Response to the Treasury regarding the Discussion Paper: Reform to Deductions for Education Expenses July 2013 Australian Association of Social Workers National Office Canberra Level 4, 33-35 Ainslie Place CANBERRA CITY ACT 2600 PO Box 4956 KINGSTON ACT 2604 T 02 6232 3900 F 02 6230 4399 E advocacy@aasw.asn.au www.aasw.asn.au Enquiries regarding this submission can be directed to: Senior Manager, Education & Knowledge Development: Linda Richardson Email: linda.richardson@aasw.asn.au Phone: 03 9320 1001 AASW Chief Executive Officer: Glenys Wilkinson Email: ceo@aasw.asn.au 1
Table of Contents Introduction... 3 Position Statement... 3 1. AASW Continuing Professional Development Requirements... 4 2. Case Study - One... 5 3. Case Study - Two... 6 Conclusion... 8 2
Introduction The Australian Association of Social Workers (AASW) is the key professional body representing more than 7500 social workers throughout Australia. Social work is the profession committed to the pursuit of social justice, to the enhancement of the quality of life, and to the development of the full potential of each individual, group and community in society. The AASW is in a unique position to comment on the ramifications and impact of this proposed taxation cap as it effects Accredited Social Workers and impacts upon client outcomes. On behalf of the Australian Association of Social Workers, this response is to express our deepest concern and opposition to the proposal of imposing a $2000 tax cap on expenses incurred for self education. We provide the following information in relation to Discussion Paper Reform to Deductions for Education Expenses. Position Statement The AASW believes that the ongoing requirement of Continuing Professional Development (CPD) for Social Workers is essential to ensure the highest possible standards of social work practice and to achieve the best possible outcomes for clients. To this end, the AASW requires practising Social Workers to maintain their accreditation by completing a minimum number of continuing professional development hours. Added to this requirement, the CPD must be across three identified categories of expertise. For a Social Worker to be fully engaged and complete the CPD program required for AASW membership they must participate in a broad range of activities and events. From seminars, conferences, online learning courses, practice group meetings, reading and reflection, CPD learning may come in many forms and in most cases, incur a financial cost. This cost is born by the member and in particular, for those in private practice, there is no recourse to employer support or subsidies. As an example: it is expected that AASW members will attend the National Symposium being held in Melbourne and we as an association have worked hard to keep registration costs low. Notwithstanding this, for interstate delegates cost would be in the vicinity of $2000. This calculation is for basic travel, symposium registration and accommodation. This would also not be the only CPD event that members would undertake in the year. Registration costs for the Remote and Rural Social Worker Conference in Inverloch, Victoria is $380 plus travel and accommodation expenses to be incurred. To introduce a taxation cap on self education expenses incurred is to effectively be a disincentive to learning participation and in the long term would impact upon the skills of the member and the profession as a whole. The client of the Social Worker will also be impacted. Having a professional who is able to access and receive the latest professional development will ensure the client receives the best possible care and management. The AASW believes that to maintain quality skilled care for clients it is important to provide support through the taxation system by Social Workers being able to maintain their current opportunity to claim self education expenses. Rural and Remote Social Workers Social Workers who live and work in regional and remote areas of Australia face a number of challenges accessing and participating in professional development. In many instances, travel to other locations is required to participate in seminars or conferences and they incur significant costs to do so. They face many challenges in working with their clients in isolated or small communities and will now be even more disadvantaged in gaining new learning through this proposed tax cap. We would suggest that this proposed 3
capping undermines the Government s own Social Inclusion and Productivity polices through the outcomes for this specific cohort of workers. The AASW trusts that this submission informs the Treasury and Discussion Group of the negative impact of the current proposal upon Social Workers. 1. AASW Continuing Professional Development Requirements Over 7500 AASW members participate in and meet the CPD requirements for membership completing between 30 50 hours of professional development. CPD is how AASW members maintain, improve and broaden their skills, knowledge and expertise, and develop the qualities required for professional practice. CPD is an ongoing process throughout a career informed by the changing practice environment, professional domains, new information and community need. To support the goals of CPD, categories of CPD are provided and are required by AASW members to be completed. This ensures that Social Workers keep their knowledge and skills set current across the breadth of social work practice. 1.1 Accredited Member CPD Goal A total of 30 hours of professional development including; 10 hours of Category 1 Reflection, Ethical Practice and Career Development including: 10 hours of Category 2 Skills & Knowledge ; 10 hours of any type(s) of PD (from Categories 1, 2, & 3). 1.2 Advanced Accredited Member CPD Goal A total of 50 hours of professional development including; 10 hours of Category 1 Reflection, Ethical Practice and Career Development including: 10 hours of Category 2 Skills & Knowledge ; 10 hours of Category 3 Professional Identity ; 20 hours of any type(s) of PD (from Categories 1, 2, & 3). 1.3 Accredited Mental Health Social Worker (AMHSW) CPD Goal A total of 50 hours of professional development including: 10 hours of Category 1 Reflection, Ethical Practice and Career Development including; 10 hours of Category 2 Skills & Knowledge ; 10 hours of Category 3 Professional Identity ; 20 hours of any type(s) of PD (from Categories 1, 2, & 3). Additional Requirement: AMHSW are required to complete Mental Health and Focused Psychological Strategies (FPS) relevant Professional Development. The total of 50 hours listed above must include: 20 hours relevant to Mental Health practice; 10 hours relevant to Focused Psychological Strategies. 1.4 CPD Categories Members are required to locate the professional development they complete within an appropriate category, noting that any activity that is consistent with the categories rationale should be recorded not just those activities similar to provided examples. A rationale is given for each category along with examples of possible activity types. 1.4.1 Category 1: Reflection, Ethical Practice and Career Development Practice and career development, reflection on practice, ethical and professional frameworks, values and standards, and the consideration of the development needs of the practitioner are important in 4
ensuring accountability as a Social Worker. Activity types for this category could include (but are not limited to): Supervision Mentoring and coaching Peer support/consultation Reviewing professional and ethical standards Practice group discussions and case studies Workplace performance reviews Developing a CPD plan Maintaining a reflective journal 1.4.2 Category 2: Skills and Knowledge Regular and ongoing skill and knowledge development are vital for maintaining contemporary social work practice. The AASW encourages all members to participate in active, participatory learning but recognises that each member has different learning needs which are unique and therefore activity types may vary widely. Activity types for this category could include (but are not limited to): Workshops Skills training packages Online training Academic study Conferences Symposiums Practice groups Seminars Presentations Case discussion Research Study tours Reading publications Self directed learning 1.4.3 Category 3: Professional Identity The social work profession promotes social change, problem solving in human relationships and the empowerment and liberation of people to enhance well-being. Utilising theories of human behaviour and social systems, social work intervenes at the points where people interact with their environments. Principles of human rights and social justice are fundamental to social work. 1 Maintaining and developing the professional identity of Social Work is an important part of the professional development as a Social Worker. 2. Case Study - One The Case Study provided is the story by one of our AASW members and this example outlines how this member through being actively engaged in Social Work as a profession and with having a focus on meeting: CPD requirements Maintaining and improving their professional capacity to provide high quality client service will be impacted by the proposed tax cap on self education. In his own words.. This proposed cap is very low and has profound implications for social workers, like myself, who 1. 1 Definition of Social Work, IFSW, 2012 5
work in private practice and claim tax deductions for continuing professional expenses such as the following: supervision, conference, seminar and workshop attendance, etc. In addition to the above expenses, I am also undertaking training in child and adolescent psychotherapy. This is post-graduate course work, and requires the flowing financial outlays: Course fees: $4,500 p.a. Personal therapy: (required twice weekly) approximately $16,560 p.a. (calculated @ a cost of $180/ per session x 2 (per week) x 46 (p.a.) Supervision: (weekly) Approx. $6578 p.a. ($143/session x 46 weeks). The above expenses DO NOT include my regular attendance at conferences and seminars etc., as well as supervision for my adult patients ($143/fortnightly). As an example of this, in May, I attended a two week intensive training program in order to gain accreditation as a coder for disorganized attachments for infants aged 12 18 months. This is highly specialized work, which I use when providing expert advice in Children s Court and Family Court Assessments. On several occasions, I have been vigorously cross examined for the opinion I have provided, thus my expertise is a precondition of doing this kind of work. The cost of this training was as follows: Course Participation: $2,875.00 Accommodation & Meals: $2000 Airfare: (approx). $450.00 These figures do not include income lost whilst not working. Perhaps the most concerning thing about this proposal is that ongoing professional development (supervision, continued training, conference and seminar attendance etc.) is crucial when working with patients with severe emotional and mental disturbances. These patients cannot receive the continuity or quality of care they require in the public system and the proposed cap would severely limit the financial viability of continuing professional development for private practitioners who rely upon legitimate tax deductions to manage ongoing expenses. 3. Case Study - Two Case Study This case, which involved the treatment of a young sex offender, illustrates some of the complexities of providing ongoing treatment for private patients, who cannot be seen in the public system. It also illustrates the importance of practitioners being able to claim tax rebates for costs associated with ongoing professional development. Background Master A was referred to me when he was in his early teens, after an extended family member disclosed that he had been sexually assaulting her for the past year. There was a complex relationship between the offender s family and the victim s family, so the offender was not charged and the victim did not receive a forensic pediatric examination. The offender s parents were most alarmed by the disclosure of abuse and sought therapy for their child. Although the matter was referred to the Joint Investigation Response Team (JIRT), the Department of Community Services advised that it was not in a position to provide the offender with any treatment. This was because the risk of re-abuse was considered low and the offender s parents were willing to pay for private treatment. Because the offender was not charged, he was not eligible for a mandated treatment program. 6
Assessment My assessment revealed that the offender had very severe personality and emotional deficits. He showed very little remorse beyond fearing his own incarceration and social alienation, if his offending was made public. He had a very limited capacity to empathize with others distress, was sadistic and sensation-seeking. His abuse of the victim involved systematic and repetitive rituals of depersonalisation. However, these findings need to be seen in the context of his adolescence, a time when a person s defenses are most heightened, when insight is very limited, and with the understanding that many adolescent sex offenders do not progress to adult offending. Treatment I commenced treating the offender twice weekly. This increased to thrice weekly during a more intense period of treatment. Treatment goals were to help the offender to develop the capacity for remorse, to mature emotionally, to address the cognitive distortions which permitted him to justify his offending to himself, and to reduce his vulnerability to ongoing emotional and behavioural disturbances, including repeat offending. Given his lack of remorse and his capacity for cruelty, I was most concerned about the ongoing risk he posed to the community. As he was not charged, he could not be required to engage in any other treatment, nor could he be incarcerated, if he resisted therapy or failed to participate meaningfully. Costs I incurred in relation to this case The offender s treatment lasted approximately two and a half years. As it was an unusually complex and demanding case, and as the child was resistant to therapy, I undertook considerable professional development specifically for this child s treatment. I was also concerned about the ongoing threat this child posed to the community and that I lacked recourse to enforced containment, such as detention. To ensure that I was providing the most informed treatment, I sought ongoing clinical supervision from three more senior practitioners, with expertise in the field of forensic psychology, adult psychopathology and severe adolescent disturbance. This cost approximately $11, 000 for each year of treatment. Additional costs I incurred in relation to this case were: Conference and seminar attendance also related specifically to work with children and adolescents with severe emotional disturbances, approximately $1000 for each year of treatment. Professional membership, journal subscriptions and the purchase of text books relating specifically to the treatment of this child: approximately $500 per year for every year of treatment. Several hours per month of peer consultation with the therapist who provided family/marital therapy for the child s parents. The cost of this can be measured in income lost, several hundred dollars per month. In total, the direct costs associated with this child s treatment were approximately $13,000 per year. These costs do not include other expenses related to my usual continuing professional development, including supervision of other cases, more general conference attendance, professional membership fees, and expenses related to other text books and journal subscriptions. For the two years to 2012 FYE, this has cost an average of approximately $7, 500 per year. 7
Conclusions Several things should be clear from this case study: The severe nature of this child s offending and the emotional disturbances which drove it meant that he needed intensive, long term treatment. There was no public facility available to provide such treatment. As a therapist, my duty of care (to the child, his family, and the community at large) meant I had an obligation to ensure I provided the most well-informed treatment available. I bore the cost of ensuring I provided the patient with the best possible treatment. I could not have borne this cost if I was unable to claim tax deductions for the services I engaged in. Placing financial limitations on the costs I incurred in order to fulfill my professional obligations, including my duty of care, would have severely affected the quality of treatment I was able to provide to this child. Conclusion The AASW believes that the proposed tax cap on self education expenses will have a detrimental effect on Social Workers and their ability to gain the skills and experience required to deliver quality care to clients and will have a negative impact in the longer term on the profession as a whole. The tax cap acts as a disincentive to professional learning. The AASW recommends that the Treasury does not introduce the proposed $2000 taxation cap on self education expenses as outlined in the Paper - Reform to Deductions For Education Expenses. Submitted for and on behalf of the Australian Association of Social Workers Ltd Glenys Wilkinson Chief Executive Officer 8