30 July 2025
Spencer Jones
[FYI request #31216 email]
Kia ora Spencer
Your Official Information Act request, reference: GOV-041227 Thank you for your email of 9 July 2025, asking for the following information under the Official
Information Act 1982 (the Act):
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
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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.
We note that you had made another request for similar information of 3 July 2025 (original request). We
emailed you on 8 July to clarify that request. We have taken the above request, dated 9 July, as a
clarified request which has replaced the original request. This is in accordance with section 15(1AA) of
the Act. Our responses are below.
Our response
We have interpreted this request as asking for further information related to our 27 June 2025 response
(Ref: GOV-040605). As such, we are providing information for the period 2018 to 2024, which
corresponds to the information provided in GOV-040605.
Severity Classification of traumatic brain injury (TBI) Claims (Question 1)
Severity assessments and grading
ACC receives medical records which are reviewed before ACC accepts cover for a concussion. Please
see our GOV-040605 response, specifically, the documents provided in response to Part 2 and Part 3 of
your request. Those documents contain information about how concussions or TBI claims are
assessed. For example, the document
Concussion – Guidelines for accepting cover for concussion (document 3 of GOV-040605) refers to concussion symptoms such as loss of consciousness and
Glasgow Coma Score as being some of the types of medical evidence that may be needed to support a
claim for a concussion injury.
Breakdown of TBI claims by severity
We refer you to Table 5 in the GOV-040605 response, which includes a breakdown by injury severity for
TBI claims caused by falls. This includes injury profiles ‘05- Severe Brain Injury/Anoxia’, ‘06 - Moderate
Brain Injury’, and ‘Concussion.’ Concussion represents any claim that has an injury description with
the keyword ‘concussion’ or where the injury diagnosis is concussion where no serious injury profile is
present. This is how we measure TBI claims by severity.
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See also Tables 1 and 2 within Appendix 1 attached, where we have also provided a breakdown of TBI
claims related to falls by type of claim or type of payments (which can in some cases, indicate the
severity of the injury). This includes fatal claims and claims with a serious injury flag.
Access to Rehabilitation and Concussion Pathways (Question 2)
Regarding the first four bullet points under question 2, please see Table 3 within Appendix 1.
In response to the fifth and sixth bullet points, some claims have more than one diagnosis on the claim,
but if they have a diagnosis for a TBI injury and have had a concussion service or neuropsychological
assessment, it is likely to be related to that TBI diagnosis. Vocational rehabilitation services will usually
take all diagnoses on the claim into account, including TBI.
ACC ensures that clients access appropriate services for persistent post-concussion symptoms
through the services we fund. For example, the Concussion Service is a clinical assessment and
rehabilitation service for clients with a mild to moderate TBI. The service aims to prevent long-term
consequences, such as persistent concussion symptoms, by identifying clients at risk and delivering
effective assessments, education, triage and rehabilitation. In consultation with the client, the provider
and ACC will agree on the appropriate services for the client’s rehabilitation.
For clients with a moderate to severe TBI, we use other services to ensure clients receive the treatment
they need for persistent symptoms. For example, we will look at whether the client should be
transferred to residential rehabilitation, which involves neurological rehabilitation, nursing and medical
services.
For more information on this, please see the
Concussion Services Service Page, provided with our
GOV-040605 response (see document 6 within the attachment).
We have also attached
Traumatic Brain Injury Residential Rehabilitation (TBIRR) Service Overview
Service Page (Appendix 2, attached)
.
Functional and Compensation Outcomes (Question 3)
Please refer to Tables 4, 5, and 6 within Appendix 1, and the notes included.
PCS Diagnostic Timing and Delayed Onset (Question 4)
Please refer to the documents we provided for GOV-040605. In particular, Document 2, which is an
ACC position statement on PCS. It states that
“ACC no longer accepts ‘post-concussion syndrome’ as
a covered injury. Where clients/patients have persisting symptoms that clinicians consider are caused
by concussion, the appropriate covered injury would be ‘concussion’. Symptoms that persist beyond
three months are most appropriately described as ‘persisting concussion symptoms.’” Although PCS is not accepted as a covered injury itself, any delayed-onset concussion symptoms can
still be taken into account during treatment under the covered diagnosis (of concussion or similar).
ANZSIC Code Descriptions (Question 5)
ANZSIC code descriptions can be found on the Stats NZ website, here:
https://aria.stats.govt.nz/aria/#ClassificationView:uri=http://stats.govt.nz/cms/ClassificationVersion/
CARS5587 - This shows the specific industries included within each grouping. For example, if you click
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the arrow beside ‘Agriculture, Forestry and Fishing’ it shows that Agriculture, Aquaculture, Forestry and
Logging, Fishing, Hunting and Trapping, and Agriculture, Forestry and Fishing Support Service are
included within that code. Each of these can also be further broken down by clicking on each arrow.
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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