1
GOV-044915
From: SPENCER JONES <[email address]>;
Received: Fri Dec 05 2025 15:01:39 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - Request for ACC Organisational Structure, Staffing Distribution, Contractor Use &
Associated Cost Structures (2020/21–2024/25)
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Dear Accident Compensation Corporation,
Under the Official Information Act 1982, I request the following information relating to ACC’s organisational structure, staffing
distribution, and associated resourcing arrangements for the period 1 July 2020 – 30 June 2025 (or the closest 12-month
datasets available).
I am seeking this information to understand how ACC’s workforce and contracted services are structured across functions and
regions.
1. Staffing Distribution and Organisational Structure
Please provide:
1.1 Total staffing numbers for each financial year 2020/21–2024/25, broken down by:
• permanent FTE
• fixed-term FTE
• contractors (headcount and/or FTE equivalent)
• agency temps
• secondments (inbound and outbound)
1.2 Breakdown by organisational function (e.g.):
• Operations / Client Service Delivery
• Claims Management
• Corporate Services
• ICT / Digital & Data
• Provider Services
• Legal Services
• Strategy & Finance
• People & Culture
• Injury Prevention
• Executive Office
(Please provide staff counts or FTE by subdivision if already held in ACC’s HR or Finance systems.)
1.3 Breakdown by regional location, including:
• Branch locations
• Service centres
• Specialist hubs (e.g., sensitive claims, serious injury, complex claims)
2. Contractor, Consultant & Third-Party Services
2.1 Contractor and consultant expenditure for each financial year, broken down by:
• function
• cost centre
• vendor type (e.g., legal, ICT, HR, project/PMO, advisory, rehabilitation, data analytics)
• whether contractors were replacing vacancies or providing specialist services
2.2 A list of third-party suppliers routinely engaged across ACC, including categories such as:
• ICT & digital implementation
• external legal services
• external dispute resolution support
• consultancy or advisory firms
• outsourced operational services
(Individual contract values are not required unless this is readily available.)
3. External Legal Services
For financial years 2020/21–2024/25, please provide:
3.1 Total expenditure on external legal services, broken down by:
• disputes / reviews
• ICRA representation
• FairWay Reviews
• appeals (District Court, High Court, Court of Appeal, Supreme Court)
• special investigations
• regulatory / compliance advice
• panel provider costs
3.2 Total number of matters referred externally vs managed internal y by ACC’s in-house legal team.
If ACC already holds this in summary reporting (e.g., enterprise reports, legal services dashboards), providing those documents
wil satisfy this part of the request.
4. Cost Centre & Budget Al ocation Information
4.1 A list of ACC cost centres, with the title of each cost centre and the function/team it relates to.
4.2 High-level budget al ocation by cost centre group, including:
• operational vs corporate spending
• claims-management operational spend
• ICT and digital-transformation spend
• spending on contractors
• spending on property and facilities
• spending on external legal services
(I am not requesting line-item detail, only high-level aggregates already contained in internal financial reporting.)
5. Organisational Charts & Supporting Documents
Please provide:
5.1 Organisational charts for 2020/21–2024/25 (the versions already maintained by ACC).
5.2 Workforce planning, recruitment, and resourcing summaries, if already produced, for any of these years.
If individual documents are extensive, a list or index would also satisfy this part of the request.
Format
Electronic format (Excel, CSV, PDF) is preferred.
If any part of this request is likely to require refinement, I am happy to discuss narrowing or focusing the scope.
Thank you for your assistance.
Kind regards,
Spencer Jones
2
GOV-044929
From: SPENCER JONES <[FYI request #33150 email]>;
Received: Fri Dec 05 2025 15:39:18 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - Request for information regarding ACC’s annual performance outcomes, clinical quality
assurance, turnaround-time standards, contractor oversight, and workforce adequacy
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Kia ora,
I am requesting information under the Official Information Act 1982 regarding ACC’s operational performance, service delivery
timeliness, quality-assurance mechanisms, and contractor oversight, across the last five financial years.
This request is informed by best-practice international audit frameworks (including external inspector-general healthcare
reviews), and seeks comparable data for ACC.
1. Annual performance outcomes and failures
Please provide ACC’s annual performance results (2019/20–2023/24) relating to:
1. Timeliness / turnaround-time standards for clinical decision-making, assessments, specialist triage, and treatment
pathway approvals.
2. The minimum expected benchmark, and the actual percentage of cases that met that benchmark each year.
3. Any internal findings, reports, or audits identifying failure to meet turnaround KPIs, similar to the findings
summarised in the VA OIG report where performance targets were repeatedly missed.
If ACC does not measure specific turnaround KPIs, please confirm.
2. Workforce adequacy and staffing shortfal s
Please provide:
1. ACC’s internal assessments of staffing levels, shortages, and workforce constraints that impact service delivery,
similar to the “national shortage” issues documented in the VA report.
2. Reports identifying how staffing deficits affect:
• decision-making timeframes
• case manager capacity
• clinical advisor availability
• vendor / assessor performance
3. Any plans of action produced to address workforce shortages (internal or external contractors).
3. Oversight of contracted clinical providers and assessors
The VA audit identified major failures caused by unclear responsibilities, outdated agreements, and inconsistent policies.
Accordingly, please provide:
1. Copies of ACC’s current contracts, service agreements, and MOUs with:
• radiology providers
• teleradiology providers (if applicable)
• clinical assessors
• integrated services providers
• triage services
• telehealth platforms
2. Information on how ACC ensures:
• contractor quality assurance
• peer review or audit of contractor error rates
• monitoring of clinical accuracy, delays, or misreads
• internal escalation processes when contractor error causes harm
3. Any internal findings identifying:
• conflicting guidance
• unclear lines of responsibility
• delays caused by external vendors
(as occurred in the VA system, contributing to harm).
4. Quality-assurance systems, peer review, and error detection
From the VA report, QA processes were inconsistent, mismanaged, and poorly understood, contributing to delayed care and
misreads.
Please provide for ACC:
1. Al policies describing clinical quality-assurance, peer-review of clinical advisors and contracted assessors, and error-
rate monitoring.
2. The annual number of quality-assurance reviews conducted each year since 2019/20.
3. Data identifying:
• the number of incorrect clinical decisions detected
• the number of clinical misjudgments overturned on review
• the number of initial decisions requiring correction due to error
4. Reports relating to:
• systemic QA failures
• lack of monitoring
• unresolved risks
• delays caused by QA gaps
5. Delays in service delivery causing risk of harm
The VA OIG report documented multiple cases where delayed readings put patients at risk.
Please provide:
1. ACC’s equivalent data on delays that created risk, including:
• delayed treatment
• delayed clinical advice
• delayed approval for specialist care
2. Any internal investigations or incident reviews.
6. Contingency planning and system outages
The VA report found many providers lacked contingency plans, leading to systemic failures during outages.
Please provide ACC’s:
1. Contingency plans for:
• major system outages
• digital platform failures
• contractor unavailability
• inability to access clinical files
2. Al reports of service disruption affecting:
• client decision-making
• access to records
• clinical processes
7. Internal patient-safety or client-safety reporting
1. Copies of anonymised internal “client safety” or “service risk” reports.
2. Trends or themes recorded across the past five years, including:
• delays
• miscommunications
• administrative errors
• incorrect decisions
• unprocessed evidence
8. Financial information underpinning the above
Without requesting granular line-item costs, please provide:
1. ACC’s annual expenditure on:
• contracted assessors
• clinical panel reviewers
• external radiology / imaging
• telehealth or remote review services
2. Any performance-based penalties, abatements, or remediation actions applied against contractors for failure to
meet KPIs.
9. Copies of any internal reviews comparable to an Inspector-General audit
If ACC has conducted internal or external audits evaluating:
• performance failures
• clinical quality
• contractor oversight
• systemic delays
• operational reliability
…please provide these.
If no equivalent audits exist, please state.
Format Requested
Electronic, searchable PDF or Word documents are preferred.
Reason for Request section 12(2)
This information wil assist in understanding ACC’s operational performance, service delivery reliability, and quality-assurance
mechanisms, using international y recognised oversight frameworks as a point of comparison.
Kind regards,
Spencer Jones
3
GOV-044959
From: Spencer Jones <[email address]>;
Received: Mon Dec 08 2025 20:49:33 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Re: OIA Response Ref GOV-044491 CRM:0305311
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To: Accident Compensation Corporation (ACC)
Subject: Request for Clarification of “Unidentified” Injury Category in Appendix to GOV-044491
Dear ACC,
Under the Official Information Act 1982, I request clarification of the “Unidentified” injury category listed in the Appendix
released on 3 December 2025 in response to OIA GOV-044491.
The Appendix records 231 accepted treatment-injury claims under the category “Unidentified.”
To better understand this classification, I request the following information:
⸻
1. Definition & Criteria
1.1 ACC’s definition of “Unidentified” as used in the Appendix.
1.2 The criteria or internal coding standards that result in an injury being assigned to “Unidentified.”
⸻
2. Diagnostic Status
2.1 Whether these 231 cases represent:
• injuries that were clinically diagnosed but not mapped to a standard ACC category,
• injuries stil under clinical investigation,
• incomplete diagnostic information at the time of coding,
• legacy coding placeholders awaiting reclassification,
• or another reason.
(High-level explanation only — no personal or case-specific information requested.)
⸻
3. Coding & Reclassification Process
3.1 Whether ACC intends to reclassify any of these 231 cases into specific injury categories (e.g., cardiac, neurological,
musculoskeletal) as part of future Treatment Injury Refresh updates.
3.2 If available, the proportion of these “Unidentified” cases that ACC expects wil eventually be reassigned into known injury
categories once coding or clinical information is complete.
⸻
4. Internal Documentation
4.1 Copies (or the title/index) of any internal guidance, coding rules, or documentation used when assigning treatment-injury
claims to “Unidentified.”
If the documents are extensive, an index or excerpt of the relevant section is sufficient.
⸻
Format
I request the information in electronic form.
If any part of this request requires refinement, please advise.
Thank you for your assistance.
Kind regards,
Spencer Jones
-----Original Message-----
Kia ora
Please find attached our response to your official information request
dated 18 November 2025. If you have any questions about the response you
can contact us at this [1]address, for al other matters please use our
contact form at:
[2]https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.acc.co.nz%2Fcontact%2F&data=05%7C02%7C
governmentservices%40acc.co.nz%7Cb8547fe1c3614f0f0fa308de362e503f%7C8506768fa7d1475b901cfc1c222f496a%7C0%7
C0%7C639007769730511391%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXa
W4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=K0TJQyDqy9iqIU5szhkWvjLZBHstHqUxAr%2FKbbbtR1
4%3D&reserved=0 alternatively give us
a cal on 0800 101 996.
If you are having trouble viewing the PDF, please ensure you have the
latest version of Adobe Acrobat Reader. To download this freeware please
click [3]here.
4
GOV-044985
From: Spencer Jones <[email address]>;
Received: Mon Dec 08 2025 20:56:23 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Re: Official Information request - treatment injury claims related to COVID-19 vaccinations
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Request for Clarification of Myocarditis & Pericarditis Reporting in Treatment-Injury Claims (COVID-19 Vaccine)
Dear ACC,
Under the Official Information Act 1982, I request clarification regarding the reporting of myocarditis and pericarditis in the
COVID-19 vaccine-related treatment-injury dataset released under OIA GOV-044491 (Appendix dated 3 December 2025).
Earlier ACC Treatment Injury Refresh documents (2021–2023) reported myocarditis and pericarditis as separate, named injury
categories.
In the latest release, however, myocarditis/pericarditis has been aggregated into “Cardiac injury” without diagnostic
breakdown.
To better understand this change, I request the following information:
⸻
1. Reporting Change Explanation
1.1 An explanation of why myocarditis and pericarditis are no longer reported as separate injury categories in the COVID-19
vaccine treatment-injury dataset.
1.2 Whether this change reflects:
• a change in ACC’s internal injury-coding system,
• a classification merge for reporting simplicity,
• reduced diagnostic specificity in clinical notes,
• or another reason.
(High-level explanation only.)
⸻
2. Reclassification Records
2.1 Whether ACC stil codes myocarditis and pericarditis internal y as distinct injury diagnoses (e.g., using SNOMED, Read
codes, or internal claim taxonomy), even if the public summary aggregates them.
2.2 If so, please provide the number of accepted claims coded as myocarditis and the number coded as pericarditis for the
period:
18 February 2021 – 21 July 2025.
Only aggregated totals are requested — no personal or case-level information.
⸻
3. Future Publication Plans
3.1 Whether ACC intends to reinstate separate reporting of myocarditis and pericarditis in the January 2026 Treatment Injury
Refresh, or whether these conditions wil continue to be reported only within the broader “Cardiac injury” category.
⸻
4. Supporting Documentation
4.1 Any internal coding guidance, reporting manuals, or classification-change notes that explain the shift from separate
reporting to aggregated “Cardiac injury” reporting.
If extensive, an index or excerpt of the relevant sections is sufficient.
⸻
Format
Electronic format is preferred.
If any part of this request requires refinement, please advise.
Thank you for your assistance.
Kind regards,
Spencer Jones
-----Original Message-----
Kia ora,
Thank you for contacting ACC’s Government Services inbox.
If your request fal s within scope of the Official Information Act, we
wil endeavour to respond as soon as possible, and no later than 20
working days after receipt of your request. If we are unable to respond
within the statutory timeframe, we wil notify you of an extension.
Please note that during the holiday period there is a three-week period
where days are not counted as working days. This is from 25 December 2025
to 15 January 2026, inclusive. You can read more about this on the
Ombudsman website here: [1]Official Information requests over the
2025/2026 holiday period.
The information you have requested may involve documents which contain the
names and contact details of individuals. Please let us know whether you
are seeking that information as part of your request. We may need to
consult before deciding whether we can release this information, and this
may take a bit more time. If we do not hear from you, we wil assume that
you do not require it.
For more information about Official Information Act requests, please
visit: [2]Ombudsman New Zealand | Tari o te Kaitiaki Mana Tangata.
If your request relates to your claim, or you’d like more information
about lodging a claim, please contact ACC’s claims team at 0800 101 996
or [3][email address].
For personal information requests or privacy matters,
please visit [4]Request for personal information (acc.co.nz).
For general queries, please visit: [5]Contact us (acc.co.nz).
Ngâ mihi,
Government Services
5
GOV-044948
From: SPENCER JONES <[email address]>;
Received: Mon Dec 08 2025 14:42:45 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - Request for Information on External Legal Expenditure, Investigator Engagements &
Assessor Governance Frameworks (2019–2025)
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Under the Official Information Act 1982, I request the following information relating to ACC’s use of external legal providers,
investigative contractors, and independent medical assessors for the period 1 January 2019 – 31 December 2025 (or the most
recent period available).
This request focuses on aggregated financial data, governance frameworks, and contract structures only.
1. External Legal Services (Litigation, Reviews, ICRA, Advisory)
1.1 Annual total expenditure on external legal services for each financial year 2019/20–2024/25, broken down by:
ICRA representation
FairWay Review representation
District Court appeals
High Court litigation
Court of Appeal / Supreme Court matters
Specialist advisory work
Panel-provider costs
(If already held in internal summary or dashboard form, providing that report satisfies this request.)
1.2 Number of matters referred external y vs internal y each year, for:
ICRA
Reviews
District Court appeals
High Court appeals
2. Private Investigators & External Fact-Finding Contractors
2.1 Total annual expenditure on private investigators or contracted fact-finding services, including surveil ance providers, for
each financial year 2019/20–2024/25.
2.2 A high-level list of categories of investigative services used, such as:
surveil ance
social-media scanning
background checks
workplace or functional-capacity observation
site or circumstance investigations
(not requesting provider identities)
3. Independent Medical Examiners (IMEs) & Panel-Assessor Governance
3.1 A copy of ACC’s current governance, procurement, and quality-assurance framework for:
Independent Medical Examiners
specialist assessors
vocational and functional assessors
mental-health and neuropsychological assessors
This may include any documents outlining:
selection and accreditation processes
training or competency requirements
performance-monitoring systems
audit mechanisms
conflict-of-interest management
escalation or removal procedures
If extensive, an index of documents is sufficient.
3.2 Aggregate annual expenditure on IME and panel assessments, broken down by assessment type if held in that form.
4. Contractual Structures & Oversight
4.1 High-level description or copy of any internal policies relating to:
when external legal services should be used in preference to internal counsel
when private investigators may be engaged
how IMEs are selected for ICRA, reviews, or court matters
monitoring and auditing of external providers
thresholds for escalation to external legal or investigative resourcing
(Again, if documents are extensive, an index is acceptable.)
Format
I request the above in electronic format (Excel, PDF, or internal summary documents).
If any part of this request is likely to exceed reasonable collation, please advise so I may refine it.
Thank you for your assistance.
Kind regards,
Spencer Jones
6
GOV-044950
From: SPENCER JONES <[email address]>;
Received: Mon Dec 08 2025 14:47:06 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - Request for Information on Conflicts of Interest, Assessor Governance, and Panel-
Selection Processes (2019–2025)
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Under the Official Information Act 1982, I request the following information relating to ACC’s management of conflicts of
interest, provider independence, and assessor-governance processes for the period 1 January 2019 – 31 December 2025 (or
the most recent period available).
This request is limited to aggregated data, high-level documents, and governance frameworks.
1. Conflict-of-Interest Declarations & Management
1.1 Annual number of conflict-of-interest disclosures made by the following categories of external providers:
Independent Medical Examiners (IMEs)
vocational assessors
pain specialists
neuropsychological assessors
mental-health assessors
functional capacity or occupational assessors
external clinical reviewers
(Please provide aggregate numbers only.)
1.2 Number of cases each year where ACC:
required a change of assessor due to conflict of interest
identified an undeclared conflict after an assessment
took corrective action related to assessor independence
1.3 A high-level description of ACC’s process for verifying assessor independence, including:
checks for prior treating relationships
checks for commercial or contractual conflicts
rotation requirements
internal auditing mechanisms
(If a governance document exists, providing it — or an index — satisfies this request.)
2. Panel-Assessor Selection & Al ocation
2.1 A copy of any internal documents outlining how assessors are selected or al ocated, including guidance on:
rotating assessors
assignment to ICRA, review, or appeal matters
avoiding perception-of-bias issues
ensuring assessor diversity across specialties
If documents are extensive, a list or summary is acceptable.
2.2 Total number of assessments completed by each category of assessor per year (not individual assessor names), including:
general medical IMEs
orthopaedic specialists
pain specialists
neurologists
neuropsychologists
psychiatrists
vocational/functional assessors
(Providing figures by category helps maintain privacy while enabling transparency.)
3. Complaints & Quality Reviews Concerning Assessor Conduct
3.1 Number of complaints received each year relating to assessor conduct or independence, including categories such as:
perceived bias
inaccurate or insufficient assessment
procedural fairness concerns
failure to consider medical evidence
conflict-of-interest allegations
(Please provide aggregate counts only.)
3.2 The number of complaints substantiated each year, and any high-level corrective actions taken (e.g., retraining, removal
from panel, review of processes).
4. External Provider Relationships & Oversight
4.1 High-level list of external provider categories that ACC contracts with for assessments, such as:
multidisciplinary rehabilitation providers
specialist assessment firms
report-writing services
multidisciplinary panel companies
(Not requesting provider names.)
4.2 A copy of ACC’s current or recent policies relating to:
assessor independence
conflict-of-interest management
quality-assurance of assessment reports
auditing of external assessors
escalation or removal procedures
If a policy manual or governance framework exists, an index is sufficient.
Format
I request the above in electronic format (PDF, Excel, or existing internal report formats).
If any part of this request is likely to require refinement, please advise and I wil narrow the scope.
Thank you for your assistance.
Kind regards,
Spencer Jones
7
GOV-044952
From: SPENCER JONES <[email address]>;
Received: Mon Dec 08 2025 14:54:06 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - Request for Information on Performance Targets, Operational Time Standards, Decline
Rates & Staff Pressure Frameworks (2019–2025)
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Under the Official Information Act 1982, I request the following information relating to ACC’s performance targets,
operational timeframes, productivity expectations, and decision-making pressures for the period 1 January 2019 – 31
December 2025 (or the closest period for which data exists).
This request is limited to high-level, aggregated information, policies, and internal frameworks.
No personal staff information is sought.
1. Internal Performance Targets & KPIs
1.1 Copies or summaries of any internal Key Performance Indicators (KPIs) applied to staff involved in:
claims management
cover decisions
weekly compensation decisions
clinical advice
operational call centres
data assessment or QA functions
including any KPIs relating to:
timeliness
throughput
processing speed
clearance rates
backlog reduction
decision output volumes per staff member
(If formal KPI documents exist, an index wil satisfy this request.)
1.2 A list of al formal performance measures in place from 2019–2025, including any changes in KPIs introduced during this
period.
2. Time Standards, Expectations & Productivity Metrics
2.1 Internal documents describing expected timeframes for:
making cover decisions
assessing weekly compensation
requesting and reviewing clinical information
completing internal assessments
progressing complex or sensitive claims
2.2 Any internal performance dashboards or summary reports (even in high-level form) relating to:
average processing times
overdue tasks
timeliness standards
backlog management programmes
productivity expectations for staff
If complete dashboards cannot be released, a list or extract of relevant indicators is sufficient.
3. Decline Rates, Approvals & Operational Decision Drivers
3.1 Annual aggregate data (2019–2025) showing:
number of cover decisions made
number approved
number declined
percentage decline rates per year
any internal monitoring or analysis of fluctuations in decline rates
(National-level data is sufficient; no regional or staff-level data requested.)
3.2 Any internal documents discussing the relationship between performance targets and claim outcomes, including:
pressure to meet timeframes
backlog-reduction initiatives
impacts of staffing shortages
operational directives or performance programmes
internal commentary on fairness or accuracy risks
A summary or thematic analysis is sufficient if ful documents cannot be provided.
4. Operational Pressure, Staffing Capacity & Risk Assessments
4.1 Copies or summaries of internal risk assessments relating to:
staff workload
claim volumes
resourcing constraints
impacts on decision accuracy
pressure or burnout affecting service-quality outcomes
4.2 Any internal documents assessing whether staffing capacity is adequate to meet statutory timeframes and internal KPIs,
including:
workforce planning summaries
capacity-gap analyses
risk ratings for under-resourcing
If these exist only in annual planning documents, providing the relevant extracts is sufficient.
5. Feedback Loops & Corrective Action
5.1 Internal documents or summaries describing how ACC monitors whether performance pressures have contributed to:
inconsistent decision-making
premature declines
errors requiring correction
quality concerns identified by review bodies (ICRA, FairWay)
elevated complaint or reconsideration rates
5.2 Any internal improvements or mitigation steps implemented between 2019 and 2025 addressing the above issues.
A list or summary wil satisfy this request.
Format
Electronic format (PDF, Word, Excel, or existing internal reporting formats) is preferred.
If any part of this request requires refinement, please advise and I wil amend it.
Thank you for your assistance.
Kind regards,
Spencer Jones
8
GOV-044951
From: SPENCER JONES <[email address]>;
Received: Mon Dec 08 2025 14:51:08 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - Request for Information on Data Integrity Processes, File Accuracy, Evidence Handling &
Decision-Making Quality Assurance (2019–2025)
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Under the Official Information Act 1982, I request the following information regarding ACC’s systems, quality-assurance
processes, and internal controls relating to data integrity, file accuracy, evidence handling, and consistency of decision-making
for the period 1 January 2019 – 31 December 2025.
This request is for high-level documents, internal frameworks, aggregated data, and system descriptions only.
No personal y identifiable information is sought.
1. Data Integrity & File Accuracy Controls
1.1 Copies (or a list) of ACC’s internal policies, frameworks, or guidance documents relating to:
data accuracy standards
file integrity management
correction of errors
verification of clinical information
management of duplicate or incomplete entries
audit or quality checks on claim files
internal processes for escalating data-quality concerns
If documents are extensive, an index will satisfy this request.
1.2 The number of file-accuracy or data-integrity issues recorded each year, including (if held):
incorrect information added to files
missing documents
inconsistent summaries
retrospective corrections
misfiled or incomplete clinical notes
system-generated errors
(Only aggregated counts are requested.)
2. Evidence Handling, Missing Documents & Retrieval Processes
2.1 A high-level description of ACC’s document-handling and evidence-management procedures, including:
how supporting evidence is received, scanned, and al ocated
how evidence is tagged or categorised in Eos or other systems
how missing or misplaced documents are identified and remedied
any internal KPIs relating to evidence completeness
2.2 Annual data from 2019–2025 on the number of instances where:
evidence was identified as missing or unavailable
evidence had to be resubmitted by claimants or providers
internal teams triggered a “missing documentation” workflow
external reviewers or ICRA raised concerns about incomplete files
If these numbers exist only in internal audit or QA summaries, providing such summaries satisfies this request.
3. Decision-Making Consistency & Variation
3.1 Any internal documents describing how ACC monitors consistency of decision-making, including:
internal quality-audit programmes
peer-review processes
variation analysis
decision templates or standardisation tools
guidance on avoiding inconsistent outcomes across regions or teams
(If a framework or methodology exists, a copy or index is sufficient.)
3.2 Aggregated annual data from 2019–2025 on:
the number of decisions amended or overturned internally due to quality issues
the number of decisions returned for rework due to inconsistency or incomplete evidence
instances where internal QA teams flagged systemic variation across teams, regions, or decision types
(No case-level data is requested.)
4. Review, ICRA & Court Feedback Loops
4.1 Any high-level internal documents describing ACC’s processes for analysing external feedback, including:
FairWay reviewer commentary
ICRA reviewer commentary
District Court and High Court appeal findings
trends from independent adjudicator decisions
quality improvements implemented in response
4.2 Annual aggregated data showing:
number of decisions changed following review (FairWay or ICRA)
number of decisions changed following appeal
themes or categories of decision-making errors identified during reviews
(Only summary or thematic documents are requested.)
5. System Reliability & Internal Audit
5.1 Internal audit or assurance reports (or an index of such reports) relating to:
system accuracy
claim file completeness
integrity of electronic records
handling of medical evidence
systemic error risks
5.2 Any internal data-quality improvement plans implemented between 2019–2025.
If full reports cannot be released, a list or summary of findings wil satisfy this request.
Format
I request the information in electronic format (PDF or existing internal summary documents).
If any portion of this request requires refinement, please advise so I may adjust the scope.
Thank you for your assistance.
Kind regards,
Spencer Jones
9
GOV-044947
From: SPENCER JONES <[email address]>;
Received: Mon Dec 08 2025 14:31:06 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - Request for Information on Provider Bil ing Irregularities, Audit Processes, and Fraud
Controls (2019–2025)
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Dear ACC,
Under the Official Information Act 1982, I request the following information relating to ACC’s management of provider bil ing
integrity, audit processes, and fraud-detection systems for the period 1 January 2019 – 31 December 2025 (or the closest
period for which data is held):
1. Provider Audits and Bil ing Irregularities
1.1 The total number of provider audits conducted by ACC relating to unusual, irregular, or potential y non-compliant bil ing.
1.2 The number of providers investigated for any of the following categories of bil ing concern (aggregate numbers only):
services bil ed but not provided
inflated treatment duration
duplicate bil ing
retrospective amendments to treatment notes
bil ing inconsistent with ACC service schedules
any other identified bil ing anomalies
1.3 The number of these investigations where bil ing irregularities, overcharging, or fraud were substantiated.
2. Outcomes and Recoveries
2.1 The total amount recovered by ACC from providers (annual figures), broken down into:
overpayments
overbil ing
fraudulent claims
audit adjustments
voluntary repayments after audit findings
(If already held in a consolidated internal report, providing that report would satisfy this request.)
2.2 The number of providers who:
were subject to corrective action plans
were suspended from delivering services
had contracts terminated
were referred to Police, Serious Fraud Office, or other regulatory bodies
3. Categories of Providers
3.1 For analysis and public transparency purposes, please provide high-level categories (not names) of provider types that
have been the most frequently identified with bil ing irregularities from 2019–2025.
Examples may include:
physiotherapy, chiropractic, pain management, vocational rehabilitation, occupational therapy, radiology, specialist
assessment providers, etc.
I am not requesting individual provider identification.
4. Fraud-Detection Framework and Audit Thresholds
4.1 Copies of any internal ACC documents that outline:
fraud-detection methodology
bil ing-anomaly detection rules
red-flag indicators
audit thresholds
internal referral pathways for suspected provider misconduct
monitoring or performance-assurance procedures used by ACC to detect potential irregularities
If documents are extensive, a list or summary index of relevant documents is sufficient.
Format
I request the above information in electronic form (Excel, PDF, or existing internal report formats).
If any part of the request is likely to require refinement, please advise so I may adjust the scope.
Thank you for your time.
Kind regards,
Spencer Jones
1
GOV-044978
0
From: Spencer Jones <[email address]>;
Received: Tue Dec 09 2025 12:21:44 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Re: OIA Response Ref GOV-044691 CRM:0305335
Kia ora ACC OIA Services,
Thank you for your 9 December 2025 response (GOV-044691). I appreciate the timely reply.
However, several aspects of the response require clarification because the explanations provided appear inconsistent with
both ACC’s own public reporting and previous OIA releases, and because the use of s18(e) and s12(2) in this instance raises
legitimate concerns under the duty to assist (s13) and the purpose of the OIA (s4).
This reply outlines the key contradictions and requests clarification so the request may proceed on an accurate basis.
1. Claimed non-existence of cost centres, project codes, programme codes, or sub-codes
Your response states that ACC holds no codes—beyond analysis code 06030—capable of distinguishing expenditure for:
• ICRA
• FairWay
• High Court
• District Court
• Tribunal matters
• External legal counsel
This claim appears inconsistent with:
A. ACC’s own public reporting
ACC annually publishes separate performance and volume reporting for:
• ICRA
• FairWay reviews
• Decline rates
• Resolution times
• Outcomes by forum
It is not possible to generate these public metrics without some form of internal segmentation or classification structure,
whether cost-centre based or metadata-based.
B. ACC’s 26 November OIA release (GOV-044064)
In that release, ACC provided separate expenditure totals for:
• ICRA ($10.7M in 2024/25)
• FairWay ($8.06M in 2024/25)
If ACC has no codes or attributes capable of distinguishing these forums, then it is unclear how these figures were generated.
C. Oracle and Med Fees Processing (MFP) system requirements
Both systems require:
• data dictionaries,
• field definitions,
• schema-level metadata,
• audit trails,
to function correctly and comply with public-sector finance and data-governance standards.
Therefore, the assertion that no definitional documentation or classification metadata exists at al is difficult to reconcile with
ordinary ERP operations and with Treasury Instructions 2024 and Cabinet metadata standards (CO(02)3).
I therefore request clarification on how ACC produces segmented reporting internal y and publicly if no segmentation is
recorded in the ERP or associated metadata.
2. Claimed absence of a data dictionary or field-definition documentation
Your response declines the request for a data dictionary under s18(e) on the basis that it “does not exist.”
However:
• Oracle financial systems require definitional metadata for al fields.
• MFP (which you confirm is also used) similarly requires schema documentation.
• Treasury Instructions require government agencies to maintain operational data dictionaries.
• ACC’s annual financial reporting requires structured field definitions for audit and assurance.
A statement that none of these materials exist at all appears inconsistent with the minimum governance requirements for
public entities operating ERP systems.
Please confirm whether:
1. ACC interprets “data dictionary” narrowly as only the one produced for GOV-044064,
or
2. ACC is asserting that no field-definition, metadata set, schema documentation, or internal definitional material exists
anywhere within Finance, Data & Analytics, or Technology Services.
This distinction is important for the accurate application of s18(e).
3. Inability to distinguish ICRA and FairWay within analysis code 06030
Your response states that:
“There are no sub-codes, attributes, or fields used to distinguish ICRA from FairWay.”
Yet ACC routinely publishes separate:
• ICRA volumes
• FairWay volumes
• Resolution times
• Decline rates
• Success/overturn statistics
and ACC released separate expenditure totals under OIA (#GOV-044064).
It would assist transparency to explain:
• The internal process or classification method used to produce these segmented totals if no coding or metadata
exists;
• Whether this segmentation occurs outside the ERP (e.g., manual collation, data-warehouse views, PowerBI models,
MFP tagging, etc.).
This clarification is essential to ensure the s18(e) refusal has been applied correctly.
4. Declining a clarification question under s12(2)
My Part 5 question asked:
“Can the structural metadata be supplied without invoking s18(f)?”
This was not a request for information, but a clarification designed to al ow you to meet your obligations under s13: duty to
assist.
Using s12(2) to decline a clarification question is unusual and appears inconsistent with Ombudsman guidance, which states
that agencies should actively help requesters refine their questions before relying on refusal grounds.
I therefore respectfully request that ACC:
• Either state whether structural metadata can be provided without substantial collation (s18(f)),
• Or advise what refinement would al ow the release of that information.
5. Request for reconsideration / further clarification
Given the issues outlined above, could ACC please:
A. Reconsider the application of s18(e)
in light of the publicly demonstrated existence of segmented ICRA/FairWay reporting and the standard operational metadata
required for Oracle/MFP systems.
or
B. Provide a brief explanation of how ACC internal y produces separate ICRA and FairWay expenditure and performance
reporting
if no codes, attributes, or metadata exist in the financial systems.
This clarification is needed so the public can understand the basis for expenditure reporting and so the OIA can continue on a
proper footing.
6. Acknowledgement of polite and constructive engagement
I appreciate the professionalism and timeliness of the responses received to date.
My questions are raised respectfully and in good faith, in the interests of ensuring the OIA process is accurate, transparent,
and consistent with obligations under:
• s4 (purpose of the Act),
• s13 (duty to assist),
• s14 (transfer obligations), and
• s18(e)/(f) (proper application of refusal grounds).
I look forward to your clarification.
Kind regards,
Spencer Jones
-----Original Message-----
Kia ora
Please find attached our response to your official information request
dated 26 November 2025. If you have any questions about the response you
can contact us at this [1]address, for al other matters please use our
contact form at:
[2]https://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.acc.co.nz%2Fcontact%2F&data=05%7C02%7C
governmentservices%40acc.co.nz%7Cb823bea7194c4f040b6d08de36b08954%7C8506768fa7d1475b901cfc1c222f496a%7C0
%7C0%7C639008329045900073%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOi
JXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=D0a10Z%2BsHQFwPNseZnAkv4%2F5WLO2pjf6TpD
qXeX%2B4PU%3D&reserved=0 alternatively give us
a cal on 0800 101 996.
If you are having trouble viewing the PDF, please ensure you have the
latest version of Adobe Acrobat Reader. To download this freeware please
click [3]here.
Ngâ mihi
Christopher Johnston (he/him)
Manager | OIA Services
* PO Box 242, Wellington 6011
ACC cares about the environment – please don’t print this email unless it
is really necessary. Thank you.
1
GOV-045041
1
From: SPENCER JONES <[email address]>;
Received: Wed Dec 10 2025 19:09:28 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Official Information request - ACC – clarification of ERP metadata and s18(e) refusals for dispute-resolution spend
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Dear Accident Compensation Corporation,
I refer to your responses GOV-044064 (26 November 2025), GOV-044691 (9 December 2025), and GOV-044440 (10 December
2025) concerning ACC’s external legal expenditure on reviews, appeals, and dispute resolution.
In GOV-044691 you refused parts 1–3 of my 26 November follow-up request under section 18(e) of the Official Information
Act 1982 on the basis that certain cost-centre, project code, and data-dictionary information “does not exist”. At the same
time, GOV-044064 and GOV-044440 demonstrate that ACC is able to produce disaggregated dispute-resolution figures by GL
account and forum (e.g. DCAPPS, HCAPPS, CAAPPS; 43070 “Statutory Appeals”; 06020 “Appeal, Mediation & Review”).
To clarify those refusals and to avoid any further misunderstanding, I request the following narrow items of information:
Data dictionary / field definitions actual y used for the tables already released.
Please provide any existing data dictionary, field definition list, or similar documentation that finance, reporting, or BI staff use
for the fields appearing in the appendices to GOV-044064 and GOV-044440, including (but not limited to):
GL Account
GL Account Description
Analysis Code
Analysis Code Description / Forum
Supplier / Supplier Type
If no formal data dictionary or field-definition document exists for these specific fields, please confirm this explicitly in writing.
Definitions of the appeal-related analysis codes already disclosed.
Please provide any document (for example a finance procedure, chart of accounts extract, reporting specification, or system
design note) that defines or describes the analysis codes:
CAAPPS
DCAPPS
HCAPPS
and explains how these codes are used to distinguish Court of Appeal, District Court, and High Court dispute-resolution
expenditure in ACC’s finance/ERP systems.
Section 23 statement of reasons for the section 18(e) decision in GOV-044691.
Under section 23 of the Official Information Act, please provide the reasons for ACC’s decision in GOV-044691 to refuse parts
1–3 of my 26 November 2025 request under section 18(e), including:
the findings of fact relied upon to conclude that relevant cost-centre, project-code, and data-dictionary information “does not
exist”; and
the titles or descriptions of any internal documents, if any, that were checked before that conclusion was reached.
These questions are tightly confined to metadata and reasoning that must already exist in order for ACC to produce the
dispute-resolution spend tables released in GOV-044064 and GOV-044440. No new data extraction or per-claim review is
sought.
I am happy to receive the information in PDF or Word format.
Kind regards,
Spencer Jones
1
GOV-045119
2
From: Spencer Jones <[email address]>;
Received: Sun Dec 14 2025 11:25:28 GMT+1300 (New Zealand Daylight Time)
To: ACC <[ACC request email]>; Government Services <[ACC request email]>;
<[ACC request email]>;
Subject: Re: Official Information request - ACC external legal services – finance/ERP extracts, GL codes, and panel spend
(2020/21–2024/25), with note to Claim #10038184163
Subject: Clarification of Part 4 – FYI OIA #32534 (GOV-044691)
Kia ora Christopher,
Thank you for your response of 9 December 2025 (GOV-044691).
I am writing to clarify **Part 4 only** of my request, which you indicated could not be answered due to section 12(2) (due
particularity).
To be clear, **I am not requesting any new information**, raw data, or analysis, and I am not expanding the scope of my
original OIA.
Clarification of Part 4 (Structural Metadata Only)
Part 4 seeks **confirmation only** of whether ACC holds any *existing structural metadata* associated with the systems you
have identified (Med Fees Processing and Oracle), **beyond** what was provided in GOV-044064.
Specifically, please confirm **yes or no** whether ACC holds **any of the following existing artefacts**, in any form:
1. **System schemas, field lists, or table definitions** for MFP and/or Oracle that describe how litigation or dispute-resolution
expenditure is categorised (for example: forum, matter type, review/appeal indicator, internal vs external legal spend).
2. **Configuration documentation or system design records** that define how analysis code 06030 is applied within those
systems.
3. **Any internal documentation** (including technical notes or configuration guides) that explains how the data in Appendix
2 of GOV-044064 is structured or derived.
If **none of the above artefacts exist**, please confirm this explicitly under **section 18(e)** of the Official Information Act.
If any exist but are withheld, please cite the **specific refusal ground(s)** relied upon.
Reason for Clarification
This clarification is provided to meet section 12(2) and to enable ACC to make a substantive decision under Part 2 of the Act,
consistent with the duty to assist in section 13.
I am **not** asking whether metadata *can be created* or *collated*, only whether **existing structural documentation is
held**.
Please treat this email as a clarification of the existing request, not a new OIA.
Kind regards,
Spencer Jones
FYI OIA #32534
