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Commercial In Confidence
Decision Document
National Investigations Unit Structure
Claims Management Group
30 May 2014
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Contents
1.
Introduction
3
Current context
3
Consultation and submissions
3
2.
Key themes from submissions
4
3.
Detailed decisions
10
4.
Feedback required: Intelligence model and structure
14
5.
Implementation
18
Support
18
Process
18
Implementation
18
Timeframe for implementation
18
Figures
Figure 1: New Integrity Services Structure ............................................................................... 11
Figure 2: Proposed New Intelligence Structure ........................................................................ 15
Tables
Table 1: Impact on current positions – Integrity Services ......................................................... 12
Table 2: New positions established – Integrity Services ........................................................... 13
Table 3: Proposed impact on positions – Intel igence Model .................................................... 16
Table 4: Proposed new roles – Intel igence Model ................................................................... 17
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1. Introduction
Current context
On 10 April 2014, we issued a consultation document proposing a new structure for the National
Investigations Unit (NIU) including a change in unit name, business group reporting line, and
operating model.
As outlined in the Proposal for Consultation, the current NIU model has an almost exclusive focus on
client (external) fraud, which has been to the detriment of achieving prevention, deterrence, and
detection outcomes with providers and levy payers. The current model is also not linked to ACC’s
newly established Counter-Fraud Outcomes Model which sets out the framework for ACC to have a
more robust approach to the wide range of potential third party and employee-focused threats it
faces.
Consultation and submissions
The consultation document was provided to staff within the NIU, with submissions due by 5pm on
Wednesday, 7 May 2014. The wider organisation was also given the opportunity to comment on the
proposal.
A total of 36 submissions were received covering a wide range of views concerning both the content
of the proposals and matters of process. Submissions were of a high quality reflecting that
considerable thought and analysis had gone into reviewing the proposal and developing alternative
options for consideration.
In summary staff were generally supportive of the new direction proposed. This document sets out
the decisions for the new Integrity Services (formerly National Investigations Unit) structure at ACC.
There are two main parts to the document. Section 2 deals with the key themes that emerged from
the submissions which have been summarised, while section 3 sets out more specific issues and
decisions.
The five key themes to emerge from submissions are in relation to:
New fraud model proposed;
Intel igence model;
Impact on roles;
Additional (fourth) area; and
General
Thank you for those of you who took the time to make submissions on the consultation document.
Yours sincerely
Sid Miller
Herwig Raubal
General Manager, Claims Management
General Manager, Actuarial and Risk
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2. Key themes from submissions
There were five key themes that emerged from 36 submissions provided. These are covered in this section.
Theme One: New Fraud Model Proposed
Feedback
Response
Feedback was supportive of the alignment to the
ACC are committed to ensuring that the shift leads the team in the right direction and provide ACC a
enterprise wide ‘three lines of defence’, with staff
counter-fraud model, which better suits its risk capability framework.
confirming their familiarity with this model.
Staff highlighted potential workflow issues moving into A focus on a change in the mix of investigations across Levy Payers, Clients and Providers that are
the new structure and felt that it will not be
‘high impact’ investigations which have a high return on financial and reputational (deterrence)
sustainable given the increase in workload with the
outputs for the organisation. An enhanced intel igence model (see proposed change in section 4) to
unit’s current capacity.
determine appropriate areas for investigation that result in higher level outcomes will assist to achieve
this.
Once the new structure is implemented, the Head of Integrity Services will be responsible for
determining appropriate resourcing to ensure the Counter-Fraud Outcomes Model can be delivered
successfully across the team.
Staff expressed the need for training in the new areas ACC is committed to providing development across the new fraud areas and ensuring that the
of; provider, levy and internal fraud investigation.
Counter-Fraud Outcomes Model is successful y implemented. Once the new structure is embedded,
the Head of Integrity Services will be responsible for delivery of the strategy.
Theme Two: Intelligence Model
Feedback
Response
A group submission was received from the
The feedback provided was considered significant and prompted reconsideration for retaining a
Intel igence Team that made a number of
modified version of the centralised model. The rationale for a centralised versus decentralised model
recommendations. These recommendations are
is also considered critical to the success of the proposed new structure and Counter-Fraud Outcomes
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addressed throughout this theme.
Model. Further thought in this area was undertaken and we are seeking further feedback on the
Intel igence structure within Integrity Services. More information can be seen in section 4.
The Intelligence team submission stated the new
proposed decentralised model would provide specific
chal enges including:
a lack of support and peer review;
no quality control risking privacy issues;
a reduction in the consistent detection and
prevention methodologies; and
a lack of future professional development
opportunities for staff.
Feedback was provided from the Intelligence group
This feedback was considered important in looking at how the future structure could provide greater
outlining the need to look at what the future
support to the investigation teams across the country. The decision to propose (see section 4) a
intel igence model needs to target in the new
portfolio model as opposed to decentralised model will result in improved data analytics.
structure. This has been a perceived gap by the
investigators wanting a data analytics intel igence
focus (30/70) and intel igence wanting to deliver their
perceived best practice evidence based approach
(70/30).
Unanimous feedback from Intelligence staff (including The feedback provided was considered significant and prompted reconsideration for retaining a
the Manager, Intel and Support) outlined the need for
modified version of the centralised model. The rationale for a centralised versus decentralised
a technical Intelligence Manager moving forward in
model is also considered critical to the success of the proposed new structure and Counter-Fraud
the new structure.
Outcomes Model. Further thought in this area was undertaken and we are seeking further feedback
on the Intelligence structure within Integrity Services. More information can be seen in section 4.
Staff were divided with the proposal to decentralise
As previously mentioned the feedback provided was considered significant and prompted
the Intel igence team.
reconsideration for retaining the centralised model. After a great deal of deliberation it was decided
to retain the centralised Intelligence function to ensure consistency of profiling and prioritisation of
what should be investigated. A portfolio approach will also be implemented across the Intelligence
Analysts that provides focused an aligned customer centric relationship to the Regional
investigations teams. The introduction of a new management structure supporting an enterprise
ACC approach to the risk of fraud which is focused on consistent profiling to support enterprise
prioritisation and investigation decision making is key moving for forward with the new structure.
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It wil be the responsibility of the new Head of Integrity Services and direct reports to build a culture
of improved intelligence and investigations interrelationships, through better understanding of each
function and how critical the relationship is for the success of the new Integrity function.
It is confirmed the Intelligence Analyst roles wil not be disestablished in the new structure.
Submissions from the investigators supported the
This feedback was considered important in looking at how the future structure could provide greater
decentralised intel igence model, highlighting how this support to the investigation teams across the country. The decision to propose (see section 4) a
would help improve data analytics which would help
portfolio model as opposed to decentralised model will result in improved data analytics. Having
investigators with high value high risk cases and the
dedicated Intelligence Analysts for each area wil develop greater understanding and knowledge of
ability to gain local knowledge and improve teamwork
the local issues and deliver greater customer centricity to the investigation team, creating a
across the Unit.
symbiotic relationship moving forward. This will be supported by four Intelligence Analysts having a
dedicated regional portfolio and dotted reporting line to the respective Area Investigations Manager.
There was a strong view from the Intelligence
We agree there is a need in the new structure for a senior level of intelligence capability which was
collective that the Unit needed a high level of
original y envisaged in the role of Manager, Intel igence & Support Services, reporting to the new
technical intel igence capability at a management
Head of Integrity Services.
level to support a modified centralised model.
Given the unanimous feedback that the role of Manager, Intel igence and Support Services does not
There was also feedback suggesting the Manager of
provide the level of technical intel igence expertise vital in the new structure, we are proposing a new
Intel igence should be aligned to the same level as
role of Counter Fraud Intel igence Manager, reporting directly to the Head of Integrity Services. It is
the Area Investigations Managers.
now proposed to disestablish the role of Manager, Intel igence and Support Services.
It is stil proposed that the current role of Manager, Intel igence is disestablished and a senior
leadership role is created reporting to the proposed new role of Counter Fraud Intelligence Manager.
Theme Three: Impact on roles
Feedback
Response
There was no feedback provided regarding the
Given there was no feedback regarding the proposed disestablished positions and staff were
proposed disestablishment of any positions.
generally supportive of the new operating model and structure, we can confirm the disestablishment
of the following roles:
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National Manager, Investigations; and
Investigations Manager (x2).
Staff were positive about the proposed new positions. The following proposed roles will be established:
Head of Integrity Services;
Area Investigation Manager (Waikato / BOP / Northland);
Team Administrator (Waikato / BOP / Northland); and
Integrity Investigation Manager.
No contrary feedback received regarding roles with
The proposed Operations Support and Risk Assessment Manager role title and new position
proposed minor changes.
description is confirmed in the new structure. The proposed changes to Investigator and Area
Manager position descriptions are also confirmed.
There was feedback stating that the new role of
The intel igence and investigation functions need to be consistent across all fraud areas and aligned
Integrity Investigations Manager should sit with the
to the fraud model. The Integrity Investigation Manager’s focus wil be the deterrence, prevention and
People Team.
detection of employee fraud, which could also be linked to an external party. Any HR implications
from a Code of Conduct breach perspective would continue to be investigated and managed by the
People Team, supported by the Integrity Investigations Manager.
Feedback presented the need for a consistent
Once the new structure is implemented, the Head of Integrity Services will be responsible for
investigator and senior investigator mix across the
determining appropriate resourcing requirements to ensure the Counter-Fraud Outcomes Model can
structure.
be delivered successfully across the team.
Theme Four: Additional (fourth) area
Feedback
Response
There was positive support for the establishment of
While we agree that the newly established area is large geographical y, it is important that this role
an additional area aligned to the Claims Network
align with the Claims Management Network model to ensure consistency and customer centricity.
model. Staff identified the need to make necessary
This geographical split wil continue to be reviewed consistent with the regional breakdown of the
adjustments to suit obvious geographical constraints
Branch Network.
like Whangarei being added in this coverage as it is
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better suited in the Northern Area portfolio.
Feedback referred to an error in the structure where
It was an error in the proposed and this has been corrected in Figure 1.
Tauranga appeared to have one investigator as there
are two currently. The question was asked if this was
going to be decreased in the new structure.
Theme Five: General
Feedback
Response
Generally staff were supportive of the new direction
We can confirm that the unit wil now be named Integrity Services and wil report through to the Chief
proposed, the business unit name change and
Risk and Actuarial Officer.
business group reporting line.
Staff identified the need for a case management
Once the new structure is implemented, the Head of Integrity Services will be responsible for
system and workflow tools. Also the need for
determining appropriate resources, systems and tools required to ensure the Counter-Fraud
objectives which are quality not only compliance in
Outcomes Model can be delivered successfully across the team.
focus.
The objectives wil be aligned to ACC Performance Development Cycle policies and framework that
incorporates objectives with line of sight to ACC statement of intent and competencies which are
aligned to ACC organisational values.
Some staff commented on the length of time between We appreciate this feedback and acknowledge that the time between the Deloitte report and
the Deloitte report being finalised and the consultation proposal for change may have been unsettling for staff. Following the Deloitte report being finalised
proposal being presented.
on 28 November 2013, senior management wanted to consider the information and structure
recommended. However given the importance of this team to ACC’s integrity, a lot of thought and
changes went into the proposed structure that was presented to staff in April 2014.
Some staff raised concerns in respect to the impact of The Deloitte report was only one aspect of the process to decide how the operating model and
the Deloitte report on the decisions to modify the
structure wil look moving forward. The Deloitte review looked at best practice information,
structure as proposed.
interviews across the team and business with the findings considered by the ACC Executive. Views
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of the ACC Executive team, key stakeholders and customers were also sought in the development
of the proposal provided to staff for consideration.
The consultation process allowed staff to provide their feedback on the proposed options, much of
which has been taken into account in the final decision document. This is also evident in the
additional feedback sought on the Intelligence model to ensure an effective fraud structure is
implemented for ACC.
We are satisfied that a robust process has taken place in determining the final operating model and
structure and key stakeholders have been part of reaching this final decision.
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3. Detailed decisions
This section sets out the detailed decisions for Integrity Services (formerly National Investigations
Unit). The key changes between this finalised structure and the former structure are:
Implementation of the new Counter-Fraud Outcomes Model as the strategic
foundation of Integrity Services with a broader focus across all fraud risks both internal
and external;
Change of business unit name to Integrity Services, to reflect the new holistic focus of
the Counter-Fraud Outcomes Model which includes planning, prevention, detection and
response;
Change of business group reporting line to Risk and Actuarial, to sit alongside the
other risk management functions within ACC, and improve its enterprise framework as part
of the three lines of defence model;
Improved focus on internal fraud, with specific capability based within Integrity Services;
Establish four new positions, and disestablish three positions; and
Retain the centralised Intelligence model and begin further consultation on a proposed
new structure for this team.
In addition to the key detailed decisions outlined above, to ensure the new structure is successful
development on the Counter-Fraud Outcomes Model will be provided to the wider team.
Whilst these decisions are confirmed, we have decided to seek further feedback on the
Intel igence model and structure that supports Integrity Services. More information about this is
outlined in section 4.
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4. Feedback required: Intelligence model and structure
There was a variety of feedback received regarding the intelligence model and structure as part of
the original consultation process as outlined in section 2 of this document. In summary, while there
was support for improved customer service and dedicated focus to the regions, there was also
concern that distributing the Intelligence Analyst roles into the regions would reduce the Centre of
Excellence approach required to support a holistic fraud model at ACC.
Based on this feedback
we have decided not to disestablish any of the existing Intelligence
Analyst positions, by reason of location change, and instead to retain a centralised Intelligence
function. Further, two additional Intel igence Analyst positions wil be established (in addition to the
four existing) to increase the capacity of this unit and the support it provides to the regional hubs.
The Intelligence Analysts will continue to be based in Wellington; however four wil be al ocated a
work portfolio aligned to each of the four regions. The two additional Intelligence Analyst positions
will provide wider strategic support to the Counter Fraud Intelligence Manager and take on any
overflow of work from the other analysts. Portfolios will not be static, and may change depending on
capacity and capability available. It is important that a stronger sense of customer service and
support to the regional areas is developed, and we believe a portfolio approach can achieve this.
We are seeking further feedback on the
proposal to establish a new role of Counter Fraud
Intelligence Manager, which will replace the existing positions of Manager – Intel igence & Support
Services, and the Manager – Intelligence that would be disestablished under this proposal. An
illustration of the proposed new intel igence model and structure is summarised in Figure 2.
It is proposed the Intelligence Analysts wil report to the Counter Fraud Intel igence Manager.
Through dotted line responsibility to the Area Investigation Managers, four Intel igence Analysts will
be accountable for the intel igence support to their al ocated area. This will include the need to
regularly visit and attend meetings within the relevant region to ensure regional requirements are
both understood and are being met. The Collection Manager, and Operations Support & Risk
Assessment Manager will also report to the proposed new Counter Fraud Intel igence Manager.
The
timeline for feedback on the proposal to establish the Counter Fraud Intel igence Manager
position; and disestablish the Manager – Intel igence & Support Services, and the Manager –
Intel igence will close at 12pm on 9 June 2014
Further rationale for this proposed change is outlined in Table 3 below.
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Confirm decisions to affected staff
Advise all staff of decisions
Feedback on proposed new Intel igence Model opens
12pm Monday, 9 June 2014
Consultation on Intel igence Model closes
Thursday, 12 June 2014 or
Final Intelligence structure confirmed
Friday, 13 June 2014
Expressions of interest opens
(indicative)
Friday, 20 June 2014
Expressions of interest closes
(indicative)
Monday, 23 June 2014 until
Expression of Interest interviews
Friday, 27 June 2014
Week beginning Monday, 30
Expression of interest process completed
June 2014
Appointment to new roles completed
(indicative)
Week beginning Monday, 7 July
Recruitment begins for any remaining vacancies
2014
July 2014. Specific date to be
New Integrity Services structure effective
confirmed.
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