ACC’s handling of Permanent Injury Compensation (PIC), ACC18 medical certificates, and repetitive review processes

SPENCER JONES made this Official Information request to Accident Compensation Corporation

Response to this request is delayed. By law, Accident Compensation Corporation should normally have responded promptly and by (details and exceptions)

From: SPENCER JONES

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

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From: Government Services
Accident Compensation Corporation

Kia ora,

Thank you for contacting ACC’s Government Services inbox.

If your request falls within scope of the Official Information Act, we
will endeavour to respond as soon as possible, and no later than 20
working days after receipt of your request. If we are unable to respond
within the statutory timeframe, we will notify you of an extension.

 

The information you have requested may involve documents which contain the
names and contact details of individuals. Please let us know whether you
are seeking that information as part of your request. We may need to
consult before deciding whether we can release this information, and this
may take a bit more time. If we do not hear from you, we will assume that
you do not require it.

 

For more information about Official Information Act requests, please
visit: [1]Ombudsman New Zealand | Tari o te Kaitiaki Mana Tangata.

If your request relates to your claim, or you’d like more information
about lodging a claim, please contact ACC’s claims team at 0800 101 996
or [2][email address].

For personal information requests or privacy matters,
please visit [3]Request for personal information (acc.co.nz).

For general queries, please visit: [4]Contact us (acc.co.nz).

 

 

Ngâ mihi,

Government Services

PO Box 242 / Wellington 6011 / New Zealand / [5]www.acc.co.nz

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From: Government Services
Accident Compensation Corporation


Attachment GOV 040419 Appendix 1.pdf
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Attachment GOV 040419 Appendix 2.pdf
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Attachment GOV 040419 Response.pdf
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Kia ora

 

Please find attached our response to your official information request
dated 26 May 2025. If you have any questions about the response you can
contact us at this [1]address, for all other matters please use our
contact form at: [2]https://www.acc.co.nz/contact/ alternatively give us
a call on 0800 101 996.

If you are having trouble viewing the PDF, please ensure you have the
latest version of Adobe Acrobat Reader. To download this freeware please
click [3]here. 

 

Ngâ mihi
Christopher Johnston (he/him)
Manager | OIA Services

* PO Box 242, Wellington 6011

ACC cares about the environment – please don’t print this email unless it
is really necessary. Thank you.
 
 
------------------- Original Message -------------------
From: SPENCER JONES <[FYI request #31103 email]>;
Received: Tue May 27 2025 07:41:41 GMT+1200 (New Zealand Standard Time)
To: ACC <[ACC request email]>; Government Services
<[ACC request email]>; <[ACC request email]>;
Subject: Official Information request - ACC’s handling of Permanent Injury
Compensation (PIC), ACC18 medical certificates, and repetitive review
processes

[You don't often get email from
[FYI request #31103 email]. Learn why this is
important at [4]https://aka.ms/LearnAboutSenderIdentific... ]

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

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recipient, you are not authorised to use or copy this message or any
attachments or disclose the contents to any other person."

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From: 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)

Link to this

From: Government Services
Accident Compensation Corporation

Kia ora,

Thank you for contacting ACC’s Government Services inbox.

If your request falls within scope of the Official Information Act, we
will endeavour to respond as soon as possible, and no later than 20
working days after receipt of your request. If we are unable to respond
within the statutory timeframe, we will notify you of an extension.

 

The information you have requested may involve documents which contain the
names and contact details of individuals. Please let us know whether you
are seeking that information as part of your request. We may need to
consult before deciding whether we can release this information, and this
may take a bit more time. If we do not hear from you, we will assume that
you do not require it.

 

For more information about Official Information Act requests, please
visit: [1]Ombudsman New Zealand | Tari o te Kaitiaki Mana Tangata.

If your request relates to your claim, or you’d like more information
about lodging a claim, please contact ACC’s claims team at 0800 101 996
or [2][email address].

For personal information requests or privacy matters,
please visit [3]Request for personal information (acc.co.nz).

For general queries, please visit: [4]Contact us (acc.co.nz).

 

 

Ngâ mihi,

Government Services

PO Box 242 / Wellington 6011 / New Zealand / [5]www.acc.co.nz

ACC cares about the environment – please don’t print this email
unless it is really necessary. Thank you.

 

Disclaimer:

"This message and any attachments may contain confidential and privileged
information. If you believe you have received this email in error, please
advise us immediately by return email or telephone and then delete this
email together with all attachments. If you are not the intended
recipient, you are not authorised to use or copy this message or any
attachments or disclose the contents to any other person."

References

Visible links
1. https://www.ombudsman.parliament.nz/
2. mailto:[email address]
3. https://www.acc.co.nz/contact/request-fo...
4. https://www.acc.co.nz/contact/
5. http://www.acc.co.nz/
http://www.acc.co.nz/

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