Defence Determination, Conditions of service Amendment (Compassionate travel and approved clubs) Determination 2019 (No. 15)

The instrument operates by amending specific clauses in the Principal Determination and by inserting transitional arrangements. The core concepts introduced or clarified in the text are:

• Payment mechanics for benefits, as set out in the new section 15.3.32: benefits under the Division may be paid either directly to the service provider or by way of reimbursement to the person who incurred the cost. This is a binary payment mechanism; the Determination does not specify a preference or ordering between the two methods, it simply authorises both (Schedule 1 item 4, new s 15.3.32).

• Eligibility tied to postings and relationships: the new s 15.3.33, 15.3.34 and 15.3.35 all hinge on the member being on a long-term posting overseas or the member’s spouse or partner accompanying them on that posting, and on the existence of a serious illness, very serious illness, or death of a close relative or spouse/partner. The text repeatedly conditions eligibility on these factual predicates (Schedule 1 items 5-7).

• Discretion vested in the CDF: multiple provisions require that the CDF be satisfied that travel is reasonable in the circumstances before benefits are payable. The CDF must consider particular matters in some instances, for example the views of the member or spouse/partner and the member’s spouse/partner's personal legal representative when determining eligibility for a close relative’s visit under s 15.3.33(2) (Schedule 1 item 5). For member or partner travel, where more than one trip is sought, the CDF must consider past trips, relationship and reasons (s 15.3.35(3), Schedule 1 item 7).

• Cost-limiting formulae and caps: the Determination repeatedly caps the benefit at the lesser of the “allowable travel cost” or the “cost of the fares paid” in a number of contexts (for example s 15.3.33(3), s 15.3.34(3), s 15.3.35(4)(a)). For overseas travel by a member or partner, the instrument prescribes an “outcome of the following calculation, but not less than $0” and identifies variables a (fares paid) and b (allowable travel cost from Sydney to the overseas location and return) though the textual formula for the calculation is not present in the supplied extract (s 15.3.35(4)(b), Schedule 1 item 7). The "allowable travel cost" is a term linked to section 12.3.3 of the Principal Determination, which the Determination references for transitional reimbursement calculations (Schedule 3).

• Removal of local definition entries: the Determination omits the entries for “Very seriously ill” and “Seriously ill” from s 15.3.31 (Schedule 1 items 2-3). Concurrently, it amends the table entry for section 1.3.72 (Serious illness), so the textual effect appears to shift how “serious illness” interacts with specified leave and travel provisions (Schedule 1 item 1). The instrument does not reinsert alternative definitions for these expressions within the supplied text.

• Transitional retroactivity: two transitional provisions extend reimbursement entitlements to a defined cohort of members who were posted overseas between 13 May 2018 and commencement and who incurred travel costs to visit a close relative with a serious illness or to attend the funeral of a dependant. The entitlement is payable as the lesser of fares actually paid and the “allowable travel cost” as it would have been had Schedule 1 commenced on 13 May 2018 (Schedule 3 items 1-2).

The Determination therefore centres on eligibility predicates tied to long-term postings and close familial relationships, discretion exercised by the CDF, and monetary limits expressed as comparisons between an “allowable travel cost” benchmark and actual fares paid, while also adjusting the administrative list of approved clubs.

The instrument affects a defined set of actors listed or implied in the amended sections of the Principal Determination. The parties who are directly affected, according to the text, are:

• Members on long-term postings overseas, and their spouses or partners who are accompanying them: multiple provisions in the amended sections (s 15.3.33-15.3.35, Schedule 1) apply specifically where the member is posted overseas on a long-term posting and where a spouse or partner accompanies the member. Eligibility for travel benefits to visit ill close relatives or to attend funerals is expressed in terms of these posting arrangements.

• Close relatives of members and of spouses or partners: the new provisions use the phrase "close relative" and make travel entitlements available to close relatives in particular circumstances. For example, s 15.3.33 allows a close relative to be eligible to travel to the location of a seriously or very seriously ill person where the member’s spouse or partner is accompanying the member on long-term posting overseas and the spouse/partner has been certified by a doctor as seriously or very seriously ill (Schedule 1 item 5). The instrument also identifies close relatives as potential objects of member or partner travel under s 15.3.35.

• Members (and their spouses/partners) who travel from overseas to visit a close relative who is seriously ill or who has died: s 15.3.35 expressly makes the member and the member's spouse or partner eligible to have travel costs paid in such circumstances, subject to reasonableness assessments and caps (Schedule 1 item 7).

• Close relatives who must travel from their home to attend funerals or make necessary arrangements following the death of a member or of a spouse/partner accompanying a member on long-term posting overseas: s 15.3.34 permits one close relative to be eligible for travel costs in such events, subject to CDF satisfaction that the travel is reasonable (Schedule 1 item 6).

• Persons who incurred costs prior to commencement: the transitional provisions in Schedule 3 create eligibility for reimbursement for members who were posted overseas between 13 May 2018 and commencement and who paid the travel cost themselves to visit a close relative or attend a funeral. Those members may be eligible for a refund equal to the lesser of the fares paid and the allowable travel cost as defined in s 12.3.3 of the Principal Determination had the Schedule 1 changes taken effect on 13 May 2018.

• Service providers or agents: the new s 15.3.32 allows payment to be made directly to service providers or their agents, so entities providing travel or funeral-related services may be direct recipients of benefit payments under this Division.

• The CDF as decision-maker: the text repeatedly makes payment conditional on the CDF being satisfied that travel or reimbursement is reasonable in the circumstances, so the Chief (or the office identified as "CDF" in the Principal Determination) is given gatekeeping authority over eligibility and payment, and thus is materially affected in terms of decision workload and discretion.

Notably, the Determination restricts eligibility in some ways: in two sections it expressly notes that "only one close relative may be eligible for travel benefits" under that section, which concentrates the benefit to a single individual in those circumstances (s 15.3.33, note; s 15.3.34, note; Schedule 1 items 5-6). The instrument therefore affects members, their spouses/partners, close relatives, service providers, and the CDF as the decision authority, and it also creates a cohort of prior-travellers eligible for transitional reimbursement.

The Determination establishes a set of structured entitlements and creates decision duties for the CDF and administrative mechanics for payment. The principal operative duties and rights created or clarified by the text are these:

Rights and entitlements:

• A right to payment of benefits (subject to conditions) for travel in compassionate circumstances, structured as either direct payment to the service provider or reimbursement to the person who incurred the cost. This is the payment mechanism set out in the new s 15.3.32(1)-(1)(b) (Schedule 1 item 4). The right is conditional on the other eligibility tests in s 15.3.33-15.3.35.

• A close relative's entitlement to travel from home to the location of a seriously or very seriously ill person where certain conditions apply, notably where the member’s spouse/partner is accompanying the member on a long-term posting overseas and a doctor has certified the spouse/partner’s serious or very serious illness; the entitlement is subject to the CDF being satisfied it is reasonable and is capped at the lesser of allowable travel cost to the posting location and return, or fares paid (s 15.3.33(2)-(3), Schedule 1 item 5).

• A close relative's entitlement to travel to attend the funeral or make necessary arrangements following the death of a member or of a spouse/partner accompanying a member on long-term posting overseas, again subject to CDF satisfaction that it is reasonable and capped at the lesser of allowable travel cost or fares paid (s 15.3.34(2)-(3), Schedule 1 item 6).

• An entitlement for the member or the member's spouse/partner who is accompanying the member on a long-term posting overseas to have travel costs met to visit a close relative who is seriously ill or very seriously ill, or to attend the close relative's funeral if the close relative dies, with the allowable payment calculated differently for domestic and overseas destinations and subject to CDF consideration when multiple trips are requested (s 15.3.35(1)-(4), Schedule 1 item 7).

• Transitional reimbursement rights for members who were posted overseas between 13 May 2018 and commencement and who paid travel costs for certain compassionate travel. The members may be eligible for reimbursement of the lesser of fares paid or the allowable travel cost as defined in s 12.3.3 under a hypothetical effective date of 13 May 2018 (Schedule 3 items 1-2).

Duties and discretion:

• The CDF has a statutory duty to be satisfied that travel is reasonable before authorising benefits under s 15.3.33(2), s 15.3.34(2) and s 15.3.35(2). The Determination lists factors the CDF must consider for particular entitlements, such as the views of the member, the member’s spouse or partner and, if relevant, the spouse/partner's personal legal representative (s 15.3.33(2)(a)-(c)). For member or partner visits, where multiple trips are proposed, the CDF is required to consider the number of trips already provided, the relationship, and the reasons for the request (s 15.3.35(3)).

• Administrative duty to make payment consistent with the capped amounts: where the entitlement is payable, payment must not exceed the lesser of the allowable travel cost or the fares actually paid, or in the specific overseas member/partner case, the Determination requires the "outcome of the following calculation, but not less than $0" using variables a and b (s 15.3.35(4)(b)). The Determination therefore prescribes a numeric caping mechanism that administrators must apply.

• Duty to enforce the "only one close relative" limitation: the notes in s 15.3.33 and s 15.3.34 state that only one close relative may be eligible for travel benefits under those sections, which imposes an administrative duty to determine and record which close relative is to receive the benefit.

Conditional evidentiary duty:

• The eligibility tests in the amendments require a doctor’s certification in certain circumstances. For example, s 15.3.33(1)(b) requires that "A doctor has certified that a member's spouse or partner has a serious illness or very serious illness"; s 15.3.35(1)(a)(i) also requires a doctor’s certification regarding the close relative’s state. These are procedural preconditions to the substantive rights; administrators must obtain and assess such medical certification.

Payment options:

• The Determination creates two payment pathways for approved benefits, direct payment to the service provider or reimbursement to the person who incurred the cost (s 15.3.32). Administrators therefore have a duty to process payments under one of these methods, and to document the method chosen for each claim.

Limits and caps:

• Reimbursement is limited to the lesser of the fare actually paid and the allowable travel cost, where that term is invoked, or by the specified overseas calculation. The administrative apparatus must therefore compute and apply these comparative assessments.

The Determination thus creates conditional rights for designated persons while imposing evaluative duties on the CDF and administrative staff to apply evidence, reasonableness tests and cost caps when authorising and effecting payment.

The supplied Determination text does not create explicit criminal or civil penalties, enforcement sanctions, or administrative penalties within the content provided. The instrument operates by amending entitlements and administrative rules in the Principal Determination; its operative enforcement mechanisms are procedural rather than penal, consisting of decision gates, caps and documentary prerequisites.

Enforcement and approval mechanisms shown in the text are administrative in nature:

• The CDF’s satisfaction threshold is the central gatekeeping mechanism for authorising travel and reimbursement. The CDF’s evaluative role is the instrument’s primary control on who receives benefits and in what amount, for example s 15.3.33(2) and s 15.3.34(2) require the CDF to be satisfied that the travel is reasonable (Schedule 1 items 5-6).

• Cost controls are enforced via the prescribed cap rules: benefits are limited to the lesser of the allowable travel cost and the fares paid in several instances (see s 15.3.33(3), s 15.3.34(3), s 15.3.35(4)(a)). Administrators must apply these arithmetic comparisons when calculating payment amounts.

• The instrument imposes eligibility constraints that function as enforcement by exclusion. For instance the requirement that only one close relative may be eligible in particular circumstances restricts multiple claimants; administrators must enforce that single-beneficiary rule (s 15.3.33, s 15.3.34, notes).

The Determination does not set out appeal, review or penalty provisions within the supplied text. It also does not specify audit, repayment or recovery procedures where payments may have been made incorrectly, nor does it create distinct disciplinary offences related to false claims in the text provided. Any avenues for review, remedies for adverse decisions, or sanctions for misuse would therefore remain those present in the Principal Determination, Defence Act 1903, or other applicable statutes and administrative law mechanisms, none of which are appended or recited in this instrument.

Because the instrument prescribes decision-making standards (CDF satisfaction, consideration of specified views, requirement for doctor’s certification) these functions create implementation points where administrative review, record-keeping and governance processes will be required, even though no express penalty or enforcement regime is included in the text supplied.

The Determination expressly situates itself as an amendment to the Principal Determination, Defence Determination 2016/19, Conditions of service. It relies on and refers to terms and sections of that Principal Determination and on the Defence Act 1903 for authority. Key interaction points in the supplied text are:

• Statutory authority: the Determination is made under section 58B of the Defence Act 1903 (see item 3, Authority). The instrument therefore operates as a delegated instrument under the Defence Act, and its legal validity is framed by the powers accorded by section 58B. The Determination does not itself restate any of the procedural limits or contestable rights contained in the Defence Act; it simply records the enabling power.

• Reliance on the Principal Determination’s definitions and cost benchmarks: the cap calculations repeatedly refer to the "allowable travel cost" and to section 12.3.3 of the Principal Determination. The transitional provisions in Schedule 3 compute reimbursements having regard to what the allowable travel cost would have been "had the changes made by Schedule 1 of this Determination commenced on 13 May 2018." Therefore, the instrument interacts with the Principal Determination by changing how allowable travel cost benchmarks operate and by retroactively applying altered benchmarks for transitional reimbursements (Schedule 3 items 1-2). The text therefore presumes the Principal Determination contains definitional and computational detail that implementers must consult.

• Internal cross-referencing within the Principal Determination: the substitution in section 1.3.72 and the removal of definition entries in section 15.3.31 alter the internal definition architecture of the Principal Determination. The instrument removes entries for “Very seriously ill” and “Seriously ill” from s 15.3.31 and substitutes a new table entry into s 1.3.72 that references compassionate leave under Chapter 5 Part 9 Division 2 and travel for compassionate leave under Chapter 15 Part 3 Division 6. Those internal textual changes will alter how other provisions in the Principal Determination that reference those terms operate, but those other provisions are not reproduced in the supplied text.

• Administrative payment and procurement law interfaces: by authorising direct payment to service providers or reimbursement to claimants (s 15.3.32), the Determination creates an interface with government payment procedures and possibly procurement or travel-contractor arrangements; those processes and any constraints on direct payment would be governed by broader departmental financial delegations and Commonwealth procurement rules, which are not included in the Determination text.

• No express modification to external statutes or rights: the instrument does not purport to override other Commonwealth statutes, nor does it set out remedies, judicial review access, or interactions with social security, taxation, immigration or transport law in the supplied text. Any such interactions would be indirect, for example where reimbursement of fares may have incidental tax or visa consequences for individuals, but those are outside the Determination’s text.

• Approved clubs list amendment: the insertion of "Spain Holmes Place - Capitán Haya, Madrid" into section 15.8.7 adds a location to an internal list of approved clubs. That list may interact with other administrative entitlements or allowances that reference approved club locations in the Principal Determination.

Overall, the Determination is drafted as an internal amendment to the Defence Conditions of service framework, operating by cross-reference to the Principal Determination and relying on financial and administrative systems external to the instrument for implementation. The Determination’s substantive effect therefore depends on the content and operation of the Principal Determination and on departmental administrative rules; implementers must consult the Principal Determination (for example s 12.3.3) and financial delegations to fully operationalise the changes.

The instrument itself is an amending Determination to Defence Determination 2016/19, Conditions of service. The supplied text records the following specific amendments and temporal mechanics:

• Commencement: the Determination commences on 13 June 2019 (item 2, Commencement). The date of signature is 31 May 2019.

• Schedule 1 amendments to the Principal Determination:

  • Section 1.3.72 (Serious illness) had item 1 omitted and substituted with a new table entry referencing compassionate leave under Chapter 5 Part 9 Division 2 and travel for compassionate leave under Chapter 15 Part 3 Division 6 (Schedule 1 item 1). The supplied text shows the substitution but does not include surrounding table context from the Principal Determination.
  • Section 15.3.31 had the entries for “Very seriously ill” and “Seriously ill” omitted (Schedule 1 items 2-3).
  • Section 15.3.32 was wholly omitted and substituted with a short payment rule enabling payment directly to service providers or by reimbursement to the person who incurred the cost (Schedule 1 item 4).
  • Sections 15.3.33, 15.3.34 and 15.3.35 were replaced by new clauses setting out eligibility, CDF discretion, caps and calculation methods for various compassionate travel scenarios (Schedule 1 items 5-7).

• Schedule 2 amendment:

  • Section 15.8.7 (Approved clubs) was amended to insert "Spain Holmes Place - Capitán Haya, Madrid" after the entry for Solomon Islands (Schedule 2 item 1). The instrument does not list other entries in the approved clubs table within the supplied text.

• Schedule 3 transitional provisions:

  • Two transitional provisions were inserted to provide reimbursements for members posted overseas between 13 May 2018 and commencement who had paid travel costs to visit a close relative with a serious illness or to attend a funeral for a dependant (Schedule 3 items 1-2). These provisions compute the reimbursable amount as the lesser of the fares paid and the allowable travel cost as defined in s 12.3.3 of the Principal Determination, had Schedule 1 changes taken effect on 13 May 2018.

• Authority and maker: the Determination is made under s 58B of the Defence Act 1903 and is signed by Louise Judith Memmolo, Acting Assistant Secretary, People Policy and Employment Conditions, Defence People Group, indicating the administrative origin of the amendment.

The supplied text does not include prior amendment traces within the Principal Determination, nor does it list earlier versions or the legislative history of the Principal Determination itself. The amending instrument records specific insertions, substitutions and omissions and it provides a narrowly drafted retroactive remediation in Schedule 3 for a defined cohort of members who paid fares in a specified prior interval.

The instrument, as supplied, contains no recorded litigation history, case references, or judicial determinations. It is an administrative amending Determination; the text does not mention any past or ongoing litigation, nor does it cite precedent or judicial interpretation.

From the text alone, the following observations about potential legal friction points can be drawn, noting these are observations about features that commonly lead to review rather than citations of actual cases:

• The Determination vests evaluative discretion in the CDF by requiring the CDF to be "satisfied" that travel is reasonable in a number of circumstances. In administrative practice such discretionary decisions may be susceptible to merits or judicial review under administrative law frameworks where applicants allege error of law, unreasonableness or procedural unfairness. The Determination itself does not specify internal review rights or processes in the supplied text.

• The instrument removes the entries for “Seriously ill” and “Very seriously ill” from s 15.3.31. Removing textual definitions can create interpretive disputes about the threshold that must be met for medical certifications; however the supplied text does not reproduce alternative definitions or guidance. Such interpretive uncertainty is a common locus for administrative review, though there is no record of litigation in the instrument.

• The overseas travel calculation in s 15.3.35(4)(b) requires "the outcome of the following calculation, but not less than $0" and identifies variables a and b (fares paid; allowable travel cost from Sydney to the overseas location). The supplied extract does not include the full mathematical formula for the calculation. Absence of the formula in the supplied text could generate implementation or legal challenges around how the calculation is to be applied; the Determination as presented does not indicate how disputes about the calculation are to be resolved.

Because no cases are mentioned in the Determination and no litigation history is included, the instrument itself provides no primary material about prior judicial treatment. Implementers or advisers seeking to assess litigation risk will need to consult the Principal Determination, the Defence Act 1903, and general administrative law principles, none of which are reproduced in the supplied text.

The Determination contains several implementation and interpretive features that warrant close administrative attention, because they create concrete obligations and potential ambiguity:

1. Removal of definition entries without visible replacements in the supplied excerpt:

   • The instrument omits the entries for “Very seriously ill” and “Seriously ill” from s 15.3.31 (Schedule 1 items 2-3) while substituting the table entry in s 1.3.72. The supplied text does not show alternative definitional text for those expressions elsewhere. Implementers must therefore verify whether the Principal Determination contains other operative definitions or whether the substitution in s 1.3.72 is intended to reframe the applicable test. Failure to reconcile definitions may lead to inconsistent decision-making on doctor certification thresholds.

2. The CDF’s evaluative discretion and evidentiary expectations:

   • Several entitlements are subject to the CDF being "satisfied it is reasonable having considered" particular factors (s 15.3.33(2); s 15.3.34(2); s 15.3.35(2)-(3)). The Determination specifies some factors the CDF must consider in certain contexts, such as the views of the member or spouse/partner and, if relevant, the spouse/partner's personal legal representative. Administrative officers must therefore capture and preserve evidence of those considerations in the decision record to demonstrate compliance with the Determination.

3. "Only one close relative" limitation:

   • The notes to s 15.3.33 and s 15.3.34 state that only one close relative may be eligible for travel benefits under those sections. Administrators must have an operational rule or process for determining which close relative receives the benefit, and how competing requests are prioritised. The Determination does not prescribe a tiebreaker; absence of such guidance could generate disputes.

4. Cap mechanics tied to an external benchmark:

   • Payments are frequently capped at the lesser of the “allowable travel cost” and fares paid (for instance s 15.3.33(3), s 15.3.34(3), s 15.3.35(4)(a)). The term "allowable travel cost" is defined in section 12.3.3 of the Principal Determination, which the supplied text does not reproduce. Administrators must therefore ensure they consult that section to compute caps correctly.

5. Missing calculation text for overseas travel:

   • Section 15.3.35(4)(b) refers to "the outcome of the following calculation," identifies variables a and b, then in the supplied text the actual formula is not present. This is a concrete operational hole in the supplied excerpt. Decision-makers and finance officers must obtain the complete text to apply the cap, otherwise they risk inconsistent or incorrect payments. The Determination as supplied signals the existence of a calculation but does not provide it.

6. Transitional provisions with hypothetical effective-date benchmarking:

   • Schedule 3 computes reimbursements by reference to what the allowable travel cost "had the changes made by Schedule 1 of this Determination commenced on 13 May 2018." Implementers must therefore perform a hypothetical recalculation of allowable travel cost as at 13 May 2018 and compare it to fares actually paid to determine the refund. This is administratively awkward, and requires access to historical rate tables or cost schedules from the Principal Determination as they would have operated under the hypothetical effective date.

7. Payment routing options:

   • Section 15.3.32 permits payment either directly to the service provider or by reimbursement. Administrators need to ensure departmental payment processes are in place to pay external service providers where authorised, and to manage evidence and authorisation for reimbursements. Financial delegations and procurement rules not included here will interact with this choice.

8. Approved clubs insertion:

   • The insertion of "Spain Holmes Place - Capitán Haya, Madrid" into the approved clubs table (s 15.8.7) may have downstream impacts if other entitlements or allowances tie location-based benefits to the approved clubs list. Responsible officers should confirm any additional administrative or security approval requirements for interactions with overseas clubs.

Those implementing the Determination should therefore confirm the missing or cross-referenced material in the Principal Determination, establish evidence capture and decision-recording procedures to document CDF reasoning, adopt a consistent process for selecting the single eligible close relative when multiple claimants exist, and ensure financial and procurement rules are reconciled with the choices permitted in s 15.3.32.

Compliance under the amended Determination requires administrative processes to establish eligibility, obtain supporting evidence, apply the cap calculations and record CDF satisfaction. Concretely, administrators and decision-makers should adopt the following steps grounded in the instrument’s text:

1. Verification of eligibility predicates:

   • Confirm the member’s posting status is a long-term posting overseas where the clauses require it. The Determination repeatedly conditions entitlements on the member being on a long-term posting overseas and on whether the spouse/partner is accompanying them; confirm and document posting and accompaniment status before progressing any claim (see s 15.3.33(1)(a), s 15.3.34(1), s 15.3.35(1)).

2. Obtain required medical certification:

   • For entitlements premised on serious or very serious illness, obtain the doctor’s certification required by the relevant section, for example s 15.3.33(1)(b) and s 15.3.35(1)(a)(i). Record the certifier’s details and the medical statement in the file as documentary proof.

3. Evidence for death or funeral travel:

   • For s 15.3.34 (close relative travel following death) and for travel to attend a funeral under s 15.3.35(1)(b), obtain a death certificate or other documentary proof of death and funeral arrangements to substantiate the claim.

4. Establish the claimant and single-beneficiary decisions:

   • Where the Determination limits the benefit to only one close relative, record the decision identifying the eligible close relative and the rationale for choosing that person if more than one candidate exists (notes to s 15.3.33 and s 15.3.34). Maintain a written decision record, including any competing requests.

5. Prepare the CDF decision record:

   • Where the text requires the CDF to be satisfied that travel is reasonable, present to the CDF a succinct memorandum that addresses the factors specified in the applicable provision. For example s 15.3.33(2) lists the views of the member and spouse/partner and, if relevant, the spouse/partner's personal legal representative; s 15.3.35(3) lists factors to consider for multiple trips. Record the CDF’s consideration and conclusion in writing.

6. Compute allowable travel cost and apply caps:

   • Retrieve the definition and computational method for "allowable travel cost" from s 12.3.3 of the Principal Determination and apply it when computing the lesser-of comparisons required by s 15.3.33(3), s 15.3.34(3), and s 15.3.35(4)(a). For s 15.3.35(4)(b) relating to overseas travel, obtain the complete text of the calculation that is referenced; the supplied extract lacks the actual formula, so do not proceed using ad hoc arithmetic , consult the Principal Determination or departmental guidance.

7. Apply payment mechanics and financial controls:

   • Choose the payment method authorised by s 15.3.32, either direct payment to the service provider or reimbursement to the person who incurred the cost. Ensure the chosen payment method complies with departmental finance and procurement rules, and that receipts and proof of payment are retained.

8. Transitional claims:

   • For members posted between 13 May 2018 and commencement who paid fares and seek reimbursement under Schedule 3, determine the reimbursable amount as the lesser of fares paid and the allowable travel cost as it would have been had the Schedule 1 changes been in force on 13 May 2018. This requires reconstructing the allowable travel cost for the hypothetical date and comparing it to the actual fare paid. Keep records demonstrating how the hypothetical allowable travel cost was derived.

9. Approved clubs list:

   • Update the administrative register of approved clubs to include "Spain Holmes Place - Capitán Haya, Madrid" as inserted into s 15.8.7, and ensure any entitlements or approvals that rely on the approved clubs table are adjusted accordingly.

10. Recordkeeping and audit trail:

    • Maintain a comprehensive file for each claim that includes evidence of posting status, doctor’s certification or death certificate, cost documentation including fares paid, computations of allowable travel cost, the CDF’s consideration and decision, and the method of payment. This supports internal audit, future review and compliance checks.

11. Consult the Principal Determination and financial delegations:

    • Because multiple elements in the Determination cross-reference other sections of the Principal Determination (for definitions and allowable travel cost formulas) and because payments may interact with departmental financial controls, implementers must work from the consolidated text of the Principal Determination together with this amending Determination and applicable departmental financial delegations.

Adhering to these steps will align claim handling with the provisions in the amended sections, ensure that CDF-dependent discretionary gates are properly documented, and that cost caps and payment routing are applied consistently and defensibly.