Summary: National Seniors Australia Consultation Regulation Impact Statement on Paper Billing
Current exemption programs for paper billing fees are underutilized, leading to older consumers being inadvertently charged.
Majority of consumers have never applied for exemptions from paper billing fees.
Option 1 proposes maintaining the status quo with an industry-led consumer education campaign.
National Seniors Australia does not support Option 1 as it does not guarantee eligible individuals will receive exemptions from paper billing fees.
Current exemption programs are underutilized as they require consumers to apply directly with businesses.
There is concern that vulnerable older consumers may not be aware of or able to access these exemption programs effectively.
National Seniors suggests that exemptions from paper billing fees should be more readily available to all eligible individuals without the need for direct application.
Option 2 proposes a ban on paper billing fees, which is supported by older cohorts but may not encourage cost-saving behavioral changes.
Option 3 suggests prohibiting essential service providers from charging for paper bills, which may be complex and costly to administer.
Option 4 suggests limiting paper billing fees to a cost recovery basis.
National Seniors Australia does not support Option 4 as a standalone solution.
They view the requirement to limit paper billing fees to cost recovery as complementary to a targeted approach of prohibiting charges for Age Pensioners and concession card holders.
The organization believes that a targeted first response of prohibiting charges for specific groups should precede implementing cost recovery limitations for paper billing fees.
This approach aims to ensure that vulnerable individuals are not financially burdened by paper billing fees.
Option 5 involves promoting exemptions through a statement on paper bills, but may not guarantee eligible customers receive the benefit.
National Seniors recommends capping paper billing fees at postage rates plus a nominal printing cost to protect consumers and maintain customer loyalty.