According to DHHS, this is NOT abuse, what are your thoughts?

I received this message from a concerned person regarding the care of a little boy. I would like your (the Australian public) opinion whether or not this constitutes abuse. According to DHHS it does not! Below is the message I received and the picture I would like to have your opinion on. "Hi sue i wanted to forward this to you as i have been forwarded this picture of a child's foot that brings the question of neglect into the equation. This were taken from X XXX XXXXs photos after the shoes were removed during a visit. This child has lost weight and showing signs of trauma. If you would like further information please get back to me. Kind regards XXXX XXXXX