St Vincent de Paul Society Victoria Inc. ABN: 28 911 702 061 RN: A0042727Y 43 Prospect Street Box Hill Vic 3128 Locked Bag 4800 Box Hill Vic 3128 Telephone: (03) 9895 5800 Facsimile: (03) 9895 5850 Email: info@svdp-vic.org.au Website: www.vinnies.org.au/vic
28 March 2008
Submission To: Victorian Competition and Efficiency Commission - Enquiry into enhancing Victoria’s Livability From: St Vincent de Paul Society Victoria Inc. Prepared by Gavin Dufty Manager Research and Policy Unit Background: The St Vincent de Paul Society Victoria Inc. has approximately 8000 members and volunteers in this state. The Society assists approximately half a million individuals annually across Victoria. Of this, a significant number are based in the nonmetropolitan area. The St Vincent de Paul Society also delivers a number of community support services including: aged care facilities, housing services, youth services and disability services. The St Vincent de Paul Society welcomes the opportunity to submit to the Victorian Competition and Efficiency Commission enquiry into enhancing Victoria’s livability. This submission is particularly concerned with identifying factors that are “reducing the barriers to opportunity” for some Victorians. This we believe is a critical element in enhancing and improving the livability of all the citizens of this State. By definition reduced livability is where individuals and families are denied access to, or are excluded from participating within the broader social and economic life at a level consistent with community norms. Broad categories of exclusion the Society is particularly concerned about are: Access exclusion: the restriction of access through the process of organizational/ business risk management. Condition exclusion: where the conditions attached to products and services effectively exclude particular groups of people. Price exclusion: Where some people can only gain access at prices that are unreasonable or act to exclude. Market exclusion: Excluding through products and services not being offered. Self exclusion: Where some people decide not to apply because they believe they will be refused.
St Vincent de Paul Society Victoria Inc. ABN: 28 911 702 061 RN: A0042727Y 43 Prospect Street Box Hill Vic 3128 Locked Bag 4800 Box Hill Vic 3128 Telephone: (03) 9895 5800 Facsimile: (03) 9895 5850 Email: info@svdp-vic.org.au Website: www.vinnies.org.au/vic
Many of the issues of exclusion identified above have become more prevalent as a result of the broad economic reforms for the past 15 years. This has resulted as a result of activities such as outsourcing, competitive tendering and the privatization of many traditional Government delivered services and other Not for Profit services. The reform of these product and service areas was undertaken with the specific goal of increasing economic efficiency though eliminating cross subsidies and other social and environmental objectives, resulting in a much more aggressive and pure business focused behavior and service and product delivery. This often had unintended detrimental outcomes for some within community across Victoria. In particular members of the St Vincent de Paul Society have seen an increase in the various forms of market exclusions. This places barriers on certain households through denying or limiting the products or services that households either receive or are offered. While these structural reforms have been occurring regulatory instruments and other strategies such as cash and non cash transfers to target groups, used to ameliorate these impacts have fallen short. This has occurred either through failure to adjust to changing industry practice or broader community standards or a failure of these instruments to adequately enforce or meet there stated policy / legal objectives. Some examples of exclusionary practices that exist include: The imposition of fees and other charges by State educational institutions, such as fees to access computers and Internet, and failure to pay these fees resulting in children being excluded from use of the critical educational tools. They exist through the exclusion of or limitation of the provision of credit by mainstream financial institutions to low income and disadvantaged households. This results in some groups being reliant upon high cost alternatives, such as pawnbrokers, and other payday lenders. The introduction of co-payments or the reduction of customer service levels by health, child care and other social service providers, such as meals on wheels. These charges and reductions in service effectively limit participation of households within the broader social and economic life of the community. Aggressive billing and collection practices of many essential service providers including electricity, gas and water utilities.
St Vincent de Paul Society Victoria Inc. ABN: 28 911 702 061 RN: A0042727Y 43 Prospect Street Box Hill Vic 3128 Locked Bag 4800 Box Hill Vic 3128 Telephone: (03) 9895 5800 Facsimile: (03) 9895 5850 Email: info@svdp-vic.org.au Website: www.vinnies.org.au/vic
Recommendations The St Vincent de Paul Society recommends that the Victorian Competition and Efficiency Commission to review the adequacy and effectiveness of the current broad consumer protections and community service obligations frameworks with particular regards to ensuring they adequately address various forms of market exclusions. That the Victorian Competition and Efficiency Commission review the regulatory and license compliance failure rates of various industries groups. That the Victorian Competition and Efficiency Commission review the effectiveness of the enforcing of various consumer protection institutions, including the Department of Consumer Affairs the Essential Services Commission, and the various State Ombudsman (dispute resolution) schemes. For example two institutions have oversight of unfair contract and marketing practices for the energy industry, the Essential Services Commission and Consumer Affairs Victoria. We have experienced many cases where inappropriate and we believe illegal industry practice has failed to be addressed. This may occur as the regulation straddles two institutions or indicate a systemic failure of these institutions to effectively carry out their regulatory obligations.
Gavin Dufty Policy and Research Unit St Vincent de Paul Society Victoria Inc. 9895 5816