Subject: Request for Information – Permanent Injury Compensation, ACC18 Validation, and Systemic Entitlement Transparency Failures.
Pursuant to the Official Information Act 1982, I request the following information relating to the assessment, disclosure, and administration of Permanent Injury Compensation (PIC) entitlements, and the handling of medical incapacity evidence and review processes.

Part 1: Entitlements and Transparency Obligations
1. Disclosure Policies:
• All internal ACC policies, guidelines, manuals, or directives describing the legal obligation to disclose a full list or breakdown of entitlements available to a claimant under a covered claim.
• How and when this information must be communicated to claimants in writing, particularly for those in long-term claim or review status.
2. Client Access to Entitlement Information:
• Systems or databases used to store and track claimant entitlements.
• How claimants can obtain a full breakdown of their individual entitlements and legislative basis.
• Audit trails or access logs kept to confirm this information was shared.

Part 2: Use and Recognition of ACC18 Medical Certificates
3. Validation of Medical Evidence:
• All current policies and operational guidance (including training materials, workflows, or protocols) describing how ACC18 certificates are reviewed and validated in support of incapacity or PIC claims.
• Criteria or thresholds for overriding an ACC18 certificate signed by a registered medical professional.
• How ACC ensures clinical recommendations are not arbitrarily dismissed.
4. Historical Data:
• Number of PIC-related decisions between 2020–2025 that resulted in a 0% impairment rating despite an ACC18 certificate confirming incapacity.

Part 3: Review Processes and Repetition of Assessments
5. Repetitive Review Handling:
• Policies or SOPs on repetitive/successive reviews following declined PIC claims.
• Criteria for requiring new evidence versus reusing prior assessments.
• Limits or escalation procedures for repeated internal reviews.
6. Timeframes and Delays:
• KPIs or benchmarks for resolving PIC entitlement reviews.
• Anonymised data on average time from PIC lodgement to ICRA resolution (2020–2024).

Part 4: Systemic Issues and Complaints
7. Ombudsman & Complaint Tracking:
• Number of complaints (since 2020) referred to the Ombudsman or Privacy Commissioner regarding entitlement transparency or dismissal of ACC18s.
• Outcome summaries or resolution categories (anonymised).
8. Internal Reporting on Systemic Failures:
• Internal audits, QA reviews, or executive summaries identifying systemic issues in:
- Entitlement disclosure;
- Use or dismissal of ACC18 evidence;
- Procedural fairness in PIC reviews.

Format and Response
Please provide all information in accessible electronic formats (PDF, DOCX, or CSV). If any part of this request may be refused under sections 18(d), 18(f), or 18(g), please consult with me to refine the scope.

Clarifying Context. This request supports mediation process and reflects a broader need to understand about systemic practices within ACC. I am seeking transparency and procedural fairness under the Accident Compensation Act 2001 and Privacy Act 2020.

Yours faithfully,

SPENCER JONES

Dear Government Services,

Follow-up OIA Request: Clarification and Refinement of FYI Request #31103 – Permanent Injury Compensation (PIC), ACC18 Override Criteria, and Review Processes

This request is submitted as a formal follow-up to my earlier Official Information Act request lodged via FYI.org.nz on 26 May 2025 (ref: #31103), and ACC’s response dated 25 June 2025 (GOV-040419).

Further to that response, I now seek clarification and refinement on the following matters, in accordance with sections 12, 14, and 23 of the Official Information Act 1982. Where parts of my initial request were declined under section 18(f) due to substantial collation, I have narrowed the scope to facilitate meaningful disclosure.

⸻

🔹 Refined Request for Information

1. Override of ACC18 Medical Certificates

Please provide the following:
• Any written criteria, policies, clinical guidelines, internal memos, or standard operating procedures used by ACC to override, disregard, or substitute the clinical opinion of a treating provider recorded in an ACC18 medical certificate—particularly in relation to:
• Permanent Injury Compensation (PIC) decisions;
• Section 113 suspensions;
• Assessment of ongoing incapacity or stable impairment.
• If no such written criteria exist, please explicitly confirm this.

2. Repetitive or Recurrent Use of Reassessments and Independent Clinical Advice (ICA)

Please provide:
• Any internal ACC guidance, policy, or limits on the frequency of reassessments, ICA referrals, or repeat specialist reviews in relation to the same condition or claim.
• If no frequency limit or procedural safeguard exists, please state this clearly.

3. Audit Trails and Decision Transparency
• Please confirm whether the Eos system used by ACC includes audit logs or access trails recording when and how entitlements, claim decisions, and medical certificate overrides are communicated to clients.
• If available, please provide the policy or technical description of how such audit trails are maintained and reviewed.

4. Internal Audits or Reviews Related to ACC18 Handling and PIC Decision-Making (2020–2024)
• Please provide the executive summaries, findings, or redacted excerpts from any internal audits or quality assurance reviews since 1 January 2020 that:
• Address the handling of ACC18 medical certificates;
• Review the consistency, fairness, or integrity of PIC decision-making or reassessment practices;
• Relate to complaints received by the Ombudsman or Privacy Commissioner in this context.

⸻

🟨 Notes on Scope and Format

To assist in managing workload, you may:
• Limit all disclosures to the period 1 January 2023 – 31 December 2024;
• Provide redacted excerpts or executive summaries where full reports are voluminous;
• Treat this as a refinement under section 14 of the OIA in light of the s18(f) refusals cited in your June 25 response.

I request that all information be provided in electronic form via FYI.org.nz, with appendices or file uploads attached as appropriate.

⸻

⚠️ Public Interest Statement

This request relates to systemic decision-making within ACC that materially affects the rights and welfare of claimants—especially those subject to ongoing impairment assessments. There is significant public interest in ensuring that:
• Clinical evidence is not arbitrarily dismissed;
• Reassessment processes are fair and not abusive or repetitive;
• Claimants receive accurate, transparent communication of their entitlements.

⸻

Thank you for your time and continued engagement on this important matter. I look forward to your response within the statutory timeframe.

Kind regards,

Spencer Jones
Via FYI.org.nz (OIA Request #31103)

Dear Government Services,

Tēnā koe,

This is a refined follow-up to my earlier OIA request #31103, following ACC’s refusal to provide aggregate data under section 18(f). I now seek more specific, time-limited information to clarify the scale and oversight of the issues raised.

Under the Official Information Act 1982, I request the following information:

⸻

1. Repetitive ACC18 Issuance – Long-Term Claims

For each of the last five calendar years (2020–2024), please provide:

a. The number of active claims that were 2 years or more in duration
b. Of those, how many had been issued with:
• 3 or more ACC18 medical certificates
• 5 or more ACC18 medical certificates
• 10 or more ACC18 medical certificates

c. Of those with 5 or more ACC18s issued, how many had:
• A confirmed Whole Person Impairment (WPI) assessment
• A final Permanent Injury Compensation (PIC) decision issued

⸻

2. PIC Application and Decision Delays

Please provide:

a. The average time (in months) from injury stabilisation to WPI assessment for all claims assessed for PIC in 2022–2024.
b. The number of cases where a PIC application was declined on the basis that the injury had not stabilised, despite being in receipt of 5 or more ACC18s.
c. Any internal audit, review, or quality assurance documents from the past 5 years examining delays or barriers to accessing PIC for long-term claimants.

⸻

3. Support and Escalation Mechanisms

Please provide a copy of any current:
• Internal guidance or SOPs (standard operating procedures) for case managers relating to escalation of long-term claims to PIC or IMA assessment
• Criteria or policy thresholds that guide when a long-term claimant should be referred for WPI/PIC evaluation

⸻

Background & Public Interest Justification:

This request seeks to clarify whether repetitive short-term certification is functioning, in practice, as a barrier to PIC for long-term injured persons. The request is limited in timeframe (5 years), specific in scope (claims >2 years, ACC18 counts, PIC status), and seeks only aggregated or existing internal review documents. There is a strong public interest in ensuring fairness and transparency in how ACC handles permanent injury entitlements.

If any part of this request remains too burdensome, I respectfully request that you contact me to assist in refining the scope, as required under section 13 of the OIA.

⸻

Yours sincerely,

SPENCER JONES