This submission provides our assessment of the Exposure draft of the Charities Bill 2013 and associated Bills, building on the comments we made in our December 2011 submission to the consultation on ‘A Definition of Charity’.

We believe that the Exposure draft of the Charities Bill 2013 and associated Bills, while sound in structure and purpose, needs to be amended so as to provide greater clarity and certainty in the following key areas: the disqualifying purpose; application of the presumption of public benefit; and the treatment of “infrastructure” entities which support charities in fulfilling their purpose and mission.

UnitingCare Australia welcomes the opportunity to comment on the Second Draft Discussion Paper regarding the Accommodation Pricing Guidelines, Significant Refurbishment of residential Aged Care Services, Fees and Payments Principles 2013, Subsidy Principles 2013, Aged Care (Maximum Accommodation Payment Amount) Determination 2013.

We have been an active participant in the consultation processes to establish the Australian Charities and Not-for-profits Commission (ACNC) and the Commonwealth Government’s wider not-for-profit (NFP) reform agenda.

UnitingCare Australia welcomes the tabling of the five Aged Care Bills that are designed to
give effect to the “Living Longer, Living Better” package of reforms.

UnitingCare Australia works with and on behalf of the UnitingCare network to advocate for policies and programs that will improve people’s quality of life.

UnitingCare Australia would like to commend the Department of Human services for undertaking an independent
review of Centrepay system, and for seeking comment from the community in this process.

Through the work of our agencies with vulnerable consumers UnitingCare Australia sees the benefits of Centrepay as a money management system for our clients. There are, however a range of issues with the current system, and this review indicates that the Department of Human Services is committed to improving this service to better meet the needs of vulnerable Australians.

This submission provides our assessment of the proposed governance standards for entities registered with the ACNC. Our assessment has been made in consultation with the UnitingCare network and with regard to the Commonwealth Government’s wider NFP reform agenda; in particular the findings of the Council of Australian Government’s recently published Regulatory Impact Assessment (COAG RIA) of potential duplication of governance and reporting standards for charities.

UnitingCare Australia welcomes the introduction of the National Disability Insurance Scheme pointing to a future where people with a disability will have access to the supports they need to live as valuable citizens in the Australian community. It is critical that the National Disability Insurance Scheme Bill 2012, provides a mechanism for all people with a disability to have access to these supports and have
choice and control over how they are provided.

Apart from fixing some nomenclature issues, a revision of the Act is needed to ensure it correctly articulates the new and changed commitments made by the Australian Government in the Living Longer Living Better package of aged care reforms, and the different context for provision of aged care services as a result of these changes.