IN-CONFIDENCE
OIA assessment
Date:
8 March 2023
Security Level:  IN-CONFIDENCE
To:
Official and Parliamentary Information Team
Official Information Act Request: O'Riley, Lance (FYI
Website)  -  Information relating to 52-week income
summary and overpayments including internal processes,
data pulls for last 15 years broken down by region, age
range, benefit type and ethnicity. [CE]
The Ministry of Social Development has received a request for information under
the Official Information Act 1982. Your business unit holds information relevant
to the request. The request is for:
1a:  All Internal correspondence including emails regarding requesting a 52
Week income summary
1b:  Official processes and guidelines for requesting a 52 week income summary
1c:  All internal documentation about why a 52 week income summary should
be requested
2a: What is the internal process for calculating the amount of an overpayment
2b:  What circumstances can an overpayment be written off when it results from
a genuine oversight or error from a client rather than an intentional act.
For Questions 3a onwards please provide this data by month for the last 15 years
and broken down by region, age range, benefit type and ethnicity.
(Age range can be interpreted anyway you chose, so long as it is reasonable and
in line with commonly used age brackets)
3a: The number of times a 52 week income summary has been requested
3b: The number of times a 52 week income summary has resulted in an
underpayment
3c:  The number of times a 52 week income summary has resulted in an
overpayment
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IN-CONFIDENCE
3d: How many times was a 52 week income summary requested when a client
was self-disclosing a possible overpayment.
4a: For all underpayments, what is the average amount that has been underpaid
4b: For all overpayments, what is the average amount that has been overpaid
4c: For all overpayments, how was this amount calculated
4d: For all overpayments, how many have had a review of decision requested
4e: For all review of decisions, how many resulted in the overpayment amount
being found to be an error
4f:  For all overpayments being found to be an error, what was the average
amount that was calculated incorrectly.
4g: For all overpayments being found to be an error, what is the reason for the
error
4h:  For all overpayments being found to be an error, how many were written
off as a result of said error
5a: For all overpayments, how many were found to be intentional and/or
fraudulent
5b: For all overpayments, how many were found to be non-intentional
5c:  For all overpayments found to be non-intentional, how many were written
off under section 208
5d: For all overpayments found to be non-intentional, and were later repaid,
why were these not written off as per Section 208
6a:  For interpreting the criteria noted in Section 208, please provide internal
documentation discussing this, including emails and policy guidelines.
File ref:
//OIA//06/22-15650
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IN-CONFIDENCE
Recommended actions
It is recommended that you:
1
Note the contents of this OIA assessment.
2
Sign the attached letter to Lance O’Riley.
Note that the response letter will be published on the Ministry’s website.
Insert DATE
Bridget Saunders
Date
Manager Issue Resolution
Service Delivery
7/3/23
p.p.
Sarah Quigan
Date
Manager
Official Information
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IN-CONFIDENCE
Due Date
1  The response to the requestor was initially due on 8 February 2023. The time required
to make a decision has been extended. A decision is now due on or before 8 March
2023.
Background
2
This is the requestor’s second request for official information from the Ministry.
3
The first OIA request from the Ministry was regarding Emergency Housing:
3.1  O'Riley, Lance (Individual - FYI Website) - Request to know the numbers of
people who have been placed in emergency housing in the wider Wellington city
area since 2010 [CE] (qA687107)
4
The requestor has had numerous OIA requests to other agencies.
5
The requestor has had his comments published and has been quoted in news articles:
5.1  https://www.nzherald.co.nz/nz/anti-vaccine-billboard-near-middlemore-
hospital-removed-after-raft-of-
complaints/3J7OXHZ4VQLWXXBKSTOQX3VURQ/
6  The requestor may be a previous client of the Ministry who was deemed to receive an
overpayment, though this cannot be confirmed as the requestor has not provided further
identifying details.
Suggested Response
7
Please see the Appendix at the bottom of this report for a list of each question and
whether it is refused or granted, for reference.
8
The questions have been answered in the following categories: policy and guidelines
for requesting an income summary, overpayments, underpayments  and the debt
write-off criteria.
9
The People Group advised that there are no modules specific to the request in the
Learning Management System.
10  Requesting an income summary
10.1 Question 1a is refused under section 18(f) of the Act as it would require
substantial manual collation to locate and assess all correspondence in scope of
this request.
10.1.1
I have considered the Ministry’s obligations under section 18A and
18B of the Act, and have determined that either consulting with the
requestor, extending for a further  period, or fixing a charge would  not
remove the reason for refusal.
10.2 Questions 1b and 1c have been interpreted as documents specifically regarding
income summaries. As such, these questions  are  answered with links to the
public MAP website and copies of the following Doogle pages:
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IN-CONFIDENCE

10.2.1
Income and Asset Details
10.2.2
Review of Annual Income
10.2.3
Review of Annual Income – client groups
10.3  Question 3a is refused under section 18(f) of the Act as it would require
substantial manual collation to manually review individual case files to find
information about how many times a 52-week income summary is requested, as
this information is not centrally recorded.
10.3.1
I have considered the Ministry’s obligations under section 18A and
18B of the Act, and have determined that either consulting with the
requestor, extending for a further period, or fixing a charge would not
remove the reason for refusal.
11  Overpayments
11.1 Questions 2a and 4c are answered by providing an explanation of how
overpayments are calculated, and links to a relevant public MAP page and
legislation.
11.2 Questions 3c, 3d, 4b. 4f, 4g, 4h, 5a, 5b, 5c, 5d are refused under section 18(f)
of the Act as it would require substantial manual collation to manually review
individual case files to find information about the amount overpaid, the cause of
the overpayment itself, whether a debt write-off was the result of an error, and
how many overpayments were or were not written off under Section 208, as this
information is not centrally recorded.
11.2.1
I have considered the Ministry’s obligations under section 18A and
18B of the Act, and have determined that either consulting with the
requestor, extending for a further period, or fixing a charge would  not
remove the reason for refusal.
11.3 Question 4d is responded to with five data tables as follows:

11.3.1
Table 1: The number of Review of Decisions lodged with the
Benefit Review Committee where action reviewed relates to
Overpayments from 1 July 2006 to 30 June 2022, by financial year ending
June and action reviewed
11.3.2
Table 2: The number of Reviews of Decisions received by the Ministry
for an overpayment of financial assistance for the period 2007 to 2022,
broken down by age group and financial year

11.3.3
Table 3: The number of Reviews of Decisions received by the Ministry
for an overpayment of financial assistance for the period 2007 to 2022,
broken down by benefit type and financial year
11.3.4
Table 4: The number of Reviews of Decisions received by the Ministry
for an overpayment of financial assistance for the period 2007 to 2022,
broken down by reported ethnicity and financial year
11.3.5
Table 5a - 5g: The number of Review of Decisions lodged with the
Benefit Review Committee where action reviewed relates to Overpayments
from 1 July 2008 to 30 June 2022, by financial year ending June, and total
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IN-CONFIDENCE

response ethnicity

11.4 Question 4e is refused under section 18(f) of the Act as it would require
substantial manual collation to manually review individual case files to find
information about whether a ROD received because of an overpayment was found
to be an error, as this information is not centrally recorded.
11.4.1
I have considered the Ministry’s obligations under section 18A and
18B of the Act, and have determined that either consulting with the
requestor, extending for a further period, or fixing a charge would  not
remove the reason for refusal.
12  Underpayments
12.1 Questions 3b and 4a are refused under section 18(f) of the Act as it would require
substantial manual collation to manually review individual case files to find
information  about  the average amount underpaid and the reason for an
underpayment, as this information is not centrally recorded.
12.1.1
I have considered the Ministry’s obligations under section 18A and
18B of the Act, and have determined that either consulting with the
requestor, extending for a further period, or fixing a charge would  not
remove the reason for refusal.
13  Debt write-off criteria
13.1 Question 2b is answered by providing a link to public MAP about debt write-off
criteria, which includes information about overpayments established because of
client error.
13.2 Question 6a is answered in part:
13.3 The requestor is provided with policy guidelines including links to public MAP, and
an excerpt of the following Doogle pages, as the rest of the document is outside
of the scope of the request.
13.3.1
What’s New for December 2021 – Debt write off under regulation 208
13.4 The requestor for internal correspondence about Section 208 is refused under
section 18(f) of the Act as it would require substantial manual collation to locate
and assess all correspondence in scope of this request.
13.4.1
I have considered the Ministry’s obligations under section 18A and
18B of the Act, and  have determined that either consulting with the
requestor, extending for a further period, or fixing a charge would  not
remove the reason for refusal.

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IN-CONFIDENCE

Internal consultations

Business unit
FYI/consulted  Comments worth noting
Media
FYI

Legal
N/A

CE’s office
N/A

Client Advocacy and
Consulted
Provided information regarding Reviews of
Review
Decision.
Business Intelligence
Consulted
Provided data for question 4d and
confirmed that they cannot provide data
for other questions refused under section
18(f).
Service Delivery
Consulted
Provided advice on approach.
Client Service Support
Consulted
Provided advice on approach – confirmed
Doogle and MAP contain guidance.
Operational Policy
Consulted
Provided advice on approach – confirmed
Doogle and MAP contain guidance, as well
as the legislation that supports income
summaries, calculations etc
People Group
Consulted
Advised that there are no specific modules
regarding the request in the Learning
Management System.

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IN-CONFIDENCE

Table 1: Document table: information relevant to the request
Document type
(e.g., Cabinet
Release or
Were consultations
No.
Date
REP number
withhold
created
(if available)
paper, report,
Title
Reason & relevant context
necessary and what
MaES advice
aide-memoire,
[include page
was the result?
email etc.)
numbers]
All internal correspondence

N/A
N/A
N/A
regarding requesting a 52-week
Refuse
Section 18(f)
No
Refuse under section
income summary
18(f)
Processes and guidelines for
requesting a 52-week income
summary:
•
Income and Asset Details
SD

N/A
N/A
N/A
•
Review of Annual Income  Grant in full
In response to request
CSD
Grant in full
•
Review of Annual Income
OpPol
– client groups
Links to MAP

N/A
N/A
N/A
The number of times a 52-week
income summary is requested
Refuse
Section 18(f)
BI
Refuse under section
18(f)
Process for determining an
SD

N/A
N/A
N/A
overpayment:
MAP links
Grant in full
In response to request
CSD
Grant in full
Contextual explanation
OpPol
The number of 52-week income

N/A
N/A
N/A
summaries requested by the
Refuse
Section 18(f)
BI
Refuse under section
Ministry over the last 15 years
18(f)
Breakdown of overpayments over
the last 15 years including:
-
number of times a 52-
week income summary
has resulted in an
overpayment
-
number of times a 52-
week income summary
has been requested
when a client discloses a

N/A
N/A
N/A
possible overpayment
-
average amount
Refuse
Section 18(f)
BI
Refuse under section
18(f)
overpaid
-
average amount
calculated incorrectly
-
error reason for all
overpayments
-
how many
overpayments are
written off for an error?
-
how many
overpayments are
The Aurora Centre, 56 The Terrace, PO Box 1556, Wel ington – Telephone 04-916 3300 – Facsimile 04-918 0099

IN-CONFIDENCE

intentional and/or
fraudulent?
-
how many
overpayments were
nonintentional?
-
How many non-
intentional
overpayments were
written off under
regulation 208
-
Why were all non-
intentional
overpayments repaid by
the client not written off
under regulation 208?

N/A
N/A
N/A
Overpayment ROD

Data about how many RODs
received because of an

N/A
N/A
N/A
overpayment resulted in the
Refuse
Section 18(f)
BI
Refuse under section
overpayment being found to be an
CAR
18(f)
error
Breakdown of underpayments over
the last 15 years including:
-
The number of times a

N/A
N/A
N/A
52-week income
summary has resulted in Refuse
Section 18(f)
BI
Refuse under section
18(f)
an underpayment
-
Average amount
underpaid
Circumstances that an
SD

N/A
N/A
N/A
overpayment can be written off

Grant in full
In response to request
CSD
Grant in full
MAP link
OpPol
Internal documentation about
interpreting regulation 208

MAP and legislation links
SD

N/A
N/A
N/A

Excerpt of the following page:
Grant in part
Out of scope information not
provided
CSD
Grant in part
-
• What’s New for
OpPol
December 2021 – Debt
write off under
regulation 208
SD

N/A
N/A
N/A
All internal correspondence about
Refuse under section
interpreting regulation 208
Refuse
Section 18(f)
CSD
OpPol
18(f)

Please create further rows, if needed.

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IN-CONFIDENCE

Table 2: Risk Assessment
-  Complete the section in green, using the business risk framework. Use a separate line for each document. Think about the story
which the information tells. Risks in releasing or withholding information often arise where:
  It would have a negative impact on public trust and confidence in the Minister or Ministry.
  We have not done what we said we would.
  It would cause confusion or be misused.
  It is topical, with likely significant media and public interest.
-  MaES may add and assess additional risks, such as those associated with refusing the request, consistency with earlier responses,
potential publication and so on. MaES will check the overall risk rating based on your assessment and might discuss the accuracy of
that rating with you. Where you identify different ratings across the various documents, MaES will apply the highest rating to the
entirety of the request.
Risk
No
assessment
Risk rating
Risk rating
.
Risk description
pre-mitigations
Planned mitigations
post-
mitigations
Consequence
Likelihood
-
Rare
-
-
-
-
Cause: what could trigger this risk?

Routine
-
Unlikely

Very low
-
What could be put in place to reduce or

Very low
-
-
Minor
-
-
low
-
low

Risk: what could happen?

Possible
manage this risk?
-
-
-
-
Effect: what would happen if the risk eventuated?

Moderate
-
Likely

Medium
-
Who would be responsible for the planned

Medium
-
-
-
-
Owner: who owns the risk?

Major
-

High

High

-
Severe

Almost
-
mitigations and timeframe?
-
Certain

Very High

Very High

There are no notable risks associated with this response.
-
-
-
-
-
Please create further rows, if needed.
3

link to page 11 IN-CONFIDENCE

Appendix 3: Authorisations framework
As above, the Ministry’s risk rating tools are used to determine whether the risk
is: very high; high; medium; low; or very low. The risk rating can be reassessed
at any stage. The final risk rating will determine the sign-out process, as set out
below.

MaES1
Business
Unit
Comms
DCE
OCE
Minister’s
Office
Very High
Approval
Approval
Consult
Approval (*)
Approval
FYI
High
Approval
Approval (*)
Consult
Approval
FYI
FYI
Medium
Approval
Approval (*)
FYI
FYI

Low
Approval
Approval (*)
FYI

Very Low
Approval
Approval (*)
FYI

(*) indicates preferred signatory.
Additionally, any responses that are likely to come into the public domain – e.g.,
media; political parties; bloggers; public advocacy groups – irrespective of risk
rating – will be reviewed by the media team.
All Written Parliamentary questions will be assessed by MaES as ‘medium’ risk
upon receipt. Once commissioned, the business unit or DCE office, may amend
the risk to ‘high’ or ‘very high’, which will then require the corresponding sign-out
process.
Any OIA decisions involving multiple business units, GM MaES wil  determine the
appropriate signatory on a case-by-case basis. In such cases the Manager OPI
Team or GM MaES may be designated as the signatory.
Where subsequent approvals result in significant changes to content, the signatory
should consider whether it should be resubmitted to MaES for review.
Business units involved on an ‘FYI’ basis should advise MaES immediately if they
wish to comment or seek changes to the response.

1 All work is first peer reviewed in MaES. Senior Advisors may sign ‘very low’ risk refusals.
Manager OPI Team may sign ‘low’ risk refusals. GM MaES approval is required for any ‘high’ or
‘very high’ risk work.
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Appendix
Table: Question number and whether it is refused or granted

Question
Granted or
Section of letter
number
refused?
1a
Refused
Income summary
1b
Granted
Income summary
1c
Granted
Income summary
2a
Granted
Overpayment
2b
Granted
Debt write-off
3a
Refused
Income summary
3b
Refused
Underpayment
3c
Refused
Overpayment
3d
Refused
Overpayment
4a
Refused
Underpayment
4b
Refused
Underpayment
4c
Refused
Overpayment
4d
Granted
Overpayment
4e
Refused
Overpayment
4f
Refused
Overpayment
4g
Refused
Overpayment
4h
Refused
Overpayment
5a
Refused
Overpayment
5b
Refused
Overpayment
5c
Refused
Overpayment
5d
Refused
Overpayment
6a
Partially granted
Debt write-off

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Document Outline