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Spotlight on economic abuse<br />
Catalyst Paper 3:<br />
Income security<br />
and economic abuse<br />
Primary researcher: Fiona Macdonald<br />
Project team: Tanya Corrie, Kath Deakin, Sue Fraser, Karen Hucks,<br />
Emily Jackson, Kathy Landvogt, Magdalena McGuire<br />
© Good Shepherd Youth & Family Service and Kildonan UnitingCare<br />
November 2012
This paper is one of a series of six catalyst papers written for the Spotlight on Economic<br />
Abuse Project, a joint initiative of Good Shepherd Youth & Family Service and Kildonan<br />
UnitingCare. Both organisations provide services to some of the most vulnerable people in<br />
our community. These services include family violence intervention programs, financial<br />
counselling and financial inclusion initiatives such as financial literacy education and<br />
microfinance. The Spotlight on Economic Abuse Project emerged from Good Shepherd<br />
and Kildonan shared concerns about the impacts of economic abuse on people accessing<br />
their services, with women and children most often affected.<br />
Spotlight on Economic Abuse publications<br />
Catalyst Papers<br />
Paper 1: An overview of economic abuse<br />
Paper 2: Credit, debt and economic abuse<br />
Paper 3: Income security and economic abuse<br />
Paper 4: Financial capability and economic abuse<br />
Paper 5: Child support and economic abuse<br />
Paper 6: Community sector collaboration and economic abuse<br />
Fact Sheet<br />
Fact sheet about economic abuse<br />
Literature and policy review<br />
Macdonald, Fiona Spotlight on Economic Abuse: a Literature and Policy Review<br />
(Good Shepherd Youth & Family Service and Kildonan UnitingCare, 2012)<br />
This project was made possible through the generous support of the SHARE Community<br />
Appeal; the Alfred Felton Bequest, administered by ANZ Trustees; and the Victorian<br />
Women’s Benevolent Trust and the Grosvenor Foundation, administered by Equity Trustees.<br />
Kildonan UnitingCare<br />
www.kildonan.unitingcare.org.au<br />
Sue Fraser, Senior Advocacy Manager<br />
sfraser@kildonan.org.au<br />
Good Shepherd Youth & Family Service<br />
www.goodshepvic.org.au<br />
Kathy Landvogt, Social Policy & Research Unit Manager<br />
klandvogt@goodshepvic.org.au
Catalyst Paper 3: Income security and economic abuse<br />
How can we build on current policy and practice to enable women to<br />
gain long-term economic security following economic abuse?<br />
The purpose of this paper is to prompt discussion about the ways in which the<br />
income support system can respond effectively to abuse. The paper focuses on how<br />
we can build on recent recommendations made by the Australian Law Reform<br />
Commission (ALRC) for changes to policy and practice to prevent abuse and lessen<br />
its impacts. The companion paper, ‘An Overview of Economic Abuse’, provides an<br />
overview of economic abuse and its impacts.<br />
ECONOMIC ABUSE AND ITS IMPACTS<br />
Economic abuse is a form of domestic and<br />
family violence. It involves behaviours that<br />
negatively affect a person’s finances and<br />
undermine their efforts to become<br />
economically independent (Weaver et al.<br />
2009). Economic abuse has only recently<br />
been included in family violence laws in<br />
Australia. Public awareness and<br />
understanding of this form of abuse and its<br />
impacts is poor (VicHealth 2010; McGregor<br />
2009).<br />
Domestic and family violence can have<br />
significant negative consequences for<br />
women’s economic wellbeing. They are likely<br />
to lead to financial hardship. Potentially, they<br />
can have a range of negative consequences<br />
for women’s health, housing, employment,<br />
interpersonal relationships and parenting.<br />
Economic abuse can also adversely impact<br />
on children’s wellbeing. Alone or in<br />
combination with other forms of domestic<br />
violence, economic abuse can affect<br />
women’s ability to find safe, affordable and<br />
appropriate accommodation, buy basic<br />
household necessities, care for children, gain<br />
financial stability and become economically<br />
secure in the long-term.<br />
Economic abuse is a complex issue. Along<br />
with other forms of domestic and family<br />
violence, this abuse is often not identified<br />
until after women leave relationships. Having<br />
experienced economic abuse, women may<br />
have few – if any – financial resources to<br />
draw on. Leaving a relationship may be a<br />
time of crisis in which women are dealing<br />
with multiple issues. In addition, women may<br />
incur additional financial costs for items such<br />
as health services, housing and legal issues<br />
associated with the violence, and separation<br />
and parenting arrangements.<br />
Effective income support can be critical<br />
Following economic abuse and domestic and<br />
family violence, some women may need to<br />
rely on the social security system in the<br />
short-term. Others may need to access the<br />
social security system for a longer period due<br />
to the lasting impacts of violence. In either<br />
case, it is crucial for the social security<br />
system to provide women with a real safety<br />
net that offers them financial independence.<br />
Indeed, for some women, having access to<br />
financial resources through the social<br />
security system may be a factor that enables<br />
them to leave a relationship in which there is<br />
violence.<br />
Catalyst Paper 3: Income security and economic abuse November 2012 1
Assistance available through the social security system<br />
Women who experience domestic and family violence may require access to income support payments at<br />
various points in time. For example, women may need access to income support payments when they are<br />
living in a relationship in which there is violence, when making the decision to leave a relationship, or when<br />
seeking safety after escaping violence.<br />
Women may seek access to various types of assistance provided through Centrelink. The main income<br />
support payments provided by Centrelink include the Parenting Payment, Newstart Allowance, Disability<br />
Support Payment and Youth Allowance. Other relevant payments are Special Benefits (which may be paid<br />
to people experiencing financial hardship who are not eligible for other forms of income support), Crisis<br />
Payments (which are one-off payments that may be paid to someone in extreme or difficult circumstances,<br />
including domestic and family violence) and Rent Assistance. There are also payment arrangements that<br />
can assist people who are experiencing violence, including weekly instead of fortnightly payments, advance<br />
payments and temporary exemptions from participation requirements attached to payments (such as the<br />
requirement to search for a job).<br />
However, recent research and submissions<br />
to public inquiries have raised questions<br />
about the effectiveness of the social security<br />
system as a positive support for women who<br />
have experienced domestic and family<br />
violence. These include concerns that<br />
payments are inadequate, that there are<br />
barriers to accessing assistance, and that<br />
some women who are in need are not eligible<br />
for assistance. In addition, economic abuse<br />
may be perpetrated through the income<br />
support system with devastating<br />
consequences for women. This paper<br />
focuses on some of these issues, and<br />
considers how well the social security system<br />
responds to the needs of women who have<br />
experienced violence.<br />
ARE INCOME SUPPORT PAYMENTS<br />
ADEQUATE?<br />
The low levels of income support payments<br />
mean that people who rely on these<br />
payments are among the poorest in the<br />
Australian community (Whiteford 2012).<br />
Financial hardship is likely to be a problem<br />
for many people who rely on income support<br />
payments – even for a short period. Financial<br />
hardship may also impact on the ability of an<br />
individual or family to gain financial security<br />
in the longer-term (ACOSS 2012).<br />
Women who are escaping domestic and<br />
family violence may be reliant on Parenting<br />
Payment Single if their youngest child is<br />
under eight years old. If their children are<br />
over eight years old, they are likely to receive<br />
the Newstart Allowance. The rates of<br />
payments of Parenting Payment Single are<br />
lower than other pensions, and Newstart<br />
Allowance rates are lower still (ACOSS<br />
2012). Recent evidence shows that, among<br />
people of working age who are receiving<br />
social security payments:<br />
• at least a third receiving Newstart<br />
Allowance, Parenting Payment or Disability<br />
Support Payment lacked $500 in<br />
emergency savings<br />
• forty per cent on Newstart Allowance could<br />
not afford to pay a utility bill on time in the<br />
past year<br />
• between 47 per cent and 60 per cent<br />
receiving Newstart Allowance, Parenting<br />
Payment Single and Disability Support<br />
Payment identified their household as<br />
‘poor’<br />
• one fifth of children in families receiving<br />
Newstart Allowance or Parenting Payment<br />
lacked up-to-date school uniforms and<br />
books (ACOSS 2012, p. 6). i<br />
A woman leaving a violent relationship may<br />
need to meet the cost of re-establishing a<br />
home. She may also have legal, medical and<br />
Catalyst Paper 3: Income security and economic abuse November 2012 2
other costs, as well as debts arising from the<br />
economic abuse and other violence (Braaf &<br />
Barrett Meyering 2011). In such<br />
circumstances, low levels of income support<br />
payments are likely to present a major barrier<br />
to building financial stability. While there are<br />
other social security arrangements that may<br />
assist in situations of domestic and family<br />
violence, these are unlikely to significantly<br />
lessen the problem of low levels of payments.<br />
This is discussed in further detail below.<br />
WHAT ARE THE BARRIERS TO<br />
ACCESSING INCOME SUPPORT<br />
PAYMENTS AND OTHER ASSISTANCE?<br />
The ALRC’s recent inquiry into the treatment<br />
of family violence in Commonwealth laws<br />
included a consideration of the legal<br />
framework and administration of the social<br />
security system (ALRC 2011a, 2011b). The<br />
ALRC considered a large number of matters<br />
and, in its final report, made extensive<br />
recommendations relating to social security,<br />
as well as other related areas of policy,<br />
regulation and service provision. There is<br />
only space here to touch on some of the key<br />
issues raised in the ALRC’s inquiry.<br />
The ALRC (2011a) made recommendations<br />
for a common framework providing a<br />
consistent definition of family violence in all<br />
relevant Commonwealth legislation and other<br />
guidelines. The ALRC (2011b) also identified<br />
a range of barriers within the social security<br />
Research on Centrelink and domestic and family violence<br />
system that may prevent victims of domestic<br />
or family violence from accessing payments.<br />
The Commonwealth departments with key<br />
responsibilities in this area are the<br />
Department of Families, Housing, Community<br />
Services and Indigenous Affairs (FaHCSIA),<br />
which has policy responsibility, and the<br />
Australian Government Department of<br />
Human Services (DHS), which has<br />
responsibility for Centrelink service delivery.<br />
These departments were generally<br />
supportive of the themes identified by the<br />
ALRC. However, FaHCSIA did not support all<br />
the proposals put forward in the initial ALRC<br />
(2011b) discussion paper (DHS 2011;<br />
FaHCSIA 2011).<br />
Overarching issues for social security<br />
identified by the ALRC include the need to:<br />
• increase consistency, transparency and<br />
certainty in the treatment of people<br />
experiencing family violence<br />
• improve support for disclosure of family<br />
violence<br />
• get greater consistency and transparency<br />
in relation to the information that Centrelink<br />
relies on to assess claims of family<br />
violence.<br />
The ALRC (2011a) final report included<br />
recommendations for improved information in<br />
the Guide to Social Security Law and for<br />
“consistent, regular and targeted training” for<br />
Centrelink staff and Social Security Appeals<br />
Recent research by the Australian Domestic and Family Violence Clearinghouse explored the experiences of<br />
women affected by domestic and family violence. The research revealed that most women found Centrelink<br />
helpful in providing quick access to income support. However, it also identified the following barriers to<br />
accessing Centrelink services:<br />
• lack of readily available information about eligibility for different types of payments, particularly Crisis<br />
Payment, and conflicting information about payments and requirements from staff<br />
• lack of assistance to fill in forms<br />
• having to frequently retell domestic violence experiences to different Centrelink staff and/or having to do so<br />
without privacy – despite information already being on file<br />
• lengthy waiting times for payments, gaps in payments and payments being cut off due to administrative<br />
errors without compensation<br />
• negative encounters with Centrelink staff (Braaf & Barrett Meyering 2011, pp. 96-98).<br />
Catalyst Paper 3: Income security and economic abuse November 2012 3
Tribunal members (ALRC 2011a, p. 27). In its<br />
submission to the inquiry, DHS (2011)<br />
identified a current ‘Service Delivery Reform’<br />
process as the main means through which it<br />
is improving approaches to family violence.<br />
Four other broad areas of the social security<br />
system’s response to family violence are the<br />
subject of recommendations made by the<br />
ALRC. These are:<br />
• how decisions are made about a person’s<br />
relationship status and how family violence<br />
is taken into account in these decisions<br />
• proof of identity and residence<br />
requirements for accessing benefits and<br />
crisis payments<br />
• methods of payments and overpayments<br />
• taking account of violence in determining<br />
capacity to work.<br />
Key aspects of these issues are outlined<br />
below.<br />
DETERMINATION OF RELATIONSHIP<br />
STATUS AND INCOME SUPPORT<br />
If family violence is not properly taken into<br />
account in social security decisions about a<br />
person’s relationship status, this may have<br />
implications for their eligibility for payments.<br />
For example, where economic abuse is<br />
present in a relationship, a woman may have<br />
no or limited access to any financial<br />
resources. Yet, at the same time, the woman<br />
may be deemed ineligible for assistance. As<br />
another example, a woman might be deemed<br />
by Centrelink to be a member of a couple<br />
when she has remained in a relationship due<br />
to duress or because of economic abuse.<br />
The ALRC (2011a) made a number of<br />
recommendations to address these<br />
concerns, including that changes be made to<br />
the Guide to Social Security Law (the Guide).<br />
FaHCSIA’s (2011) submission stated that<br />
some of these issues were already<br />
adequately dealt with in the Guide, but that<br />
additional references to the issues could be<br />
considered as part of the Guide review<br />
processes.<br />
ACCESS TO CRISIS PAYMENTS<br />
A Crisis Payment equivalent to one week’s<br />
standard benefit is available for people who<br />
experience severe financial hardship due to<br />
family or domestic violence. However, strict<br />
eligibility requirements prevent some women<br />
from accessing this payment. In order to<br />
receive the payment, a person must:<br />
• be already eligible for income support<br />
payments<br />
• have had to leave their home because of<br />
violence or be remaining in the home after<br />
a family member has left due to domestic<br />
violence<br />
• make the claim within seven days of the<br />
‘extreme circumstance’ leading to it.<br />
These conditions mean that women who are<br />
not eligible for income support payments, and<br />
women who experience violence perpetrated<br />
by ex-partners, cannot access the payment.<br />
Submissions to the ALRC inquiry raised<br />
concerns about the restrictive conditions for<br />
Crisis Payments ii . The ALRC (2011a)<br />
responded with recommendations for the<br />
Case study: Sandy<br />
‘Sandy’ was a woman who spent more than one<br />
week in hospital due to domestic violence. Upon<br />
leaving hospital, she was taken to McAuley<br />
Community Services for Women’s crisis<br />
accommodation program. Sandy was 38 weeks<br />
pregnant and was suffering from gestational<br />
diabetes. She was denied a crisis payment for two<br />
primary reasons. The first was that the incident of<br />
violence had occurred more than seven days ago (it<br />
had occurred 10 days ago when she made the<br />
application. The fact she was in unconscious and<br />
hospitalised due to the act of family violence was<br />
disregarded). The second reason was that the act of<br />
family violence did not occur in her home. Centrelink,<br />
City of Yarra stated, “If it is outside the home it is an<br />
assault and not domestic violence”.<br />
Adaptation of a case study in a submission to the<br />
ALRC by Good Shepherd Youth & Family Service,<br />
Kildonan UnitingCare and McAuley Community<br />
Services for Women (2011)<br />
Catalyst Paper 3: Income security and economic abuse November 2012 4
Crisis Payment to be made available without<br />
the need for income support eligibility,<br />
without the requirement that it be associated<br />
with the person or perpetrator leaving home<br />
and without the seven day limitation on the<br />
claim period. In its submission<br />
to the ALRC, FaHCSIA (2011) was not<br />
supportive of these proposed changes.<br />
PAYMENT ARRANGEMENTS AND<br />
OVERPAYMENTS<br />
The ALRC made recommendations to<br />
address concerns about access to other<br />
payments and about payment arrangements.<br />
These include a recommendation that family<br />
violence should be named as a circumstance<br />
in which urgent and advance payments may<br />
be made. The ALRC also called for<br />
clarification that urgent payments can be<br />
made in family violence circumstances in<br />
addition to Crisis Payments.<br />
The ALRC also recognised the potential for<br />
economic abuse to occur in payment<br />
arrangements where a person receiving<br />
social security has nominated someone else<br />
to act as their ‘agent’. It recommended that<br />
the effect of family violence should be taken<br />
into account when considering a person’s<br />
capacity to consent to a nominee<br />
arrangement. This recommendation was not<br />
supported by FaHCSIA in its submission to<br />
the Inquiry.<br />
In relation to overpayments, the ALRC<br />
responded to concerns that economic abuse<br />
cannot be taken into account when<br />
considering whether a Centrelink debt can be<br />
waived. The ALRC addressed this concern<br />
by recommending an amendment to the<br />
Social Security Act 1991. The ARLC also<br />
identified that better information provision is<br />
needed in this area.<br />
RESIDENCE REQUIREMENTS<br />
Residence requirements that restrict access<br />
to income support payments are a problem<br />
for women on temporary or other visas if they<br />
experience domestic and family violence.<br />
For example, these women may be unable to<br />
leave a violent relationship due to the lack of<br />
options for financial assistance. The ALRC<br />
recognised this and made a number of<br />
recommendations to address this problem. It<br />
advised that changes should be made to<br />
migration law. Further, it advised that<br />
changes should be made to the eligibility for<br />
Special Benefit, and sought a specific<br />
exemption due to family violence from<br />
income support waiting periods for newly<br />
arrived residents. The Federal Government<br />
has responded positively to one of the<br />
ALRC’s recommendation for migration law<br />
change and has indicated this is a<br />
‘preliminary response’ (Bowen 2012).<br />
INCOME MANAGEMENT<br />
Under the income management scheme, a<br />
proportion of a person’s income support<br />
payments are ‘quarantined’ or only able to be<br />
spent on certain goods and services. This<br />
scheme has recently been extended, and<br />
now applies in specific locations in five states<br />
as well as in the Northern Territory. The<br />
extension of the scheme to people<br />
experiencing economic abuse has been seen<br />
as ‘victim blaming’. It casts victims as<br />
responsible for the circumstances created by<br />
the abuse. It also implies that a lack of<br />
financial knowledge and management skills<br />
are the causes of poverty and low income<br />
(ADFVC 2010). The ALRC considered the<br />
treatment of family violence under the income<br />
management scheme and concluded that:<br />
“the complexity of family violence and the<br />
intertwining of family violence with a number<br />
of the ‘vulnerability indicators’ that trigger the<br />
imposition of compulsory income<br />
management leads to serious questions about<br />
whether it is an appropriate response” (ALRC<br />
2011a, p. 247).<br />
The ALRC recommended that people<br />
experiencing family violence should not be<br />
subject to compulsory income management.<br />
However, FaHCSIA’s (2011) submission<br />
indicates that it does not support this<br />
recommendation. The ALRC (2011a)<br />
Catalyst Paper 3: Income security and economic abuse November 2012 5
ecommended a voluntary and flexible model<br />
of income management for people<br />
experiencing family violence. It also<br />
recommended that people under income<br />
management should not be prevented from<br />
purchasing travel and other crisis-related<br />
needs.<br />
SUPPORTING WOMEN TO GAIN LONG-<br />
TERM ECONOMIC SECURITY THROUGH<br />
EMPLOYMENT PARTICIPATION<br />
In contemporary public policy, employment<br />
participation is generally regarded as the<br />
primary means for women to gain economic<br />
wellbeing. Employment is also regarded as a<br />
pathway to economic independence and selfsufficiency<br />
following domestic violence. In<br />
addition, policies to address domestic and<br />
family violence specifically identify<br />
employment participation as a preventative<br />
measure supporting women’s economic<br />
independence.<br />
The activity and participation requirements<br />
for people receiving social security payments<br />
can also have an impact on women who<br />
have experienced economic abuse and other<br />
violence. A major issue here concerns the<br />
treatment of women who face numerous<br />
barriers to seeking and gaining employment.<br />
How well the social security system responds<br />
to these women can be critical in preventing<br />
hardship, supporting financial stability in the<br />
short-term and assisting women to gain<br />
economic wellbeing in the long-term.<br />
Positive responses include minimising or<br />
ceasing job seeker activity requirements for<br />
women when appropriate, and ensuring that<br />
women receive adequate assistance to<br />
obtain and maintain suitable employment.<br />
Multiple agencies have responsibilities in this<br />
area, including Job Services Australia and<br />
Disability and Indigenous Employment<br />
services providers contracted by government.<br />
The policies and practices of the Department<br />
of Employment, Education and Workplace<br />
Relations (DEEWR) along with FaHCSIA,<br />
Centrelink and DHS shape the ways in which<br />
people experiencing family violence are<br />
treated as recipients of payments and as job<br />
seekers.<br />
The ALRC identified the need to change<br />
policies and practices that relate to the<br />
determination of individuals’ capacity to work<br />
to improve protections for people<br />
experiencing family violence. The ALRC<br />
responded to concerns that processes<br />
conducted by Centrelink and job services<br />
providers were not conducive to disclosure of<br />
family violence and may not take adequate<br />
account of the impacts of family violence.<br />
Concerns related to both the content and the<br />
administration of the Job Seeker<br />
Classification Instrument (JSCI). The JSCI<br />
determines the level of employment<br />
assistance that a person may receive and<br />
whether they will be referred for further<br />
assessment. This, in turn, may determine<br />
whether a person is eligible for an exemption<br />
from activity requirements.<br />
The ALRC (2011a) recommended that the<br />
JCSI be administered in person and in<br />
private. DEEWR’s advice to the ALRC was<br />
that this does not occur in the majority of<br />
cases of initial assessments by Centrelink.<br />
However, they advised that this practice was<br />
in accordance with DEEWR’s guidelines to<br />
job services agencies. iii The ALRC made<br />
additional recommendations around training<br />
for assessors and for increased requirements<br />
on employment services providers to take<br />
account of family violence in tailoring service<br />
responses to individual job seeker needs.<br />
They also recommended that a specific<br />
family violence category of information be<br />
included in the JSCI. They advised that the<br />
JSI should take into account safety concerns,<br />
caring responsibilities for children, and the<br />
impact of family violence on a job seeker’s<br />
housing, transport and health. Further, the<br />
ALRC recommended a review of employment<br />
services assessments with a focus on<br />
impacts on job seekers experiencing family<br />
violence.<br />
Catalyst Paper 3: Income security and economic abuse November 2012 6
The ALRC responded to concerns that the<br />
current exemptions from activity tests and<br />
participation requirements are inadequate for<br />
people who have experienced domestic and<br />
family violence. These concerns included<br />
that, in practice, there is a lack of awareness<br />
of these exemptions. Furthermore, these<br />
exemptions are often granted for short<br />
periods only. This means that women often<br />
have to re-apply for the exemptions and retell<br />
their stories to someone else. The ALRC<br />
recommended that the DEEWR review the<br />
exemption periods to ensure that a long<br />
enough time is allocated for victims of family<br />
violence. They also recommended that family<br />
violence be made a ‘reasonable excuse’ for<br />
the purposes of activity tests and other<br />
requirements.<br />
Where to next?<br />
EFFECTIVE EMPLOYMENT ASSISTANCE<br />
It is critical for employment services to<br />
effectively assist women who have<br />
experienced violence, and who may have<br />
been outside the workforce for a period of<br />
time. There are many aspects of this issue<br />
that cannot be considered in this paper. For<br />
example, there is little published research<br />
relating to effective responses in this area;<br />
this could be the focus of further<br />
investigation. Past Commonwealth<br />
employment programs specifically designed<br />
to assist sole parents, including the Jobs<br />
Education and Training program, are<br />
considered by community sector groups to<br />
have been positive initiatives for women who<br />
are parents and carers (ACOSS 2012).<br />
This paper has sketched out some of the key areas that require action to ensure that the income<br />
support system is a positive and effective support for people experiencing economic abuse. Its<br />
purpose is to focus attention on these issues, and to prompt discussion and action to achieve<br />
change. To this end, the following questions are posed:<br />
In the wake of the ALRC’s inquiry how can we build on income support and employment<br />
assistance policy and practice to enable women to gain long-term economic security<br />
following economic abuse?<br />
Do the ALRC recommendations adequately address the issues?<br />
What views and insights do community sector organisations have in regard to the concerns<br />
outlined by the ALRC review?<br />
Are the ALRC recommendations being acted on by the Federal Government? If not, why<br />
not? Are there other ways in which the social security system could better respond to<br />
economic abuse?<br />
Catalyst Paper 3: Income security and economic abuse November 2012 7
References<br />
ACOSS (Australian Council of Social Service) 2012, 'Surviving<br />
not living' Submission to Senate Employment Committee on<br />
adequacy of 'allowance' payments, ACOSS Paper 192,<br />
ACOSS, Strawberry Hills, NSW, viewed 25 August 2012,<br />
.<br />
ALRC (Australian Law Reform Commission) 2011a, Family<br />
violence—commonwealth laws, discussion paper, discussion<br />
paper no. 76, ALRC, Sydney.<br />
ALRC (Australian Law Reform Commission) 2011b, Family<br />
violence and commonwealth laws—improving legal<br />
frameworks, Final Report, report 117, ALRC, Sydney.<br />
Bowen 2012, media release 17 June, viewed 25 July at<br />
).<br />
Braaf, R & Barrett Meyering, I 2011, Seeking security:<br />
promoting women’s economic wellbeing following domestic<br />
violence, Australian Domestic & Family Violence<br />
Clearinghouse, University of NSW, Sydney.<br />
DEEWR (Department of Employment Educaiton and Workplace<br />
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Commonwealth Laws, viewed 14 August 2012,<br />
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DHS (Department of Human Services) 2011, Response to<br />
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FaHCSIA (Department of Families, Housing, Community<br />
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and Commonwealth laws, FaHCSIA, Canberra, viewed 12<br />
August 2012, .<br />
McGregor, K 2009, National community attitudes towards<br />
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i<br />
ACOSS citing data supplied by the Social Policy Research<br />
Centre, University of NSW from the Poverty and Exclusion in<br />
Modern Australia (PEMA) survey.<br />
ii<br />
Submissions to the ALRC can be viewed at<br />
<br />
iii<br />
The ALRC cites DEEWR correspondence15 June 2011 (ALRC<br />
2011a, p. X, fn X).<br />
8