MSD consultation : Empowering families: Increasing certainty and preventing debt in the Working for Families scheme. Yeah right.

As I wrote this submission, I felt my life force slowly ebbing away. I had promised I would never again provide unpaid unvalued submissions to government departments and their working groups. Sucked in again. My forebodings were confirmed by this acknowledgment of my submission on 3rd July from an AI bot:

Kia ora
This is an automated email response to acknowledge receipt of your submission on the discussion document Empowering families: Increasing certainty and preventing debt in the Working for Families scheme. Your submission will help shape final policy proposals for the Government’s consideration. If the Government chooses to proceed with the proposals, they will be included in a future taxation Bill. Thank you very much for taking the time to provide your views on this consultation. 
Ngā Mihi
Policy Webmaster
Policy | Inland Revenue

Insanity is doing the same thing and expecting a different result. But this will be the last one ever I ever waste my time on I swear.

MSD Submission 3rd July 2025.

Thank you for the opportunity extended to myself and to NGOS to comment on this document. 

I am experienced policy analyst with a particular interest in Working for families WFF over many years. I append the last decade of my articles and interviews (several hundreds) to this submission.

I do not necessarily speak for other NGOs, but you may find they resonate with much of this submission.  Unfortunately, many of us find that the last rounds of consultations with MSD and IR over many years have been very discouraging and excessively time-consuming. They have absorbed a large amount of painstaking unpaid work with little feedback or any sign improvement in the policies. Our views have been presented in good faith but volunteers doing the very hard work of patching up the frayed social fabric have run out of energy and patience.

The last major review of Working for Families under Labour was quietly shelved along with all our various submissions since the WEAG report.  

• St John, S (2023) So this is the best we can expect from the Working for Families (WFF) review?14th August 2023
• St John, S (2023) What are we to make of welfare and Working For Families reform now? Daily Blog 10th August, 2023

Other reviews proved equally pointless: eg

• St John, S (2024)  Review of crippling debts to government now delayed to the Never Never.  Daily Blog 24th June 2024

And among other demands on our time, there was the critical but failed review of the purpose and principles of the Social Security Act  

• St John, S. ( 2022)   Social security purposes and principles are cold comfort for too many NZ Herald 25th July 2022

I note the extensive analysis on all aspects of WFF and previous consultations as provided in various OIAs. The latest one I have received, 19th Sept 2024, is 184 pages long and does not appear on the official IR OIA site. The extensive consultations from advocacy groups concerned with child poverty received a brief summary:

I provide the following brief comments on the current consultative document.

• The title: Empowering families: Increasing certainty and preventing debt in the Working for Families scheme promises more than it can possibly deliver. Families are not empowered and will not be under the scope of this consultation.
• It does not start from first principles of asking what the purpose of WFF should be and therefore takes as the starting point the status quo. Paid work is prioritised over the needs of children.  The deficiencies of WFF are embedded and tinkering with the issues under consultation here will make a marginal difference only.
• The recent minimal increases to the threshold and the rise in the abatement rate to 27.5% are backward steps. They follow other backward steps that have increased the IWTC and frozen thresholds.
• Tax accountant Jeremy Beckham’s submission on the shortening of the period of assessment I endorse in full.  This very detailed assessment will not be further repeated here but must be given prominence in the IR review.  
• CPAG submitted years ago on the IR transformation project that real time assessment for WFF will not work. Our submission was ignored: See Making Tax Simpler Better Administration of Social Policy: Working for families (WFF).  We also note the recent negative experience of 3 monthly assessment for Family Boost.
• The problem is the design of WFF itself as we have said on so many occasions. It requires a multiparty approach for reforms to be long-term and sustianable. At front of mind must be that we are failing to support our poorest children.
• CPAG’s submission to Labour’s WFF review spells out what needs to be done. If adopted significantly more children and their families will be empowered to live free from the toxic stress of poverty.

To conclude: it must be accepted that WFF is seriously flawed and does not work in many respects. It is in need of major reform; to simplify, to prevent poverty and to actually encourage work effort. The MSD is asked to review all the submissions the NGO sector has made over the period of WFF reviews since the WEAG report. Tinkering is time consuming and takes the gaze off the real problems of flawed design.