Schedule to the Guidelines for Rehabilitation Authorities 2012 Compliance Report Rehabilitation Management System Corrective Action Plan

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1 Schedule to the Guidelines for Authorities 2012 Compliance Report Management System Corrective Action Plan A Comcare external audit of the Management System, Australian National University (ANU), was conducted on the April The following corrective action plan addresses follow up actions to be implemented in response to non conformances observations identified in the audit report dated 19 May Non Conformances Non Conformance Corrective action Criterion 3.3. The rehabilitation authority communicates relevant information regarding the rehabilitation process to its employees including their rights obligations. ANU Manual, template letters flow charts to be reviewed to ensure 31/07/2016 In this requirement is detailed at each point of the process where employees are to be correctly notified of their rights. ANU does not always ensure that employees are correctly notified of their rights. Case Management training session to be conducted to review requirements, process issues to ensure this occurs. ANU intranet pages related to injury management workers compensation are to be reviewed to ensure that information is provided on employee rights as well as links to appropriate Comcare documentation. Proposed claims management system information technology systems are to be developed with access to employee notice of rights for these to be generated attached to appropriate documentation as required. Revision: Version 1.0 Page 1

2 Schedule to the Guidelines for Authorities 2012 Compliance Report ANU does not effectively use the provisions of section 36 to conduct rehabilitation assessments in accordance with the SRC Act the Guidelines. Management System Corrective Action Plan Non Conformance Corrective action Criterion 3.6. The rehabilitation authority effectively uses the provisions of section 36 to conduct rehabilitation assessments in accordance with the SRC Act the Guidelines. ANU Manual, template letters flow charts to be reviewed to ensure 31/07/2016 In that the provisions for section 36 are effectively appropriately used. Example s36 assessment medical specialist questions are to be stored in a central location to assist with maintaining appropriate best practice correspondence. Case Management training session to be conducted to review requirements, process issues for s36 assessments. ANU Intranet pages related to injury management workers compensation are to be reviewed to ensure that information regarding s36 assessments is appropriate provides links to further Comcare documentation. Proposed claims management system information technology systems are to be developed with access to proforma s36 letters as examples for Case Management use. 31/07/2016 In progress Revision: Version 1.0 Page 2

3 Schedule to the Guidelines for Authorities 2012 Compliance Report Management System Corrective Action Plan Date to be Non Conformance Corrective action Completed Criterion 3.9. The rehabilitation authority makes determinations in accordance with the SRC Act the Guidelines: Current Status Action Officer (i) (ii) (iii) ANU does not in all cases follow its procedures when making determinations. that are in writing give adequate reasons that are signed by the delegate that are not retrospective ANU Manual, template letters flow charts to be reviewed to ensure this requirement is detailed at each point of the process when Case s are making determinations. Case Management training session to be conducted to review requirements, process issues to ensure this occurs. ANU Intranet pages related to injury management workers compensation are to be reviewed to ensure that information provided re rehabilitation determinations is appropriate, that links to further Comcare documentation is provided. 31/07/2016 In Revision: Version 1.0 Page 3

4 Schedule to the Guidelines for Authorities 2012 Compliance Report Management System Corrective Action Plan Non Conformance Corrective Action Criterion 4.3. The rehabilitation authority conducts audit program performed by competent personnel in accordance with the requirements of the Commission Comcare to measure performance of its rehabilitation management system. ANU does not have an audit program. Audit procedure to be developed approved following consultation to encompass the safety, rehabilitation claims management systems. Internal external audit schedule to be developed approved following consultation to encompass the safety, rehabilitation claims management systems. audit program elements to be designed implementation coordinated. External auditor options to be identified requirements discussions to be conducted with each company. Quotes for services to be obtained. 31/07/2016 In Service level agreements to be completed for the use of external auditor services. 31/07/2016 In Revision: Version 1.0 Page 4

5 s Schedule to the Guidelines for Authorities 2012 Compliance Report Management System Corrective Action Plan Corrective Action Criterion 1.2. The rehabilitation management system provides for internal external accountability. While ANU has a External auditor options to be identified requirements discussions to be number of internal conducted with each company. Quotes for services to be obtained. accountability measures, it does not have external measures, such as an Review of external auditor service provision to be conducted annually to ensure that audit program a service level provision stards are meet. service level agreement with a firm of auditors. Date to be Completed Current Status 31/07/2016 In Service level agreements to be completed for the use of external auditor services. Action Officer Revision: Version 1.0 Page 5

6 Schedule to the Guidelines for Authorities 2012 Compliance Report ANU s procedures regarding noncompliance do not reflect the provisions of sections of the SRC Act. Management System Corrective Action Plan Corrective action Criterion The rehabilitation authority makes determinations in relation to employee non compliance in accordance with the SRC Act, Guidelines their written policy procedures. ANU Manual, template letters flow charts to be reviewed to ensure 31/07/2016 In this requirement is detailed at each point of the process when Case s are addressing issues of non compliance. Case Management training session to be conducted to review requirements, process issues to ensure this occurs. ANU Intranet pages related to injury management workers compensation are to be reviewed to ensure that information is provided on employee non compliance as well as links to appropriate Comcare documentation. Proposed claims management system information technology systems are to be developed with access to proforma non compliance letters as examples for Case Management use. Revision: Version 1.0 Page 6

7 Schedule to the Guidelines for Authorities 2012 Compliance Report A number of files lacked evidence of any feedback with rehabilitation providers. Management System Corrective Action Plan Nature of corrective action Criterion 4.2. The rehabilitation authority monitors rehabilitation providers performance in terms of quality of service delivery, costs, progress reports outcomes. ANU Manual, template letters flow charts to be reviewed to ensure 31/07/2016 In this requirement is detailed at each point of the process when Case s are monitoring rehabilitation provider performance. Quality stard document to be produced for provision to external Workplace Providers at time of referral for s36 assessment s37 program commencement. Service Level Agreement (SLA) document to be developed provided to all Workplace Providers contracted for the provision of services to the ANU. Case Management training session to be conducted to review requirements, process issues to ensure this occurs. Specifically targeting feedback to be provided to the Workplace Provider (WRP) on the proposed direction the WRP has detailed for the management of the rehabilitation case. WRP evaluation feedback forms to be completed at the end of service provision evidence of this feedback to be retained on file. Complete a case review / key learnings discussion at major review periods closure. Provide feedback to the WRP on their performance in managing the case. Comcare to be notified of WRP poor performance stards or quality assurance issues identified in service provision. 31/10/2016 Ongoing Ongoing In In Revision: Version 1.0 Page 7

8 Schedule to the Guidelines for Authorities 2012 Compliance Report Management System Corrective Action Plan Nature of corrective action Criterion 4.2. The rehabilitation authority monitors rehabilitation providers performance in terms of quality of service delivery, costs, progress reports outcomes. Proposed claims management system information technology systems are to be developed with access to proforma Workplace Provider letters as examples for Case Management use. Nature of corrective action Criterion 4.4. Audit outcomes are appropriately documented actioned. The rehabilitation authority reports to senior executive on its rehabilitation management system performance, including audit outcomes. Audit procedure to be developed approved following consultation to encompass the safety, rehabilitation claims management systems how audit result will be communicated to senior management. ANU does not have an audit procedure that sets out how audit results will be documented, actioned reported to senior management. Summary of Management System audit results corrective action plan to be made available to the WHS Policy Committee Meeting. Internal audit program to target compliance with the requirements through follow up of reporting requirements to senior executive. Revision: Version 1.0 Page 8

9 Schedule to the Guidelines for Authorities 2012 Compliance Report ANU does not have an audit procedure that sets out how audit results will be communicated to its employees. Management System Corrective Action Plan Criterion 4.5. The rehabilitation authority communicated the outcomes results of rehabilitation management system audits to its employees. Audit procedure to be developed approved following consultation to encompass the safety, rehabilitation claims management systems how audit result will be communicated to employees. Summary of Management System audit results corrective action plan to be made available to WHS Committee Meeting Chairs for communication to employees. Internal audit program to target compliance with the requirements through follow up of communication requirements to employees. Revision: Version 1.0 Page 9