Identifying and making suitable referrals to the Complex Assessment Officer (CAO) 101-05070010

Is the customer responding to a request for information about a program review of private trust and/or private company?

• Yes, see Customer contact regarding trusts and companies program review. A CAO referral is not required for these reviews
• No, go to Step 2

Is the customer claiming Commonwealth Seniors Health Card (CSHC), Carer Allowance (CA) or Family Tax Benefit (FTB)?

• Yes, a CAO referral is not required for these claims as eligibility is determined by assessing the claimant's adjusted taxable income.
  Procedure ends here.
• No, before making a CAO referral, assess customer's circumstances:

If the customer indicates they have not been involved in a private trust or company in the last 5 years, but their record is linked to a private trust or company record, a CAO referral is required to update the information.

Referral is not required if a CAO has documented that the customer's involvement in the entity has ceased or the entity has been coded as wound up. Staff must check the entity record in the Environment A (accessed from Link Summary (LS) screen of the customer’s record) for details of previous CAO assessment.

New claims (including where the customer is already getting an income support payment, and claiming a different payment):

• If it is clear the claim is to be rejected (e.g., basic qualification reasons are not met), do not refer the case to the CAO
• For previously rejected claims, the claim must be re-indexed before the referral
• The CAO referral is to be made within the Process Direct new claim activity, including re-indexed claims, where available. If the claim is being actioned within Customer First, follow the appropriate referral process
• If a CAO assessment is needed to determine payability, the CAO report must be completed and the recommendations applied before assessing the claim

Relationship status:

• Update the relationship status of the customer before the referral. E.g., link or unlink as required. If the referral is part of a new claim, complete the relationship status update outside of the claim activity
• Exception: for Parenting Payment Single (PPS) benefit transfers, as linking cannot be completed before the referral, include 'new partner not linked - Partner CRN xxx xxx xxx' within the CAO referral

Documentation:

• CAOs may require additional information that is not evident to a Service Officer. To limit customers receiving multiple requests for information, if the customer has provided required modules and some supporting documents, Service Officers should not make further requests for information. Some common documentation required for CAO referrals include
• for Private Companies:
  • Private Company (MOD PC), fully completed and signed, see Completing the Private Company MOD PC
  • Appropriate documents from the 'Checklist', see Documents needed to assess a private company for guidance
• for Private Trusts:
  • Private Trust (MOD PT), fully completed and signed, see Completing the Private Trust details in the MOD PT
  • Appropriate documents from the 'Checklist', see Documents required to assess a private trust for guidance

Do not create a CAO referral where it is clear that documents requested through the claim have not been provided or are incomplete. Make a request for information.

Note: only one referral is required including for partnered customers.

Staff must check for existing CAO referral. Using Work Optimiser, complete a customer search for both the customer and partner Customer ID numbers. If there:

• are duplicate or multiple referrals, close the newest referral ensuring only the oldest referral remains. See Table 3
• is an existing CAO referral for a 'reassessment' and a 'new claim' referral is now required and the referral was created in:
  • Customer First, add the keyword CAONCL to the open CAO Ref DOC via the Activity List (AL) screen in Customer First or Customer Record (place a 'V' next to the activity to add keyword)
  • Process Direct, complete the WLM Technical Assistance Form > New Item to request recategorisation

Is there an existing CAO referral?

• Yes, and:
  • additional CAO referral reason(s) now identified, complete the WLM Technical Assistance Form to make sure that work is directed to appropriately skilled CAOs
  • additional details have been provided, annotate the first referral with the details. A new referral is not needed
  • place the relating activity (new claim or non-new claim assessment) on Hold for 100 days. Procedure ends here
  • urgent CAO action is needed, see Table 2
• No, go to Step 4

Note: when a customer is being paid under assets hardship provisions and notifies of a change in circumstance, income or assets, a CAO reassessment request is to be sent. Send a Fast Note - select Auto text, use Complex Assessment > Request for action > CAO Asset Hardship.

Is a CAO referral being considered for an assessment of assets hardship?

• Yes, go to Step 5
• No, go to Step 8

A claim for hardship can be considered when the customer has made a claim for payment, and:

• the payment has been cancelled or rejected due to excess assets, or
• for pensioners, the customer's payment is paid at a reduced rate because of the assets test

Before inviting a claim under assets hardship provisions, the case must be discussed with a CAO. CAOs can advise of the issues to be considered and concessions that may be available to the customer.

A list of CAOs in the Asset Hardship Team can be found within Officer Locator, see the Resources page for instructions and a link.

Service Officers are to take no action to approve or reject payment under the assets hardship rules. Refer all cases to the CAO for determination.

Has the case been discussed with a CAO from the Asset Hardship Team?

• Yes, go to Step 6
• No, go to Step 7

Customers are required to lodge an SA233 (claim for consideration under Asset Hardship provisions).

When the claim is lodged, Service Officers are required to:

• reindex rejected claim for income support payment, (if applicable)
• scan SA233 to record. Do not scan to store or close the SA233 work item
• create CAO referral:
  • referrals for Asset Hardship must be created as a new claim referral to make sure the appropriate priority
  • new claim referrals can only be created in Process Direct where previously rejected claim is reindexed
  • for current customers with reduced rate, create referral using Customer First

If using:

• Process Direct, go to Step 12
• Customer First, go to Step 14

In an open work item, give an overview of the special circumstances that have led to the customer seeking consideration under assets hardship. The CAO will contact the customer to discuss their circumstances and initiate a claim if appropriate.

To create an open work item in either:

• Process Direct:
  • Use Notes, select
  • Select the referral Category
  • Select Add details - include details of the special circumstances for consideration under assets hardship
  • Select Save
• Customer First:
  • Use Fast Note - select Auto text, use Complex Assessment > Request for CAO Action > CAO Asset hardship

Procedure ends here.

Determine the reason the CAO assessment is needed:

• Home Equity Access Scheme, see Table 2
• Special Disability Trust (SDT), see Table 2

Check if the customer and/or partner are involved in or claiming one or more of the following:

• Private Trust in the last 5 years (including bank accounts held in trust)
• Private Company in the last 5 years (unless the private company acts as trustee only for self-managed superannuation fund (SMSF), and does not trade, nor hold any assets nor liabilities in its own right. An assessment of these private companies is not required)
  Note: if the customer's rate is reduced due to a trust distribution or company dividend and they may be experiencing family and domestic violence (FDV), include this in the CAO referral notes.
• Farm Household Allowance (FHA) reviews where the customer is involved in a private trust or company or complex partnership
• Partnerships and sole traders:
  • If there are multiple business activities that are unrelated. This excludes investment income and rental income, see Offsetting of profit and losses between businesses
  • Where real estate assets may need to be linked to a business, see Assessing and coding real estate details
• Primary production partnerships and sole traders that have any liabilities (aggregation) (except for FHA and Low Income Card assessments)
• Trading partnership/sole traders that have multiple loans including secured loans (except for FHA and Low Income Card assessments )
• Trading partnerships of more than 2 members (except for FHA and Low Income Card assessments)
• Irrecoverable loans/failed loans
• Scams
• Life interest or surrender of a life interest
• Beneficial ownership and constructive trusts
• Actuarial valuations
• Granny flat arrangement if deprivation may have occurred
• Transfer of farm for forgone wages
• Sale leaseback and sale on terms or term contracts
• Contrived arrangements (cases involving situations where a customer manipulates their circumstances to take advantage of the income/assets test)
• A contingent, remainder or reversionary interest created by a customer or acquired for valuable consideration
• Asset-test exempt lifetime or life expectancy income streams from self-managed superannuation funds (SMSF) or small APRA funds (SAF)
• Annuity - Deferred annuity, a purchased annuity or annuity received on transfer of property for disposal purposes (not an annuity purchased from a financial institution)

Are the customer and/or partner involved in or claiming one or more of the above?

• Yes, go to Step 9
• No, if not specified as a CAO assessment reason, for all other types, follow normal escalation processes. Local Peer Support (LPS) and /or Service Support Officer (SSO) are to investigate the individual circumstances before any referral to a CAO is made. See Tier 0 technical support - self-sufficiency

Is a CAO referral being considered for a deregistered Private Company or vested Private Trust?

• Yes, go to Step 10
• No, go to Step 11

Check if customer/partner:

• are already linked to the Company/Trust's CRN and the Company/Trust CRN has not already been coded as 'Wound Up'. Check the Trust and Company Miscellaneous (TRMD) screen (Environment A) via the Company/Trust CRN
• have declared gifting/deprivation in relation to the deregistered Private Company or vested Private Trust in the last 5 years before claiming
• have declared an involvement in relation to the deregistered Private Company while receiving an income support payment

Is the entity a deregistered Private Company or vested Private Trust and any of the above has occurred?

• Yes, go to Step 11
• No, a CAO referral is not required. Procedure ends here

If using Process Direct:

• New claims, go to Step 12
• For non-new claim assessments, go to Step 13

If using Customer First, go to Step 14

CAO referrals in Process Direct for new claims must be created in the new claim activity.

To launch the referral workflow:

• Select > Referral
• Referral Type: Complex Assessment Officer (CAO)
• Payment type: check this matches the payment type of the claim
• Assessment type: defaults to New trust/company
  • Note: this option is correct, even if the referral is not related to a private trust or private company
• Referral Reason(s): select the appropriate referral for the CAO to assess (for example, 'Trusts', 'Asset Hardship Claim', 'Private Companies'). Multiple options can be selected if applicable
• Select Next, the CAO Referral page displays
• Document List check the box against all documents provided, noting that the list will update when the referral reason(s) are updated
• What is Required? add details in the free text box
  • If scanned documents are relevant to the referral, nominate the date of scan and scan number in the referral notes. This will help the CAO locate supporting information
• Have all necessary documents been provided? select Yes or No, if No, enter details in the Why? field
• Select Next, the Referral Summary screen displays
• Additional comments: include a reason for requiring a CAO assessment, a reason is required regardless of having nominated the Referral Reason
• Select Finish, the referral is created and an automatic Note will be added advising a CAO referral has been created

Go to Step 15.

To launch the referral workflow:

• Select > Referral from Customer Summary
• Referral Type: Complex Assessment Officer (CAO)
• Assessment type: select appropriate option from the drop down list
• Referral Reason: select the appropriate referral for the CAO to assess (for example, 'Trusts', 'Asset Hardship Claim', 'Private Companies')
• Select Next, the CAO Referral page displays
• Document List check the box against all documents provided, noting that the list will update when the referral reason(s) are updated
• What is Required? add details in the free text box
  • If scanned documents are relevant to the referral, nominate the date of scan and scan number in the referral notes. This will help the CAO locate supporting information
• Have all necessary documents been provided? select Yes or No, if No, enter details in the Why? field
• Select Next, the Referral Summary screen displays
• Additional comments: include a reason for requiring a CAO assessment, a reason is required regardless of having nominated the Referral Reason
• Select Finish, the referral is created and an automatic Note will be added advising a CAO referral has been created

Go to Step 16.

For referrals from teams within the Payments and Integrity Group (system tool description 'Business Integrity'):

• Assessment type, select 'Reassessment'
• Referral reason, select relevant options (can select multiple options), select Next
• Select Next > Business Integrity referral
• Select the Business Integrity referral reason:
  • Authorised Review Officer, for ARO referrals (includes keyword AROCAO)
  • Random Sample, for Payment Accuracy Review referrals (includes keyword RSSCAO)
  • For any other Payments and Integrity referral, including those from Debt teams (includes keyword BICAO). Note: for Payments and Integrity referrals as part of Taskforce Integrity, after the CAO referral is created, manually add the keyword TKFCAO
• In the What is required free text field:
  • Add details of the team making the referral. Include all relevant information from the Review Summary (IRRS) screen and the requirements of the CAO assessment, including the scope of the review/assessment
  • Include whether there are any restrictions on outbound contacts or requests for information. If there are no restrictions, include this in the free text field. Note: where there are restrictions, the CAO will liaise with referring officer if further information is needed to complete their assessment
  • Include whether there are any additional documents relevant to the CAO assessment that are not scanned to the record

Go to Step 16.

Run the CAO Referral guided procedure.

For a new claim or LIC renewal:

• Select Assessment Type: New Claim
• Update the:
  • KPI Due Date. For help with Key Performance Indicators, see Timeliness standards - Claims processing
  • Date payment is due to commence. This is the date of event that the claim is expected to be granted from. For LIC claims, record the date 8 weeks before the date of grant

CAO referral required for non-new claim assessment:

• Select Assessment Type: Reassessment
• If the customer is suspended FRC or FRT, as failed to reply to a CAO request for information, select Customer Suspended: Yes

For new claims and reassessments:

• Select the Case Type to populate the document list (noting not all Case Types require documents)
• More than one Case Type can be identified to add documents. Make sure to select all documents provided and scanned for each identified Case Type
• Use Other Referral to identify additional Case Types and free text is also available to list other supporting documents supplied
• If scanned documents are relevant to the referral, nominate the date of scan and scan number in the referral notes. This will help the CAO locate supporting information
• Update Reason For Referral and DOC Details with reason for requiring CAO assessment. The reasons are required regardless of having nominated the referral Case Type

For referrals from teams within the Payments and Integrity Group (system tool description 'Business Integrity'), select BI Referral and select the assessment reason:

• Authorised Review Officer, for ARO referrals (includes keyword AROCAO)
• Random Sample, for Payment Accuracy Review referrals (includes keyword RSSCAO)
• Other, for any other Payments and Integrity referral, including those from Debt teams (includes keyword BICAO)

Note: for Payments and Integrity referrals as part of Taskforce Integrity, after the CAO referral is created, manually add the keyword TKFCAO.

• DOC details of the team making the referral, including all information relevant from the Review Summary (IRRS) screen and the requirements of the CAO assessment including the scope of the review/assessment
• Include whether there are any restrictions on outbound contacts or requests for information. If there are no restrictions, include this in the free text field. Note: where there are restrictions, the CAO will liaise with referring officer if further information is needed to complete their assessment
• Include whether there are any documents relevant to the CAO assessment that are not scanned to the record.

For FHA review referrals:

• Select the Payment Type Exceptional Circumstances Relief Payment
• Add keywords:
  • CAOFHA
  • FHACMPRV (if the referral is in relation to a compliance activity)
• To make sure delivery of FHA referrals to FHA CAOs, the referral DOC must remain open and must be in region code FHH

Within the CAO Referral tools, the following Referral Reason/ Case Type may be available, however they are not appropriate referral reasons:

• Special Disability Trust (SDT)
• Annuities
• Multiple realisations of Superannuation Investments
• Unlisted/ overseas shares

If there is a CAO referral in Process Direct, the new claim status will automatically change to On Hold with reason Referral to CAO. A Note/DOC will be recorded on the Document List (DL) screen with Customer Referral work item ID. The claim will remain On Hold until the CAO referral is completed.

If the activity (including new claims) status has not updated automatically, place the activity On Hold for 100 days. The activity status will update when the CAO referral is completed. This does not reflect expected processing time.

If the activity ceases to be on hold and the CAO referral remains open:

• Confirm the CAO referral is required. If the referral was created inappropriately, close the CAO referral, see Table 3
• Check that the CAO assessment is not completed
• Refer to progress notes and determine if the assessment is pending a CAO request for information
• Return the status to On Hold for a minimum of 28 days, for the assessment to be completed
• DOC on hold reason. If an open DOC is necessary, hold for the same duration
• If the customer makes a request for immediate processing and meets the criteria, see Table 2. Note: before any escalation is undertaken, the CAO referral must be made and all required documents provided

If the CAO was unable to make a determination because the customer failed to provide requested information, the CAO will record a DOC including details of the outstanding information. See Rejecting a Centrelink claim.

When the CAO assessment is completed, the Service Officer must check the CAO assessment DOC for any actions that they must complete.

Changes post CAO assessment

If the customer provides further information related to the CAO assessment and before the claim finalisation, the Service Officer is required to make a new CAO referral.

This includes where the CAO is unable to complete the assessment, as the customer failed to respond to a request for information. Before rejecting the claim, check the customer record to determine if the requested information has been provided since the CAO referral was set to Completed.

If a Service Officer makes a determination that an earlier Date of Event is to apply, the Service Officer is required to make a new CAO referral.

In these circumstances, it is appropriate for a Team Leader or Service Support Officer to escalate for immediate processing. See Immediate new claim and non-new claim priority processing.