Suddhoo and Secretary, Department of Social Services (Social services second review) - [2022] AATA 1155

Suddhoo and Secretary, Department of Social Services (Social services second review) [2022] AATA 1155 (13 May 2022)
Division:GENERAL DIVISION
File Number: 2021/5453
Re:Aksheye Suddhoo
APPLICANT

AndSecretary, Department of Social Services
RESPONDENT

DECISION
Tribunal:Member S Barton
Date:13 May 2022
Place:Perth

The Reviewable Decision, being the decision of the Social Services and Child Support Division of the Administrative Appeals Tribunal dated 9 July 2021, is affirmed.
.........[Sgd]...............................................................
Member S Barton
CATCHWORDS
SOCIAL SECURITY – disability support pension – whether the Applicant met the eligibility requirements for a disability support pension – fully treated and stabilised – Qualification Period – assigning impairment ratings – Applicant’s mental health conditions fully diagnosed – Applicant’s mental health conditions not fully treated and stabilised – Applicant’s bronchial asthma and bronchitis fully diagnosed – Applicant’s bronchial asthma and bronchitis not fully treated and stabilised – Reviewable Decision affirmed
LEGISLATION
Social Security Act 1991 (Cth) – ss 23(1), 26, 94(1), 94(1)(a), 94(1)(b), 94(1)(c)
Social Security (Administration) Act 1999 (Cth) – ss 80(1), 179
Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 (Cth) – ss 3, 5, 6(1), 6(3), 6(4), 6(5), 6(6), 6(7), 10
CASES
Baum and Secretary, Department of Education, Employment and Workplace Relations [2008] AATA 1066
Freeman v Secretary, Department of Social Security (1988) 15 ALD 671
Gallacher v Secretary, Department of Social Services (2015) 68 AAR 1
Re Fanning and Secretary, Department of Social Services (2014) 144 ALD 133
Shi v Migration Agents Registration Authority (2008) 235 CLR 286
REASONS FOR DECISION
Member S Barton
13 May 2022
BACKGROUND

The Applicant seeks review of a decision made by the Social Services and Child Support Division (AAT1) of the Administrative Appeals Tribunal (the Tribunal), dated 9 July 2021 (Reviewable Decision) which affirmed a decision to reject the Applicant’s claim for a disability support pension (DSP).
FACTS
The Applicant is 38 years of age.
On 9 December 2020, the Applicant lodged a claim for a DSP with Services Australia (Centrelink). He listed in his application the conditions of ADHD, depression, anxiety, bronchial asthma and bronchitis (T63/301).
On 7 January 2021, the Applicant’s claim for a DSP was rejected because he was assessed as not having an impairment rating of 20 points or more under the Impairment Tables, being the Social Security (Tables for the Assessment of Work-related Impairment for Disability Support Pension) Determination 2011 (Cth) (T70/312) (Original Decision).
The Applicant requested a review of the Original Decision, which was referred to an Authorised Review Officer (ARO). However, on 30 April 2021, an ARO of Centrelink wrote to the Applicant to advise him that the ARO had found the Original Decision to be correct, and that his review was unsuccessful (T73/317-321) (ARO Decision).
The ARO found that the Applicant’s mental health conditions and asthma are diagnosed, but not fully treated and stabilised and therefore, they could not be assigned impairment ratings (T73/318).
On 20 May 2021, the Applicant lodged an application seeking review of the ARO Decision in the AAT1 (T2/58-63). The Applicant was also unsuccessful at the AAT1, with the AAT1 affirming the ARO Decision on 9 July 2021 (T2/5-13).
On 11 August 2021, the Applicant lodged an application for second review in the General Division (AAT2) of this Tribunal.
JURISDICTION
The application for review was made in accordance with s 179 of the Social Security (Administration) Act 1999 (Cth) (the AdministrationAct). Therefore, the Tribunal is satisfied that it has jurisdiction to review the Reviewable Decision.
MATERIAL BEFORE THE TRIBUNAL
The application was heard on Monday 28 March 2022. The Applicant was

self-represented. The Applicant gave oral evidence and was cross-examined. The Respondent was represented by Mr James Bernasconi of Services Australia. Both the Applicant and Mr Bernasconi appeared by telephone.
The Tribunal admitted the following documents into evidence at the hearing:
·Applicant’s Submissions in Reply with Annexures, filed 2 January 2021 (Exhibit A1);
(i)Annexure A – Request for Medicare claims information form, dated 15 December 2021;
(ii)Annexure B – Centrelink explanation or formal review of a decision form, dated 6 July 2021; and
(iii)Annexure C – Applicant’s table listing treatment noted on medial certificates.
·Applicant’s email – Submissions in response to Respondent’s email, dated 28 October 2021 (Exhibit A2);
·Applicant’s Submissions, filed on 29 September 2021 (Exhibit A3);
·Applicant’s Medicare Claims History between 2018 and 2021, dated 2 January 2022 (Exhibit A4);
·Applicant’s Medicare Claims History between 2014 and 2017, dated 2 January 2022 (Exhibit A5);
·Applicant’s email titled, “fraudulent or unethical behaviour impacting the AAT”, dated 21 February 2022 (Exhibit A6);
·Section 37 T-Documents, labelled T1-T78, consisting of pages 1-378, dated 8 September 2021 (Exhibit R1); and
·Respondent’s Statement of Facts, Issues and Contentions, dated 13 December 2021 (Exhibit R2).
ISSUES
The overall issue for determination by this Tribunal is whether, during the Qualification Period, the Applicant met the qualification criteria for a DSP in s 94(1) of the Social Security Act 1991 (Cth) (the Act), including:
(a)whether the Applicant had a physical, intellectual or psychiatric impairment or impairments for the purpose of s 94(1)(a) of the Act;
(b)if so, whether the impairment(s) were fully diagnosed, treated and stabilised and attracted a rating of at least 20 points under the relevant Impairment Tables; and
(c)whether the Applicant had “a continuing inability to work” for the purposes of s 94(1)(c) of the Act.
LEGISLATION
The legislation applicable to this matter is contained in:
(a)the Act;
(b)the Administration Act; and
(c)the Impairment Tables.
Qualification for DSP
The qualification requirements for a DSP are set out in s 94(1) of the Act:
(1)A person is qualified for disability support pension if:
(a)the person has a physical, intellectual or psychiatric impairment; and
(b)the person’s impairment is of 20 points or more under the Impairment Tables; and
(c)one of the following applies:
(i) the person has a continuing inability to work;
(ii) the Secretary is satisfied that the person is participating in the program administered by the Commonwealth known as the supported wage system; …
The criteria contained within s 94(1) of the Act are conjunctive, meaning for a DSP application to be successful, an applicant must satisfy each sub-section.
Impairment Tables
Section 23(1) of the Act defines “Impairment Tables” to mean “the tables determined by an instrument under subsection 26(1)”.
Section 26 of the Act states:
Impairment Tables
(1)The Minister may, by legislative instrument, determine tables relating to the assessment of work‑related impairment for disability support pension.
(2)An instrument under subsection (1) may contain such ancillary or incidental provisions relating to those tables as the Minister considers appropriate.
Rules for applying Impairment Tables
(3)The Minister may, in an instrument under subsection (1), determine rules that are to be complied with in applying the tables referred to in subsection (1) and the provisions referred to in subsection (2).
(4)An instrument under subsection (1) may contain such ancillary or incidental provisions relating to those rules as the Minister considers appropriate.
The Minister has determined tables as contemplated by s 26 of the Act in the form of the Impairment Tables. The Impairment Tables also set out rules as to how to apply the Impairment Tables.
Section 5 of the Impairment Tables sets out their purpose and general design principles, being to describe functional impacts associated with certain types of conditions, and to assign ratings to determine the level of functional impact of impairments on applicants.
“Impairment” is defined in s 3 of the Impairment Tables as “a loss of functional capacity affecting a person’s ability to work that results from the person’s condition”.
Section 6(1) of the Impairment Tables states that “[t]he impairment of a person must be assessed on the basis of what the person can, or could do, not on the basis of what the person chooses to do …” (emphasis added). An impairment rating can only be assigned if the condition is permanent (s 6(3) of the Impairment Tables).
With regard to the permanency of conditions, ss 6(4), 6(5) and 6(6) state:
Permanency of conditions
(4)For the purposes of paragraph 6(3)(a) a condition is permanent if:
(a)the condition has been fully diagnosed by an appropriately qualified medical practitioner; and
(b)the condition has been fully treated; and …
(c)the condition has been fully stabilised; and …
(d)the condition is more likely than not, in light of available evidence, to persist for more than 2 years.
(Notes omitted.)
Fully diagnosed and fully treated
(5)In determining whether a condition has been fully diagnosed by an appropriately qualified medical practitioner and whether it has been fully treated for the purposes of paragraphs 6(4)(a) and (b), the following is to be considered:
(a)whether there is corroborating evidence of the condition; and
(b)what treatment or rehabilitation has occurred in relation to the condition; and
(c)whether treatment is continuing or is planned in the next 2 years.
Fully stabilised
(6)For the purposes of paragraph 6(4)(c) and subsection 11(4) a condition is fully stabilised if:
(a)either the person has undertaken reasonable treatment for the condition and any further reasonable treatment is unlikely to result in significant functional improvement to a level enabling the person to undertake work in the next 2 years; or
(b)the person has not undertaken reasonable treatment for the condition and:
(i) significant functional improvement to a level enabling the person to undertake work in the next 2 years is not expected to result, even if the person undertakes reasonable treatment; or
(ii) there is a medical or other compelling reason for the person not to undertake reasonable treatment.
Reasonable treatment, defined in s 6(7), is treatment that:
(a)is available at a location reasonably accessible to the person; and
(b)is at a reasonable cost; and
(c)can reliably be expected to result in a substantial improvement in functional capacity; and
(d)is regularly undertaken or performed; and
(e)has a high success rate; and
(f)carries a low risk to the person.
Section 10 of the Impairment Tables outlines how to identify the applicable Impairment Table to apply when assessing impairments. It is first necessary to identify the loss of function and refer to the Impairment Tables related to that function, and then to identify the correct impairment rating.
Qualification Period
Section 80(1) of the Administration Act provides that where the Secretary is satisfied that a social security payment is being paid to a person who is not qualified for the payment, the Secretary is to determine that the payment is to be cancelled or suspended.
The qualifying period for assessing whether or not a person is qualified for a payment has been the subject of a number of decisions in both the Federal Court and the High Court. In Freeman v Secretary, Department of Social Security (1988) 15 ALD 671, the Court found, at 674:
The ambit of the jurisdiction of the Administrative Appeals Tribunal in relation to the review of a decision to cancel a pension or benefit is therefore less than would be the jurisdiction of the Tribunal in respect to a refusal to grant a pension or benefit or a decision suspending the payment of a pension or benefit. In the latter cases, there may well be an ongoing entitlement to a pension or benefit which the Tribunal should recognise when formulating its decision. However, if the Tribunal comes to the view that the decision to cancel was the correct or preferable decision, then no further matter remains for the Tribunal’s consideration. Any entitlement of the applicant to a pension or benefit at a subsequent time must be the subject of a further claim which, having been made, would only become the subject of review within the Tribunal’s jurisdiction once a decision with respect to it had been made by an officer of the Department of Social Security and that decision had been the subject of appeal and reconsideration in accordance with s 19.
Referring to this decision, in Shi v Migration Agents Registration Authority (2008) 235 CLR 286, the High Court found, at [144]:
In Freeman, Davies J identified the importance of the nature of the decision under review, in determining what facts the Tribunal might take into account…
The Tribunal was entitled to take into account all the facts placed before it, but the issue was whether the decision it was reviewing, to cancel the pension, was the correct or preferable decision when it was made. It was not whether Mrs Freeman had an entitlement to a widow’s pension at the date of the Tribunal’s decision.
(Footnotes removed.)
The effect of these decisions is described by Deputy President Forgie in Baum and Secretary, Department of Education, Employment and Workplace Relations [2008] AATA 1066, at [48]:
Applying these principles to the decision I am required to review, it seems to me that the inherent nature of the decision and the statutory context in which it is made confine me to evidence that relates to Mr Baum’s condition, impairment and work capacity during that 13 week period. That does not mean that all of the evidence in the form of reports, assessments or records had to be generated in that period. What it means is that they must relate to that period.
Following these established precedents, the Tribunal is restricted in its consideration of the Applicant’s condition at the date of his claim, or within 13 weeks of that claim, which provides the Tribunal with a qualification period of 9 December 2020 to 10 March 2021 (Qualification Period).
Following the practice in Re Fanning and Secretary, Department of Social Services (2014) 144 ALD 133, 139 at [31], cited with approval in Gallacher v Secretary, Department of Social Services (2015) 68 AAR 1, medical reports generated after a qualification period must be relevant to that period.
MENTAL HEALTH CONDITIONS
As detailed above, on 9 December 2020, the Applicant submitted a claim for DSP, listing attention deficit hyperactivity disorder (ADHD), depression and anxiety (T62/295-296).
The Applicant was diagnosed with ADHD in his country of origin (Mauritius) on 14 July 2014 by his psychiatrist Dr T Ramkoosalsing and was prescribed Ritalin as a treatment (T4/153).
On 22 June 2015, his general practitioner, Dr Karivandan, referred him to psychiatrist Dr Kevin O’Daly for his professional opinion and management, listing his current medication Ritalin (T8/158).
On 10 July 2015, the Applicant presented to Fiona Stanley Hospital Department of Emergency with a panic attack, he was discharged with a recommendation to consult his general practitioner for a review and treatment as required (T9/159). The Applicant’s medical records note that on 5 August 2015 he saw Dr Karivandan for a mental health assessment, with a diagnosis of anxiety and depression recorded (T60/284).
On 18 January 2016, Dr Karivandan referred the Applicant to psychiatrist Dr Sanjay Khanna for his professional opinion and management regarding his ADHD condition (T10/160).
Separately, on 24 February 2016, the Applicant was examined by psychiatrist Dr Frederick Ng to provide an independent medical opinion for a workplace compensation claim (T11/161-178). Dr Ng noted that the Applicant was currently taking the antidepressants Efexor XR, Mirtazapine (commencing in February 2016 and January 2016 respectively) as well as the Ritalin for his ADHD (T11/167).
Dr Ng provided the following diagnosis (T11/175):
Based on the history elicited, the mental status examination, having perused the copies of documentation provided and from my clinical experience… I form the opinion that in the context of the plausible allegations of being victimised and mistreated at work after your client brought to the attention of the employer pay irregularities, he developed pathological anxiety symptoms with associated panic attacks which could be categorised as at least an adjustment disorder with anxiety (DSM 5).
Additionally, he also developed pathological depressive symptoms which could be categorised as major depressive disorder (DSM 5). In the alternative some may consider that he developed at least an adjustment disorder with depressed mood.
The anxiety component and depressive component at its worse were to a moderate extent and with the passage of time have improved and are currently partially treated.
The reported diagnosis of ADHD, was unrelated to the alleged difficulties at work and was a pre-existing condition…
Your client would benefit from individual psychotherapy.
He would currently benefit from at least a further 6-12 sessions of psychotherapy which should occur at least once every 2 to 4 weeks…
Concurrently, he would benefit from continuing to take on a daily basis the 2 different antidepressants, 1 in the morning and 1 at night for at least the next 1 to 3 years…
(Original emphasis.)
In correspondence, dated 5 June 2016, to the Applicant’s lawyers (with respect to the above workplace compensation claim), psychiatrist Dr Sanjay Khanna noted that he had assessed the Applicant on 21 January 2016, 10 February 2016, 16 March 2016 (error in original) and 18 May 2016 (T15/189).
After the Applicant’s first consultation, Dr Khanna noted (T15/191):
My impression after the first assessment was Learning Difficulty probably on background of intellectual impairment along with ADHD. I prescribed Ritalin and added anti-depressant Mirtazapine 15 mg nocte to manage anxiety symptoms.
Following the subsequent visits, Dr Khanna made adjustments to the Applicant’s medication, noting that he was currently on a course of Venlafaxine in the morning, Mirtazapine in the evening, Lorazepam at night and Symbicort as indicated by his general practitioner (T15/192). Dr Khanna made a diagnosis of adjustment disorder with mixed emotions of anxiety and depression (T15/194).
Having regard to the medical evidence presented above, the Tribunal accepts that, for the purpose of s 94(1)(a) of the Act, the Applicant suffered from a psychiatric impairment relating to ADHD and an adjustment disorder (anxiety and depression). It is noted that the Secretary accepts that the Applicant’s ADHD and adjustment disorder (anxiety and depression) were diagnosed during the relevant period.
Are the conditions fully treated and stabilised?
As is detailed above, an impairment rating can only be assigned if the condition is permanent, which, for the purposes of the Impairment Tables, is if it has been fully diagnosed by an appropriately qualified medical practitioner; if it has been fully treated and stabilised; and if it is more likely than not, in light of available evidence, to persist for more than two years.
In Dr Ng’s diagnosis, he recommended both pharmacological treatment and psychotherapy. Dr Khanna, in his report dated 5 June 2016, made similar recommendations, stating that the Applicant would need (T15/195):
…a regular follow up from a psychiatrist to manage his symptoms of anxiety, depression and panic. He would also need regular assessment by a psychiatrist for ADHD symptoms and medications. I would suggest a follow up appointment at least every 2-4 weeks is required depending upon the improvement…
He may also benefit from Cognitive Behaviour Therapy through a psychologist, which will help in managing his anxiety and depression.

Based on the medical evidence presented to the Tribunal, it appears that the appropriate treatment for the Applicant’s adjustment disorder rests on two planks: medication and some form of counselling or therapy.
On 13 January 2017, Dr Craig Shaw provided Centrelink with a medical certificate that recorded the Applicant’s past treatment as “…medication, seeing psychiatrist and psychologist”, his current treatment as medication and planned treatment as "[c]ontinued psychological input” (T19/201).
On 23 February 2017, Dr Carina Limgence referred the Applicant to the Bentley Hospital Mental Health Clinic, noting “[h]e reports seeing a Psychiatrist and attends counselling” (T20/202).
Following that referral, on 14 March 2017, psychiatrist Dr David Chang from the East Metropolitan Health Service, wrote to Dr Limgence, noting that the Applicant will continue seeing Dr Khanna and recommended referring the Applicant to a psychologist on a Mental Health Care Plan (T21/203-204).
On 13 April 2017, Dr Chandra Gopisetty provided a medical certificate to Centrelink noting that the Applicant’s planned treatment was “[c]ontinued psychology input” (T22/205). The continuation of psychological treatment as a planned treatment for the Applicant is also repeated in further medical certificates by other general practitioners in January 2018 (T26), April 2018 (T30), July 2018 (T31), September 2018 (T32), January 2019 (T34) and March 2020 (T49).
In an Employment Services Assessment Report submitted on 17 April 2019, it notes that the Applicant still sees a psychiatrist, it also recommends a number of interventions including cognitive behaviour therapy and counselling (T40/249-250).
A medical certificate dated 16 August 2019, notes that the Applicant is awaiting “psychologist review” (T42/254). On 3 June 2020, a GP Mental Health Care Plan Patient Assessment notes that the Applicant’s treatment is antidepressants (T51/266).
From the medical evidence detailed above, it is evident that the Applicant was taking medication for his condition from 2016 in the lead up to the Qualification Period. However, it is less clear what psychological interventions, be it cognitive behaviour therapy or counselling, the Applicant had undertaken.
The Tribunal does note however, that according to the Applicant’s Medicare Claims History between 17 December 2014 and 17 December 2017, the Applicant did attend eight sessions with Mrs Sarah Parraga-Martin, a clinical psychologist between 21 July 2017 and 8 December 2017 (A5/5).
According to the Applicant’s Medicare Claims History between 16 December 2018 and 16 December 2021, the Applicant also attended three sessions with Mrs Fakhar Jehan on 11 December 2019, 18 December 2019, and 7 January 2020 for “[p]rofessional attendance for the purpose of providing focussed psychological strategies services” (A4/4-5).
In his online claim for the DSP, the Applicant recorded his past treatment as “[c]ognitive behavioural therapy. Medication. Specialist health review.” He listed his current treatment as “[m]edication, Specialist or health professional review, Psychological or psychiatric treatment, Counselling.” (T63/302).
Upon receipt of his claim, a Centrelink assessor made an assessment of the Applicant’s medical eligibility, recording a recommendation that the Applicant was “[m]anifestly medically ineligible”, providing the following rationale (T64/305):
Whilst there is evidence of consultation with psychiatrist in 2017 for anxiety, depression at that time, the nature of [the Applicant’s] current mental health issues are unclear given there is no verification of diagnosis of co-morbid adjustment disorder by a clinical psychologist or psychiatrist. Whilst [the Applicant] is reported to have attended with psychologist and he is on medication, there is no corroborating and current evidence by psychologist and psychiatrist to indicate all reasonable treatment has been undertaken. Further interventions including clinical psychological interventions and optimisation of psychopharmacotherapy by psychiatrist may result in some functional improvement within next 24 months. Condition cannot be assessed fully treated and stabilised at present.
On 30 April 2021, the Job Capacity Assessor came to a similar conclusion, noting (T74/325):
In the absence of medical evidence to support otherwise, it may be reasonable to consider psychological conditions are not fully treated and stabilised. Evidence does not support consistent psychologist intervention over time.
The Respondent has noted that there is no available evidence that the Applicant received treatment from a mental health professional since 2016, though the Applicant advised the Tribunal he had seen Dr Khanna in 2018 (R2/9).
In his written submissions to the Tribunal, the Applicant has stated that financial pressures prevented him from seeing Dr Khanna. He added (A1/4):
… all my prior psychologists were practising in the same medical practice I was seeing my GP and were bulk billed; as such it was easy to follow my treatment. As such, I could not attend to any of those referrals made in 2020 and 2021 since I had no way to get to those appointments, it was only partly bulk billed and I could not afford so. With no public transport or Uber in my area, a taxi would cost me $100 to go to my psychologist appointment in Mandurah and come back home but I do not have that money.
In its decision AAT1 recorded that (T2/10):
He still struggles with symptoms of anxiety and depression despite taking Efexor 150 mg daily and Lorazepam 1mg at night; these have been prescribed by his general practitioners since 2016. He said there had been a short period of time when he was taking Valium and his doctor decided he needed to discontinue this; he is now being prescribed a small dose of lorazepam instead. He last consulted Dr Khanna in 2018. He stopped taking Ritalin in 2019 because he is not studying now, and he doesn’t need help concentrating or focusing with activities of daily living. When questioned, [the Applicant] said he has not had a specialist medication review since 2018 and the dosage of medications he has been taking haven’t been adjusted or altered since then. He stopped attending counselling in 2019. He moved to Pinjarra recently and has a new general practitioner who has suggested he undergo a specialist review; this will be arranged shortly.
As detailed above, the Tribunal is restricted in its consideration of the Applicant’s condition at the date of his claim, or within 13 weeks of that claim, that is 9 December 2020 to 10 March 2021. The Applicant has previously received treatment for his condition in the form of both medication and, for a period, some psychological counselling between 2016 and early 2020. While it is prior to the Qualification Period, it is still may be relevant in forming a view of the Applicant’s condition and impairment during the Qualification Period. However, there is insufficient evidence to form a view of that treatment. For example, the Tribunal is not aware of the results of the sessions the Applicant undertook with Mrs Parraga-Martin in 2017 or Mrs Jehan in 2019.
More relevantly, the Tribunal notes that the Applicant has not consulted a psychiatrist since 2018 and was recently in the process of organising future counselling. In these circumstances, it is not open for the Tribunal to conclude that the Applicant’s condition is fully treated or fully stabilised.
The Tribunal is not satisfied that the Applicant’s mental health conditions were fully treated and fully stabilised during the Qualification Period, as such the Applicant’s impairment cannot be assessed against the Impairment Tables
BRONCHIAL ASTHMA AND BRONCHITIS
The Tribunal accepts that the Applicant suffers from a number of respiratory complaints, namely asthma and chronic bronchitis (T33/229 and T43/255). He has taken Symbicort for this condition, as noted by Dr Khanna in 2016 (T15/192). However, there is very little evidence of ongoing treatment and there is no recent information relating to this condition.
As such, it is difficult to make any assessment on the Applicant’s condition: the Tribunal cannot determine if they are fully treated or stabilised.
CONCLUSION
The Tribunal finds that during the relevant Qualification Period, the Applicant’s conditions were not fully treated and stabilised. Therefore, an impairment rating cannot be assigned under the Impairment Tables because the Applicant’s conditions do not meet the requirements of being permanent. The Applicant has not satisfied s 94(1)(b) of the Act. Given this requirement is not met, it is not necessary to consider whether the Applicant had a continuing inability to work.
DECISION
The Reviewable Decision, being the decision of the Social Services and Child Support Division of the Administrative Appeals Tribunal dated 9 July 2021, is affirmed.

I certify that the preceding 66 (sixty-six) paragraphs are a true copy of the reasons for the decision herein of

.............[Sgd]...........................................................
Associate
Dated: 13 May 2022

Date of hearing: 28 March 2022

Applicant: Self-represented

Advocate for the Respondent: Mr J Bernasconi, Services Australia

Date of hearing:	28 March 2022
Applicant:	Self-represented
Advocate for the Respondent:	Mr J Bernasconi, Services Australia