“See barriers”: how a redress report entered Centrelink’s compliance record

Truth Sequences × FOI Warfare · 14 November 2026

On 7 August 2026, Frank went to the Warrnambool service centre to update his address and see the NDIS staff who shared the building. At 11.04 am, the officer who dealt with him recorded that he was “polite and co-operative”. At 1.13 pm, another officer recorded an attempt to call him about a “breach of restrictions”. Both officers were describing the same visit. Walking through the door was enough for the second entry.

See the page images and read the extracts · Read the official files · Who received the 14 November notice?

Frank is the name the participant uses in his occupational therapy assessment. The officer at the counter was enforcing a Managed Service Plan. The medical history that later appeared in the review of that plan can be traced back six years, to a psychiatrist engaged by Frank’s solicitors. Her report went into a Centrelink pension assessment. On a single page, the assessor named that psychiatrist as a source and recorded two barriers, H02 and H13. Asked to explain its assessment of Frank’s risk of non-compliance, Centrelink entered two words: “see barriers”.

A later letter from Frank’s treating psychiatrist placed schizophrenia in the family history. Centrelink later cited him as verifying it in Frank. Whether software selected a code, calculated a risk rating or influenced the decision to close the counter remains an open question. The distinction matters on 10 December, when agencies acquire a new duty to tell the public how computer programs use personal information in significant decisions.

Warrnambool attendance: Services Australia, LEX 93986, released p. 11. Coding and rationale: Job Capacity Assessment, 27 February 2021, pp. 2–5. Document and legal sources.

Read the entries for yourself

Three rows on a Centrelink screen tell you which door was closed, which number you could ring and which channel stayed open. A different record tells you what the officer said when Frank asked about that number. These are crops from the released pages. Tap an image to enlarge it, or read the wording beneath it. Open the sixteen full source pages in one searchable PDF.

Phone and face-to-face restrictions · What the NDIA recorded · ESAt and JCA barrier codes

Could Frank call as often as he wanted?

The active plan ran from 20 August 2026 to 19 April 2027. It barred face-to-face service and directed telephone calls to Personalised Services. The table gives no numerical call cap. The words “no limitations” belong to the written and digital channel. Nine phone contacts counted in the review on page 4 describe what happened during the period. Nine was never stated there as an allowance.

Three approved channels in the August 2026 plan
Services Australia · LEX 93986 · stamped p. 1
Three approved channels in the August 2026 plan

Phone — Partially Restricted — Approved. Writing — Available — Approved. Face to Face — Restricted — Approved.

The review spells out the phone and writing rules
Services Australia · LEX 93986 · stamped p. 4
The review spells out the phone and writing rules

“Partial Phone - Customer is directed to only call their One Main Contact or Personalised Services Officer.” The next field reads “Available Writing - Customer has no limitations on how to contact the agency through any written or digital channel.”

There is a passage closer to “unlimited telephone calls”. The officer’s narrative for the 9 April 2025 service-centre incident says Frank could call one staff member “each time you want to engage with Centrelink”. The incident date is on stamped page 84. The words are on stamped page 86, the 82nd page of the released PDF. The same narrative records Frank saying his calls went unanswered. The assurance concerned how often he could try the designated contact. It gave him no access to another telephone queue.

What a staff member said about repeat calls
Services Australia · LEX 93986 · stamped p. 86 (PDF p. 82)
What a staff member said about repeat calls

“speak with one staff each time you want to engage with Centrelink.” The next line records “this person on the letter will answer you and help you each time”. The officer also records Frank saying that “every time he tries and calls no one answers”.

The sequence matters. The February 2025 table lists only a partial telephone restriction. On 23 April 2025, a delegate approved the addition of a full face-to-face restriction. The rationale attributes the change to what staff described as escalating behaviour and newly coded incidents. Those are the agency’s characterisations. Its later review also records a direct referral from the FOI team for “excessive correspondence” (LEX 93986, stamped pp. 6, 17 and 24). The two entries describe different stages.

The February 2025 plan lists a telephone restriction
Services Australia · LEX 93986 · stamped p. 26
The February 2025 plan lists a telephone restriction

Phone — Partially Restricted — Approved. The note reads “Contact with PS/PSSO on 1800 312 004, Option 1”.

The 23 April 2025 decision to add full face-to-face restrictions
Services Australia · LEX 93986 · stamped p. 24
The 23 April 2025 decision to add full face-to-face restrictions

The approver records “full F2F and partial phone restrictions”. The rationale describes the previous arrangement as “proactive, partial phone restriction only” and recommends adding a “full F2F restriction”.

One visit, two agencies’ records

On 7 August 2026 the Warrnambool officer recorded Frank’s request to see the co-located NDIS staff, his conduct and the instruction to leave. Read the times on the right. The 11.04 am entry appears below the 1.13 pm entry. Twelve days later an NDIA enquiry attributed his removal to the volume of FOI requests. The linked complaint identifies that account as Frank’s allegation. The NDIA entries show what reached the NDIS file. The approval for the restriction sits in the Services Australia release.

Two entries for the same Warrnambool visit
Services Australia · LEX 93986 · stamped p. 11
Two entries for the same Warrnambool visit

11.04 am — “wanted to see NDIS (who is co-located with WMB SC)” and “was polite and co-operative.” 1.13 pm — “Customers attendance at Service Centre and breach of restrictions.”

How the NDIS enquiry described the restriction
NDIA · FOI 26/27-0675 Part 3 · stamped p. 197
How the NDIS enquiry described the restriction

“PPT was removed from Services Australia due to being on restricted Service Australia status, due to too many FOI requests.”

Where the NDIS complaint attributes the account to the participant
NDIA · FOI 26/27-0675 Part 3 · stamped p. 199
Where the NDIS complaint attributes the account to the participant

“Participant alleges the restriction relates to the volume of FOI requests and complaints made to Services Australia.”

Where H02, H13 and “see barriers” actually appear

Look for ESAt, short for Employment Services Assessment, on the Warwick and Ararat reports. Mirrabooka and Huonville are Job Capacity Assessments (JCAs). The 2019 barrier list already records anxiety and a mood disorder. Neither H02 nor H13 appears among its seven entries.

The seven barriers before H02 and H13 appeared
Centrelink Warwick · ESAt · 14 August 2019 · p. 3
The seven barriers before H02 and H13 appeared

“Physical limitations restricting type of work (V03)”, “Transport issues (G02)”, “Anxiety Disorder (ANX)”, “Chronic pain (H12)”, “Endurance limitations (H07)”, “Episodic fluctuations (H04)” and “Mood Disorder (MOD)”.

In 2021 the Mirrabooka assessor put Professor Dennerstein in the “Treating Health Professional” field. The date attached to that entry is 28 December 2020. Her report to the solicitors was dated 11 October 2020. The two crops below come from the same assessment page. Turn to page 5 and the assessor tells the reader where to look for the reason for the compliance rating.

How the reference table identifies Professor Dennerstein
Centrelink Mirrabooka · JCA · 27 February 2021 · p. 3
How the reference table identifies Professor Dennerstein

Reference ID 4629952. Dated 28/12/2020. Source “Treating Health Professional”. Author “PROF L Dennerstein”. Field “Psychiatrist”.

The two barrier codes on the same page
Centrelink Mirrabooka · JCA · 27 February 2021 · p. 3
The two barrier codes on the same page

“Psychological/psychiatric condition (H02)” and “Substance abuse (H13)” appear under “Barriers to be addressed”.

The rationale recorded below the moderate compliance rating
Centrelink Mirrabooka · JCA · 27 February 2021 · p. 5
The rationale recorded below the moderate compliance rating

“The risk of non-compliance is rated as Moderate”. Rationale — “see barriers”.

Ararat’s 2023 ESAt repeats both codes and the same two-word rationale. There are four barriers on this page. The form does not tell us which one carried weight or who, if anyone, later acted on it.

Both codes recur in the employment assessment
Centrelink Ararat · ESAt · 2 August 2023 · p. 3
Both codes recur in the employment assessment

“Psychological/psychiatric condition (H02)”, “Substance abuse (H13)”, “No or limited job seeking skills (V06)” and “ADD/ADHD (ADD)”.

Ararat repeats the compliance rationale
Centrelink Ararat · ESAt · 2 August 2023 · p. 5
Ararat repeats the compliance rationale

“The risk of non-compliance is rated as Moderate”. Rationale — “see barriers”.

Huonville supplies the check on any claim that both flags stayed active indefinitely. In 2024, page 4 puts H02 under “Currently Addressed Barriers”. H13 is absent from the list. Page 5 raises the risk rating to High, specifies 52 weeks and separately identifies PPM. None of these fields identifies a computer rule that imposed the office restriction or suspended a payment.

The heading changes to Currently Addressed Barriers
Centrelink Huonville · JCA · 5 December 2024 · p. 4
The heading changes to Currently Addressed Barriers

“Currently Addressed Barriers” — “Psychological/psychiatric condition (H02)”.

The 52-week rating and the separate PPM indicator
Centrelink Huonville · JCA · 5 December 2024 · p. 5
The 52-week rating and the separate PPM indicator

“The risk of non-compliance is rated as High with a review period of 52 weeks.” The next field lists “PPM - Psychiatric problems or mental illness”.

2019 gives us a before picture

On 14 August 2019, an occupational therapist at Warwick completed an Employment Services Assessment (ESAt) from the file after attempts to reach Frank were unsuccessful. The medical evidence described osteoarthritis as permanent and anxiety and depression as temporary, with expected end dates of 8 November 2019. The barrier list included anxiety (ANX), mood disorder (MOD), chronic pain (H12) and transport issues (G02). Neither H02 nor H13 appears in that list. The assessor recommended a temporary exemption and a deferred employment-service referral.

That assessment supplies a dated comparison. By 2019 the agency already had a vocabulary for mental health and a way to record when a condition was expected to end. The psychiatric and substance-use categories at the centre of this investigation first appear together in the February 2021 assessment examined here.

Warwick ESAt, 14 August 2019, pp. 1–5.

A report for a solicitor becomes a report from a “Treating Health Professional”

Professor Lorraine Dennerstein interviewed Frank by Zoom for two hours on 8 October 2020. Her report of 11 October was addressed to Maurice Blackburn. Among the documents she received were Frank’s draft National Redress Scheme application and a report to Nazareth Boys’ House dated 13 February 1974. Her brief covered the effects of childhood abuse on education and work, the prospects for treatment and its likely cost.

Dennerstein gave an opinion that Frank met criteria for PTSD and schizophrenia. She also set out an alternative explanation for some symptoms, described substance use disorder as being in partial remission, and recommended assessment by a treating psychiatrist. Her answer to the solicitor said Frank was receiving no treatment for his psychiatric disorders at that time. Her medication history nevertheless recorded Duromine. Calling him simply “unmedicated” would erase a distinction the psychiatrist herself considered relevant.

Now turn to the Mirrabooka Job Capacity Assessment (JCA). Centrelink interviewed Frank by telephone on 18 February 2021 for a Disability Support Pension claim and submitted its report on 27 February. Page 2 names Dennerstein and the date of her report, alongside evidence from his GP. Page 3 identifies Dennerstein as author of reference 4629952, dates that reference 28 December 2020, assigns it a file location and classifies its source as “Treating Health Professional”. The same assessment records Frank saying he had seen the psychiatrist once for medicolegal purposes. Someone reading the source field alone would miss who commissioned the opinion and why.

Immediately below that reference are the fields “Psychological/psychiatric condition (H02)” and “Substance abuse (H13)”. The narrative preserves the qualification about partial remission. The H13 label has nowhere in its wording to put that qualification. Page 4 lists substance-use counselling (H60), psychiatric treatment (P54) and torture/trauma counselling (P53) as interventions. Page 5 assigns a Moderate risk of non-compliance and refers the reader back to the barriers. This is a documented link between a clinical source, a coded assessment and a compliance judgement. The report gives no weight for either code and identifies no calculation.

Dennerstein, 11 October 2020, PDF pp. 1, 3, 10–13. Mirrabooka JCA, pp. 1–5. The October report date and December reference date are distinct entries.

Ararat repeats the codes. Huonville changes them.

APM Employment Services referred Frank for direct registration with Disability Employment Services in July 2023. A Centrelink social worker at Ararat completed a file assessment on 31 July, submitted on 2 August. It again names Dennerstein, dates her report and uses the earlier account of Frank’s symptoms and treatment. It adds ADHD evidence from a GP certificate dated 1 June 2022. The formal references box says “No references were recorded”, although the narrative names both clinicians. The assessment records no fresh participant interview.

What changed in the assessment fields
AssessmentBarriers recordedWork capacity and compliance
Aug 2019
Warwick
V03, G02, ANX, H12, H07, H04 and MOD.Baseline 15–22 hours a week. Temporary capacity 0–7 until 16 January 2020. The “Low” entry concerns personal factors affecting work.
Feb 2021
Mirrabooka
H02 and H13 listed as barriers to address. No impairment rating recorded.Baseline 8–14 hours, 15–22 with intervention. Temporary capacity 0–7 until 18 August 2021. Non-compliance risk Moderate.
Aug 2023
Ararat
H02 and H13 recur. V06 is limited job-seeking skills. ADD is the report’s code for ADD/ADHD.Baseline 8–14 hours, 15–22 with intervention. Non-compliance risk Moderate. Rationale again reads “see barriers”.
Dec 2024
Huonville
H02 appears under “Currently Addressed Barriers”. H13 is absent from the list. PPM appears separately as a psychiatric vulnerability indicator.Baseline and with-intervention capacity both 0–7 hours. Table 5 mental health impairment rated 20 points. Non-compliance risk High, with a 52-week review period.

The risk rating went up in the assessment that omitted H13. That matters to anyone proposing that an active substance flag dictated the outcome. “Permanent” appears in the 2021 medical-condition field. The assessor still recorded that treatment had yet to stabilise the condition for pension assessment purposes. Neither entry assigns a duration to H13. Its omission in 2024 leaves open what an older system retained, who could see it and whether anyone used it again.

The public operating instructions explain why these entries matter. The Social Security Guide says assessors can draw on earlier medical and participation history. Barriers and interventions inform eligibility for Commonwealth-funded employment services. The ESAt goes to the employment provider and can inform participation requirements. Later Inclusive Employment Australia guidelines describe a Capability Management Tool on the Job Plan screen that brings together ESAt information, capability assessments and information participants report themselves. That is a documented route from assessment to a provider’s screen. The archive has no transaction showing that H13 produced a demerit, payment suspension or refusal of service for Frank.

Ararat ESAt, pp. 1–5. Huonville JCA, pp. 2–6. Social Security Guide on ESAts · Barriers and interventions · Provider guidelines, §5.4.

Whose diagnosis was it?

Dr Manish Chauhan’s 22 November 2024 letter supported Frank’s pension application. He described treating Frank since August, identified schizotypal disorder and documented difficulties with social contact, work and daily living. His letter gives the family history in these words: “a history of schizophrenia in his mother”.

Page 2 of the Huonville JCA, submitted on 5 December, says Chauhan’s letter verifies a “long term diagnosis of schizotypal disorder, schizophrenia, PTSD, ADHD and Autism” in Frank. The reference table dates the source 22 November and gives it ID 5262919. The prose above it dates the letter “2/11/24”. The original letter resolves the date and identifies whose history Chauhan was describing. Dennerstein had offered a separate opinion in 2020. Attributing that opinion to the treating psychiatrist in 2024 gives a reader the impression of independent confirmation that the cited letter does not supply.

Chauhan’s later letter, dated 10 September 2025, lists schizotypal disorder, PTSD, ADHD and level 2 autism among Frank’s diagnoses. Schizophrenia is absent from that list. Frank expressly disputed the label in writing in July 2026. The documentary question can be answered without settling a clinical diagnosis: the 2024 assessment misstates what its cited source says about Frank.

Chauhan, 22 November 2024, p. 1 and 10 September 2025, p. 2. Huonville JCA, pp. 2–3. NDIA FOI 26/27-0675, Part 3, released pp. 237–238.

The NDIS correspondence identifies a second route

For the 6 December 2025 Fly2Health functional capacity assessment, Frank took part in a telehealth interview on 28 November. The report cites Chauhan’s September letter. Its account of everyday function is concrete: Frank told the assessor about living in a caravan without electricity or running water. The executive summary records his use of AI to help process language. His self-reported WHODAS disability score was 155/180, reported as 86%. What assistance would let him understand correspondence, maintain hygiene or manage appointments? That was the purpose of this assessment.

Occupational therapist Michael Lewis saw Frank in Norwood on 27 April 2026 and observed the conditions in his car. His Individualised Living Options report, dated 23 June, recorded a WHODAS score of 71.86%, which he described as severe limitation. He listed both Fly2Health and Dennerstein under reports reviewed. On page 2 he listed schizophrenia among conditions drawn from collateral material. Page 16 expressly attributed a substance-use history to the 2020 report. Neither WHODAS score establishes a diagnosis or assigns either Centrelink barrier code.

On 16 July Frank asked for the schizophrenia entry to be amended. On 22 July, Ability Action Australia team leader Leann Butler identified Dennerstein’s October 2020 report as the source and said Lewis had not been provided with Chauhan’s report. She offered a review on receipt. Frank replied that he had sent it previously and that his support coordinator could resend it. This exchange survives in the NDIA disclosure. A clinician in one service had cited the newer letter. A clinician in the next service had the first clinician’s assessment and the older medicolegal opinion. The two accounts differ on delivery. An offer to review is the last step verified here.

That correspondence explains how a six-year-old opinion entered a housing-support recommendation even though the occupational therapist had assessed Frank in person. The provider identifies the document it consulted. Nothing in that exchange shows Centrelink transmitting H02 or H13 to the NDIA, or either code deciding Frank’s housing funding.

Fly2Health, 6 December 2025, pp. 1–3, 10–13. Lewis, 23 June 2026, pp. 2, 4, 16, 31–32. NDIA FOI 26/27-0675, Part 3, released pp. 218–223 and 237–238. The July emails are reproduced in the agency release.

What actually closed the counter

Services Australia’s own Managed Service Plan (MSP) provides the answer to what the Warrnambool staff enforced. LEX 93986 records a proactive plan starting on 20 February 2025 that restricted telephone contact. The reactive plan starting on 23 April shows a face-to-face restriction as well. An entry dated 22 August 2025 says staff completed the update to replicate restrictions in Medicare. This is an identifiable transfer between service records. It says what was replicated: the contact restriction.

At 10.43 am on 6 August 2026, Personalised Services had already recommended another eight months of full face-to-face and partial telephone restrictions. Frank’s “polite and co-operative” visit came the next day. The time stamps rule out that visit as the origin of the recommendation. They also show its practical reach. The service centre manager told Frank he could not stay in the building, including to see the co-located NDIS staff, and directed him to the telephone.

The mandatory social-work consultation dated 7 August provides a narrower, demonstrable link between medical classification and the access decision. The reviewer cited what they called an ESAt completed on 3 January 2025 and repeated the claim that Chauhan verified schizophrenia among Frank’s diagnoses. The reviewer also cited contact history and staff concerns about emails and supported the extension. The January assessment itself was not located. The December JCA is a separate dated record. The review summary elsewhere says there were no participation requirements or compliance issues, gives the last ESAt/JCA as “None”, and still lists a psychiatric vulnerability. Those entries cannot all be read as one consistent account of the assessment history.

On 11 August a weekly panel endorsed the extension. The agency’s rationale described email volume, correspondence staff considered threatening, and the prospect of the conduct recurring. It also recorded a period in which the emails ceased. These are the agency’s stated reasons. The approved plan ran from 20 August 2026 to 19 April 2027. Face-to-face service was withdrawn, telephone access was confined to Personalised Services, and writing remained available. The review template contains an instruction to paste a macro. The release identifies human recommendations and approval. It does not show that the macro calculated risk, populated the medical history or selected the outcome.

The NDIA recorded the incident differently. On 19 August, enquiry 37637709, staff alias CFR162, attributed the restriction to “too many FOI requests”. The related complaint, 37617802, identifies that explanation as Frank’s allegation and refers back to the first case. Its next step was referral for review. The same-day contact alert characterised some emails as “non sensical” and said Frank appeared to use AI. The December OT report gives a reason he used it: help with language and information processing. The records show how two services described the same means of communication. The NDIA note cannot establish the motive of the Services Australia delegate.

LEX 93986, released pp. 1, 3–5, 11, 16, 18 and 26. NDIA FOI 26/27-0675, Part 3, released pp. 197–199. Fly2Health, p. 2.

What changes on 10 December 2026

The most important line for an old file is in item 89 of Schedule 1 to the Privacy and Other Legislation Amendment Act 2024. The new privacy-policy duty applies to decisions made after commencement. The computer arrangement, the use of the information and the creation or acquisition of that information can all predate commencement. A report written in 2020 can therefore matter to a covered decision made after 10 December 2026. The August 2026 extension does not become a fresh decision merely because it runs until April. A later decision to renew or vary it would have to be assessed on its own facts.

APP 1.7 sets three conditions. The entity must have arranged for a program to decide something or do a step substantially and directly related to the decision. The program must use personal information about the individual in doing so. The decision must be one that could reasonably be expected to significantly affect the individual’s rights or interests. An electronic file proves storage. A rule that uses a health-related field to recommend withdrawing counter access, with staff regularly relying on its output, would present a very different case.

APP 1.8 specifies what the public must be told. The privacy policy must describe the kinds of personal information used, which kinds of decisions the program makes alone, and which kinds it materially helps a person make in the way APP 1.7 describes. APP 1.9 includes refusing or failing to decide or take the relevant step, recognises favourable and adverse effects, and gives access to a significant service or support as an example. The statutory obligation concerns decision categories. It gives Frank no automatic entitlement to a personal audit log, a copy of source code or a fresh clinical examination.

On 30 September 2026, the Office of the Australian Information Commissioner (OAIC) published its final guidance and a supplement for government agencies. It asks what staff actually do with a computer’s recommendation: how heavily they rely on it, whether they can and do override it, what they can see of its reasoning, and where it enters the workflow. An officer’s signature answers who approved the decision. It leaves open how the options reached that officer. The government supplement also points agencies to their separate obligation to publish operational information under the Freedom of Information Act.

Services Australia’s existing privacy policy acknowledges that automated tools may assist with payments and services. That statement does not identify a rule reading H02, H13 or PPM in an MSP review. If an agency uses health information in a covered class of decisions after commencement, its policy must describe that use at the level APP 1.8 requires. Parliament expressly added APP 1.7 to the Privacy Act’s section 13K enforcement framework. The public can test a policy against actual practice. The question of whether the assessment itself accurately attributes a medical opinion already falls within the terrain of APP 10 on information quality and APP 13 on correction.

Amending Act, s. 2 and Sch. 1 Pt 15, items 87–89 · OAIC release, 30 September · APP 1 Guidelines, especially ¶¶1.47–1.54 and 1.67–1.76 · Government supplement · Services Australia privacy policy · APPs 10 and 13.

Who received the 14 November notice, and who answered?

At 8.51 pm AEDT on Saturday 14 November 2026, Frank sent a notice naming both barrier codes. Eight addresses appear in the To field. They belong to APM Employment Services (Compliments and Complaints, and Privacy), the Department of Employment and Workplace Relations (National Customer Service Line and Freedom of Information), Services Australia (Freedom of Information), and the offices of Senators Malcolm Roberts, David Pocock and Jordon Steele-John. The salutation also mentions allied health representatives. No separate allied health address appears in the recipient field. The message carried no attachment.

Frank asked how the recipients would disclose the use of personal information in automated decisions ahead of 10 December. He alleged the codes had been used to suspend payments and restrict access. The Mirrabooka assessment supports one part of that account directly. Its compliance field refers back to the barriers. The notice supplies no decision log showing that either code triggered a suspension.

DEWR’s National Customer Service Line and the offices of Senators Pocock and Steele-John returned automatic acknowledgements. By the time of publication, the correspondence checked contained no substantive answer to the coding question and no reply to this notice from Senator Roberts’ office. A message addressed to a senator’s office is evidence of correspondence. Entry on the parliamentary record would require a further act.

The exchange began before Saturday night. On 11 November DEWR’s Information Law Team distinguished two copies of complaint CAS-2634696-N6Q0V3, sent on to its customer service line, from three FOI requests received on 6 and 10 November and a separate APP 12 access request. On 12 November DEWR advised Frank that it had transferred one request, LEX 2715, to Services Australia. At 7.04 pm on 14 November he followed up with Services Australia FOI for its reference and expected decision date. LEX 2715 is a separate matter from the released Services Australia file, LEX 93986.

8.01–8.08 pm. Frank sent a sequence of compensation and compliance-review emails. The first attempt drew delivery failures for a short Services Australia FOI address and DEWR’s general enquiries address. He re-addressed the correspondence to Services Australia’s full FOI address and DEWR’s National Customer Service Line. The 8.08 pm version also named Senator Roberts’ office, NDIA Feedback, the Commonwealth Ombudsman, Bendigo Bank’s feedback and privacy contacts, the Australian Financial Complaints Authority and South Australian fines authorities. The financial company AMP was on that distribution. The employment provider APM appears on the later notices.

8.39 pm. Frank wrote directly to DEWR’s Information Law Team and National Customer Service Line and to APM’s complaints and privacy offices. He sought the file for CAS-2634696-N6Q0V3 and the evidence behind disputed demerits, alleged suspensions and a $100 telephone reimbursement. Twelve minutes later he sent the eight-address H02/H13 notice.

In a separate 7.04 pm media follow-up, Frank responded to an unattended editorial inbox by writing to the contact nominated for The Age at Nine. His question there concerned a $2,840.61 Rent Assistance entry in LEX 93986. It was a different question put to a different recipient.

Correspondence checked against the two Sent folders, incoming replies and delivery-status notices. Times are Australian Eastern Daylight Time. The 8.51 pm message was headed “URGENT: Pre-10 Dec Privacy Policy Audit, Backend Codes (H02/H13), and Defective Adjudications”.

Four records would settle the remaining questions

  1. The field history for H02, H13 and PPM. For each entry, which assessor or program created it, from what source, on what date? Which values were copied, reviewed, marked addressed or retired? That would distinguish retention of a historical report from an active flag.
  2. The rules and the recorded result for each risk rating. Which fields, if any, populated Moderate in 2021 and 2023 and High in 2024? Could the assessor change the result? An event log or decision worksheet would show whether the person, the program or both supplied the rating.
  3. The 3 January 2025 assessment and the August 2026 panel material. Which assessment did the social worker actually read? What clinical source, alerts or recommendations did the panel see, and what reasons did the delegate record for accepting them? That is how to test whether a field influenced the restriction.
  4. The record of correction and onward notification. Did Ability Action Australia receive Chauhan’s letter after 22 July? Was a revised report issued, which version did the NDIA use, and did anyone correct Centrelink’s attribution? Where APP 13 applies, a person refused a correction can ask to have a statement of disagreement associated with the information.

LEX 93986 explains why the code history was outside the final scope of the release. Frank’s original request sought capacity reports and profiling metadata. The scope agreed in October narrowed to the restriction, the reasons for it and the incident records relied on. On 3 November Services Australia acknowledged a deemed refusal and released three partly redacted documents administratively. Missing rule tables are exactly that: missing evidence.

Frank went to a counter for an address change. By then a solicitor’s psychiatric report had been filed under a treating professional, an employment assessment had turned partial remission into a three-character barrier, and a restriction reviewer had credited a psychiatrist with a diagnosis his letter placed in someone else’s history. On 10 December, the public gains a more precise question to put to the agency: when a record like this reaches the next decision-maker, what has the computer already done with it?

Read the official documents

Start with page 3 of the Mirrabooka report. It names Professor Dennerstein as the source and lists H02 and H13. Page 5 gives the assessor’s reason for the compliance rating. Then turn to page 11 of LEX 93986 for the two Warrnambool entries.

These reading copies reproduce the agency documents. The four assessments and the statement of reasons are reproduced in full by page count. The entire Services Australia case-note file contains 148 PDF pages and ends with the agency stamp “Page 153 of 153”. The shorter case-note and NDIA extracts retain the agencies’ original page numbers. The publishers have masked personal identifiers and contact details in these copies. Open the exhibit folder.

How to check the record

The case evidence comes from primary documents in two Google Drive archives. Duplicate copies and quoted email chains are counted once. Page numbers for the FOI releases follow the agency’s printed numbering. Dennerstein references use PDF page positions. A comment reproduced in an agency release is attributed to its author.

  • Employment and pension assessments. Centrelink Warwick, ESAt submitted 14 August 2019, pp. 2–6. Centrelink Mirrabooka, JCA submitted 27 February 2021, pp. 2–5, evidence ref. 4629952. Centrelink Ararat, ESAt submitted 2 August 2023, pp. 1–5. Centrelink Huonville, JCA submitted 5 December 2024, pp. 2–6, evidence ref. 5262919.
  • Clinical and occupational evidence. Professor Lorraine Dennerstein’s report to Maurice Blackburn, 11 October 2020. Dr Manish Chauhan’s DSP letter, 22 November 2024, and clinical letter, 10 September 2025. Fly2Health Functional Capacity Assessment, 6 December 2025. Ability Action Australia, Michael Lewis, Individualised Living Options Recommendation Report, 23 June 2026.
  • Services Australia. LEX 93986, Documents – FINAL, particularly pp. 1, 3–5, 11, 16, 18 and 26. Statement of Reasons, 3 November 2026, pp. 1–2 and 4, for release procedure and scope.
  • NDIA. FOI 26/27-0675, Decision – Documents, Part 3, pp. 197–199 for the two August entries, pp. 218–223 for the July provider correspondence and pp. 237–238 for Frank’s amendment request.

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