Regulatory Impact Statement:

Tightening access to benefits for recent migrants.

Agency Disclosure Statement

This Regulatory Impact Statement (RIS) has been prepared by the Ministry of Social
Development (MSD). It accompanies the Cabinet paper Tightening access to benefits for
recent migrants.
The RIS provides an analysis of options considered to tighten access to benefits for recent
migrants and deal with transitional issues. The options were considered taking into account
the policy objectives and the impact on recent migrants. Other constraints such as IT and
other operational costs were considered.
The RIS provides the required level of analysis, but cost estimates are not included for
some options that were considered at an early stage of the policy development process as
these were not progressed further.
Consultation has been undertaken with relevant government agencies, but not
with a broader group of stakeholders, due to the nature of the proposals. It is
considered that the consultation with agencies, including the Office of Ethnic
Affairs and the Ministry of Womens Affairs, raised relevant issues that has
allowed officials to provide the Minister with robust policy proposals at this time.
Consultation with stakeholders will occur at the Select Committee stage if the
legislative changes are taken forward.
To give effect to the package, amendments are required to the Social Security Act 1964.
The options in this RIS are not likely to impose additional costs on business, impair private
property rights, restrict market competition, or reduce the incentives on business to
innovate and invest or override fundamental common law principles.

Anna Butler
General Manager
Housing, Income Support and Employment, Ministry of Social Development
xx July 2014

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Executive summary
1

This Regulatory Impact Statement outlines proposals with the objective of

tightening access to benefits for recent migrants, including recent migrants
who are partners of beneficiaries. The objectives aim to:

strike a better balance between the contributions recent migrants have

made to New Zealand and the welfare assistance they can currently
receive;

strengthen the incentive on recent migrants to provide for themselves and

so make more of a contribution to the New Zealand economy;

reduce the number of recent migrants, including recent migrants who are
partners of beneficiaries, accessing benefits;

achieve fairness and equity across the welfare system; and

achieve fiscal savings for government;

Issues have been identified in relation to the current settings for recent
migrants:

New Zealands residency settings for welfare eligibility mean recent

migrants (single or partnered) can access this income support relatively
quickly to the time they have spent contributing to New Zealand. This
imposes fiscal costs on the Government when these migrants have not
contributed financially to the Crown to the extent that most
New Zealanders have.

Beneficiaries with a partner can receive a couples rate of benefit, sharing

(normally half) with their partner who may not have lived in New Zealand
for any period of time. This is different to single migrants who are not
eligible for main benefits until they have two years residency.

If changes are made to the welfare settings, this could result in those
affected moving to access hardship tested benefits, as the hardship test
does not take into account factors that may be relevant for recent
migrants, i.e. available family support and considerations to avoid
hardship.

The preferred package contains proposals to:

extend the minimum residency period for accessing a main benefit from
two years to three

align the residency requirements for partners of beneficiaries with single

applicants of main benefits, and

tighten the hardship-tested benefit criteria for those who do not meet
minimum residency requirements.

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Status quo and problem definition

4

Immigration plays an important role in the New Zealand economy and has
both economic and non-economic objectives, particularly in relation to
residence. New Zealand seeks to attract and retain skilled and productive
migrants, while limiting the costs that some migrants impose on the
Government, such as, paying welfare benefits. In general, the majority of
migrants are expected to arrive in New Zealand with skills that enable them
to secure employment quickly, or arrive with employment already arranged. A
primary migrant can also bring in a partner (and children), and in some
circumstances can sponsor a parent to enter New Zealand after a period of
three years residency.

Main benefits referred to in this Regulatory Impact Statement are:

Jobseeker Support

Sole Parent Support

Supported Living Payment

Youth Parent Payment

Youth Payment

And also include the hardship tested benefits:

Emergency Benefit

Jobseeker Support - Hardship

Welfare rules under the Social Security Act 1964 1 (SSA) mean that a migrant
is not eligible for a main benefit until they have lived in New Zealand
continuously for at least two years at any one time since obtaining a
residence class visa, and are ordinarily resident. These rules do not apply to
refugees or protected persons. People who have temporary visas (of which
there were 144,978 in 2012/13) are not eligible for any benefits, and
therefore, there is an expectation that they support themselves if they find
themselves out of work2. New Zealand citizens who have been living overseas
must also meet the requirement to have lived in New Zealand continuously
for two years before they can receive a main benefit, as it relates to the
contribution and commitment a person has made to the country.

Relatively low numbers (1.5 per cent in 2011) of primary migrants under 65
years seek main benefit support after two years, as 80-90 per cent have been
in the country on temporary visas before being granted a residence visa and
have settled into employment and society. Projections from the Ministry of
Business, Innovation and Employment indicate that there will be around

1 Section 74AA of the SSA.

2 Those with temporary visas who lose their employment would not automatically lose their
temporary visa; however, they may be liable for deportation if they are not meeting the
conditions of their visa. They are required to apply for a further visa or a variation to their
existing visa if they find new employment.
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123,000 residence approvals when the current New Zealand Residence

Programme expires on 30 June 2014. This equates to approximately 41,000
approvals each year. Around 1,680 migrants (through all categories) (four per
cent) a year come onto a main benefit each year. The costs will vary
depending on the analogous benefit they would be receiving if they were
eligible for a main benefit.
8

Recent residents are eligible for EB and JS-H on hardship grounds until they
meet the two year minimum residency period. After this point, they then can
receive other welfare assistance and do not need to prove hardship.

In the year ending December 2013, 2,072 beneficiaries were receiving a main
benefit where they had lived in New Zealand for more than two years (but
less than three). The majority were receiving Jobseeker Support. Over the
period 2007 2011 there was a small increase in the number of recent
residents (0 5 years) who accessed main benefits.

Migrant partners receiving benefits

10 Partners of primary beneficiaries receive a share (normally half) of their
partners main benefit paid at a couples rate without being subject to a
minimum residency period provided they meet the other residency
requirements (that is, hold a residence class visa and be ordinarily resident in
New Zealand).
11 It is estimated that 1,500 partners of main beneficiaries a year receive a
share of their partners benefit. The majority of partners are female (78 per
cent), with partners from the Pacific making up 18 per cent, compared to 14
per cent from China and seven per cent from India 3.
Hardship-tested benefits
12 If a recent migrant finds themselves in hardship and cannot support
themselves, there are two hardship-tested benefits that can be accessed if
they have a esidence class visa: EB and JS-H.
13 Criteria for access to a hardship-tested benefit (the Emergency Benefit or
Jobseeker Hardship) is anyone:

who is not a full-time student; and

has cash assets of:

less than $4,300 if single, or $7,464 where married, in a civil union

or defacto, or is single with at least one dependent child; and

has no other means to support themselves or spouse/partner or

dependent children.

14 The EB and JS-H are paid at the rate of the analogous benefit a person would
receive if they were eligible for a main benefit. For example, a sole parent will
receive a sole parent benefit rate, while a single person would receive the
same rate as a person on Jobseeker Support.

3 Partners who have lived in New Zealand between zero and three years
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15 As at November 2013, 4,649 people with insufficient residency (less than 2

years) were receiving EB (71 per cent of the total number of those on EB),
and 18 per cent (650) were aged under 65 years. 451 (94 per cent) of those
receiving JS-H had insufficient residency. The majority of those under 65 years
receiving either EB or JS-H would be receiving payments equal to the
Jobseeker Support rate of payment.
Problem definition
New Zealands residency settings for accessing welfare assistance is
not balanced by the contributions migrants have made to New Zealand
16 In 2011, the benefit rate across all recent migrants was 5.1 per cent. A 2013
research report from MBIE Labour Market Outcomes of Recent Migrants to
New Zealand shows that benefit rates tend to increase the longer someone
has resided in New Zealand. For example, in 2011, the benefit rate two years
after residency was approved was 3.3 per cent compared to 6.3 per cent for
those whose residency was approved two to five years previously. While this
could indicate that the longer a person lives in New Zealand, the more likely
they are to need welfare support, particularly as a result of using up other
support (such as savings) that has been in place for the two year residence
period.
17 The average cost of a single person receiving Jobseeker Support over a year is
$10,800 and $15,600 for a sole parent (without additional support). A migrant
working two years on a minimum wage pays approximately $8,400 in income
tax. This can mean that overall the cost burden is borne more by the
government than the migrant when the eligibility for accessing a main benefit
is set at two years.
18 In addition, the two year residency requirement for accessing main benefits is
now out of alignment with the student support system, which has recently
increased its residency requirements to three years to ensure migrant
students are committed to New Zealand. There is evidence that some
migrants use the student support system as a means of support when they
are out of work. As they now have an extra year before they are eligible for
student support, this may incentivise a shift towards accessing the welfare
system for that additional year.
The residency requirements for single applicants and partners differ
19 Currently, single migrants need to meet all of the residency requirements to
be eligible for a main benefit, including having lived in New Zealand
continuously for at least two years at any one time since obtaining a
residence class visa.
20 Partners of primary beneficiaries, on the other hand, receive a share of their
partners benefit paid at a couples rate without being subject to a minimum
residency period provided they meet the other residency requirements.
21 This situation means that partners of beneficiaries are treated preferentially
to single migrants who have to meet all the residency requirements to receive
a benefit. It raises equity issues based on family status. For example, a New
Zealand beneficiary can have a foreign partner who has lived in New Zealand
for less than two years and receive the married rate of benefit payment.

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While a single migrant has to wait until they have lived in New Zealand for
the minimum residency period before being eligible for a main benefit.
Hardship-tested benefits
22 The current criteria for hardship tested benefits are quite wide. A recent
migrant with few cash assets who does not meet the minimum residency
period can access a full rate of benefit immediately, circumventing the
statutory minimum residency period. There is evidence that some cases of
hardship, where these benefits were granted, could have been avoided.
Additionally, New Zealand hardship tested benefits for migrants are relatively
easy to obtain compared to the hardship tested benefits in other countries.
For example, in Australia a migrant must have a significant change in
circumstances before being eligible for a Special Benefit.

Objectives
23 The objectives of this package are to:

strike a better balance between the contributions recent migrants have made to
New Zealand and the welfare assistance they can currently receive;

strengthen the incentive on recent migrants to provide for themselves in their first
few years to make more of a contribution to the New Zealand economy;

reduce the number of recent migrants, including those who are partners of
beneficiaries, accessing benefits;

achieve fairness and equity across the welfare system; and

achieve fiscal savings for government.

24 The package contains proposals which are designed to achieve the objectives.

Proposals
Out of Scope?
25 Those aged 65 years and over, and refugees and protected persons, will not
be affected by these proposals. Other initiatives, such as a compliance-based
data match currently being developed between MSD and MBIE will identify
sponsored migrants where they are accessing a benefit during their
sponsorship period. The Parent Category, the main sponsorship visa, allows
parents to reside in New Zealand. If identified, a migrants benefit may be
cancelled and their sponsor may be required to repay any costs paid in
benefits.

Options and impact analysis

Option 1: Retaining the current welfare policy settings (status quo)
26 This option retains the relatively generous current settings and does not meet
the objective of achieving fiscal savings, or reducing the number of migrants
accessing benefits. It also means that there would continue to be a
misalignment between the student support system and the welfare system,
meaning it may incentivise some migrants to access the welfare system
rather than the student support system.

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27 Partners of beneficiaries will continue to be eligible for a share of their

partners benefit, paid at the couples rate, without being subject to a
minimum residency period, continuing the differing treatment of couples from
single migrants. This does not meet the objective of fairness and equity.
28 Contributions remain disproportionate to the cost of providing benefits.
Option 2: Change the welfare policy settings (preferred option)
29 This option is for changes to the welfare policy settings in particular
extending the minimum residency period from two years to three and
requiring all partners of main beneficiaries to also meet this new minimum
residency period.
Extending the minimum residency period from two years to three
30 On balance, MSD prefers establishing a three year minimum residency period
as this is considered to be a reasonable length of time for a recent migrant to
have lived in New Zealand before accessing a benefit (unless the person is in
hardship). Early consideration was given to introducing a contributions-based
welfare eligibility rule. However, this was rejected as it is a fundamental
change to the welfare settings and would be complex to administer. Changes
to the welfare system from the welfare reforms are still bedding in and this
type of change would require a multi-agency approach.
31 This option also generates a modest level of fiscal savings without unduly
lengthening the minimum residency period for a benefit and is a
straightforward legislative change. It still achieves the objective of reducing
the number of people accessing a main benefit.
32 Increasing the minimum residency period from two years to three years would
also align with the Governments policy change in January 2014 to extend the
minimum residency period for Student Loans and Student Allowances from
two years to three.
Partners
33 It is also considered that both members of a couple should individually meet
the minimum residency period before the main applicant is eligible for the
couples benefit rate or equivalent.
34 MSD considers that this option for partners will achieve a reduction in the
number of people claiming half a couples benefit or a benefit in their own
right. Fiscal savings would therefore be achieved and this option is more
equitable as partners accessing a share of a main benefit would need to meet
a minimum residency requirement regardless of their family status or whether
they are a primary applicant or partner.
35 Partners who are no longer eligible to be included in the couple rate of benefit
or equivalent through their partner may be eligible for a hardship tested
benefit in their own right under the proposed tightened rules.
Impact
Extending the minimum residency period from two years to three

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36 Approximately 1,450 migrants will be affected by extending the minimum

residency period from two years to three each year. 4 In the year ending
December 2013, 1,843 beneficiaries were receiving a benefit where they had
lived in New Zealand for more than two years but less than three. Of these,
275 migrants were refugees who would not be affected by the changes
because the existing rules already protect them.
37 Overall, the number of recent migrants granted a benefit between two and
three years is relatively consistent across all age groups (although most are
aged 20 24 years).
38 An increase from two years to three years would require recent migrants to
ensure that they had support (savings, family support) for an extra year
before they became eligible for a benefit. This would need to be accompanied
by an information campaign to ensure prospective and existing migrants
seeking residence in New Zealand knew about the new requirements. It could
encourage them to have sufficient savings if they found themselves in need
of financial support. If they genuinely struggled, they could still apply for a
hardship tested benefit.
39 It is considered that the prospect of having to save for possible longer-term
financial support or access hardship for an extra year will not usually impact
on a prospective migrants decision to migrate. Few primary migrants
themselves access benefits, and there continues to be a substantial number
of migrants who enter on a temporary visa (and are not eligible for any
welfare support), indicating that access to welfare is not a major factor in
deciding whether to migrate or not. A recent study by the London School of
Economics concluded that the destination countrys welfare system does not
impact greatly on a migrants decision to move there 5.
Partners
40 It is estimated that 1,500 partners of main beneficiaries would be impacted
by introducing a minimum residency requirement for partners.
41 These couples would have to ensure they had enough savings to support
themselves, given that the migrant partner would not be eligible for their first
three years of residence. If this proved insufficient then they would need to
rely on support from family or, as a last resort may be able to access
assistance through hardship tested benefits. Tightening the criteria for
hardship-tested benefits will mitigate the number of recent migrants using
this as an alternative means of support while continuing to assist those who
are in hardship.
42 Partners aged between 25 34 years will be most affected implying that there
may also be children affected which could be concerning if household income
reduced to a single beneficiary rate. To mitigate the impact on children, the
eligible main beneficiary would be eligible for a sole parent rate of assistance
(which is higher than the Jobseeker Support rate). They would also be eligible
4 This estimate is based on the number of grants rather than the number of people who
accessed a benefit so the total number of people may be lower.
5 Schulzek, N The impact of welfare systems on immigration: An analysis of welfare
magnets as a pull-factor for asylum seekers and labour migrants LSE Migration Studies Unit
Working papers No. 2012/02
8 | Regulatory Impact Analysis: Regulatory Impact Statement

for other assistance (such as Accommodation Supplement, childcare

subsidies, etc).
43 Extending the minimum residency period from two to three years is expected
to create savings of $8.178 million in 2016/17 and $8.350 million in 2017/18,
assuming uptake of EB and JS-H is 40 per cent by those who no longer meet
the minimum residency criteria. Forty per cent is considered conservative
given that the criteria for EB and JS-H is being tightened.
44 Aligning the residency requirements of partners of main beneficiaries with
single applicants could generate estimated savings of $3.180 million in
2016/17, and $6.414 million in 2017/18 based on EB uptake of 20 per cent
(assuming that the hardship test to access a hardship-tested benefit is
tightened).
45 The proposal requiring partners of main beneficiaries to meet a minimum
residency period before accessing a share of their partners income draws a
distinction based on marital status and creates a disadvantage for people who
are in a relationship with a main beneficiary due to the period of three years
before being eligible for a share of their partners income.
46 The proposal to introduce a minimum residency period serves an important
objective: striking a fairer balance between the length of residency in New
Zealand and entitlement to government assistance. The removal of the
distinction based on marital status enables the Government to treat all
applicants the same regardless of their marital status.
Alternative main benefit setting options considered but rejected
Extending the minimum residency period to four or more years
47 Extending the minimum residency period to four or more years was
considered. This option would provide greater savings and reduce fiscal costs
but may be perceived as being too stringent on recent migrants who choose
New Zealand as their new home, and goes against the ethos of new Zealand
being a welcoming country. Recent migrants would continue to be eligible for
EB and JS-H on hardship grounds during the period they are ieligible for a
main benefit (under a tightened test), but MSD considers that it would not
strike a fair balance between the length of time a migrant has resided in
New Zealand and the government financial assistance they can receive.
48 Increasing the residency period longer than three years would put New
Zealand out of step with the majority of similar jurisdictions. Very few
jurisdictions require a welfare eligibility period of four years or more. Ireland,
Sweden and the United Kingdom have two year residency requirements
before eligibility to welfare but this is balanced by the fact that these are
contributions-based. Australia also has a two year period before welfare
eligibility, but this does not extend to New Zealanders 6 and permanent
residence visas to migrants of other jurisdictions are restricted.
Requiring all migrant partners of main beneficiaries aged under 55 years to meet
a minimum residency requirement

6 New Zealanders in Australia are only eligible for a one-off six month duration benefit after
10 years or more being resident in Australia.
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49 Officials considered the option to restrict the minimum residency

requirements to partners of main beneficiaries aged under 55 years to three
years. In this option, partners over the age of 55 years would not be affected
by the proposals, recognising that some older partners, particularly women,
may have had fewer opportunities to engage in paid work and may therefore
be more reliant on receiving a share of their partners income.

50 While those aged 55-65 who may have fewer opportunities to engage in paid
work, this option was not progressed further as a higher proportion of women
now participate in the labour force than previously. For example, in 19867, the
female labour market participation rate for those aged 60 64 years was 22
per cent; now, it is 66 per cent.
51 The option would discriminate on the basis of age and having these different
rules would be unjustifiably discriminatory. In contrast, the preferred option
applies to all partners on the basis that that all partners accessing a share of
a main benefit would need to meet a minimum residency requirement
regardless of their family status.
This preferred option would also require a tightening of hardship-tested
benefits
52 Under this proposal, recent migrants with less than three years residence may
also apply for EB and JS-H. To support the changes proposed above to meet
the objectives and be effective, the hardship test would be tightened so that
these benefits are granted in restricted circumstances only for those who do
not meet minimum residency requirements.
53 The hardship test would have additional criteria for people with insufficient
residency so that it applied to anyone:

who is not a full time student and has cash assets of:

less than $4,300 if single, or $7,464 where married, in a civil union or defacto,
or is single with at least one dependent child

and has no other means to support themselves or spouse/partner or dependent

children;

AND
the hardship circumstances were not reasonably foreseeable, and/or
there is not a good and sufficient reason for avoiding hardship, and/or

they could not reasonably rely on family support.

54 It is estimated that 40 per cent of those who no longer meet the three year
residency criteria would access hardship-tested benefits, as would 20 per cent
of those who would no longer be eligible for a benefit through their partner.
This reflects the fact that a number of these migrants would still be able to
meet the current criteria for hardship.
55 The tightened hardship rules could be implemented amending the Social
Security Act 1964 and amending the Ministerial Direction in relation to
7 The Household Labour Force Survey began in 1986. In order to compare the participation
rate with present day, 1986 data has been used rather than earlier data.
10 | Regulatory Impact Analysis: Regulatory Impact Statement

Emergency Benefit and Benefits on Ground of Hardship. This ensures that the
criteria are transparent and enforceable. It is considered that while the
Direction could be amended independently of the SSA, all parts of the
proposals mutually support each other and are best done simultaneously to
achieve the objectives.
Option 3: Change the immigration policy settings
56 This option would change the immigration settings to achieve the desired
reduction in recent migrants accessing benefits. These changes would likely
include tightening access to residence class visas through ensuring that
migrants applying for residence had sufficient financial means to support
themselves for the first few years, tightening the criteria by which migrants
can be approved residence, and widening the scope of temporary visas,
amongst other things.
57 This would provide greater contributions and fiscal savings, but would also
have a wide effect on all prospective recent residents (including those who
will never access the welfare system) and potentially lower numbers of
prospective migrants from applying for residence in New Zealand. In an effort
to reduce the number of migrants accessing benefits, overall migration would
potentially be restricted, thereby not achieving the objective of fairness and
equity.
58 However, it is acknowledged that changing immigration settings would have
an impact on the number of migrants accessing benefits. The preferred
approach of amending the welfare settings would complement any changes
to the immigration settings, which must be made by MBIE and the Minister of
Immigration.
59 MSD supports work that MBIE is undertaking to review settings where
migrants may be gaining residence who do not have sufficient means to
support themselves and are, therefore, accessing government support.
Proposed transitional arrangements
60 The proposed transitional arrangements are designed to be simple to
administer. From the date the proposed policy changes come into effect, new
clients will need to meet the new criteria as outlined in the above proposals.
61 Existing clients who no longer meet the minimum residency requirements will:

continue to be covered by the previous settings while they are

beneficiaries

be subject to the new criteria if they applied for a benefit (excluding

supplementary assistance) after these new provisions came into effect.

62 The same transitional rules will apply to partners of main beneficiaries.

Impact of the preferred package
Overall, the package will affect around 3,000 recent migrants a year.
Cost implications of the preferred package

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11

63 The overall impact of the initiatives is limited relative to the overall level of
expenditure on main benefits. Expenditure on these benefits will total $4.523
billion in the year ending June 2014. By comparison:

the cost of paying benefits to primary beneficiaries with between two and
three years residence is estimated at around $8.5 million a year (0.19 per
cent of that total).

the cost of paying benefits in respect of partners with less than three
years residence is estimated to be around $6.6 million a year (0.15 per
cent of that total).

64 However, total savings for these proposals are estimated to be $11.358

million8 in 2016/17 and $14.546 million in 2017/18 depending on uptake of
hardship tested benefits9.
65 Implementation costs are expected to be $1.180 million in 2015/16 with
ongoing operational costs of $0.06 million in 2016/17 and the outyears.
Further analysis will be required to refine the IT costs as they could change
depending on more detailed analysis. The majority of IT costs would be
incurred by the new requirements for partners to meet a minimum residency
period. Currently, there is no IT system set up to do this. Other significant
costs are in communications, where translating information and republishing
brochures (as they are currently explicit regarding the minimum residency
period required before being eligible for a main benefit) will be necessary.

Consultation
66 The Ministry of Business, Innovation and Employment; the Ministry of
Education; the Treasury; the Ministry of Foreign Affairs and Trade; the Ministry
of Justice, Veterans Affairs New Zealand, the Office of Ethnic Affairs and the
Ministry of Pacific Island Affairs have been consulted on these proposals in the
Cabinet paper and RIS and their comments have been incorporated. The
Department of Prime Minister and Cabinet was informed.
67
68 Initial consultation with stakeholders was constraned by the initiative being
Budget Sensitive. Subsequent conultation was then considered as having the
potential to cause behavioural changes in decision-making by skilled migrants
not to migrate to New Zealand at all, even though the policy was only in its
initial policy proposal stages. Consultation is further constrained by the preElection period, where the Governemnt is limited in its ability to respond to
concerns in the immigration space. As an alternative, it is considered that
many government agencies are connected to migrant issues and could
adequately raise potential concerns about this policy without unduely
influencing potential skilled migrants at this early stage of the policy porcess.

8 These savings exclude implementation costs.

9 Assuming take up of EB and JS-H is: 40 per cent by those who no longer meet the three
year residency criteria and 20 per cent by partners who are no longer eligible through their
partner.
12 | Regulatory Impact Analysis: Regulatory Impact Statement

69 as such, consultation with agencies has raised relevant issues that officials
are confident provide the Minister with robust policy proposals at this time.
The Ministry of Womens Affairs were concerned with the impact of these
proposals on migrant women who are victims of domestic violence, and the
Office of Ethnic Affairs raised concerns regarding the impact on workers who
report worker exploitation and have to leave their employment. In response to
these concerns, we advise that MSD policies already provide financial support
for migrants in these situations and the proposed changes to hardship tested
benefits would not change this.
70 These changes will require legislative change and therefore public
consultation will be undertaken as a part of this process.

Conclusions and recommendations

71 MSD analysed each of the options set out above against the policy objectives.
The preferred option is based on this analysis above, and therefore MSD
recommends:

extending the minimum residency period from two years to three; and

aligning the residency requirements for partners of beneficiaries with

single applicants of main benefits (three years), and

72 These changes are best supported to meet the objectives by also tightening
hardship-tested benefits.

Implementation plan
73 To implement these proposals IT system changes would be required, for
example, to adjust existing assessment and eligibility rules. Operational
processes would need to be changed and front line staff would need to be
informed of the changes and trained. MSD will work with officials from the
Ministry of Foreign Affairs and MBIE so that migrants and prospective
migrants, considering applying for residence in New Zealand, are aware of the
changes.
74 To implement the package, legislative changes to the SSA are required.
75 The Ministerial Direction in relation to Emergency Benefit and Benefits on
Ground of Hardship will also need to be amended, and to provide a robust
package that meets the objectives, the SSA and the Direction should be
amended at the same time.

Monitoring, evaluation and review

76 MSD will review the effectiveness of this policy as part of the usual monitoring
of main benefits. Findings will feed into ongoing implementation of both
proposals and any improvements required.It is expected that the number of
migrants and partners of main beneficiaries accessing main benefits between
two and three years after gaining residence will drop significantly.

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13