What would these improvements look like?
Following the co-design process, we're now working through what the improvements would look like in more detail. It's important to note that the overall structure of AEP will remain the same as what's currently in place and we'll continue to work with our customers to improve AEP.
We've outlined below what the improvements might look like as an end-to-end process: from an organisation considering joining AEP through to leaving the programme. These improvements would involve incremental changes across all areas to the programme, and we would consult with our customers on any proposed changes.
The end-to-end process
An employer is considering joining AEP
We'll review the information we provide for organisations who are thinking of joining AEP to make this process more transparent.
Entering the programme and becoming accredited
Co-design told us that improving the three-factor accreditation process provides assurance that organisations have the capability and capacity to stand in the shoes of ACC. An accredited employer (AE) would only be accredited if they were up to date in the following three areas:
We didn’t identify any improvements to the financial assurance entry criteria. However, there is an opportunity to offer a more flexible range of product plan options.
In the future, we could tie performance into the options available. Eg high performance could unlock more attractive options.
Claims and injury management certification
Strengthening certification was identified to ensure AEs and third-party administrators (TPAs) have the right processes in place to effectively manage claims and injuries (initial care, rehabilitation and return to work) through their own processes.
Assessment and, where relevant, improvement to the current audit process would be needed to achieve this. AEs and TPAs would be certified to ensure they could effectively manage claims and injuries. Currently TPA capability is assessed indirectly through their contribution to the AE audit.
Certification periods could be tied to performance e.g. high performance would show that systems, processes and capability are working well.
- Improved employee contribution to the certification process, providing an additional view on AE and TPA capability and recent performance.
- AEs and ACC are assured that TPAs can provide effective injury claims management services.
- With clear certification criteria and standards, all parties can proactively raise their claims and injury management capability.
- High performing AEs would have demonstrated they have effective systems, processes and capability, so their certification periods could be longer, providing more time to focus on continuously improving their injury prevention.
Health and safety system assessment
Removal of ACC’s audited safety management practices requirements and replacement with an independent, external health and safety system assessment was identified to support AEs to focus on improving worker experience and participation in their health and safety systems in accordance with the Health and Safety at Work Act 2015. Each employer would be responsible for gaining and maintaining their own independent, externally assessed health and safety standard(s) relevant to their industry.
We would need a way to check which assessments would be appropriate for providing assurance that an AE has appropriate experience in managing occupational health and safety.
Some AEs could continue to use their current external health and safety assessment, saving time and cost. Those not using an equivalent external health and safety assessment already would need to make a financial and system investment in this area.
- All parties would have clarity about the focus of AEP and would be assured that an AE could provide a healthy and safe workplace that complies with the Health and Safety at Work Act 2015.
- Appropriate safety standards would be encouraged rather than a one-size-fits-all approach.
- Improved health, safety and wellbeing for employees and greater organisational injury prevention.
Being in the Accredited Employers Programme
Contract (the Agreement)
The AEP contract and schedule set out the complete agreement between ACC and AEs. Changes to the contract are through schedule variation. The way schedules are written and used could be improved, fine-tuning how we describe and agree the expected performance standards. Including stronger contractual obligations to workers and evidence of continuous improvement.
We’d need to review AE performance against the contractual agreement prior to preparing the schedules each year.
AEs and TPAs might be required to collect and store more information to demonstrate their performance against their contractual obligations. As a result, recommendations for improvements will be included in contract renewals.
- Performance expectations would be clear and transparent.
- Employees would have an improved experience as a result of their increased engagement in health, safety and well-being in the workplace.
We'd like to replace the two current options with one plan. This provides more flexibility, helps meet differing circumstances, and limits financial exposure.
In the future we could tie performance to plan options. Eg high performance means there would be a wider selection of products available to an AE. Linking plan options to performance would mean we’d need to have very clear performance standards and measures.
- We could align plan option availability to performance, which would incentivise accredited employers to continue to improve their claims management and injury management performance.
Performance Framework and monitoring of performance
A Performance Framework would define the standards and measures we would use to monitor performance. In accordance with this, we would set clear performance expectations and outcomes for AEs, and establish a clear monitoring and response framework with consequences for good and poor performance.
Our performance expectations and monitoring and response framework could continuously improve over time. To achieve this:
- we’d collect more comprehensive information from AEs, to have a clear view of how they’re performing
- performance measures would include the experience of an injured employee and their return to work
- we’d provide AEs with more monitoring, reporting and feedback on their performance
- we’d compare AE performance across industries, levy risk groups and within the programme
- our monitoring and response framework would clearly describe situations where poor performance would need to be addressed and would outline a course of action for improvement.
- Performance data would be made up of both data supplied by AEs as well as data gathered by us through claims file checks and the experience of the injured employee. This means the programme would have broader and more meaningful performance information available to everyone.
- Trends in AE performance would be tracked, and we would make sure AEs responded to feedback from us in a timely way, making sure employees received a good standard of claims and injury management.
- We’d clearly define what data AEs are required to provide and be measured on, so that AEs would be clear about expectations and what improvements they need to make.
What would this mean for AEP?
- All parties would be required to store, supply, analyse, report and feedback additional data and information.
- Performance standards and measures would be developed and continuously reviewed for relevancy. We’d need to develop meaningful evidence-based performance standards and measures.
- Linking plan options to performance would mean we must have clear performance standards and robust measures. We would also need to establish baseline data in order to begin assessing performance against the new standards and measures – this would take time.
- The contract and schedule would need updating.
Improving how we work with AEs was identified, such as providing guidance material and direction to lift performance. We would also learn from high performing AEs. To do this we would take a more systematic and proactive approach to working with AEs and TPAs on their performance.
- AEs would have clear guidance on how to improve their performance, ultimately improving outcomes for their employees when they are injured and lowering injury rates.
- A more collaborative approach would mean good practice could be shared amongst AEs.
- We’d know which AEs are not performing well and have evidence to exit the AE from the programme if their performance didn’t improve.
What would this mean for AEP?
- We’d need more intensive relationship management with AEs.
- It’s likely that new capabilities for all involved in AEP would need to be developed in response to the changes in the engagement approach.
- We’d use a targeted performance response matrix to understand the most appropriate way to work.
Leaving the Accredited Employers Programme
We’d ensure we provided clear information for AEs about leaving the programme and how they could transition to other levy products. The evidence required to exit an AE from the programme would be more robust with improved data and performance monitoring in place.