GOV 041016 Response.pdf

14 July 2025

Spencer Jones
[FYI request #31103 email]

Kia ora Spencer
Your Official Information Act request, reference: GOV-041016
Thank you for your email of 25 June 2025, asking for the following information under the Official
Information Act 1982 (the Act):

Fol ow-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 fol ow-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 fol owing 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 col ation, 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.

GOV-041016 Page 1 of 3

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.
5.  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 ful  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.

Question 1
Please refer to page 2 of our response 25 June 2025 (GOV-040419) where we provided relevant
documents regarding ACC18 Medical Certificates. There are no further documents specifically relating
to ACC18 Medical Certificates being overridden or disregarded. Therefore, we are refusing this part of
your request under section 18(e) of the Act, as the information does not exist.

Question 2
ACC’s Business Rule (Client reassessment request for an independence allowance entitlement) and
the Independence Allowance Reassessment Policy were provided in our response of 25 June 2025
(GOV-040419).

Question 3
As advised in our response of 25 June 2025 (GOV-040419) clients can access personal information
about themselves via the ACC website at www.acc.co.nz/contact/request-for-personal-information.
This includes requesting a digital footprint of your Eos record. We have attached the relevant document
- Complete Digital Footprint Request, Nintex Process Manager in the appendix.

Question 4
We refer to our response of 25 June 2025 (GOV-040419) in which we advised that ACC does not hold
information about internal reviews being undertaken pertaining to the points you have outlined.
Therefore, we are refusing this part of your request under 18(e) of the Act, as the information does not
exist.

Please note, ACC has not refused any part of your previous request under section 18(f) of the Act.

GOV-041016 Page 2 of 3

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

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