services, as well as cultural support services and schooling initiatives.

It also includes developing sustainable and locally relevant employment pathways and a stronger investment in jobs creation, as well as initiatives which support and stimulate creative enterprise for young people in Australia.

29.
29.

Social inequalities are commonly reinforced by a lack of voice and power, and programmes which are implemented without appropriate consultation or community participation may feed inequality and feelings of disengagement and dissent, particularly among children and youth.
UNICEF Australia notes that compulsory income management for welfare recipients under the NTER resulted in ‘a loss of dignity; disempowerment, disillusionment, resentment and anger; shame, frustration, embarrassment and humiliation; and a sense of reversion to a protectionist era evoking “ration days”, with the attendant loss of autonomy’.40 Meaningful contribution by key stakeholders is important at all stages including in the design, implementation and evaluation of social protection policies and programmes.
This level of participation is relevant to social protection in two ways: social protection policies and their redistribution mechanisms need to be justified and validated by beneficiaries and non-beneficiaries; and implementation mechanisms and structures require the active participation of beneficiaries to enhance their relevance, appropriateness and ownership, and to ensure their effectiveness.41 30.
UNICEF Australia encourages the Australian Government to ensure that there is sufficient consultation with children and families and young people who are recipients of income support, from the earliest stages of design and commencement through to implementation and evaluation of the CDC model.
UNICEF Australia stresses the importance of obtaining direct input from children and young people who have or may be impacted by the CDC, and whose perspectives will likely prove invaluable in 40 Alison Vivian and Ben Schokman, ‘The Northern Territory Intervention and the Fabrication of “Special Measures”’ (2009) 13(1) Australian Indigenous Law Review 78, 90.
41 UNICEF, Integrated Social Protection Systems: Enhancing Equity for Children – UNICEF Social Protection Strategic Framework (2015), <https://www.unicef.org/socialpolicy/files/UNICEF_Social_Protection_Strategic_Framework_full_doc_ std.pdf> at 46.
13 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 providing clarity on the effectiveness of the CDC in addressing the inequalities they experience.

31.

Financial inclusion approaches should also seek to unlock opportunities for children and families to protect themselves from hardship and invest in their futures.
Affordable, effective and safe financial services pertaining to savings, insurance and credit can play a transformative role by fostering more equitable growth and furthering vital development goals, such as poverty reduction, job creation and gender equality.
Financial inclusion principles are also considered enablers of the Sustainable Development Goals 2030, and feature in eight out of the 17 goals.42 UNICEF Australia notes that it is unclear whether the CDC model has been designed with due regard for the G20 Principles for Innovative Financial Inclusion, including: leadership, diversity, innovation, protection, empowerment, cooperation, knowledge, and framework.43 32.
Additionally, one of the aims of effective social protection is to foster individual responsibility and provide a platform for people to move up and out of welfare dependency.

During an address to the Western Australian Liberal Party on 3 September 2017, Prime Minister Malcolm Turnbull spoke of the CDC Trial as ‘an exercise in practical love’, and said, ‘It is critically important that we do everything we can to encourage people to get off welfare.
To help themselves.’44 However, UNICEF Australia has concerns that compulsory income management in the form of the CDC model may not help build individual capacity or long-term community change, and may in effect build a dependency on welfare support.

For example, UNICEF Australia notes the evaluation findings of the New Income Management scheme introduced in the Northern Territory in 2010, which replaced the BasicsCard introduced as part of the NTER in 2007.
Research conducted for the Department of Social Services between 2010 and 2014 found that ‘rather than promoting independence and the building of skills and capabilities, New Income Management in the Northern Territory appears to have encouraged increasing dependence upon the welfare system, and the tools which were envisaged as providing them with the skills to manage have rather become instruments which relieve them of the burden of management’.45 This 42 United Nations Capital Development Fund, UNCDF and the SDGs: Financial Inclusion and the SDGs, <http://www.uncdf.org/financial-inclusion-and-the-sdgs>.
43 Global Partnership for Financial Inclusion, G20 Principles for Innovative Financial Inclusion, <http://www.gpfi.org/sites/default/files/documents/G20%20Principles%20for%20Innovative%20Financ ial%20Inclusion%20-%20AFI%20brochure.pdf>.

44 Malcolm Turnbull, ‘Prime Minister’s Address to the WA Liberal Party State Conference’, speech, Western Australia, 3 September 2017, <https://www.malcolmturnbull.com.au/media/address-to-the- wa-liberal-party-state-conference-3-september-2017>.
45 J Rob Bray, Matthew Gray, Kelly Hand and Ilan Katz, Evaluating New Income Management in the Northern Territory: Final Evaluation Report (Australian National University: Social Policy Research 14 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 raises questions about the sustainability of the CDC model as an income management measure, given that the CDC model appears to take a long-term view on restricting rights, as evidenced through the indefinite nature of the timeframes attached to the CDC Trial in Ceduna and the East Kimberley.
33.

UNICEF Australia is of the view that the CDC model may not be sufficiently flexible or appropriate for women and children experiencing family violence who are recipients of income support.
The CDC model creates the risk of further disempowering individuals who have experienced or are currently experiencing coercive and controlling behaviours from their partners, who are then subjected to a government- imposed loss of independence, autonomy and control over their finances in the form of income management.46 There is a more pressing need for appropriate support services and appropriately supportive social security mechanisms, given the vulnerable position of people experiencing family violence and the complex needs for their safety and protection.
An effective social security system should responsibly assist women and children whenever necessary to leave violent situations and rebuild their lives.

However, compulsory income management may risk putting women and children in further danger, impeding their ability to flee family violence and take independent action due to the limited cash funds available under the CDC model.47 34.
UNICEF Australia also notes that a broader roll-out of the CDC model will likely have a disproportionate impact on the large number of young people who are recipients of income support, such as Newstart and Youth Allowance.
In particular, this includes young people who are proactively seeking opportunities for productive employment, who do not engage in problematic behaviour involving excessive consumption of alcohol, illicit drugs or gambling, and who thereby do not necessarily require assistance in managing the income support they receive.
For these young people, compulsory income management is not a reasonably justifiable measure, and the inherent restrictions of the CDC model may have considerable short and long-term negative impacts on their freedom and capacity to independently manage their finances.
Instead, UNICEF Australia advocates for greater levels of investment by Centre, September 2014), <http://caepr.anu.edu.au/sites/default/files/cck_misc_documents/2014/12/Evaluation%20of%20New% 20Income%20Management%20in%20the%20Northern%20Territory_full%20report.pdf> at xxii.

46 Australian Law Reform Commission, Family Violence and Commonwealth Laws – Improving Legal Frameworks: Final Report, Report No 117 (2011), <http://www.alrc.gov.au/sites/default/files/pdfs/publications/whole_alrc_117.pdf> at 260-261.
47 Australian Law Reform Commission, Family Violence and Commonwealth Laws – Improving Legal Frameworks: Final Report, Report No 117 (2011), <http://www.alrc.gov.au/sites/default/files/pdfs/publications/whole_alrc_117.pdf> at 264-265.
15 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 the Australian Government in creating more opportunities for relevant training and for ‘decent work’ for young people in Australia.

35.
35.

UNICEF Australia also recognises the potential for unintended negative consequences and circumvention behaviours under the CDC model, as identified in reviews of the NTER.

This may include an increase in theft and burglary or commercial sex work, risks that are always present when implementing measures that limit the availability of cash within communities.

36.

Similarly, the CDC model may involve unintended financial consequences for welfare recipients.
An evaluation of the BasicsCard under the NTER found that: ‘Significant problems reported with respect to the BasicsCard include the imposition of minimum purchase limits, the imposition of surcharges on the use of the card, and the limited number of outlets at which it could be used.

In addition, the approach to merchant approval meant that many people reported having to purchase items at higher prices at approved merchants.
The payment of rent was a major problem for some people in urban areas in a range of situations, including group housing and where landlords sought cash payment.’48 UNICEF Australia is keen to understand whether these issues have been resolved in the design and implementation of the CDC model.

Framing income management as a child protection measure 37.

Globally, UNICEF promotes the strengthening of all components of child protection systems.
To ensure positive outcomes for children, it is essential that child protection is mainstreamed at a systems-level across government departments and in cross- sector service delivery.

Child protection systems may cut across social welfare, education, health and social security sectors, depending on the particular national context and the vulnerabilities sought to be addressed.

38.

The Australian Government has spoken of the value of the CDC as a child protection measure.
During his address to the Western Australian Liberal Party on 3 September 2017, Prime Minister Malcolm Turnbull stated that the CDC ‘speaks to values of compassion and of love, but also of ensuring that we protect the most vulnerable’.
He said that the CDC Trial in Ceduna and the East Kimberley had resulted in ‘a massive reduction in alcohol abuse, in drug abuse, in domestic violence, in violence generally; a really huge improvement in the quality of life, not just for the families who are using 48 J Rob Bray, Matthew Gray, Kelly Hand and Ilan Katz, Evaluating New Income Management in the Northern Territory: Final Evaluation Report (Australian National University: Social Policy Research Centre, September 2014), <http://caepr.anu.edu.au/sites/default/files/cck_misc_documents/2014/12/Evaluation%20of%20New% 20Income%20Management%20in%20the%20Northern%20Territory_full%20report.pdf> at xxi.
16 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 the Cashless Welfare Card, but for the whole community.

But above all, above all it’s an investment in the future of the children.’49 39.
In order to qualify as a child protection measure, the CDC must have as its primary objective the protection of children, and must be supported by integrated initiatives that increase community awareness and understanding of child protection, enhance community capacity to respond to children who may be living in complex circumstances, and appropriately address gaps in quality service provision for children and families.
To date, the CDC does not appear to have been designed or implemented in a way that is child-centred, child-friendly, or in a manner that addresses issues of child protection in a holistic way.

40.

The CDC appears to have been conceived of as a child protection measure in the absence of data or information about the impacts of the CDC Trial on children already in contact with or subject to the child protection system.
UNICEF Australia is particularly interested in understanding how many children who have been in contact with the child protection system or have been subject to child protection orders are currently, or have been, impacted by income management.

41.
41.

Further, the primary assumption underlying the CDC appears to be that income management, if successful in addressing problematic social behaviours including excessive alcohol consumption, illicit drug use or gambling, will thereby prevent violence and child sexual abuse.

UNICEF Australia cautions the Australian Government of the danger in relying on this assumption, and creating an unrealistic expectation of what income management in the form of a CDC can reasonably seek to achieve.
The CDC model risks failing to address the many complex and entrenched underlying social norms that perpetuate violence against children.

42.

Rather than seeking to rely on a CDC to address serious issues affecting children who are dependent on income support, UNICEF Australia encourages the Australian Government to make a stronger investment in effective child protection for families dependent on income support.
UNICEF Australia advocates for sustainable, holistic and ‘bottom up’ initiatives to enhance child protection, developed by communities with the support and resources of government and other services.
This should include community education, positive parenting programs, strengthened child protection systems, policing support, experienced case workers and social workers appropriately trained to address social norms at community level, and access to 49 Malcolm Turnbull, ‘Prime Minister’s Address to the WA Liberal Party State Conference’, speech, Western Australia, 3 September 2017, <https://www.malcolmturnbull.com.au/media/address-to-the- wa-liberal-party-state-conference-3-september-2017>.
17 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 family counselling services.

Income management in the form of a CDC can only reasonably be seen as a small part of influencing a broader, long-term agenda for improving child protection in Australia.

Cashless Debit Card Trial research design and data gaps 43.
UNICEF Australia believes there is some value in questioning the strength of the data sources relied upon and research methodologies undertaken by ORIMA Research for the Department of Social Services in evaluating the CDC Trial in Ceduna and the East Kimberley.

44.

UNICEF Australia notes the short time frames involved in the data collection for the CDC Trial evaluation – Wave 1 data was obtained a few months after the implementation of the CDC Trial, while Wave 2 data was obtained only 9 months later.
UNICEF Australia questions the extent to which this time frame is sufficient to properly assess the short, medium and long-term impacts and stated aims of the CDC Trial.

45.
45.

UNICEF Australia notes in particular the following key evaluation findings of the Final Report, including that:  The CDC Trial has been effective in reducing alcohol consumption and gambling in both Trial sites and is also suggestive of a reduction in the use of illegal drugs;50 and  There was some evidence that there has been a consequential reduction in violence and harm related to alcohol consumption, illegal drug use and gambling in the Trial sites.51 46.
According to the Final Report, there was ‘limited available administrative data’ on which to base findings of a reduction in the consumption of alcohol, illegal drug use, or gambling.52 The main data source relied upon appears to be self-reporting in results from face-to-face surveys of Trial participants, family members of Trial participants, and non-participants (including community leaders, stakeholders and merchants).
The primary evidence for the conclusion that the CDC Trial was effective in reducing alcohol consumption and gambling and suggestive of a reduction in the 50 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 117.

51 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 117.
52 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 4.

18 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 use of illegal drugs was self-reported behavioural change by CDC Trial participants collected via the quantitative survey.53 47.
The Final Report also acknowledges a number of limitations in self-reported behavioural change, including recall error, as the evaluation was conducted six to 12 months after the completion of the Trial.54 Further, that self-reported data is subject to ‘social desirability bias and hence should be interpreted with due caution’.55 For example, this was identified as being particularly problematic when assessing changes in the use of illegal drugs.
The Final Report acknowledges that the ‘use of illegal drugs is difficult to reliably assess due to the clandestine nature of the behaviour’,56 and states that ‘self-reports of illegal drug use in a survey context are subject to a high risk of social desirability bias’.57 48.

Perception-based data can prove useful anecdotally.
However, UNICEF Australia questions whether the findings on perceived positive changes in behaviour, based on observations by Trial participants and non-Trial participants, can be relied upon to add evidentiary weight to the evaluation’s findings.
For example:  In relation to illegal drug use, the Final Report states that: ‘In terms of observable impacts, most of the feedback received in the qualitative research appeared to be very much anecdotal and based on hearsay rather than based on hard or direct evidence – this is not surprising as drug taking behaviour was reported as being “hidden” given its illegal nature.’58  In relation to perceived changes in levels of violence in communities, the Final Report states that: ‘Qualitatively, stakeholders and community leaders indicated that violence had slightly reduced in their communities at Wave 1.
This trend continued in Wave 2, with most stakeholders and community leaders reporting that violent and aggressive behaviours had reduced.’59 However, this appears to be contradicted by perceptions reported by Trial 53 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 7.
54 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 9.

55 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 117.

56 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 50.
57 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 50.

58 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 53.

59 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 64.
19 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 participants.
The Final Report states that: ‘In contrast, perceptions among CDCT participants were more mixed, with there being no statistically significant difference on average across the two sites between those who perceived that violence had decreased (20%) and those who perceived that it had increased (24%) ...

In EK [East Kimberley], at both Wave 1 and Wave 2, a greater proportion of participants felt that violence had increased than had decreased.’60 49.
Further, some of the findings in the Final Report suggest that initial positive impacts may have reduced in the time between the Wave 1 and Wave 2 evaluations, including that:  ‘Community leaders’, stakeholders’ and merchants’ ratings to a short questionnaire in the qualitative research indicated that they perceived that alcohol abuse … had increased marginally in the East Kimberley Trial site between the Wave 1 evaluation and the Final Report, from 6.8 to 7.4 out of 10 (8.3 pre-Trial), based on average ratings on a scale of 0 (not at all) to 10 (extremely severe).’61  East Kimberley participants were more likely to report that they had noticed more gambling at Wave 2 than Wave 1 (16% as opposed to 8%) and less likely to report that they had noticed less gambling (a reduction from 30% down to 22%).
A similar trend was apparent amongst East Kimberley non- participants.62 50.

Findings of the ORIMA evaluation indicate that it is not clear that the CDC Trial successfully achieved its stated aims of a reduction in crime, violence and harm.

This raises concerns about the efficacy of the CDC in addressing anti-social and disruptive behaviours, and its value as a social policy tool to improve safety and wellbeing for children and young people in Australia.
For example:  Administrative data available in relation to criminal activity across the two Trial sites generally did not show evidence of a reduction in crime since Trial commencement.63 At the time of the Wave 1 data collection, ‘there was only limited evidence to suggest that there was a reduction in crime, violence and 60 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 64.
61 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 44.

62 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 55.

63 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 117.
20 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 harm related to alcohol consumption, illegal drug use and gambling since the Trial commenced’.64 The Final Report makes clear that ‘crime statistics showed no improvement since the commencement of the Trial’,65 and states that: ‘Comparisons of crime statistics in Kununurra, Wyndham and Ceduna before and after the Trial did not show a decrease in the number of assaults (domestic and otherwise) and other offences against the person, and robbery and related offences (including theft and burglary).
In East Kimberley, an overall increase in criminal incidents were recorded … The only notable reductions were recorded in relation to drug driving offences and PIA [Public Intoxication Act] apprehensions in Ceduna.’66  Similarly, the evaluation findings provide limited evidence of an improvement in perceptions of safety in the Trial locations.67 The Final Report stated that on a scale of 0 (very poor) to 10 (very well), community leaders’, stakeholders’ and merchants’ ratings of their community’s performance in terms of community safety increased from 4.2 pre-Trial to only 5.7 out of 10 in East Kimberley, and 4.6 pre-Trial to only 6.3 out of 10 in Ceduna.68  Findings on whether the CDC Trial had any impacts on levels of domestic violence in the Trial communities are not contained in the Final Report.
The Wave 1 Report states that a reduction in the number of injuries indicative of domestic violence presenting at the East Kimberley hospital was reported by the Accident and Emergency department.

However, it also stated that ‘a few stakeholders had identified some increase in domestic violence/intervention orders’.69 Limited consideration of the impacts of the CDC Trial on children and families 51.
The evaluation of the CDC Trial appears to have involved limited investigation into the particular impacts of the CDC on children and families, and young people who 64 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 4; ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Wave 1 Interim Evaluation Report (February 2017), at 46.
65 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 4.

66 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 60.

67 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 117.
68 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 5.

69 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Wave 1 Interim Evaluation Report (February 2017), at A60.
21 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 are dependent on income support.

In the absence of this information, it is difficult to properly assess whether the CDC is an appropriate social policy tool to improve the safety and wellbeing of children and young people in Australia.

52.
52.

The Final Report presents inconsistent findings about the impact of the CDC on parenting and family-related outcomes for Trial participants with children.

These included that:  At Wave 2 on average across the Trial sites, 40% of participants who had caring responsibilities reported that they had been better able to care for their children since being in the CDC Trial.
However, a larger number (48%) of participants reported a more neutral finding that they had not been better able to care for their children since being in the CDC Trial.70  Similarly, on average across the Trial sites at Wave 2, 39% of participants with caring responsibilities said they had become more involved in their children’s homework and schooling since being a CDC Trial participant.
However, 40% of participants said that they had not.71  When asked about the impact of the Trial on their child/children’s lives overall, at both Wave 1 and Wave 2 stages, more participants reported that their lives had become worse rather than better as a result of the CDC Trial.
At the time of the Wave 2 evaluation, 24% of participants felt their child/children’s lives were worse (consistent with 20% at Wave 1), in comparison to the 17% who felt their child/children’s lives were better as a result of the Trial (consistent with 18% at Wave 1).72  The Final Report states that positive parenting impacts were also evidenced by qualitative and quantitative findings of an overall improvement in parental responsibility, including improved care and nurture of and expenditure on children, and parent engagement.73 However, Trial participants reported that there was a perceived deterioration in relation to the provision of items for children.74 A large number of participants (55% at Wave 2, up from 40% at Wave 1) reported that they had run out of money to pay for things that their 70 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 78-79.
71 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 79-80.

72 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 80.

73 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 69.
74 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 72.
22 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 child/children needed for school, or that they had run out of money to pay for essential (non-food) items for their children (54% at Wave 2, up from 40% at Wave 1).75 53.

The Final Report presents inconsistent findings about whether the CDC Trial resulted in unintended positive social impacts.
The Final Report stated that there was some qualitative feedback which indicated that there had been positive social impacts, demonstrated by observations of increased optimism, positivity, family interaction and the ownership of more food/goods.

However, a few other stakeholders and community leaders felt that there had been no observable change.76 54.

The findings were also inconsistent about rates of school attendance for children.
The Final Report stated that ‘available administrative data on school attendance rates showed little change during the CDC Trial period in Ceduna and surrounds.

In Kununurra, available administrative data on school attendance also showed little change in average attendance rates for Indigenous children during the CDC Trial period.’77 55.

In addition, the CDC Trial does not appear to have had a positive impact in other areas of particular importance to children and families, such as adequate housing.
According to the Final Report, most stakeholders and community leaders reported that the Trial had not had a material impact on housing in the Trial sites, and lack of housing, overcrowding and rough sleeping were still noted as key ongoing issues in the Trial communities.78 56.
UNICEF Australia also notes that the scope of the CDC Trial evaluation did not include long-term outcomes (defined as being of two years or more), many of which are of critical importance to assessing the success of a CDC as a social policy tool for children and families.
These include whether the CDC Trial resulted in:  An increase in community safety and security;  An increase in safety of women and children;  More powerful community expectations and norms for alcohol use, drug use, gambling and violence; 75 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 72-73.
76 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 69.

77 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 78.

78 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 80.
23 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017  More powerful community expectations and norms around housing and schooling;  Increased community, personal and children’s well-being (including school attendance); and  The intended societal change of safer children’s families and communities, by reducing welfare-fuelled violence arising from alcohol and other drug use and gambling.79 Concluding recommendations 57.
UNICEF Australia recommends that: a) the Australian Government commits to a strategic, holistic approach to social protection that is responsive to the different dimensions and manifestations of inequality, and appropriately addresses the particular vulnerabilities and inequalities experienced by children and families and young people dependent on income support.
This should include sustainable, community- led and locally relevant initiatives resourced by government to improve child protection, education, health, housing, job creation and family support, as well as systems-level improvements in service delivery in areas that are important to children’s survival and development.
b) any social protection measures that are implemented at a community level have their foundations in strong community consultation and participation, and are implemented with the support of, and in partnership with, communities.

c) the Australian Government invests greater time and resources into evaluating the short, medium and long-term impacts of the CDC Trial in Ceduna and the East Kimberley.
This must include investing in a more robust research methodology, underpinned by a stronger monitoring and evaluation framework.

It must also include thorough consultation and input from children and families, young people dependent on income support, and Indigenous communities, to better understand the impacts of the CDC Trial on their safety and wellbeing.
d) the Australian Government ensures that there is a strong and credible evidence base that a CDC is an effective social policy tool in addressing violence and harmful social behaviours, before implementing the CDC model in additional sites.

79 ORIMA Research for the Australian Government Department of Social Services, Cashless Debit Card Trial Evaluation, Final Evaluation Report (August 2017), at 128.
24 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51 UNICEF Australia – Submission to the Inquiry into the Social Services Legislation Amendment (Cashless Debit Card) Bill 2017 e) the CDC model is revised and assessed against the core Financial Inclusion principles before implementing the CDC model in additional sites.
f) the CDC model is revised and assessed as to its appropriateness in situations involving family violence, ensuring that its implementation is not accompanied by unintended negative consequences including circumvention behaviours or additional costs for welfare recipients.
g) the CDC model should have a nil cost for users, and the Australian Government should ensure that all users are appropriately informed and credited for their financial and other data that may be relied upon by the government in the administration and assessment of the CDC model.
h) any further implementation of a CDC is done in a voluntary manner on an ‘opt-in and opt-out’ basis that is more adaptable to individual circumstances and is responsive to the particular needs of children and families, young people on income support, and Indigenous communities.

25 Social Services Legislation Amendment (Cashless Debit Card) Bill 2017Submission 51