22 August 2025
Spencer Jones
[FYI request #31103 email]
Kia ora Spencer
Your Official Information Act request, reference: GOV-042112
Thank you for your email of 6 August 2025, asking for information under the Official Information Act
1982 (the Act). We are responding to the individual parts of your request in turn below.
1. Criteria for Overriding or Supplementing ACC18 Certificates
a. Please provide any specific written criteria, thresholds, or decision-making guidance
(including in internal manuals, case manager guides, or training materials) used between
1 Jan 2022 and 31 Dec 2024 to override, disregard, or supplement the clinical opinion in an
ACC18 medical certificate for:
* PIC eligibility decisions;
* Section 113 suspensions;
* Ongoing incapacity or stable impairment determinations.
b. If no such criteria exist, please confirm explicitly.
c. Provide any current (as at 2024) case manager training content on evaluating or challenging
ACC18 evidence for claims longer than two years.
4. Internal Audits and Quality Reviews
Between 1 Jan 2022 and 31 Dec 2024:
a. Provide executive summaries, high-level findings, or redacted conclusions from any internal
audits, quality assurance reviews, or reports concerning:
* Handling, validation, or override of ACC18 certificates;
* Timeliness or fairness of PIC/WPI assessments;
* Related Ombudsman or Privacy Commissioner complaints.
b. If none exist, confirm explicitly and advise whether any reviews were planned or underway as
at 31 Dec 2024.
5. Eos Audit Trail and Transparency Controls
Provide any policy, procedure, or technical documentation governing how the Eos system
records and reviews audit logs for:
* Communications about claimant entitlements (including PIC eligibility);
* Decisions to override or supplement ACC18s;
* Referrals for PIC/WPI assessment.
If no such documentation exists, describe the processes in place to ensure transparency and
accountability.
7. Ombudsman Complaint Outcomes (ACC18/PIC)
For 1 Jan 2022 – 31 Dec 2024:
a. The number of complaints referred to the Ombudsman relating to ACC18 handling or PIC
decisions.
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b. Anonymised summaries or resolution categories (e.g., upheld, dismissed, partially resolved).
If unavailable, provide any aggregated data.
Our response
We refer our responses of 25 June 2025 (GOV-040419), 14 July 2025 (GOV-041016) and 5 August 2025
(GOV-041488) where we provided the information you are seeking in these parts of your request.
We are refusing these parts of your request under section 18(h) of the Act, because we consider them
to be frivolous or vexatious.
2. ACC18 Issuance – Parallel Processing and Limits
a. Can two ACC18 medical certificates for the same claimant be in motion or processed at the
same time?
b. How many ACC18 medical certificates per claimant, per year, are permitted or actionable
under ACC policy or system rules? Please provide the relevant policy or procedural extract.
Our response
ACC considers all relevant and available information which it has on file for a claimant, to make a
decision on a claim. We refer to page 2 of our response of 25 June 2025 (GOV-040419) and page 2 of
our response of 14 July 2025 (GOV-041016) where we provided relevant documents in scope of this
part of your request.
As advised in response GOV-041016, no further policies around ACC18 certificates exist. For the
purposes of this response, we have referred you to our previous responses where this information has
been provided. However, if we continue to receive requests for the same information, we will refuse to
respond under section 18(h) of the Act.
3. PIC Denials Linked to Repetitive ACC18s
For the period 1 Jan 2022 – 31 Dec 2024, please provide:
a. The number of PIC applications declined on the basis that the injury had not stabilised, where
the claimant had received five or more ACC18 medical certificates.
c. A breakdown of the recorded reasons for PIC denials in claims with ≥ 5 ACC18s (e.g., “injury
not stabilised,” “insufficient evidence,” “other”).
If exact retrieval is not possible without substantial collation, please provide any aggregated,
sample-year, or dashboard-based data, or explain the specific system limitations.
Our response
We refer to page two of our response of 14 July 2025 (GOV-041488) where we advised that information
about injury stability, as a reason for decline, is not readily retrievable. Stability of an injury is not
relevant in every application and is not recorded electronically in our claims management system.
ACC does not systematically record decline reasons for PIC applications, an initial search of claims
where a PIC decline letter was issued resulted in approximately 3,100 decision letters for 2,900 claims.
To provide the information you are seeking for this part of your request, it would require someone with
subject matter knowledge to review al claims with PIC decline decision letters issued, in the specified
timeframe, requiring substantial collation and research. Accordingly, we are refusing these parts of
your request under section 18(f) of the Act.
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In doing so, we considered extending our timeframe to respond and charging (as allowed under the
Act). However, it was determined that the resources required to extract the data would have a
significant impact on the everyday functions of the team(s) involved.
3b. The number of claims with five or more ACC18s referred for a Whole Person Impairment
(WPI) assessment but not resulting in a PIC award.
Our response
We refer to table 3 in Appendix 1 of our response of 5 August 2025 (GOV-041488). This table includes
the number of claims with five or more ACC18s on file, broken down by WPI assessments and PIC
claims which have received payment. The data supplied has provided an answer to your request.
6. Escalation Thresholds for Long-Term Claims
Provide any mandatory or discretionary criteria, thresholds, or case manager guidance in effect
between 1 Jan 2022 and 31 Dec 2024 that determine when a long-term claimant (claim duration
> 2 years) should be referred for a WPI or PIC assessment. If none exist, confirm explicitly.
Our response
We refer to page 2 of our response of 5 August 2025 (GOV-041488) where we advised that ACC has a
Permanent Injury Compensation team who determine if a client is eligible for assessment using the
information provided on the ACC554, the accident date for determining entitlement type and
information from any previous impairment assessments (if relevant). We also refer to the documents
we have provided in this response.
There are no additional documents in scope of this part of your request.
If you have any questions about this response, please get in touch
You can email me a
t [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 a
t www.ombudsman.parliament.nz. Ngā mihi
Christopher Johnston
Manager Official Information Act Services Government Engagement
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