plied by approved societies from their Health Insurance records showed any remission of arrears that had been allowed in the material contribution years, and where in the examination of the claim for pension there was no information indicating that the conditions of title to remission of arrears had not been complied with, it was at once apparent that a full credit of contributions was available for the purpose of the average required by the Pensions Act. The decision of claims involving question of grant of credits in respect of unemployment was thus facilitated in a very substantial degree.

It was only in a very small minority of those cases where remission of arrears had been granted by approved societies that any necessity arose for independent enquiry for the purpose of verifying genuine unemployment. In these few cases the information given in the claim for pension, or elicited in the investigation of doubtful claims, was such as to indicate that the approved society would not have allowed any remission of arrears had the facts as disclosed on the submission of the pension claim been before the society at the time the question of title to remission of arrears was being considered. In such cases any claim for the recognition of weeks of genuine unemployment for purposes of the average of contributions had to be investigated on its merits, and where it was finally apparent that the circumstances had not warranted remission of Health Insurance arrears, approved societies were acquainted with the facts as ascertained. In cases of unemployment where no information was available from Health Insurance records, it was generally possible to obtain information as to payment of unemployment benefit or registration at an employment exchange from the central records of the Ministry of Labour, provided that the person was insured under the Unemployment Insurance Act, or, it not so insured, had registered at an employment exchange. There was, however, a considerable residuum of claims where the claimants were excluded from the scope of unemployment insurance because they were employed either in agriculture or in domestic service. It was found that very frequently such persons when unemployed had not registered at an employment exchange. Where no information was available from the records of the Ministry of Labour, it proved somewhat difficult to obtain adequate evidence of genuine unemployment.

13. Contributions not paid at the due dates. It is an essential condition of title to pension between 65 and 70 that at least 104 contributions under the Insurance Scheme must have been paid since the insured person's date of last entry into insurance. The responsibility for payment of insurance contributions rests on the employer, and, except where other arrangements are specially authorised by virtue of the regulations, payment of the contribution must ordinarily be made not later than the time when wages are paid in respect of each week of employment. Where contributions have not been paid at the due dates and are subsequently paid, they can be recognised for purposes of a claim

for old age pension only if they have been paid prior to the date from which the title to pension would otherwise arise. The examination of the claims for pension between the ages of 65 and 70 disclosed a number of cases of apparent non-compliance by employers with the provisions of the Insurance Act relating to liability for contributions. In such cases action was taken with all possible expedition so that the contributions, if found after enquiry to be due, might be paid and brought to account before 2nd January where the conditions of title had to be satisfied by the commencing date.

14. Irregular payment of contributions by insured persons.— It was discovered in a surprisingly large number of cases that persons had been irregularly affixing stamps to their contribution cards during weeks when they were not employed. The conditions under which an insured person is entitled to pay contributions when not employed are expressly restricted by the provisions of the National Health Insurance and Contributory Pensions Acts. With certain express exceptions no person is entitled to pay contributions himself unless as a voluntary contributor. Voluntary insurance is permitted under certain conditions, laid down in the Insurance Act, which in general require that the person must have been engaged in employment within the meaning of the Insurance Act for a period of not less than 104 weeks since the date of his last entry into insurance. It is necessary also that the person must give notice of desire to become a voluntary contributor within a prescribed period, ending usually one year after the end of the week in which employment ceases. Married women are not allowed to be voluntary contributors.

The distinction between the employed contributor whose employer pays contributions in respect of the employment and the voluntary contributor who pays his contributions himself is not merely one of liability for payment of the contribution. Certain privileges attach to the insurance of an employed contributor which do not attach to that of a voluntary contributor; and the voluntary contributor is under certain liabilities which are not imposed upon the employed contributor. Both for purposes of National Health Insurance and insurance for Contributory Pensions, an employed contributor is entitled to certain relief in respect of periods of genuine unemployment. It is only in connection with pensions and in expressly restricted circumstances that any right attaches to genuine unemployment in the case of a voluntary contributor. Under National Health Insurance, arrears of an employed contributor may be commuted by payment of what is known as an arrears penalty at a modified rate which is very much less in amount than the aggregate value of the deficient contributions. The voluntary contributor, on the other hand, must ordinarily discharge his arrears by a payment equivalent to the number of contributions that are missing. Further, a voluntary contributor is required to maintain a certain minimum of contributions, and if his record falls below the

standard he loses the right to continue to pay contributions as a voluntary contributor. These conditions do not apply to the employed contributor.

By paying contributions irregularly without the knowledge of their approved societies when unemployed, members of the insured population create many difficulties for themselves, for their approved societies, and for the central administration. When the irregular payment of contributions comes to light their position has to be regularised in relation to the requirements attaching to voluntary insurance or, alternatively, their insurance so far as it has been constructed by irregularly-paid contributions must be nullified with consequent adjustments in respect to the erroneously-paid contributions and to the benefits which may have been paid by virtue of the erroneous crediting of those contributions.

It is not the policy to cancel irregular voluntary insurance on the ground only that notice as required by the Act was not given within the time allowed. The insurance is regularised provided that at the time the irregular payment of contributions comes to notice the person would still, had notice been duly given, comply with the other conditions imposed by the Act upon voluntary contributors. This is not always the case. Through the very irregularity of their insurance, persons in this group expose themselves to the danger of failing to satisfy the tests applied to voluntary insurance. Had they given due notice to their approved societies, their societies would from time to time have issued arrears notices, appropriate to voluntary insurance, which would have had the effect of protecting the insured person against the danger of loss of the contributory right through insufficient payment of contributions due to lack of knowledge. While irregular contributing may thus be prejudicial to the rights of the insured person, it may be prejudicial also to his approved society and generally to the convenience of National Health Insurance administration. In many cases which have been brought to light, persons who have maintained their insurance by irregular payments and have continued to be treated by their approved society as though they were employed persons have been granted year after year the privileges limited to employed contributors. They have been granted relief from arrears in virtue of genuine unemployment, their benefits have been assessed and the amount of arrears penalties determined on the basis of treatment peculiar to employed contributors, and they have accordingly received benefits to which they have not been entitled. An improper burden has therefore been placed on Health Insurance funds at a time when owing to the prevalence of unemployment the liabilities to which the Health Insurance Scheme is exposed have been greatly weighted.

15. Claims disallowed.-Out of a total of 52,630 claims decided up to 30th December, 1927, 5,826 claims had been disallowed. This number included no less than 3,973 claims which had been made in misapprehension of the provisions of the

Act under which married women may qualify for pension between. the ages of 65 and 70 in right of the insurance of their husbands.

Leaving out of account these 3,973 claims, the number of claims disallowed was 1,853. Of a total of 52,630 claims decided that is a very small proportion. Six hundred and fifty-four, or fully one-third, of these claims were disallowed for the reason that the claimant had not attained the age of 65, and these claims might properly be added to those which have been accounted for as made under misapprehension. They were really premature claims, and the disallowance in no way prejudices the emergence of a title to pension if the conditions of qualification are complied with when the person attains the statutory age.

A woman who is not herself insured is qualified for a pension between the ages of 65 and 70 in right of the insurance of her husband if her husband is or has been entitled to a pension between the ages of 65 and 70 through his own insurance. It will be seen that the condition requires that the husband himself must first become entitled to a pension between the ages of 65 and 70 before any question arises of his wife becoming qualified in virtue of his insurance. It was through a fairly common failure to appreciate this that most of the disallowed claims were made.

The figure of 3,973 claims made under misapprehension was made up entirely of claims by uninsured women who could not qualify for a pension from the appointed day for the reason that their husbands could not then, and in the majority of cases could never, qualify for a pension between the ages of 65 and 70. The claimants were mainly widows or women whose husbands had already attained the age of 70 before the appointed day.

Some criticism was occasioned by the exclusion of certain types of uninsured women, particularly of wives under 70 of men who attained 70 before the provisions relating to pensions between the ages of 65 and 70 came into operation. The representations received were based generally on the argument that the woman should not be deprived of pension merely because her husband was too old, and on the assumption that had the husband been under 70 it would have automatically followed that the wife would have become entitled in right of his insurance to a pension between the ages of 65 and 70. It was also submitted fairly frequently that if a man had qualified for pension under the Old Age Pensions Acts payable by virtue of his insurance free from the conditions as to means, that should be enough to entitle his wife, if younger than himself, to a pension between the ages of 65 and 70.

These representations failed in the first place to take account of the actuarial implications of the extensions in the scope of the scheme which they urged. No insured person can qualify for a pension between 65 and 70 unless he or she has been of contributory age for at least two years subsequent to the introduction of the Pensions Act on 4th January, 1926. The financial structure of the pensions scheme is therefore based upon a mini

mum period of at least two years of potentially contributory insurance in so far as concerns the provisions relating to pensions between 65 and 70. Under the Insurance Act a man who attained 70 before 2nd January, 1928, ceased at that age to be liable for contributions under that Act. By reason of the interlocking of the contributory provisions of the Pensions Act with those of National Health Insurance, he could not therefore complete a period of two years during which he was of contributory age under the Pensions Act. Consequently he could not himself satisfy by virtue of contributory insurance the minimum conditions of qualification required by the Contributory Pensions Act for a pension between the ages of 65 and 70.

It was generally overlooked also that the conditions under which a man who had attained the age of 70 before 2nd January, 1928, could qualify for a pension under the Old Age Pensions Acts in right of insurance were of a much simpler and easier kind than the conditions of qualification for a pension between the ages of 65 and 70. Collectively the actuarial value of the relief from the enquiries as to means which distinguishes the pension payable under the Old Age Pensions Acts by virtue of insurance is fractional in relation to the value of a pension payable between the ages of 65 and 70.

It was represented also that a woman should not have to wait for an old age pension until her husband attained the age of 65. This again ignored the actuarial foundations of the scheme. There is involved also the suggestion that it can be determined while the husband is still under 65 whether or not he will be entitled to a pension on attaining the age of 65. That is, of course, not the case inasmuch as the conditions of qualification refer to the period immediately prior to the date on which the right to pension, assuming satisfaction of the required conditions, will arise.

It may be said, generally, with regard to the criticisms evoked by the exclusion of women in all of the groups that have been mentioned that they fail to take account of the fundamental principle of the scheme of pensions, which is that a pension is paid only after payment of the due premium.

Only 738 claims had been disallowed by the end of the year because of some deficiency in the insurance record that debarred the claimant from satisfying the conditions as to insurance which are required by the Contributory Pensions Act. The figure is so small as to arrest attention. It would indicate that the public were very well acquainted with the conditions as to insurance which were required before a claim for pension could be established. It suggests also that persons who have had a footing in insurance have, wherever possible, been careful to take all possible steps to avoid forfeiture of a prospective title to pension.

16. Questions of Law. The introduction of the provisions relating to pensions between the ages of 65 and 70 was smoothed and assisted by the earlier settlement, in the course of the ad