Names used in all published decisions are pseudonyms. Any references appearing in square brackets indicate that information has been omitted from this decision and replaced with generic information pursuant to subsection 16(2AB) of the Child Support (Registration and Collection) Act 1988.

1. Mr Dodgson and Ms Maxwell are the parents of [the child], born [April] 2010. He is now 15 years old.
2. A child support assessment was registered with Services Australia - Child Support (Child Support) for [the child] on 17 May 2023, with Child Support being responsible for the collection of child support from then.
3. The care was recorded as the mother providing 100% of [the child]'s care.
4. On 17 September 2024, the father lodged two online care change advices, according to which he had been providing 42% of [the child]'s care from 2 June 2024, and 28% of [the child]'s care from 17 September 2024. The mother had been providing the remainder of the care for [the child] from those dates.
5. A child support officer recorded on 7 October 2024 that they had been unable to contact the mother, and made an original decision on that date to change the care percentages in the system as follows:
   • From 2 June 2024, the mother provided 58% of [the child]'s care and the father provided 42% of his care;
   • From 17 September 2024, the mother provided 72% care and the father provided 28% of [the child]'s care.
6. On 4 November 2024, the mother lodged an objection to the original decision.
7. On 27 October 2025, an objections officer from Child Support allowed the objection (the objection decision). The effect of this was the care of [the child] as recorded on the Child Support system went back to what it had been: that from 17 May 2023, the mother provided 100% of [the child]'s care.
8. On 11 December 2025, the father lodged an application with the Tribunal for review of the objection decision.
9. The matter was heard on 4 February 2026. Both parents attended via MS Teams audio, equivalent to attending by telephone, and gave affirmed evidence.
10. The Tribunal had before it a bundle of documents provided by Child Support, numbered 1 to 119, copies of which were provided to the parties before the hearing.

1. The statutory provisions relevant to this review are contained in the Child Support (Assessment) Act 1989 (the Act).
2. The issue which arises in this case is the amount of care provided by each parent for [the child].

1. Section 50 of the Act requires Child Support to determine a person's percentage of care during a care period, if Child Support is satisfied that the person has had, or is likely to have, a pattern of care during the care period. The percentage of care so determined must be a percentage that corresponds with the actual care of the child that Child Support is satisfied that the responsible person has had, or is likely to have, during the care period.
2. If a parent or non-parent carer has had no pattern of care during a care period, section 49 of the Act requires that a determination is made that the percentage of care was 0%.
3. Section 54D of the Act is about rounding up or down percentages of care if the percentage of care works out to be not a whole percentage. If the percentage is greater than 50% then the percentage is rounded up. If it is less than 50% then it is rounded down. (An example is that 62.2% is rounded up to 63% and 37.8% is rounded down to 37%.)
4. The legislation provides for existing percentage of care determinations to be revoked (sections 54F, 54G and 54H of the Act) and replaced by new percentage of care determinations (sections 49 and 50 of the Act).
5. Section 54F of the Act sets out that a care determination must be revoked if a change in the care percentage would affect the cost percentage. (If the cost percentage is affected, the rate of child support payable changes.) The date from which the revocation takes effect is determined according to subsection 54F(3):
   • If Child Support was notified or became aware of the change within 28 days of the change of care day, the revocation day is the day before the change of care day.
   • If Child Support was notified or became aware of the change more than 28 days after the date of the change in care, then for the person with the reduced care, the revocation day is the day before the change of care day; and for the person with the increased care, the revocation day is the day before the notification day.
6. This means that if the notification of a change in care was made more than 28 days after the change, the combined child support percentage for a child may be less than 100% during the period between the change of care day and the notification day.
7. Section 54H of the Act allows for the Registrar (Child Support) to change a care percentage even though the cost percentage will not be affected. This essentially gives the decision maker discretion to record a change or not, depending on the circumstances, even though the rate of child support payable will not be affected.
8. A care period is defined in the Act as being an appropriate period having regard to all the circumstances.

1. The mother's position is that [the child] has been in her 100% care since March 2020, following the parents' separation in January 2020.
2. On 17 September 2024, the father lodged two online care change advices, according to which he had been providing 42% of [the child]'s care from 2 June 2024, and 28% of [the child]'s care from 17 September 2024. Child Support made a decision that reflected these percentages of care.
3. When lodging her objection with Child Support, the mother gave a detailed statement providing background to the case which the Tribunal will not set out here as its focus is on the percentages of care provided by each parent.[1]
4. The mother stated that she had 100% care of [the child] except when there were overseas visitors. At these times, [the child] saw his father, but these occurred on very few occasions and did not amount to a change to the ongoing pattern of care.
5. On 19 August 2025, the father told Child Support that the last time he had seen [the child] was in December 2023. In a written statement received by Child Support on 25 August 2025, the father wrote that it had been two years since he had seen his son.[2]
6. In that written statement, the father set out the difficulties he was facing in having to pay child support based on the mother having 100% care, and that he believed the system was fundamentally flawed and unfair.
7. The Tribunal will not comment on this as its role in this review is only to determine the appropriate percentages of care.
8. At the hearing, the father said he had not seen [the child] for 2½ years, and that it was the mother who did not let him see [the child]. The father said his door was always open to [the child].
9. The mother confirmed at the hearing that she had 100% care of [the child]. She acknowledged that paying child support placed a financial strain on the father who has two young children to support. She said that she was a single mother and struggled financially also.
10. In this case, the evidence of both parents supports a finding that [the child] has been in the mother's 100% care from at least 17 May 2023, when the child support case was registered. The Tribunal finds accordingly and, therefore, can only affirm the decision under review.

[1] Page 55 of the Child Support documents.

[2] Page 82 of the Child Support documents.