Dear Accident Compensation Corporation,

Pursuant to the Official Information Act 1982, I request the following information relating to traumatic brain injury (TBI) and post-concussion syndrome (PCS) claims lodged with ACC, specifically those resulting from workplace accidents involving trips and falls.

This request aims to fill information gaps identified in prior OIA responses and research into injury causation, claim outcomes, and management protocols under the Accident Compensation Act 2001.

1. Workplace-Specific TBI and PCS Claims (2018–2024)

Please provide:
• The number of claims lodged for TBI and PCS where the cause of injury was a trip or fall at work, broken down by year (2018–2024).

For these claims, also provide a breakdown by:
• Acceptance status (accepted / declined / under investigation)
• Industry sector (e.g., construction, healthcare, office)
• Injury classification (mild, moderate, severe TBI, or PCS)
• Mechanism of fall (e.g., trip on level surface, fall from height, slip on wet floor)

If trip-specific data is unavailable, please provide the closest available dataset on workplace falls resulting in TBI or PCS, and confirm whether trip/fall cause coding is routinely recorded.

2. Causation and Clinical Evidence Requirements
• What types of clinical evidence or assessments are required or accepted by ACC to establish causation between a workplace trip/fall and a resulting PCS or TBI?
• Please supply internal clinical or operational guidance, assessment frameworks, or decision tools used by claim assessors or providers when evaluating causation in workplace TBI/PCS claims.
• For each year 2018–2024, please provide:
• The number of PCS/TBI claims arising from workplace falls declined due to insufficient proof of causation.

3. Updates to PCS Management Protocols (Post-June 2023)

Please provide:
• Copies of any updated CART (Clinical Advisor Reference Tool) guidance, internal bulletins, or policy documents issued after June 2023 that relate to:
• Diagnosis and management of PCS
• Visual symptoms or cognitive dysfunction following mTBI
• Concussion Service eligibility for workplace claimants
• If not yet finalised, please provide the expected release timeline and any available drafts or summary guidance used in the interim.

4. Workplace TBI/PCS Prevention Programs

Please provide:
• Details of any ACC-funded programmes (2020–2024) aimed at preventing workplace trips/falls that cause TBI or PCS, including:
• Target industries and interventions used (e.g., safety audits, PPE)
• Partnerships with WorkSafe NZ or sector bodies
• Outcomes reported (e.g., reduced claim volume or severity)

5. Economic and Social Impact

Please provide:
• Total direct and indirect costs of workplace TBI/PCS claims caused by trips and falls between 2018 and 2024, including:
• Medical treatment and rehabilitation
• Weekly compensation and long-term disability support
• Average duration of time off work or return-to-work delay for workers with accepted TBI/PCS claims arising from trips and falls.

Additional Notes:
• Please provide the requested information electronically (e.g., PDF or Excel format).
• If any portion of this request is declined under section 18, please explain the reason and release any available relevant material under section 16 of the Act.
• If data specific to trips is not available, please explain why and substitute the closest available category (e.g., all workplace falls).
• I am happy to receive the response via the FYI.org.nz platform.

Yours faithfully,

SPENCER JONES

Dear Government Services,

**Subject:** Follow-up Request – Workplace TBI and PCS Claims Related to Trips and Falls (FYI Ref #31216)

Tēnā koutou,

Thank you for your prompt and detailed response to my recent Official Information Act request (GOV-040452, FYI.org.nz #31216) regarding workplace accident claims involving traumatic brain injury (TBI) and post-concussion syndrome (PCS) resulting from trips and falls.

Upon review of the released dataset, I would like to formally request the following additional information to support further analysis and clinical interpretation:
---
### 🔍 Additional Information Requested

1. **Severity Breakdown (Mild / Moderate / Severe TBI):**
Please provide a breakdown of the TBI-related claims by severity classification, if recorded, across the reporting period (2010–2024). If severity is not routinely captured in your dataset, please advise what proxy indicators (e.g. diagnosis codes, medical reports, or funding decisions) may be used to infer severity level.

2. **Plain-English Industry Categories:**
The dataset references ANZSIC codes without clarification. Please provide either:
a) a plain-English key/legend matching each ANZSIC code to its corresponding industry name; or
b) a reissued version of the table where industry categories are described in full.

3. **Claim Outcomes and Functional Impairment Data:**
For the identified claims:

* Please indicate how many resulted in time off work of more than 4 weeks, 3 months, and 6 months respectively.
* Please provide, if available, anonymised aggregated data on:
* Access to neurorehabilitation services
* Use of vocational rehabilitation or return-to-work programmes
* Claimants who underwent impairment assessments under Schedule 2 of the Accident Compensation Act 2001
* Claims where a permanent impairment rating was assigned
---
### ⚖️ Justification

This information is being requested to assist in evaluating patterns of injury severity and long-term functional impact among workplace TBI and PCS claimants. It is directly relevant to the claimant’s ability to access support services, secure appropriate reassessments, and understand ACC’s rehabilitation performance in this cohort. It also assists in assessing ACC's compliance with obligations under the **Accident Compensation Act 2001** and related guidelines (e.g. ACC’s Concussion Service Pathway, Neuropsychological Guidelines, and Schedule 2 impairment assessments).
---
If any part of this request cannot be met, I respectfully request that you provide the reasons for refusal in accordance with section 19 of the OIA and indicate whether alternative formats or partial data may be supplied.

Kind regards,
Spencer Jones

Dear Government Services,

⸻
Follow-up Request: Workplace PCS/TBI Claims – Severity, Rehabilitation Access, and Outcome Tracking

Thank you for your response dated 9 July 2025 to OIA request #31216 regarding workplace claims for traumatic brain injury (TBI) and post-concussion syndrome (PCS) related to trips and falls.

I am writing to request further clarification and supplementary data under the Official Information Act 1982.

1. Severity Classification of TBI Claims

Your response indicates ACC does not code claims by TBI severity (e.g. mild, moderate, severe). Please advise:
• Does ACC hold or receive severity assessments from medical providers (e.g. via initial lodgement, clinical notes, neuroimaging results)?
• If so, what internal guidance or data structures govern severity grading (e.g. Glasgow Coma Scale, loss of consciousness, PTA)?
• Can you provide a count or breakdown of TBI claims involving workplace trips and falls (2019–2023) where severity was indicated, by severity level if available?

2. Access to Rehabilitation and Concussion Pathways

For the same set of workplace-related TBI and PCS claims (2019–2023), please provide:
• The number of claims where the client was referred to or accessed:
• A concussion service or concussion pathway
• A neuropsychological assessment
• Vocational rehabilitation services
• Whether these rehabilitation services are linked to the claim diagnosis (i.e. PCS or TBI)
• If not held, please explain how ACC determines whether a client is accessing appropriate services for persistent post-concussion symptoms.

3. Functional and Compensation Outcomes

Please provide any available data (or confirm non-collection) on the following outcomes for the same claim cohort:
• Duration of weekly compensation (e.g. <4 weeks, 4–12 weeks, >12 weeks)
• Return-to-work status within 6 months or 12 months of injury
• Number of claims that progressed to a Whole Person Impairment (WPI) assessment
• Number of Permanent Impairment Compensation (PIC) determinations granted or declined, where PCS or TBI was a factor

4. PCS Diagnostic Timing and Delayed Onset

You noted that PCS is “often not recorded at the time of lodgement.” Please clarify:
• What guidance or internal criteria are used to update a claim diagnosis to include PCS?
• Are there any thresholds or waiting periods (e.g. symptoms lasting >3 months) before PCS is recognised?
• How does ACC ensure that delayed-onset PCS is not excluded from injury-based entitlements (e.g. neuropsychological care, impairment assessment)?

5. ANZSIC Code Descriptions

Please supply a plain-English table defining the ANZSIC industry classification codes (A, B, C, etc.) used in your original data tables.

⸻

If any part of this information is not held, I request that ACC:
• Clearly state the reason under section 18 of the Act
• Indicate whether the information could be made available through refinement or in a different format
• Advise whether ACC has considered any system improvements to track the above data in the future

Please provide the information in accessible, machine-readable format (e.g. Excel or CSV), if possible.

Kind regards ,

Spencer Jones

Follow-up Request under the Official Information Act – GOV-041227 Response Clarification

Thank you for your 30 July 2025 response (Ref: GOV-041227) to my Official Information Act request. I appreciate the detailed data and supporting documents provided. I am writing to seek clarification and request further information on several points that remain outstanding or were only partially addressed.

1. Clinical Severity Classification of TBI Claims

Your response outlines claim types by outcome (e.g. serious injury, medical fees only) but does not provide a breakdown of clinical severity (e.g. mild, moderate, severe) as used in international TBI classification. I therefore request the following:

* Does ACC systematically record or classify traumatic brain injury (TBI) claims by clinical severity (mild, moderate, severe)?
* If yes, please provide a breakdown of new **workplace TBI claims involving trips and falls** by clinical severity level for the years **2019–2023**.
* If no, please confirm whether ACC receives clinical severity data (e.g., GCS scores, loss of consciousness, post-traumatic amnesia) from medical providers and whether this data is retained or used for internal classification.
* Has ACC considered improving its data systems to capture severity levels consistently?

2. PCS-Specific Access to Services

Your response refers to persistent concussion symptoms under the broader diagnosis of “concussion,” in line with the PCS position statement. However, it remains unclear whether ACC can distinguish between **acute TBI** and **persistent post-concussion symptom** (PCS) presentations in its service tracking.

Please advise:

* Does ACC track whether a neuropsychological assessment or concussion service was accessed specifically for PCS-related symptoms (e.g. symptoms persisting beyond 3 months)?
* If not, how does ACC evaluate whether clients with delayed or persistent symptoms are receiving appropriate rehabilitation, especially when PCS is not coded as a covered injury?

3. ANZSIC Industry Code Clarification

In response to my request for a plain-English table defining the ANZSIC codes used in your data tables, ACC referred me to the Stats NZ online classification viewer.

For clarity and accessibility, I now request that ACC:

* Provide a **simple table listing the ANZSIC codes (A–S)** used in the GOV-041227 data tables, with a plain-English name or industry category alongside each code (e.g. “A – Agriculture, Forestry and Fishing”).
* If subcategories were used (e.g. A01, C14), please include these as well.

4. Missing 2024 Data for WPI/PIC Outcomes

Table 6 in GOV 041227 Appendix 1.xlsx does not include data for impairment assessments or Permanent Incapacity Compensation (PIC) determinations in 2024.

* Was this data unavailable at the time of response or excluded for another reason?
* If available, please provide updated figures for 2024.

5. Referenced but Missing Documents (GOV-040605)

Your response references two important documents previously released under GOV-040605:

* **Concussion – Guidelines for Accepting Cover**
* **Post-Concussion Syndrome (PCS) Position Statement**

Please provide these two documents as attachments to this follow-up, as they were not included in GOV-041227 and are essential for understanding ACC’s clinical decision framework.

---

**Preferred format**: Please provide all data in accessible, machine-readable formats (e.g., .xlsx or .csv), and policy documents in .pdf.

If any part of this request is unclear or would require refinement, I am happy to discuss this in good faith under section 13 of the Official Information Act.

Kind regards,
Spencer Jones
FYI Request #31216 – [https://fyi.org.nz/request/31216](https://fyi.org.nz/request/31216)