Policy in arrears - BSL cataloglibrary.bsl.org.au/jspui/bitstream/1/4502/1/Lyons-M...Policy in arrears Comparing arrears procedures of the Office of Housing with those of publicly-regulated

BROTHERHOODof St LAURENCE

Policy in arrearsComparing arrears procedures of the Office of

Housing with those of publicly-regulated utilitycompanies

Marnie Lyons December 2000

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Marnie Lyons December 2000

LIBRARYBROTHERHOOD OF ST. LAURENCE 67 BRUNSWICK STREET FITZROY VICTORIA 3065

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P olicy in arrears : comparing arrears procedures o f the O ffice o f H ousing with

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LIBRARYBROTHERHOODOFST. LAURENCE 67 BRUNSWICK STREETFITZROY VICTORIA .9065

LIBRARYBROTHERHOOD OF ST. LAURENCE

BRUNSWICK STREET FITZROY VITORIA 3f}fS5



M a m i e L y o n s December 2000

AcknowledgmentsThe author would like to acknowledge:■ The public housing tenants interviewed for their willingness to discuss their rental

arrears experiences;■ The members of the reference group for their guidance, support and feedback, and■ The Office of Housing staff who provided statistics and contextual information for their

prompt and helpful assistance.

First published in December 2000 by theBrotherhood o f St Laurence67 Brunswick StreetFitzroy VIC 3065Telephone (03) 9483 1183www.bsl.org.au

Lyons, MamiePolicy in arrearsComparing arrears procedures o f the Office o f Housing with those o f publicly-regulated utility companies

ISBN 1 876250 42 91. Public housing— Victoria2. Rental housing— Victoria.I. Brotherhood o f St Laurence.II. Title.363.5962409945

© Brotherhood o f St Laurence, 2000

This book is copyright. Apart from fair dealing for the purpose o f private study, research, criticism, or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission. Enquiries should be addressed to the publisher.Edited and designed by Amra Pajalic.

http://www.bsl.org.au

Comparing arrears procedures of the Office of Housing with those of publicly-regulated utility companies

Foreword

This report on Rental Arrears processes in public housing is being released in a climate of review. The Office of Housing is currently engaged in reviewing several aspects of public housing: eligibility, the segmented waiting list system, and the Rental Housing Support Program (from which this report derives). The new Victorian Government has already made a significant impact by improving security of tenure for public housing tenants, and it is investigating innovative ways by which low cost housing can be provided.

This project arose out of a need that was very apparent to our tenant workers in the Southern Region. Where does a household go when evicted from public housing? The private rental market is not providing the solutions for low-income people that may have been hoped for when the Federal Government changed its policy focus, and funding, from public housing to private rental subsidy. Needless to say the threat of homelessness is extraordinarily stressful for anyone to face. For tenants on incomes that simply don't stretch the distance, periods of rent arrears are becoming increasingly difficult to avoid.

This report is offered as an opportunity for improvement, rather than as a criticism. It is informed by the novel approach of comparing the requirements placed by the Government on privatised utility companies on how they deal with people in arrears, with those that the Government places on itself in its role as public housing landlord in dealing with tenants in rent arrears. It uncovers some alarming inconsistencies, and finds that there is clear room for improvement. But more than this, it demonstrates a way forward.

Public housing is increasingly being required to cater for people with high support needs, living in poverty. It is critical that the Office of Housing handles this difficult area effectively, in order to contribute to a greater sense of security overall within the public housing sector.

Cath ScarthGeneral Manager, Community Services

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Policy in arrears


Table of contents

PageForeword .......................................................................................................................... iTable of contents................................................................................................................. iiiAcronyms ......................................................................................................................... iv

Summary .......................................................................................................................... 1Aim and objectives............................................................................................................1Findings............................................................................................................................ 2Recommendations............................................................................................................2

1. Introduction...................................................................................................................5The role and responsibilities of the Office of Housing......................................................5The development of the Office of Housing’s Rental Arrears Policy and Procedures......5The Southern Region....................................................................................................... 7Research aims and rationale............................................................................................ 7Methods............................................................................................................................ 8

2. Office of Housing Rental Arrears................................................................................. 11Rental Arrears Policy and Procedures...........................................................................11Rate of rental arrears......................................................................................................14Tenants seeking assistance from Brotherhood............................................................. 15Implications..................................................................................................................... 16

3. Tenant experiences of the Office of Housing’s Rental Arrears Procedures..................19Context........................................................................................................................... 19Billing.............................................................................................................................. 19Collection.................................................................... 20Improvements.................................................................................................................21

4. Minimum standards for Government-regulated utility companies................................23Rationale......................................................................................................................... 23Accountability..................................................................................................................23Billing.............................................................................................................................. 23Responding to customers experiencing payment difficulties........................................ 24Restriction/disconnection............................................................................................... 24

5. Application to Office of Housing’s Rental Arrears Policy and Procedures...................27Context........................................................................................................................... 27Accountability..................................................................................................................27Billing.............................................................................................................................. 28Responding to tenants experiencing payment difficulties..............................................30Restriction of supply/Disconnection/Eviction................................................................. 33

356. Conclusion

Policy in arrears

Appendices:Appendix 1: Map of Southern Metropolitan Region...................................................................37Appendix 2: Interview Schedule....................................................................................................39Appendix 3: Office of Housing Rental Arrears Procedures........................................................41Appendix 4: Office of Housing Rental Account Statement........................................................43Appendix 5: Office of Housing Arrears Reminder Letter............................................................45Appendix 6: Office of Housing Urgent Reminder Notice............................................................47Appendix 7: Proposed Calendar Format for Rent Payment Information................................ 49Appendix 8: Proposed Arrears Repayment Schedule................................................................51References .....................................................................................................................................53

Acronyms

BCC Benchmark Customer Contract

CCC Customer Consultative Committee

CSHA Commonwealth State Housing Agreement

EISSC Electricity Industry Supply and Sale Code

HSO Housing Services Officer

OoH Office of Housing

ORG Office of the Regulator General

MHC Ministry of Housing and Construction

NTV Notice to Vacate

PTS Public Tenant Support (Workers)

PTSS Public Tenants Support Service

RTA Residential Tenancies Act

VCAT Victorian Civil and Administrative Tribunal

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Summary

The Office of Housing (OoH) is the most significant provider of affordable housing in Victoria, accounting for 40 per cent of all low cost, rental housing stock. While eligibility for public housing is open to "those unable to obtain or maintain affordable finance for adequate and appropriate housing purchase from the private sector" (Human Services undated), it is becoming increasingly targeted to those in greatest need.

Given the OoH’s role as the main provider of low cost housing in Victoria and that housing choice for people on low incomes is limited due to the cost, supply or quality of private housing, it is essential that public housing tenants are given every reasonable opportunity to maintain their tenancy. Furthermore, given that the OoH aims to accommodate those in greatest need, there has been, and will continue to be, a significant proportion of tenants who require a more supportive response from the OoH, particularly in relation to the management of rental arrears.

The OoH Rental Arrears Procedures uses the Residential Tenancies Act as its basis and has remained generally unchanged over the last 10 years. According to Office of Housing statistics for the Southern Metropolitan Region:• 20 per cent of tenants in the Southern region were in arrears as of June 30,2000 (five

per cent were more than four weeks in arrears). The average rate of arrears equated to six days,

• Only 23.9 per cent of tenants who were in arrears as of June 30,2000 were on either a local or legal repayment agreement,

• 175 Warrants were obtained in the Southern region during 1999-00 and 70 were executed (accounting for 40 per cent of those obtained).

The Brotherhood of St. Laurence is funded under the Rental Housing Support Program to provide advice and support to public housing tenants in the Southern region of Melbourne. The need to examine the Office of Housing’s Rental Arrears Policy and Procedures was identified by the Public Tenant Support Workers who assist tenants affected by the policy.

Aim and objectivesThe aim of this research is:

To examine the Office of Housing’s Rental Arrears Policy and Procedures as they affect public housing tenants and to compare the Rental Arrears Policy and Procedures to the minimum standards regulating billing, collection and withdrawal of service required by the State Government of privatised utility companies.

The objectives are to:

1. Examine the OoH’s response to rental arrears from a public tenant perspective.2. Compare and contrast the Office of Housing’s Rental Arrears Policy and Procedures

with the Electricity Industry Supply and Sale Code (1997) and the Water Benchmark Customer Contract (1998).

3. Make recommendations to the OoH for improvement of Rental Arrears Policy and Procedures based on Objectives 1 & 2.

As with housing, the provision of utilities is seen as an essential service, fundamental for subsistence and participation in society. In Victoria, these services have recently become

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Policy in arrears

privatised (electricity and gas) or corporatised (water) and regulated by the Office of the Regulator General. The Office of the Regulator General, a State Government authority, was established to ensure customers are being treated fairly. It does this via the Electricity Industry Supply and Sale Code (1997) and the Benchmark Customer Contract (1998), which outline the minimum customer service standards required of utility companies. The Code and Contract regulate the issuing of billing, the collection of service charges and the disconnection or restriction of supply. The Office of the Regulator General convenes a Customer Consultative Committee, including customer, community, State Government and industry representation, to oversee developments in the utility sector.

It may be argued that the standards required by the State Government of private utility companies are higher than those required by the Government for the public housing services it provides.

FindingsIn examining the Office of Housing’s Rental Arrears Policy and Procedure, the Electricity Industry Supply and Sale Code (1997) and the Benchmark Customer Contract (1998), the following findings are made:

• While utility companies are subject to independent scrutiny through the Office of the Regulator General, public accountability in the form of the Code and Contract, and ongoing review in the form of the Community Consultative Committee, such structures do not exist in public housing.

• Tenants find the information presented on utility bills clear, while Office of Housing Rental Account Statements and the rent charging process is difficult to understand. Furthermore, Office of Housing correspondence does not include information to assist tenants who are experiencing payment difficulties or for whom English is not their first language, as is required of utility companies.

• Utility customers are able to enter into at least two payment arrangements in 12 months before action is taken to restrict supply. Office of Housing tenants, however, are only able to enter into one repayment agreement if they have not had an agreement in the previous two years, otherwise legal action is taken.

• Utility companies must take into account a customer’s capacity to pay when determining a repayment amount. The Office of Housing uses a standard formula (of between 28 and 30 per cent of household income) to calculate a repayment amount.

• Utility companies must not disconnect or restrict supply if a customer is unable (as opposed to unwilling) to pay their bill. The Office of Housing does not articulate such a policy.

RecommendationsIn response to these findings the following recommendations have been made:

1. That mechanisms are established to encourage the participation of tenants and appropriate community sector representatives on an ongoing basis in the review and development of Office of Housing Policy and Procedures that affect public housing tenants and applicants.

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2. That structures are established on a local, regional and statewide level to enable tenants to provide feedback to the Office of Housing in relation to policy and procedural review and development.

3. That the tenancy sign-up process is reviewed to:a. Ensure information given or explained to tenants in relation to the rent charging

system is clear and that the tenant understands the system and their responsibility;

b. Include a three month introductory payment schedule (in a calendar format) to indicate when payments are to be made and the implications of making late payments or missing payments;

c. Advise tenants to contact their Housing Services Officer (HSO) if they are experiencing difficulty meeting their rent payments and that their account may be suppressed for a limited time if they are making a late payment.

4. That Rental Account Statements are reviewed and redesigned to maximise understandability and clarity (taking into account the familiar, unambiguous format of utility bills), and include the following:a. Information on how to access assistance if experiencing payment difficulties;b. Translation into relevant languages and/or information on interpreting services;c. A graphical illustration in a calendar format showing rent charges, rent paid and

the date rent is paid up to.

5. That consideration is given to designating a Rental Arrears Liaison Officer within each Area Office to assist Housing Services Officer’s to respond to tenants experiencing payment difficulties by:a. Providing advice on appropriate action to assist tenants to maintain their tenancy

in the early stages of the Rental Arrears Process;b. Assessing a tenant’s specific circumstances, needs and their capacity to

maintain a repayment agreement, where necessary;c. Monitoring the situations of tenants experiencing payment difficulties;d. Providing appropriate assistance or referral where legal action is being taken.

6. That the Rental Arrears Liaison Officer have the flexibility to respond to tenants according to their needs. Such a response would include deferring repayment agreements for a limited time (i.e. where a tenant needs time to overcome a financial crisis before committing to a repayment agreement) or waiving rent charges (in consultation with the Housing Services Manager in special circumstances and for a limited time).

7. That Area Office staff are provided with training and information about local support services in order to provide information to tenants or make appropriate referrals to financial counsellors, emergency relief/material aid organisations, advocates, etc.

8. That protocols are developed between Office of Housing Area Offices and local support services where they do not already exist, and are utilised to facilitate referral processes and information sharing.

9. That arrears notices and letters regarding legal action are reviewed and redesigned to maximise understandability and clarity (taking into account levels of literacy and understanding of English).

10. That rental arrears letters and Notices to Vacate include:a. Rental Account Statements;

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Policy in arrears

b. A clear, individual explanation of how, or at what stage, the tenant has fallen into arrears;

c. A summary translated into main community languages and/or information about no-cost interpreter services;

d. Information about obtaining assistance if experiencing payment difficulties (including advocates, emergency relief and financial counselling organisations).

11. That the time allocated for tenants to respond to letters regarding arrears is given in working days to take into account public holidays.

12. That tenants are contacted via phone or home visit if they do not respond to an Order for Possession letter (as is required when tenants do not respond to an arrears reminder letter).

13. That tenants are given the opportunity to enter into repayment agreements according to their specific circumstances, needs and their capacity to pay.

14. That a local repayment agreement is reinstated if a tenant has made up the missing payment (as is the case with legal repayment agreements).

15. That a tenant is able to enter into two local agreements in 12 months.

16. That information provided to tenants when they sign a repayment agreement includes a repayment schedule (an example is included as Appendix 8) to show the period over which the customer will pay and how the repayment amount is calculated.

17. That a local agreement is renegotiated if a rebate backdate results in further arrears.

18. That a repayment agreement is negotiated after an Notice to Vacate is issued to be ratified at Victorian Civil and Administrative Tribunal if the tenant attends the hearing.

19. That a tenant who has maintained an Order for Possession repayment agreement for five months is able to continue with the repayment agreement while the Order for Possession lapses.

20. That the Office of Housing formally articulates the policy that no household is evicted from public housing due to a genuine inability to pay rent.

21. That where all attempts to maintain a tenancy have failed, consideration is given to the timing of evictions, above and beyond that which is stipulated in the Residential Tenancies Act, i.e. not after 3 p.m. on a weekday, not on a Friday or on the day before a public holiday.

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1. Introduction

The purpose of this section is to provide a context for the discussion of the Office of Housing’s Rental Arrears Policy and Procedures and to outline the aims and objectives of

the project

The role and responsibilities of the Office of HousingThe Office of Housing (OoH) is the largest single, residential landlord in Victoria, managing over 71,000 properties1, representing almost 4 per cent of all residential dwellings in Victoria and 18 per cent of all rental accommodation. More importantly, the OoH provides 40 per cent of Victoria’s low cost accommodation (www.dhs.vic.gov.au/ooh).

Eligibility for public housing is broadly described under the Commonwealth State Housing Agreement2 (CSHA) as "for those unable to obtain or maintain affordable finance for adequate and appropriate housing purchase from the private sector or from other sources outside the agreement". Further it states that "priority in granting assistance shall be determined by the need of assistance" (Human Services undated).

In allocating properties to public housing applicants the OoH aims to:• Use available resources effectively and efficiently,• Target housing to those most in need,• Respond to need equitably by providing similar assistance to those in similar

circumstances (Human Services undated).

The OoH provides low cost accommodation to people on low incomes3 (including families, singles, couples, older adults and people with disabilities) via a rebated rent system. Under this system tenants pay between 23 and 25 per cent of their income toward rent. In order to receive a rebate (the difference between the market value of the property and the amount the tenant is required to pay), tenants must submit a rebate application form and provide the OoH with statements showing household income, on which the assessment is based. An application form must be submitted each time household income changes. If the required documentation is not provided a tenant is not eligible for a rebate and is charged rent based on the market value of the property.

The development of the Office of Housing’s Rental Arrears Policy and Procedures

The Office of Housing’s rental arrears policy and procedures aim to reduce and prevent further rental arrears in order to maximise the revenue available for housing assistance programs and to assist tenants to maintain their tenancy (Office of Housing 1999; section 1-6).

The current Rental Arrears Procedures have remained generally unchanged since they were developed in late 1987 as a result of very high levels of rental arrears accrued during the 1980s. The Procedures were based on the Residential Tenancies Act (1980)

1 Includes short and medium term community-managed housing2 The CSHA is the mechanism through which the Federal Government provides funding to States and Territories for housing assistance3 90 per cent of public housing tenants receive a Centrelink income (Dickson Swift, 2000)

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Policy in arrears

with additional steps—i.e. an arrears reminder letter and the negotiation of a repayment agreement prior to legal action (with no minimum amount required), and the negotiation of a repayment agreement after an Order for Possession was granted. Once an Order for Possession was obtained Housing Services Managers would use their discretion to manage the case thereafter (Pellegrino, C 2000, pers. comm., 3 Oct).

A Rental Arrears Review was held in 1989-1990 as a result of concern for the rental arrears levels from both the community and the then Ministry of Housing and Construction (MHC). The key findings of the review were:• Low income is a significant factor in the accrual of rental arrears,• The incidence of arrears increase with the number of children in a household,• Almost one third of new tenants (of three months) are in arrears,• The rental rebate system is complex making it difficult for tenants to understand,• Financial stress occurs in the early stages of a tenancy due to the associated costs of

moving and establishing a home,• Energy costs are a significant Financial burden, '• Repayment agreements are subject to a high level of breakdown,• Vacated tenancy arrears recovery rates are very low,• There is a considerable tension between the goals of landlord and “social care”,• Prompt intervention has not led to resolution of rental arrears (Ministry of Housing and

Construction 1989).

In 1997 a number of changes were made to the Rental Arrears Procedures, the most significant being the restriction of one local repayment agreement in a two year period prior to legal action being taken. The rationale for this change “was to reduce the administrative resources currently required for arrears recovery activities, and to provide tenants with a clear message that the Office of Housing is serious in its intent to recover outstanding charges” (Human Services 1997; p.1). Additional changes included the calculation of agreement amounts based on percentage of income and the payment of arrears in full prior to the expiration of an Order for Possession.

The primary aim of the current Rental Arrears Policy, as outlined above, is to "reduce and prevent further rental arrears". The secondary aims are to maximise revenue for housing assistance programs and to assist tenants to maintain their tenancy. The aims are problematic for two reasons. Firstly, they infer that by reducing tenants’ arrears, they are assisting tenants to maintain their tenancy. However, in theory and practice the “assistance” provided by the OoH for tenants in arrears is limited by the OoH’s primary role as a landlord and the skills and resources available to Housing Services Officers.

Secondly, these aims have been developed based on economic objectives—the need to reduce rent arrears levels accumulated during the 1980s (or to maximise rent collected) and to meet the costs of providing housing assistance. As such there is an inherent conflict within the policy between the need to collect rent and the obligation to assist tenants to maintain their tenancy.

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The Southern RegionThe Brotherhood of St Laurence is funded by the OoH via the Rental Housing Support Program to provide advice and support to public housing tenants in the Southern Region of Melbourne. The Southern Region encompasses the Local Government Areas of Bayside, Cardinia, Casey,Frankston, Glen Eira, Greater Dandenong, Kingston, Mornington Peninsula, Port Phillip and Stonnington (see Appendix 1 for map).

Public housing accounts for only 2.7 per cent of all residential dwellings in the Southern Region, which is significantly less than the Victorian average of 4 per cent.

Research aims and rationaleAims and objectives

The aim of this research is:

To examine the Office of Housing’s Rental Arrears Policy and Procedures as they affect public housing tenants and to compare the Rental Arrears Policy and Procedures to the minimum standards regulating billing, collection and withdrawal of service required by the State Government of privatised utility companies.

The objectives are to:

1. Examine the OoH’s response to rental arrears from a public tenant perspective.2. Compare and contrast the Office of Housing’s Rental Arrears Policy and Procedures

with the Electricity Industry Supply and Sale Code (1997) and the Water Benchmark Customer Contract (1998).

3. Make recommendations to the OoH for improvement of Rental Arrears Policy and Procedures based on Objectives 1 and 2.

Research rationale

The need to examine the Office of Housing's Rental Arrears Policy and Procedures and to make recommendations for improvement was identified by the Brotherhood’s Public Tenant Support Service (PTSS) Workers, who assist tenants affected by the policy. It is generally felt that the policy takes a single approach to address problems resulting from a variety of situations—e.g. where arrears result from a rental rebate backdate, from tenants unable to pay their rent for reasons of affordability or other issues or needs. In many situations the policy creates undue stress and trauma for tenants who may be willing, although unable, to meet their rental responsibilities.

Chart 1.1 Occupied Private Dwelling Type in the Southern Region (ABS 1996)

Other & not stated 4.6%

Private Rental 24.6%

PublicHousing

2.7%

Owned39.8%

BeingPurchased

28.3%

There are also broader reasons to examine the policy. Given that the OoH is the only significant provider of affordable, long term housing in Victoria, and that alternative

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Policy in arrears

accommodation is often non-accessible or not viable due to cost, supply or quality, it is essential that public housing tenants be given every reasonable opportunity to maintain their tenancy. Futhermore, given that the OoH aims to accommodate those most in need, there will be an increase in the proportion of tenants who require a more individually appropriate and supportive response from the OoH.

In determining the focus of this project many issues relating to the Office of Housing's Allocation, Rebate and Rental Arrears policies were discussed. It is acknowledged that there are related issues that deserve equal attention, but have not been addressed in this report.

These issues include:

• The relative (in) affordability of public housing and how affordability has changed over time,

• The difficulties and confusion caused by the Rental Rebate Policy—specifically the backdating of rebates where they result in arrears and in some cases the issuing of a NTV; the disincentives created by the policy for tenants to work on a casual basis; and the inequity of assessing child maintenance payments as income (at 25 per cent),

• The impact of the changes to the Allocations Policy to target those most in need—of housing and in many cases support.

MethodsProject definition

The project was overseen by a reference group consisting of two PTS Workers, the PTSS's Assistant Manager and the Research Coordinator of the Social Action and Research unit of the Brotherhood. The group provided advice on the direction of the project, the methods used and the content of the report.

After speaking to PTS Workers in the Southern region an overview of problems faced by public tenants in rental arrears was gleaned. From this the aim and objectives of the project were developed

Information gathering

During 1998-1999 PTS Workers collected case studies of tenants who had contacted the PTSS due to rental arrears. Information collected included amount of arrears, reason for arrears and response by the OoH. This information provided a context for the quantitative data collected by PTS Workers (section 2.3).

Office of Housing manuals were referred to for relevant policy information, specifically the Debt Management (incorporating Rental Arrears Policy) and Allocations Manuals.

Contextual information in relation to developments in the Rental Arrears Policy and Procedures was obtained from the Office of Housing’s Change Management and Best Practice Team.

The Southern regional office of Human Services provided data in relation to rental arrears in the Southern region.

Information in relation to the billing and collection requirements of utility companies was taken from the Office of the Regulator General’s web page (www.reggen.vic.gov.au).

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Interviews

Nine public tenants were interviewed (seven individuals and one couple), selected by PTS workers on the reference group using opportunistic sampling methods. All of the tenants had sought assistance from the Brotherhood in relation to arrears action taken against them. All of the seven individuals interviewed were female; the only male interviewed was part of a couple. Of the eight households, two consisted of a couple with children, one was a single person and the remaining five were sole parent families. Three households received wages, while five were solely dependent upon a Centrelink income.

The tenants were interviewed face to face at their homes (the interview schedule is attached as Appendix 2). Three of the tenants were from Port/South Melbourne and six were from the Frankston/Hastings area. The interviewees were remunerated for their time.

Limitations

Literature pertaining to rental arrears and the Office of Housing's Rental Arrears Policy was sought from a number of sources with minimal success. Searches of the Internet, North East Regional Housing Council and Human Services libraries were undertaken, and a message was distributed to community organisations via the InfoXchange requesting information on alternative rental arrears procedures with few responses.

Due to the time available a limited number of tenants were interviewed. For this reason the information obtained from the interviewees provides examples of, rather than represents the experiences of public tenants in arrears.

Policy in arrears

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2. Office of Housing Rental Arrears

The purpose of this section is to outline the Office of Housing's Rental Arrears Procedures and to present data on the rate o f rental arrears in the Southern Region and the number

of tenants presenting at the Brotherhood of St Laurence's Public Tenant Support Serviceswith rental arrears inquiries

Rental Arrears Policy and Procedures(See Appendix 3 for Rental Arrears Procedure flow chart)

Context

Whilst the OoH acts as a significant provider of housing for people on low incomes, it does so within the terms of the Residential Tenancies Act (RTA) 1997. The RTA outlines the rights and obligations of landlords and tenants—public and private alike—and these are presided over by the Victorian Civil and Administrative Tribunal (VCAT). The RTA may be seen to provide the minimum standards on which the OoH bases its Rental Arrears Policy and Procedures.

The RTA provides the structure through which landlords may obtain a legal order directing tenants to repay rental arrears and/or to evict tenants. The RTA stipulates that any tenant who is more than 14 days behind in their rent can be issued with a Notice to Vacate (NTV). The landlord must apply to VCAT for a hearing in order to obtain an Order for Possession, and then obtain a Warrant of Possession to then evict the tenant. The tenant may attend the hearing and argue against the landlord obtaining an Order for Possession and request an arrears repayment agreement.

This section of the Act is primarily concerned with the rights of the (small, private) landlord, even though tenants have a right of reply at the VCAT hearing. If the RTA is seen to provide the minimum standards on which the Rental Arrears Policy and Procedures are based, it complies with one of the OoH's aims—to maximise revenue gained from rent. It follows, therefore, that to address the second aim the OoH’s Rental Arrears Procedures should provide the steps necessary to assist tenants to reduce their rental arrears and maintain their tenancy.

Office of Housing Rental Account Statements

For the purpose of this discussion, in the absence of a formal billing process, OoH Rental Account Statements will be treated as bills (Attached as Appendix 4).

Rental Account Statements are sent out on a quarterly basis and provide the following information:• Contact details of the tenant,• Account number,• Date and amount of rent charged (for the previous three months),• Date and amount of payments made (for the previous three months),• Arrears owing (as of a specific date),• Contact details of the relevant Housing Office.

While account statements are sent to tenants on a quarterly basis, they are also available on request or sent out as necessary to inform tenants of their account balance. The Rental Arrears Procedure do not stipulate that account statements be sent out with arrears reminder letters or NTV’s.

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Policy in arrears

Reminder letters

The OoH sends out two arrears reminder letters. The first is generated centrally when a tenant accrues arrears of $5.00 or more (attached as Appendix 5). The second letter (Appendix 6) is sent by the HSO 14 days after the first letter was sent, where the tenant is less than 14 days in arrears and has not responded to the first letter (Office of Housing 1999). These letters include the following information:• Contact details of the tenant,• Account number,• Date and amount of previous weekly rent amount charged,• Date and amount of previous payment made,• Arrears owing (as of a specific date),• Pay by date,• Contact details for the HSO,• Offer to discuss repayment options,• Warning that further action will be taken if the tenant does not respond.

If the tenant does not contact the HSO within the time specified (seven days from the date the letter was written), the HSO contacts the tenant via telephone or home visit to discuss the arrears and a repayment agreement, if eligible (i.e. if the tenant has not had a local agreement in the previous two years).

According to the policy the tenant is also supplied at this stage with information about assistance that is available if they are experiencing payment difficulties (in the form of support services). The policy seems to indicate that this information is provided when the tenant contacts the HSO about their arrears; this information is not included with the reminder letters.

Accounts can be “suppressed" (i.e. arrears action deferred) where tenants advise they will be making a late payment, however, only for 14 days.

Legal action

A 14 day Notice to Vacate and an application to the Victorian Civil and Administrative Tribunal is sent to a tenant who is more than 14 days in arrears and;• Has broken their local repayment agreement,• Has not responded to contact from the HSO (i.e. letters) within the specified time,• Is not eligible to enter into a local agreement.

If the rental arrears are paid in full prior to the hearing, the application for hearing may be withdrawn (i.e. the OoH must issue another NTV and application to pursue future rental arrears). A hearing may be adjourned if the tenant has an erratic payment history, but has paid the arrears in full prior to the hearing and it is their first request for an adjournment (i.e. the proceedings may be “renewed”, within a time frame, to pursue future rental arrears).

An Order for Possession is sought at the hearing if the tenant:• Does not attend the hearing,• Has had a previous legal agreement or Order for Possession,• Has broken a legal agreement for a second time,• Has paid no rent from the time the NTV was served.

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Once the Order for Possession is obtained a letter is sent requesting the tenant to contact the Office within seven days to discuss the Order for Possession and to arrange an Order for Possession repayment agreement.

If the tenant fails to make contact after receiving the letter or fails to meet the requirements of the Order for Possession agreement, a Warrant of Possession is applied for (via the Housing Services Manager and Housing Manager). The tenant is required to pay the outstanding rental arrears to avoid the eviction from proceeding.

An application to extend the Warrant may be made, subject to the Housing Services Manager’s approval, if the eviction will cause undue hardship for the tenant.

Repayment arrangements

Local repayment agreements are those that have not been legally ratified at VCAT. A tenant is only able to sign a local agreement if they have not signed a previous local agreement or they have signed a local agreement but have maintained nil arrears on their account for the previous two year period. The amount required to pay, including rent charges, is between 28 and 30 per cent of the assessable household income. If a tenant breaks a local agreement and is more than 14 days in arrears, they are sent a NTV. The agreement cannot be reinstated even if the tenant makes up the missed payment. A local agreement cannot be signed once a Notice to Vacate has been issued.

When a rental rebate backdate occurs that places a tenant into arrears and they are not eligible to enter into a repayment agreement or they are currently on an agreement, the outstanding amount must be paid within 14 days to avoid legal action.

If the tenant who has received a NTV attends the VCAT hearing and has not had a legal agreement or Order for Possession previously, a legal agreement will be sought. If a legal agreement is broken a renewal of proceedings is applied for. If the tenant does not pay the missed payment(s) prior to the renewal hearing an Order for Possession is sought. If the tenant makes up the missed payment(s) the renewal is withdrawn and the agreement reinstated, but a renewal will only be withdrawn once.

A tenant is able to sign a repayment agreement after an Order for Possession has been granted, however, if a payment is missed a Warrant of Possession will be applied for. All arrears must be paid within the six months that the Order for Possession is valid. The total repayment amount is calculated up to 30 per cent of household income, while any remaining debt is required to be paid as a lump sum by the end of the fifth month of the Order for Possession. If the agreement is broken and the tenant makes up the missed payment, the agreement is reinstated. If the agreement is broken more than once, agreement from the Housing Services Manager is required for the agreement to be reinstated.

13

Policy in arrears

Rate of rental arrearsOffice of Housing data on rental arrears in the Southern region 1999-00

Table 2.1 Rental arrears data for the Southern Region, rental general stock and moveable *units _________________________________________________________________________________

Cheltenham Dandenong Frankston Prahran Sth Melb Region

Total no. of 2,615 4,200 2,830 1,975 1,650 13,270tenancies% of total tenancies 19.7 31.7 21.3 14.9 12.4 100.0

*% of tenants in " 19.9 " * 22J0' ' ’ ' 2333 ' 23.0 >. 20.1arrears*'Ave number of 4.4 6.6 7.8 4.0 6.4 5.8days in arrears No. of tenants on ’ * **42 * ..... 116

, „ . 11>3'* ' ’ 38 ............. 51 ' * ' 360 ’ “

local agreements ■1

No. of tenants on 32 109 98 7 33 279legal agreements Total no. of tenants *

7 f , ■ ’ 225 ** 7 84 * 639on agreements ,% legal agreements of total agreements

43.2 48.4 46.4 15.6 39.3 43.7

% of tenants in arrears on local or legal agreements

...... .. 14.2 7 '" ' * 24.3 32.5 23.1 ' 22.1 23,9

Warrants obtained .......... 43 47" ' 65 10 10 1751999-00Warrants executed 1999-00

12 17* 29 ‘ 5 ' ‘ 7 ? 0 ’ ”

% of Warrants Obtained to Warrants Executed

27.9 36.2 44.6 50.0 70.0 40.0

% of total evictions 17 A' ‘ 24.3 . . --4 l 4 ■>.............. 7-'1 ' 10.0 " 100.0

Figures are as of 30/6/00* Percentages based on figures provided by the Office of Housing, Southern Region ** Average days in arrears equals total amount of debt divided by average daily rent charged.

Table 2.1 shows that 20 per cent of tenants in the Southern region are considered to be in arrears and that the average rate of arrears equates to only six days. Frankston (23 per cent), South Melbourne (23 per cent) and Dandenong (22 per cent) have above average proportions of tenants in arrears, as well as above average numbers of days in arrears. In both of these respects Prahran’s rate of arrears is relatively low.

On average 23.9 per cent of tenants who are in arrears are on either a local or legal agreement. This ranges from 14.2 per cent of Cheltenham tenants to 32.5 per cent of Frankston tenants. Of tenants who are on a local or legal agreement, 43.7 per cent of those are legal (i.e. tenants have been issued a NTV and have made an agreement at VCAT). This rate ranges from 15.6 per cent in Prahran to 48.4 per cent in Dandenong and 46.4 per cent in Frankston.

During 1999-00 175 warrants were obtained in the Southern region. Only 70 of these Warrants were executed (accounting for 40 per cent of those obtained). While the Cheltenham office executed the lowest proportion of Warrants obtained at 27.9 per cent, South Melbourne executed the highest (70 per cent).

14


The Frankston office has 21.3 per cent of the Southern region’s tenants; however, it executed 41.4 per cent of the region’s Warrants. Prahran and South Melbourne together executed 17 per cent of the region’s Warrants (7.1 and 10 per cent respectively), while accommodating just over a quarter of the region’s tenants (14.9 and 12.4 per cent).

Tenants seeking assistance from BrotherhoodBrotherhood Rental Housing Support Program data on tenants presenting with arrears issues

Table 2.2 shows the number of public housing tenants who have approached Brotherhood due to problems with rental arrears and the changes in the number of contacts since uniform data was collected beginning in 1998.

Table 2.2 Brotherhood of St Laurence Public Tenant Support Service rental arrears contact data for the Southern Region, 1998-2000______________________ ;_____________________________________

Cheltenham Dandenong Frankston Stonnington PortMelbourne

Russianspeakingworker

Total

1998 RA contacts ?...... 27- . ,.’,23.:..... • 22 - 1366 months Total contacts 205 717 206 1,133 1,899 4,160

% of total - 16:6 ‘ " ' 4.2 '• 13.1 ~ 2.0 ‘ ' H,2 3 3

* ’ ■■■ ;contacts

% of regional25 q

22.1 19.9 * ’"’ 16.9 16.2 100.0

1998-99

rental arrears contacts

RA contacts 80 97. 117 " 43 ‘ ' ' ’ 70 ’ 407Total contacts 4,483 3,400 979 2,997 3,537 15,396%’ of total ' 1.8' ' ' 2.9 ” " 12.0 " 1.4 " 2.0 " 2.6contacts % of regional 19.7 *"*” *23*8* * * * *287 *”* ”*" 1 0 6 * 17.2 ■ioo.o

1999-4)0

rental arrears contacts

RA contacts 196 U 3 P 3 0 192 86 161 107 1172Total contacts 2,760 4,354 954 1,923 3,963 2,189 16,143% of total ” 7.1 9 9 ' " " f c o . r 4.5' " 4.1 4,9 . 7.3contacts % of regional 16.7 ~ "~ 3 6 .7 16.4 7.3 1 9.1 100.0rental arrears contacts

% change RA 145 343.3 ; • 64.1 "■ ' io o :o "130.0 ' “ 188.0contacts1998- 99 to1999- 00-

Rental arrears enquiries to Brotherhood PTSS in the Southern Region increased by 188 per cent between 1998-99 and 1999-00. Increases ranged from 64.1 per cent in Frankston to 343.3 per cent in Dandenong. Rental arrears contacts accounted for 3.3 per cent of all contacts in the last half of 1998, which decreased to 2.6 per cent in 1998-99 and increased to 7.3 per cent in 1999-00.

Even though Dandenong experienced the largest increase in rental arrears contacts from 1998-99 to 1999-00 (343 per cent), the proportion of rental arrears contacts to total contacts at the Dandenong office have followed the general pattern of the Southern region. The Port Melbourne and Stonnington (Prahran) offices have both had consistently low proportions of rental arrears contacts compared to the other offices, while both offices had an increase in contacts of 130 per cent and 100 per cent respectively between 1998-

15

Policy in arrears

99 and 1999-00. Cheltenham had a relatively high proportion of rental arrears contacts in the first half of 1998, with a decrease in 1998-99 and an increase in 1999-2000. Rental arrears contacts in Cheltenham increased by 145 per cent from 1998-99 to 1999-00.

Frankston has consistently recorded an above average proportion of rental arrears contacts with 13 per cent of all contacts in 1998, 12 per cent in 1998-99 and 20 per cent in 1999-00. The increase in contacts between 1998-99 and 1999-00 was the lowest of all offices at 64.1 per cent.

During 1998 and 1999 PTS Workers collected case studies of tenants presenting at offices with rental arrears inquiries. Common reasons cited for rental arrears centre on affordability issues and budgeting difficulties—other bills to pay, unplanned expenses, etc. Another common cause is non-compliance with OoH requirements for calculating rental rebate—i.e. due to neglecting to notify the OoH of changing household circumstances or income and as these changes are backdated significant arrears can result. Other reasons can be attributed to individual issues including financial management, gambling, substance use, illiteracy or speaking a language other than English.

ImplicationsMuch of the increase in the PTSS rental arrears contacts can be attributed to tenants becoming more aware of the existence and role of the service in 1998, 1999 and 2000. Increased awareness may be due in part to the establishment of protocols between the OoH and the PTSS, which include providing the tenant with information about the PTSS when a NTV is issued. The proportion of enquiries to each office generally mirrors the proportion of tenants in each sub-region.

The OoH statistics raises questions in relation to rental arrears management:

• Firstly, a relatively high number of tenants owe a relatively small amount of rental arrears. This would indicate that many of these tenants do not have an “arrears problem” —i.e. the arrears amounts do not warrant rental arrears action more serious than a reminder letter. This may be due to misunderstandings of the rent charging system and the requirement to pay ahead. Five per cent of tenants in the Southern region are in rental arrears of more than four weeks (Connell, D 2000, pers. comm., 1 Dec). •

• Secondly, 23.9 per cent of tenants in rental arrears are on a local or legal agreement. While considering the number of tenants not included in these statistics (e.g. those on an Order for Possession agreement, those who have not contacted the OoH to discuss their arrears and to make an agreement and/or those who have further action pending), there is a considerable number of tenants in arrears not accounted for. Almost half of tenants on a pre-Order for Possession agreement (e.g. a local or legal agreement) are on legal agreements. This indicates the OoH is relying on VCAT to respond to the majority of their tenants in rental arrears (including tenants on Order for Possession agreements, etc.).

16


• Finally, only an average of 40 per cent of Warrants obtained in the Southern region are executed. While fewer Warrants being executed is better for tenants, this figure may indicate that the majority of tenants for whom a Warrant is obtained are receiving the assistance necessary to maintain their tenancy at almost the end of the rental arrears process. This may be due to a number of reasons, however, the wrong message may be sent to tenants—i.e. that the eviction can be stopped at the last minute (no need to respond sooner). This situation is costly in terms of VCAT fees ($25 per application plus $60 per Warrant) and human resources for the OoH and traumatic for tenants involved in the process.

17

Policy in arrears

18

fUr


3. Tenant experiences of the Office of Housing’s Rental Arrears Procedures

The purpose of this section is to outline the responses gained from tenants interviewed about their experience dealing with the Office of Housing in relation to rental arrears

ContextOf the nine public housing tenants interviewed, five fell into arrears due to non-payment of rent, while the remaining tenants' arrears resulted from changes to rental rebates. Two of the tenants had not complied with the rental rebate system (by neglecting to notify of household changes), while another was charged rent for her partner from whom she had separated and was unable to provide the required documentation to prove he had moved out.

While all of the tenants are on a relatively iow or fixed income, some had other issues (gambling problem, mental illness, stress-related condition) that impinged on their ability to maintain regular rent payments. Despite the tenants' different circumstances the same rental arrears procedures applied.

BillingThe most common initial comment from the tenants interviewed about their rental arrears was that either they did not understand how they had fallen into arrears or that they doubted the extent of the arrears. This indicates that the tenants did not understand the OoH's rent charging system and that information supplied at sign-up, or provided in Rental Account Statements and arrears letters, or during discussions with HSO’s, was insufficient in explaining the process clearly to tenants.

When asked if they found it easy to understand the account statements sent out by the OoH, all but two tenants said no. Comments made included: "I can't work them out" and "I just don't get it". Of the two tenants who found the statements easy to understand, one had an accounting background and both acknowledged that the statements would be difficult for other tenants to understand, specifically older people and newly arrived migrants. A particularly confusing aspect for the tenants is the requirement to be one or two weeks in credit; thus if an account statement shows a zero balance, and the tenant pays fortnightly, the tenant may actually be two weeks behind in their payments.

In one case a VCAT member presiding over a hearing ordered a HSO to provide information to the tenant to explain the rent charging system so that they could understand how they had accumulated arrears. The HSO sent the tenant a pamphlet on the rental rebate system instead, which did not provide the tenant with the necessary information.

When asked how utility bills compare to the OoH's account statements, tenants who found the account statements difficult to understand found utility bills straightforward. One tenant stated "This amount is due by whenever, please pay. You don't have to put a lot of thought into working it (utility bills) out". Another tenant said "The (electricity company) bills are simplified so simple people like me can understand it. I'm not a rocket scientist".

19

Policy in arrears

CollectionInformation

All of the interviewees found the arrears letter generally clear (i.e. they understood that the letter was informing them they were in arrears). All tenants interviewed stated that what they knew about the rental arrears process, they had learned from experience; the OoH had not provided information about what steps are taken when a tenant has arrears.

Only one tenant recalled having been given information about what to do if she was not able to pay rent. She was told, informally, that she should contact her HSO. When asked if they had been given information about services that could provide assistance if they were unable to pay their rent, only two tenants stated they had received information about the PTSS from the OoH (albeit in one case with the wrong contact information and not until they had been issued with a NTV). The remaining tenants said they had found the PTSS via word of mouth, referral from another service and in one case via her local Member of Parliament. While the OoH provided contact details for the PTSS (in two instances), information about services that provide financial assistance (emergency relief or financial counselling) was not offered.

Repayment agreements

In most cases the tenants' arrears situation led to a NTV and an application to VCAT for an Order for Possession. As all of the tenants appeared at the VCAT hearing a repayment agreement was negotiated. Many of the tenants who were issued with a NTV were not eligible for a local agreement, as they had had a local agreement in the previous two years. One interviewee was sent a NTV as she had had a local agreement to repay $90, 22 months previously—two months short of the two year period required.

Tenant responses and needs

When sent arrears letters or NTV’s, the interviewees said they "freaked", "panicked", were "devastated" and "felt attacked emotionally". The latter response was followed with "I was traumatised by the thought that I could lose the place where all my memories were".

Tenants were asked if they felt that their HSO understood their situation; two tenants felt they had (one added this was because the PTS Worker had explained her situation to the HSO), while the remainder believed they did not understand and they did not want to.One tenant who fell behind in her rent while dealing with grief said of the HSO "Her response was cold. She had no compassion at all for the state of mind I was in". Another tenant said that she believed due to her history of erratic rent payments her HSO "wasn't prepared to listen to why I was behind". Another tenant was more critical:

They don't want to know the people in their houses; we're not people we're account numbers ... They don't visit any more, they don't get to know you ... they're meant to be providing a service and they're not They don't have people skills

While most tenants contacted the OoH as soon as they received the arrears letter or NTV, some found it difficult to contact their HSO. One tenant was told the HSO had left “weeks ago”, even though her name was given as the contact on the letter. Two tenants contacted the PTSS as they could not contact their HSO, and their HSO had not

20


contacted them. One tenant, who did not contact her HSO, said that the HSO did not try to contact her by phone or home visit.

Tenants with more complex problems that affected their ability to pay rent reported difficulties communicating with their HSO. One tenant who tried to explain her circumstances reported having been told that "HSO’s are not social workers, they're landlords". Another tenant felt that her HSO was unwilling and unable to understand her situation and how that contributed to her arrears:

I needed someone with an understanding ... of mental illness. If I lose this place I won’t stay on my medication, I ’ll be hospitalised and that will cost the community more than my arrears. Maybe the OoH is not speaking to people who know about mental illness.

A tenant with a stress-related condition said he had informed his HSO on a number of occasions about his health problem, how it affects his memory and his need to avoid stressful situations. He felt that his HSO did not take his health into account when issuing a NTV.

ImprovementsSuggestions by the tenants interviewed in relation to how the OoH could improve its approach to tenants in arrears centred on information and communication. The tenants expressed a need for clearer information specifically about the rent charging system and an explanation on arrears letters to help understand how they fell behind. They also expressed the need for better communication between HSO’s and themselves so that HSO’s have an understanding of their circumstances and are able to make informed decisions about how to address different situations. One tenant, who felt she had established a positive relationship with her HSO, said, “If I didn’t know them, I would have been terrified of eviction”. Another tenant responded: “We’re not asking for any favours, just (for HSO’s to) treat people as individuals”.

21

Policy in arrears


4. Minimum standards for Government-regulated utility companies

The purpose of this section is to provide a rationale for examining the minimum standards regulating billing, collection and withdrawal of services in privately managed, utility

companies and to outline these standards

RationaleAs with housing, the provision of utilities (electricity, water, gas) is seen as an essential service; services that are fundamental for subsistence and participation in society.In Victoria, these services have recently become privatised (electricity and gas) or corporatised (water) and regulated by the Office ofthe Regulator General (ORG)—a State Government authority.

The ORG was established “as an independent economic regulator” to (among other aims) “ensure that users and consumers benefit from competition and efficiency” (www.reggen.vic.gov.au). The ORG regulates the electricity and water industries via the Electricity Industries Act 1993 and the Water Industry Act 1994. A requirement of these Acts is the development of the Electricity Industry Supply and Sale Code 1997 (hereafter known as the Electricity Code) and the Benchmark Customer Contract—Melbourne Metropolitan Water and Sewerage Retail Industry 1998 (hereafter known as the Water Contract) to set out the rights and obligations of the Companies and their customers. Included in these contracts are minimum standards for billing customers, collecting payments from customers, responding to customers who are experiencing payment difficulties and disconnecting/restricting supply to customers who fail to pay their utility bills.

AccountabilityThe ORG convenes a Customer Consultative Committee (CCC) to provide feedback on developments in the electricity and water industries. The CCC includes consumer and community representatives, as well as Government and industry stakeholders. Any variations proposed by companies to the Electricity Code or Water Contract can only be made after consultation with the CCC and approval from the ORG.

The formation of consultative committees is also a legal requirement of individual water companies, while many electricity and gas companies also convene committees including consumer representatives to provide feedback.

BillingElectricity, gas and water companies must issue bills on a quarterly basis. Specific information must be presented on bills sent to residential customers, including:• Amount due,• The date by which the amount is required,• Acceptable payment methods,• Information about assistance available if the customer is experiencing payment

difficulties,• Contact number for enquiries,• Referral to interpreter services.

23

http://www.reggen.vic.gov.au

Policy in arrears

In addition companies are required to include on their bills a graphical representation of the customer’s usage.

Responding to customers experiencing payment difficulties“(The Water Company) will provide information to customers on programs which are available to help people having payment difficulties. A brochure with this information will be provided to customers during their collection cycle where there is evidence of hardship, or on request.” (Benchmark Customer Contract 1998; p.22)

A customer is required to pay their bill within ten working days of receiving it. If a customer fails to pay the bill a second notice is sent out including the following information:• Instalment plan or alternative payment options,• Information about energy-related financial assistance programs,• Information on, or referral, to independent, free financial counselling services.

If a customer fails to pay within five working days of receiving the second bill another notice will be sent out specifying the assistance available and advising that the bill is overdue and must be paid for the customer to avoid restriction/disconnection.

A company must offer a customer an instalment plan if they are experiencing payment difficulties. This enables customers to pay by instalments toward their next bill or toward their arrears. The instalment plan must take into account the customers capacity to pay and specify the period over which the customer is required to pay, the payment amount and how it is calculated (Electricity Industry Supply and Sale Code 1997).

A company is not required to offer an instalment plan if the customer has had two plans cancelled in the previous 12 months for non-payment, unless the customer provides reasonable assurance that they will comply with the plan.

In addition to the above, water companies provide the option to defer the payment date for some or the entire amount owed (Benchmark Customer Contract 1998).

Restriction/disconnectionIf a customer is unable to pay the supply or usage charge due to a lack of sufficient income, the supplier must not disconnect the supply to the customer’s supply address until the supplier has:• Offered the customer alternative payment options,• Given the customer information on assistance available (and on request supplied the

customer with an application form for the Energy Relief Grant Scheme),• Used its best endeavours to contact the customer by visit, telephone or mail

(Benchmark Customer Contract 1998).

The supplier is permitted to restrict or disconnect supply if the previous actions have been undertaken and the customer has:• Refused or failed to accept the offer, or• Accepted the offer, but has failed to take any reasonable action towards settling the

debt within the specified time (not less than five business days) (Electricity Industry Supply and Sale Code 1997).

24


A company must not disconnect:• For non-payment where the outstanding amount is less than an amount agreed to by

the ORG ($100 for water customers),• Where there are relevant health reasons,• If the customer is in the process of applying for financial assistance,• Where a grievance procedure is being conducted, or• After 3 p.m. on a weekday, on a Friday or weekend, on a public holiday or the day

before a public holiday (Electricity Industry Supply and Sale Code 1997, Benchmark Customer Contract 1998).

25

Policy in arrears

2 6


5. Application to Office of Housing’s Rental Arrears Policy and Procedures

The purpose of this section is to compare and contrast minimum standards of customer service required by the Government of utility companies to the Office of Housing’s Rental

Arrears Policy and Procedures

ContextThe Office of Housing’s Rental Arrears Policy and Procedures have been developed internally with the aim of reducing rental arrears to cover the costs of providing housing assistance programs and to assist tenants to maintain their tenancy. The Residential Tenancies Act provides the minimum standards.

The minimum standards required by the State Government of private utility companies have been developed in consultation with community, consumer and industry representatives and cannot be amended without the permission of the Office of the Regulator General in consultation with its Customer Consultative Committee. The standards have been developed to protect consumers in a privatised environment.

It may be argued that the standards required by the Government of private utility companies are higher than those required by the Government of the services it provides.

AccountabilityIndependent scrutiny and customer consultation

The fundamental priority of an organisation established to provide a service must be to deliver that service in a way that takes into account the needs of the service recipient, as well as the capacity of the organisation to deliver that service. An organisation cannot ensure the needs of the service recipient are being met unless it has established mechanisms that promote accountability.

Structures established to promote accountability may be internal or external to the organisation, but in order to bring legitimacy to the process, there should be independent scrutiny as well as scrutiny from those whom the organisation purports to service.

In the electricity, gas and water industries, companies are subject to independent scrutiny from the Office of the Regulator General (ORG), public accountability from the Electricity Code and the Water Contract, and ongoing review in the form of the ORG’s Community Consultative Committee (CCC). The ORG convenes a CCC and requires that companies convene a committee including community and customer representation. If a company wishes to amend the standards outlined in the Code/Contract, they must consult with their committee and the ORG’s CCC and gain approval from the ORG.

Such scrutiny does not exist in public housing. It can be argued that as public housing is delivered by the State there are in-built mechanisms that ensure accountability. However, on an individual level dissatisfied customers must rely on VCAT, if the Residential Tenancies Act has been breached, or internal bureaucratic and political processes if unhappy with OoH policy or procedures. These processes rely on the tenant having the necessary skills to negotiate or to engage an advocate.

27

Policy in arrears

Consultation, either formal or informal, on policy development that affects public housing tenants has not been a feature of the OoH in the recent past. Such consultation is necessary for the OoH to take into account alternate views and experience, and to garner support for changes in policy and procedures. It is feasible that structures can be established to enable tenants (or their representatives) to participate in the development of policy and for the wider public tenant community to respond to these developments on a local, regional and statewide level, as appropriate. Such structures would need to ensure tenants are encouraged and supported to participate.

Recommendations1. That mechanisms are established to encourage the participation of tenants and

appropriate community sector representatives on an ongoing basis in the review and development of Office of Housing Policy and Procedures that affect public housing tenants and applicants.

2. That structures are established on a local, regional and statewide level to enable tenants to provide feedback to the Office of Housing in relation to policy and procedural review and development.

BillingBills issued by utility companies and the OoH’s Rental Account Statements serve a similar purpose, although with key differences. These differences occur in three areas; function, understandability and quality of the information presented.

Function

in terms of function, utility bills are issued on a quarterly basis to request payment for services provided during a specific billing period. OoH account statements, however, convey information to tenants about their account history (in the previous three months) and their current account balance according to rent amounts charged and payments made. OoH account statements do not indicate that a payment is required, even when a tenant is in arrears. It is assumed the tenant will understand and respond to the information outlined on the statements. However, if a tenant does not understand the statement, it is unlikely they will respond.

Understandability

As mentioned in Section 3 most of the tenants interviewed said they did not understand how they had fallen into arrears or questioned the level of the arrears. Most also do not find the account statements easy to understand, reflecting a general lack of understanding of the OoH's rent charging system. A major source of confusion is that the current balance on account statements does not take into account that tenants are expected to pay two weeks in advance (if they pay fortnightly), so if the balance is zero the tenant may actually be two weeks behind in their rent. The result is that tenants are not clear about when they are considered to be in arrears.

When conveying information about accounts and arrears it is imperative that information is provided in a manner that is clear and easily understandable from a customer perspective. All of the tenants interviewed found utility bills easy to understand as they clearly show how much money is owed and when it should be paid by.

28


Quality of information

While bills and account statements serve a similar purpose and provide similar information, utility bills must provide the following supportive information, which is not presented on OoH Rental Account Statements:• An outline of available payment methods,• Information about assistance available if a customer is experiencing difficulties paying

the bill; and• Information about how to access a no-cost interpreter service.

Such information, particularly of assistance available if the tenant is experiencing payment difficulties, would be beneficial to tenants who are willing, but are however having difficulties meeting their rent payments.

Another important element is the inclusion on utility bills of a graphical illustration of the amount of service provided or consumed. If taken a step further this would be a useful tool for the OoH to use to assist tenants to understand how rent is charged, specifically those with limited literacy skills or for whom English is a second language. A graphical illustration (in the form of a calendar—an example is attached as Appendix 7) could be used by the OoH to show when rent was charged, when payments have been made, the running balance and the date rent is paid to. This idea was presented to a number of the tenants interviewed and was met with support. One tenant explained that when he received an account statement he transferred the information to his calendar in order to understand it.

Recommendations3. That the tenancy sign-up process is reviewed to:

a. Ensure information given or explained to tenants in relation to the rent charging system is clear and that the tenant understands the system and their responsibility;

b. Include a three month introductory payment schedule (in a calender format) to indicate when payments are to be made and the implications of making late payments or missing payments;

c. Advise tenants to contact their Housing Services Officer if they are experiencing difficulty meeting their rent payments and that their account may be suppressed for a limited time if they are making a late payment.

4. That Rental Account Statements are reviewed and redesigned to maximiseunderstandability and clarity (taking into account the familiar, unambiguous format of utilitybills), and include the following:a. Information on how to access assistance if experiencing payment difficulties;b. Translation into relevant languages and/or information on interpreting services; andc. A graphical illustration in a calender format showing rent charges, rent paid and the

date rent is paid up to.

29

Policy in arrears

Responding to tenants experiencing payment difficultiesA successful rental arrears strategy is reliant upon good communication and information and an early and consistent response. It is important that payment difficulties are dealt with as soon as possible, before tenants accumulate arrears at a level that appear to them to be insurmountable.

Good communication encompasses both written and verbal. As with account statements, letters to tenants about arrears should be clearly written (taking into account levels of literacy and understanding of English) and include relevant information.

In general the arrears letters sent to tenants are clear, however, they do not provide adequate information to explain to tenants how they have fallen behind. The assumption made by the OoH is that tenants are aware that they are in arrears, but this is not the case according to some of the tenants interviewed.

According to the Rental Arrears Procedures when a tenant contacts their HSO in response to an arrears letter, the tenant is provided with information about assistance available to them if they are having problems paying their rent. This was not the experience of the tenants interviewed. Only two of the nine tenants interviewed received information about the PTSS, and this was not until they had been issued a NTV.

One of the most common complaints from tenants interviewed was that they feel that their HSO is not interested in their situation or the circumstances that have led to them accumulating arrears; they are interested only in getting the tenant to pay back the arrears. Such an approach does not take into account the tenants' capacity to pay their arrears and therefore maintain their tenancy.

Recommendations5. That consideration is given to designating a Rental Arrears Liaison Officer within

each Area Office to assist Housing Services Officer’s to respond to tenants experiencing payment difficulties by:a. Providing advice on appropriate action to assist tenants to maintain their

tenancy in the early stages of the Rental Arrears Process;b. Assessing a tenant’s specific circumstances, needs and their capacity to

maintain a repayment agreement, where necessary;c. Monitoring the situations of tenants experiencing payment difficulties;d. Providing appropriate assistance or referral where legal action is being taken.

6. That the Rental Arrears Liaison Officer have the flexibility to respond to tenants according to their needs. Such a response would include deferring repayment agreements for a limited time (i.e. where a tenant needs time to overcome a financial crisis before committing to a repayment agreement) or waiving rent charges (in consultation with the Housing Services Manager in special circumstances and for a limited time).

7. That Area Office staff are provided with training and information about local support services in order to provide information to tenants or make appropriate referrals to financial counsellors, emergency relief/materiel aid organisations, advocates, etc.

30


8. That protocols are developed between Office of Housing Area Offices and local support services where they do not already exist, and are utilised to facilitate referral processes and information sharing.

9. That arrears notices and letters regarding legal action, are reviewed and redesigned to maximise understandability and clarity (taking into account levels of literacy and understanding of English).

10. That rental arrears letters and Notices to Vacate include:a . ' Rental Account Statements;b. A clear, individual explanation of how, or at what stage, the tenant has fallen

into arrears;c. A summary translated into main community languages and/or information

about no-cost interpreter services;d. Information about obtaining assistance if experiencing payment difficulties

(including advocates, emergency relief and financial counselling organisations).

11. That the time allocated for tenants to respond to letters regarding arrears is given in working days to take into account public holidays.

12. That tenants are contacted via phone or home visit if they do not respond to an Order for Possession letter (as is required when tenants do not respond to an arrears reminder letter).

Repayment arrangements

Repayment arrangements are intended to assist tenants to pay back arrears gradually over time at a rate that is considered affordable. Repayment agreements made between the tenant and the OoH without VCAT intervention are preferable—providing the repayment amount is viable. Local agreements remove the trauma associated with attending a VCAT hearing; they preserve the clear relationship between the tenant and the landlord and the OoH is saved the resources associated with applying to and attending a VCAT hearing. For these reasons it is difficult to understand why the OoH will only allow one repayment agreement (for arrears more than 14 days) in a two year period and cancel a local agreement even if the missing payments are made up (unlike legal and Order for Possession agreements which are reinstated if a payment is missed and subsequently paid).

This procedure was developed to “reduce the administrative resources required for arrears recovery activities” (Human Services 1997). However, it is difficult to believe that it is cheaper to issue a NTV and attend a VCAT hearing than it is to re-negotiate a local repayment agreement. If there was a problem with local agreements breaking down (as identified in the Rental Arrears Review in 1989), the causal factors should have been, identified and addressed. Likely factors may include unaffordable or untimely agreements—i.e. tenants feeling pressured to make an agreement when they were still in a financial crisis and not in a position to honour the agreement.

31

' Policy in arrears

Utility companies allow customers to enter into two payment arrangements in 12 months and another if the customer can offer reasonable assurance they will comply. For utility customers the next step from breaking an arrangement may be disconnection. Tenants need to be aware that once they break a local agreement they will be subject to legal action, the outcome of which may be eviction.

If a tenant is on a local repayment agreement and a rental rebate backdate results in further arrears they are asked to pay that amount as a lump sum. If they do not, a NTV is issued and they are given the opportunity to enter into a legal agreement at VCAT. Many tenants would not be in a position to pay the lump sum (and if they tried they would jeopardise their capacity to repay their current arrears) and therefore their arrears situation would escalate and enter the legal realm. The likely outcome of VCAT action for the OoH, however, would be .a repayment agreement plus the costs of applying to and attending the tribunal. For both parties it would make sense to renegotiate the local agreement.

Once a tenant has been issued a NTV it would be beneficial for both the tenant and the OoH to enter into an agreement prior to attending VCAT. The agreement can be ratified at the tribunal if the tenant attends the hearing and this would enable the tenant to show their commitment to repaying the arrears. If not provided this opportunity a tenant may stop paying any rent until they know the outcome of the hearing (believing they may be evicted), accumulating a greater level of arrears.

If a tenant agrees to an Order for Possession repayment agreement they are required to repay the arrears prior to the expiration of the Order for Possession (six months). The requirement to pay the balance (the amount outstanding once the weekly repayment rate of a maximum of 30 per cent of household income has been calculated) as a lump sum by the fifth month of the Order for Possession is an onerous requirement. Again, this jeopardises the tenant’s capacity to repay their agreement. If a tenant has maintained an agreement for five months, the Order for Possession should be allowed to lapse and the agreement continue until the arrears are repaid.

Recommendations13. That tenants are given the opportunity to enter into repayment agreements

according to their specific circumstances, needs and their capacity to pay.

14. That a local repayment agreement is reinstated if a tenant has made up the missing payment (as is the case with legal repayment agreements).

15. That a tenant is able to enter into two local agreements in 12 months.

16. That information provided to tenants when they sign a repayment agreement includes a repayment schedule (an example is included as Appendix 8) to show the period over which the customer will pay and how the repayment amount is calculated.

17. That a local agreement is renegotiated if a rebate backdate results in further arrears.

18. That a repayment agreement is negotiated after a Notice to Vacate is issued to be ratified at Victorian Civil and Administrative Tribunal if the tenant attends the hearing.

32


Recommendations19. That a tenant who has maintained an Order for Possession repayment agreement for

five months is able to continue with the repayment agreement while the Order for Possession lapses.

Restriction of suppIy/Disconnection/EvictionThe eviction of public housing tenants for rental arrears is, on the whole, a relatively rare occurrence. However, given the number of warrants obtained and not executed, it seems many tenancies are saved at the very last minute—perhaps due to intervention of Managers or support agencies. In order to avoid this situation (which is costly and time consuming for the OoH and traumatic for tenants) such intervention needs to occur at an earlier stage. HSO’s currently do not have the skills or resources to provide the appropriate assistance. It is envisaged that an appropriately trained and resourced Rental Arrears Liaison Officer would identify tenants’ issues that result in rental arrears and facilitate support where appropriate.

Recommendations20. That the Office of Housing formally articulates the policy that no household is

evicted from public housing due to a genuine inability to pay rent.

21. That where all attempts to maintain a tenancy have failed, consideration is given to the timing of evictions, above and beyond that which is stipulated in the Residential Tenancies Act—i.e. not after 3 p.m. on a weekday, not on a Friday or on the day before a public holiday.

33

/Policy in arrears

34


6. ConclusionChanges to individual policies cannot occur in isolation; there needs to be consideration of how such changes affect other policies and procedures. Changes to the Office of Housing’s Allocation policy to target those in greatest need of housing have resulted in an increase in public housing tenants who have needs above and beyond those that can be met by the allocation of housing. In relation to the management of rental arrears specifically, a more supportive and responsive approach is needed from the OoH in order to assist tenants to maintain their tenancy.

Housing Service Officers are charged with the responsibility of implementing policies and are at the interface of any dealings between the OoH and tenants. HSOs, however, have little, if any influence over the development or review of tenancy management policy. While a more supportive approach may be,needed, HSOs are currently not permitted to be flexible in the implementation of policy and are therefore not able to take individual circumstances into account.

Any changes to the Rental Arrears Policy and Procedures need to be made in light of the changing nature of the public housing population, the implementation of policy at the local level, as well as successful processes and strategies developed by other industries to minimise revenue loss, while retaining customers.

35

Policy in arrears

36


Appendix 1: Map of Southern Metropolitan Region

A BaysideB CardiniaC CaseyD FrankstonE Glen EiraF Greater DandenongG KingstonH Mornington PeninsulaI Port PhillipJ Stonnington

j

37

Policy in arrears


Appendix 2: Interview Schedule

1. Introduction

(a) How did you get into arrears? When? For how long? What stage did you get to?

(b) What information had the OoH given you about what to do if you could not pay your rent?

2. Contact

(a) Did you contact the OoH about your arrears or did they contact you? How did they contact you?

(b) What was your reaction when they contacted? If written, did you understand the letter(s)/account statements? Did you respond to the letter? How? Did the OoH phone or visit you at home?

(c) What did you know about the rent arrears process? Did the OoH inform you of the process?When? Did you understand the process?

(d) Do you feel the OoH understood your situation? Did they try to find a solution to suit your situation? Did you negotiate an affordable repayment arrangement? Were you able to stick to the agreement?

(e) What information did the OoH give you about assistance that may have been available to you? How? When?

(f) How do you feel the Office of Housing treated you when you fell into arrears? What, if anything, could they have done better?

3. Utilities

(a) Have you fallen behind with other bills - e.g. electricity, gas or water?

(b) How did the utility companies treat you when you could not pay your bill? What arrangements were made? Were you given information about assistance available to help you?

4. Recommendations

(a) What could the OoH have done to improve the way they assisted you with your arrears? Did you need assistance from another service - e.g. financial counsellor, emergency relief, advocate?

(b) What could the OoH do to help you avoid arrears in the future?

39

Policy in arrears

40


Appendix 3: Office of Housing Rental Arrears Procedures

NONE ARAf-AXS J FTTtR ' •SFN) |

LOCALAGaCCMEST

1 VACAIt SENT ► A *Pf,Lfc'ATlGs‘ to krr

iAGREEMENT

E HOKESKIT H 'AKINTi

ie-DPIO AVAILS LCnCR SENT

NunrtWCCJVby

nLHCiAl *

AGREEMENT |

JL 1AGREEMENT!

SATISFIED -

........ ,asNi'-ALor ;wranstrsv. |

ORDER FOR POSSESSION hearing;

ADJOURNEDRENEWAL l

or ;i PROCEEDINGS 'i

! ORDER FOR* POSSESSION ----------------- * ACRBIrMENTi agreement satisfiedI— 1

, APPLICATION FOR A

WARRANT

..................... ...... —X ________ _ . . . . __

WARRANT « --------------------WARRANT ---------------► WARRANTLAP$£l> ISSUED ‘ EXECUTED

41

Policy in arrears

42


Appendix 4: Office of Housing Rental Account Statement

NameMailing address

Account No.Property address

D a te D escr ip tio n

R en t P a ya b le

and O th er C h arg es ($)

A m o u n tP a id

a n d O th er C red its (S)

R ece ip tN u m b er B a la n ce ($)

Balance Carried Forward 0.00DR09/03/200C Rent Payment 90.00 41586 90.00CR12/03/200C Rental Charge 85.00 5.00 CR17/03/200C Rent Payment 85.00 3543 90.00CR19/03/200C Rental Charge 85.00 5.00CR20/03/200C Rent Payment 85.00 3549 90.00CR26/03/200C Rental Charge 85.00 5.00CR02/04/2000 Rental Charge 85.00 80.00DR03/04/200C Rent Payment 85.00 4041 5.00CR09/04/2000 Rental Charge 85.00 80.00DR16/04/200C Rental Charge ’ 85.00 165.00DR17/04/2000 Rent Payment 86.50 4536 78.50DR23/04/200C Rental Charge, 86.50 165.00DR30/04/200C Rental Charge 86.50 251.50DR07/05/200C Rental Charge . 86.50 338.00DR14/05/200C Rental Charge 86.50 424.50DR21/05/200C Rental Charge " 86:50 511.00DR28/05/200C Rental Charge 86.50 597.50DR29/05/2000 Rent Payment 50.00 603I 547.50DR04/06/2000 Rental Charge 86.50 634.00DR11/06/2000 Re'ntal Charge 36.50 720.50DR18/06/2000 Rental Charge 86.50 807.00DR19/06/2000 Backdate Rebate Allowance 305.20 501.80DR25/06/2000 Rental Charge 62.90 564.70DR26/06/2000 Rent Payment 165.80 7038 398.90DR02/07/2000 Rental Charge 62.90 461.80DR09/07/2000 Rental Charge 62.90. 524.70DR

r a y m e n t n f y n i r r e n t s h n n ld a lw a y s h e m a d e o n e w e e k il a d v a n c e i f y n n j a y w p p lr ly n r tw n w p p lrs in a d v a n r p i fyou pay fortnightly. Any enquiries concerning this statement should be made at your LOCAL office on telephone number 0 3 . THIS STATEMENT SHOULD BE KEPT FOR YOUR RECORDS.Other Charges: $ 0.00CR Rental Balance: $ 524.70

after charging rent to 15/07/2000Your current rent is calculated as follows :

Weekly rent charged :$200.00Less rebate allowed :$137.10Weekly rebated rent : $62.90

plusService charge : $0.00Parking bays : $0.00

WEEKLY RENT PAYABLE : $62.90 Page No 1

43

Policy in arrears

44


Appendix 5: Office of Housing Arrears Reminder Letter

*

DEPARTMENT NAME>

<date>O ffice Name><address><address><suburb> <post code>

Contact : <init> <surname> Telephone: <tel number> Facsimile: <fax number>

<title> <first initial> <surname><address><suburb> <postcode>

ARREARS REMINDER LETTER

Dear <title> <name> <list all tenants>

Re: Account Number <account no>

I am writing regarding your rental account which is currently in arrears.

Our records show that after charging rent for the week commencing <date the last rent was charged> and crediting your last receipt <number> paid on <date of last receipt>, an amount of $<rental amount> was owing on your account.

Payment of the outstanding amount should be made by <7 days from date letter is printed >. If this is not possible, or you require further clarification about the arrears, it is important that you contact the controlling office>. A rental arrears agreement to repay this amount may be negotiable.

Do not ignore this letter. It is your responsibility to ensure your rental account is up to date. The Department will take further action if your rental arrears remain unpaid.

The Housing Services Officer responsible for your area is <name of officers <first name of officer> can be contacted on telephone number> at the controlling office>. If <first name of officer > is not available you can discuss this matter with another Housing Services Officer.

If you have already paid the amount stated, please ignore this letter.

Yours sincerely

For and on behalf of the Director of Housing

45

Policy in arrears


Appendix 6: Office of Housing Urgent Reminder Notice

DEPARTMENT NAME>

<date>

<title> <first initial> <surname> <address><suburb> <postcode>

<Office Name> <address><address><suburb> <post code>

ContactTelephoneFacsimile

<init><tel number> <fax number>

URGENT REMINDER NOTICE

Dear <title> <name> <list all tenants>

Re: Account Number <account no>

On the <date of last arrears reminder letter> you were sent a letter concerning rental arrears of $<amount of arrears on last letter>. You were requested to pay the outstanding amount by <date tenant was requested to pay amount by>.

Our records indicate that you have failed to pay your rental arrears amount in full. After charging rent for the week commencing <date of last rent period> and crediting your last receipt, number <receipt number>, paid on the <date of last payments your account balance is now $<amount> in arrears.

You are required to pay the rental arrears as a matter of urgency. This amount is to be paid in addition to your rent. Failure to maintain your rental payments represents a breach of your tenancy agreement.

If you are unable to pay the full rental arrears amount by <7 days from date of letter> you are required to contact <name of officer> at the controlling office> to discuss your repayment options. The telephone number for the Prahran Housing Office is <no.>. If <first name of officer> is not available, you can discuss this matter with another Housing Services Officer.

If you have already paid the amount stated, please ignore this letter.

Yours sincerely

<name of issuing officer> <position title><office>

47

Policy in arrears

48


Appendix 7: Proposed Calendar Format for Rent Payment information

Sun Mon Tue Wed Thu Fri Sat1 2 3 4 5 6 7

A m oun t due $57.00Paid $114.00Balance -$57.00 ' $57.00 $57,00 $57.00 $57.00. $57.00 $57.00

8 9 10 ■H 12 13 1‘4A m oun t due $57.00Paid $57.00Balance $0,00 $57:00- $57.00 $57.00 $57:00 $57.00 $57.00

15 16 17 1$ 19 20 i iA m oun t due $57.00Paid $57.00Balance $0.00 $57.00 $57.00 $57.00 $57.00 $57.00 $57.00

22 23 24 25 26 27 28A m o un t due $57.00Paid $57.00Balance $0.00 $57.00 $57.00 $57.00 $57.00 $5700 $57.00

20 30 31A m oun t due $57.00Paid $57.00Balance $0.00 $57.00 $57.00

Minimum balance

should be $57.00 if

paying weekly or $114.00 if

paying fortnightly

v*

49

/

Policy in arrears

f»

ft

50


Appendix 8: Proposed Arrears Repayment Schedule

•" tName:Address:

- Weekly rent payable: $57.00• Arrears amount: $210.00

As of (date): 14/08/00Repayment start date: 21/08/00Weekly repayment amount: $15.00

Total weekly amount payable: $72.00

Date Rent due Arrearsdue Total due Balance Notes

14/08/00 57.00 -$210.00

21/08/00 57.00 15.00 72.00 -$195.00

28/08/00 57.00 15.00 72.00 -$180.00

4/09/00 57.00 15.00 72.00 -$165.00

11/09/00 57.00 15.00 72.00 -$150.00

18/09/00 57.00 15.00 72.00 -$135.00

25/09/00 57.00 15.00 72.00 -$120.00

2/10/00 57.00 15.00 72.00 -$105.00

9/10/00 57.00 15.00 72.00 -$90.00

16/10/00 57.00 15.00 72.00 -$75.00

23/10/00 57.00 15.00 72.00 -$60.00

30/10/00 57.00 15.00 72.00 -$45.00

6/11/00 57.00 15.00 72.00 -$30.00

13/11/00 57.00 15.00 72.00 -$15.00

20/11/00 57.00 15.00 72.00 $0.00

27/11/00 57.00 15.00 72.00 $15.00

4/12/00 57.00 15.00 72.00 $30.00

11/12/00 57.00 15.00 72.00 $45.00

18/12/00 57.00 15.00 72.00 $60.00

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Policy in arrears


ReferencesDickson Swift, V. (2000). Public Housing, Private Lives, An insight into Public Housing Rent Arrearsacross the Loddon Mallee Region. Housing Research and PolicyDevelopment Program, Tenancy Support and Consultancy Services, Loddon Mallee Ltd.

Human Services (1997). Revised Rental Arrears Procedures, Memorandum from Tenancy Services Group to Regional Directors, Housing Managers and Housing Services Managers, March 19, 1997.

Human Services (undated). Housing Services Allocations Policy and Procedures Manual, Change Management and Best Practice Team.

Ministry of Housing and Construction Victoria (1989). Rental Arrears Review Panel—Report to the Minister for Housing and Construction, November 1989.

Ministry of Housing and Construction Victoria (1990). Ministerial Response to the Rental Arrears Review - Incorporating Summary of Report, April 1990.

Office of Housing (1999). Rental Arrears: Version 1.2 March 1999, Department of Human Services.

Office of the Regulator General (1997). Electricity Industry Supply and Sale Code, Effective 1 February 1997, Amended 9 April 1997.

Office of the Regulator General (1998). Benchmark Customer Contract: Melbourne Metropolitan Water and Sewerage Retail Industry, January 1998.

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Documents

Policy in arrears - BSL cataloglibrary.bsl.org.au/jspui/bitstream/1/4502/1/Lyons-M...Policy in arrears Comparing arrears procedures of the Office of Housing with those of publicly-regulated