What are your views on the proposed principles for developing the industry funding model?

It’s not clear how the model will suceed in improving the predictability and stability of funding. as contributions are voluntary, there is a very large, unknown assumption being made that the required funds will be met each and every year.

it is also not clear how the industry will benifit by have a split administration of funds. How contracts will be administered and how they will be coordinated with DSS funding. This could result in aditional administrative burden for organisations


What are your views on the proposed quantum for each year of the first three years of the model?

In WA there is a significant unmet need for financial counselling following the state Government’s decision to cut local funding about 5 years ago. I’m not confident that WA will receive sufficient funding to return to previous levels, let alone meet the current demand. Second, there is a significant issue with recruiting and retaining Financial Counsellors in regional areas. Part of this innovation should go to support regional areas to attract qualified staff.


Are there any evidence-based adjustments that could be made to the suggested contributions methodology? What are they and how could they be incorporated into the methodology?

The methodology used to identify industry weighting is flawed. This is identified in the discussion paper as it focused on presenting issues rather than identifying causal factors. This is most apparent in regard to the weighting placed on gambling, with the gambling related harm and debt being significantly under reported by the survey methodology.
To truly represent the industies proportional to the reason people seek financial counselling, the causal factors need to be identified and considered as part of the calculation matrix.


Should any businesses within a subsector be excluded (e.g. small businesses)?

This needs to be overseen by an industry peak body. if an individual business is not afiliated with a peak body it’s dificult to see how a contribution would be sought or calculated.


What are your views on options 1 and 2 for determining the split within subsectors for voluntary contributions?

For consistency across all sectors it would be better to have departmental oversight to ensure that the cost burden is proportional to the business size and the benefit they receive from Financial Counselling and situations don’t occur where those with the most influence, use this to reduce their liability.


What is your view on the different methods for within subsector splits, for your subsector?

We are a service provider to clients with gambling issues and it’s quite clear that the split of 0.33% for online and in person gambling is woefully insufficient compared to the financial harm it causes the community.


What is your view on the proposed initial three-year commitment? Is this an appropriate length to ensure flexibility and stability of funding?

A commitment of five to 10 years would be better. it takes around a year to get a new initiative up and running, particularly in regional areas which have been without support for long periods. this means that a three year trial would be loose a significant portion in just set-up and establishment. The need has been there for a long time, it would be better to have a long-term sustainable structure.


When would an appropriate time be to review the functioning of the model?

As proposed, after two years


Are peak organisations an appropriate mechanism to obtain a formal commitment from subsectors as part of the initial set up of the model? Are there alternative methods to secure commitments that could be undertaken in a timely manner?

From an administrative perspective, using peak bodies is good as they have established relationships with their sector organisations and the organisations have a vested interest in supporting the peak body. The only issue may be if this is seen as another levy on being a member and organisations they elect not to be members.


What are your views on the proposed characteristics of the independent body as set out in Table 4? Are there other characteristics that should be considered?

It’s not clear why this body is needed? Its primary goal is to distribute funds and work with service providers which is what DSS does currently with government funds. I appreciate that this will be industry funds but it seems an unnecessary duplication. it would be better to have some means of incorporating the funds into existing systems and just increasing the amount provided and number of funded services.
Additionally, the body will have the option to expand its focus, there would need to be measures in place to ensure funds are not diverted away from financial counselling into other initiatives, and that these initiatives are in line with the purpose.


Which board composition option do you prefer and why? Are there other options?

option 2


What are your views on the proposed questions the evaluation could test?

the obvious question is – whether the model is effective in increasing finacial literance in the community and in reducing the damage caused by bad debt on individuals, families and the community.