Public interest note

This request concerns ACC’s review and dispute-resolution system, including review bundles, evidential completeness, assessor instructions, impairment assessment material, disclosure controls, cost, delay, and search certification.

The request does not seek personal information about any individual claimant. It asks for policy-level, aggregated, anonymised, audit-level, or operational material only.

This request should be read alongside earlier ACC OIA material already requested and/or actioned, including:

* GOV-044064 — ACC response on external legal services, review-provider expenditure, ICRA, FairWay, and related panel spend.
* GOV-044440 — ACC response providing aggregated financial tables on dispute-resolution expenditure, including reviews, appeals, and external legal costs for 2020/21–2024/25.
* GOV-044691 — ACC response concerning ERP / finance systems, GL codes, cost centres, project codes, data dictionaries, and metadata for ICRA, FairWay, litigation and related dispute-resolution expenditure.
* GOV-044978 — follow-up clarification request concerning apparent inconsistencies between ACC’s ability to report separate ICRA/FairWay figures and its position on available cost codes or metadata.
* GOV-045041 / FYI #33222 — follow-up request concerning ERP metadata and s18(e) refusals for dispute-resolution spend.
* FYI #33170 — follow-up request seeking confirmation of GL accounts and analysis codes for dispute-resolution expenditure.
* GOV-044915 — ACC’s grouped response dated 18 December 2025, which responded to 12 related OIA emails and refused the broader grouped request under s18(f) substantial collation, while clarifying that ICRA and FairWay spend had been separated using unique vendor IDs.
* GOV-044948 — request concerning external legal expenditure, investigator engagements, and assessor governance frameworks.
* GOV-044950 — request concerning conflicts of interest, assessor governance, and panel-selection processes.
* GOV-044951 — request concerning data integrity, file accuracy, evidence handling, and decision-making quality assurance.
* GOV-044952 — request concerning performance targets, operational time standards, decline rates, and staff pressure frameworks.
* GOV-044929 — request concerning annual performance outcomes, clinical quality assurance, turnaround-time standards, contractor oversight, and workforce adequacy.

Those earlier requests established, from ACC-supplied information, a significant public-interest context. The material indicates that ACC dispute-resolution spend increased from approximately $13.5 million in 2020/21 to approximately $22.5 million in 2024/25. It also indicates that ICRA and FairWay together accounted for approximately $18.77 million in 2024/25 and approximately $73.1 million over five years. External legal spend for reviews was approximately $6.73 million over five years, and appeals expenditure was approximately $8.6 million over 2021/22–2024/25.

The purpose of this present request is not to re-ask those cost questions. The cost context has already been established.

The present request asks the next public-administration question:

If tens of millions of dollars are being spent on ACC review, dispute resolution, external legal services, review providers, and appeals, what safeguards exist to ensure that the evidence base is complete, the review bundle is accurate, assessor instructions are disclosed where appropriate, calculation pathways are available, and claimants are not forced to fight separate disclosure battles before the merits of their dispute can be fairly addressed?

ACC review is intended to provide a practical correction pathway when a claimant disputes an ACC decision. For that pathway to be fair, the claimant and reviewer need to know what evidence ACC relied on, what records were provided to any assessor, what instructions were given, whether relevant records were omitted, and whether the review bundle is complete.

Where review bundles are incomplete, assessor instructions are not disclosed, impairment calculation material is unavailable, or relevant evidence is missing or late, the review process can become slower, more expensive, and more difficult for claimants to navigate. This is especially important for injured people, self-represented claimants, people with cognitive or mental health impacts, and veterans or former service personnel dealing with complex injury pathways.

The request therefore asks whether ACC holds policies, guidance, audits, data, or internal analysis about:

* preparation and completeness of review bundles;
* disclosure of records relevant to review issues;
* disclosure of assessor instructions and medical assessment questions;
* disclosure of impairment assessment worksheets or calculation pathways;
* correction of incomplete or inaccurate review bundles;
* cost and delay caused by disclosure, bundle, assessment, or missing-record issues;
* cases where ACC changed, revoked, substituted, or reconsidered a decision before hearing;
* and whether ACC should certify search completeness, bundle completeness, assessor instructions, and evidence relied upon before a review proceeds.

This is not an allegation about any individual reviewer, assessor, or ACC staff member. It is a public-administration question about whether a statutory dispute-resolution system contains adequate safeguards to ensure that the evidence base is complete, accessible, and capable of being tested before a claimant is required to argue the merits of a dispute.

The wider issue is whether dispute and review systems can be efficient, affordable, and fair if affected people must first fight separate disclosure, search, bundle, metadata, or evidence-completeness battles before the actual dispute can be properly addressed.