GOV 040419 Response.pdf

25 June 2025

Spencer Jones
[FYI request #31103 email]

Kia ora Spencer

Your Official Information Act request, reference: GOV-040419
Thank you for your email of 26 May 2025, asking for information about Permanent Injury Compensation
(PIC) entitlements under the Official Information Act 1982 (the Act). We will respond to each of your
requests in turn.

Part 1: Entitlements and Transparency Obligations
1. Disclosure Policies:
• Al  internal ACC policies, guidelines, manuals, or directives describing the legal obligation to disclose a
ful  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.

Accident Compensation Act 2001 (AC Act) c50 state the responsibilities upon receiving a claim for cover.
This includes deciding whether the corporation accepts the claim and if so, provide the claimant with
information about the entitlements to which it considers the claimant may be entitled; and facilitate the
claimant’s access to those entitlements.

The Act is publicly available via: www.legislation.govt.nz/act/public/2001/0049/latest/DLM99494.html

The Code of ACC Claimants’ Rights outlines the rights of individuals claiming ACC entitlements in New
Zealand. This is publicly available at:
www.legislation.govt.nz/regulation/public/2002/0390/latest/DLM173115.html.
ACC does not hold a speciﬁc document that describes the legal obligation to disclose a list or breakdown
of entitlements available to a claimant. Therefore, we have refused this part of your request under
section 18(e) of the Act.

However, we refer to the Make cover or funding decision – Make PIC funding decision policy, particularly
6b), which states that ACC contacts the client upon acceptance of cover, in instances of entitlements
pending. This document is attached in the appendix.

Entitlements are based on the individual’s injury-related needs and best discussed with a recovery team
member. A list of all supports can be found on the ACC website at:
www.acc.co.nz/for-providers/treatment-recovery/recovery-services-directory

GOV-040419   Page 1 of 5

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.

Eos is ACC’s main claim management system that holds client and claim information, as wel  as client
payment and treatment information. Other ACC systems receive different types of client and claim
information from Eos to help manage a claim, support a client, and pay treatment providers.

The ACC systems that hold client and/or claim information includes:

•  Virtual Claim Folder (VCF) which stores claim ﬁle documentation.
•  Intelligent Data Platform / Enterprise Data Warehouse & Cloud Data Platform stores
information for model ing and reporting purposes.
•  Medical Fees Processing (MFP) uses claim information from Eos for treatment / provider
payments.
•  MyACC which provides client self-service functionality. It sends and receives claim information
to and from Eos.
•  SalesForce (NGCM) is the ‘front end’ system of client engagement used by ACC client facing
teams. It pul s key information from Eos.
•  Genesys Cloud is the telephony platform (phone cal s) used by al  client facing teams to enable a
seamless customer experience.
•  Te Kahu (ACC ﬁnance system) is used to manage client overpayments.

Requesting your own information, including Digital Footprint requests
Requests for personal information held by ACC can be made here:
https://www.acc.co.nz/contact/request-for-personal-information/request-personal-information-for-
myself.

Part 2: Use and Recognition of ACC18 Medical Certiﬁcates
3. Validation of Medical Evidence:
• Al  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.

The fol owing documents about processing and reviewing ACC18 certiﬁcates for decisions on PIC
assessments are attached in Appendix 1:
•  Rules for Medical Certiﬁcates for Inability to Work Policy
•  Medical Certiﬁcation for Serious Injury Claims - permanent incapacity
•  Complete ACC18 Medical Certiﬁcate Request
•  Request a Change to a Claim Lodgement Form

Since staff names have not been requested, they have been redacted from these documents.

GOV-040419   Page 2 of 5

4. Historical Data:
• Number of PIC-related decisions between 2020–2025 that resulted in a 0% impairment rating despite
an ACC18 certiﬁcate conﬁrming incapacity.

Number of claims with Impairment Assessment WPI% decisions from 1 January 2020 to 18 June
2025 resulting in impairment of 0%
WPI% decision
Claims with an Impairment
Number of those claims that had incapacity
calendar year
  Assessment outcome with
from an ACC18 medical certificate prior to
WPI% decision of 0%
WPI% decision
2020
341
104
2021
256
102
2022
202
79
2023
253
105
2024
304
119
2025 YTD
209
87

Notes and Caveats about the data
•  PIC means Permanent Injury Compensation and refers to Lump Sum and Independence
Al owance entitlements.
•  Data are aggregated by calendar year. 2025 YTD includes data up to 18 June 2025.
•  The data was extracted on 19 June 2025 and may differ if rerun at a later date.
•  The table includes claims which have a record of an Impairment Assessment with a Whole
Person Impairment decision (WPI%) of 0% issued in the timeframe.
•  If a claim has more than one Impairment Assessment outcome, only the most recent decision
per claim is included. This includes where the most recent decision is 0% despite a higher earlier
rating on which PIC may have been paid. This does not include claims that previously had a 0%
decision that has since been replaced by a new decision.
•  The second measure counts how many claims in the ﬁrst measure also have a medical
incapacity record from an ACC18 medical certiﬁcate entered on the claim ﬁle before the WPI%
decision date. Incapacity from an ACC18 medical certiﬁcate relates to weekly compensation
entitlement, not to PIC entitlement.
•  This measure counts any medical incapacity from an ACC18 medical certiﬁcate, regardless of
whether that incapacity period was approved for weekly compensation payments.

Part 3: Review Processes and Repetition of Assessments
5. Repetitive Review Handling:
• Policies or SOPs on repetitive/successive reviews fol owing declined PIC claims.
• Criteria for requiring new evidence versus reusing prior assessments.
• Limits or escalation procedures for repeated internal reviews.

GOV-040419   Page 3 of 5

The fol owing documents about the processes fol owing a declined PIC claim are attached in Appendix 2:
•  Make cover or funding decision: Make PIC funding decision
•  Independence Al owance Eligibility Criteria Policy
•  Information needed to confirm medical certification of a permanent impairment for an Independence
allowance - Business Rule
•  Independence Al owance Reassessment Policy
•  Client reassessment request for an independence al owance entitlement - Business Rule
•  ACC reassessment request for an independence al owance entitlement – Business Rule
•  Lump Sum Eligibility Criteria Policy
•  Lump Sum Reassessment Policy
•  Process a Permanent Injury Compensation application
•  Assess Eligibility for Lump Sum / Independence Al owance and Election Offer

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).

ACC does not hold KPI’s or benchmarks for resolving PIC entitlement reviews. Therefore, we are refusing
this part of your request under section 18(e) of the Act, as the requested information does not exist.
However, al  reviews work to the same timeframes, clients must lodge a review within three months of
receiving a decision, and ACC must arrange a review hearing within three months of receiving a review
application.

Reviews about PIC resolved between 1 January 2020 to 18 June 2025 and average calendar days to
review resolution.
Review outcome
Reviews about PIC completed  Average days from review lodgement to
calendar year
resolution
2020
488
125.0
2021
492
116.5
2022
480
119.0
2023
606
127.4
2024
653
122.1
2025 YTD
292
123.8

Notes and Caveats about the data
•  PIC means Permanent Injury Compensation and refers to Lump Sum and Independence
Al owance entitlements.
•  Data are aggregated by calendar year. 2025 YTD includes data up to 18 June 2025.
•  The data was extracted on 19 June 2025 and may differ if rerun at a later date.
•  The table includes reviews where the review lodgement code is "Independence Al owance" or
"Lump Sums (2001 Act)" - col ectively these are referred to as Permanent Injury Compensation.
•  Reviews are included if the review outcome date is in the speciﬁed timeframe.
•  Average days is calculated using calendar days between the review lodgement date and the
review outcome date and includes weekends and public holidays.

GOV-040419   Page 4 of 5

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).

ACC does not refer complaints to the Ombudsman, nor the Privacy Commissioner. Therefore, we are
refusing this part of your request under section 18(e) of the Act, as the information does not exist.

The Office of the Ombudsman and Office of the Privacy Commissioner, proactively publish complaints
data and case notes on their website. You can ﬁnd the information in the below links:
www.ombudsman.parliament.nz/resources/oia-and-lgoima-complaints-received-between-1-july-and-
31-december-2024
www.ombudsman.parliament.nz/resources?f%5B0%5D=category%3A74

For resources about privacy complaints and case notes, we refer you to the website of the Privacy
Commissioner at: www.privacy.org.nz/resources-and-learning/case-notes-and-court-decisions/

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.

ACC does not hold information about internal reviews being undertaken which pertain to the points you
have outlined above. Therefore, we are refusing this part of your request under 18(e) of the Act, as the
information does not exist.

As this information may be of interest to other members of the public
ACC may publish a copy of this response on ACC’s website. All requester data, including your name and
contact details, will be removed prior to release. The released response will be made available
www.acc.co.nz/resources/#/category/12. Please also view this page about making requests and our
published responses https://www.acc.co.nz/contact/official-information-act-requests.

If you have any questions about this response, please get in touch
You can email me at [email address].If you are not happy with this response, you can
also contact the Ombudsman via [email address] or by phoning 0800 802 602.
Information about how to make a complaint is available at www.ombudsman.parliament.nz.

Ngā mihi

Christopher Johnston
Manager Official Information Act Services
Government Engagement

GOV-040419   Page 5 of 5