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

Transcription

1 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 and 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 and obligations. ANU Manual, template letters and flow charts to be 31/07/2016 Attachment A: reviewed to ensure this requirement is detailed at each point of the process where employees are to be correctly notified of their rights. Manual ANU does not always ensure that employees are correctly notified of their rights. Case Management training session to be conducted to review requirements, process and issues to ensure this occurs. ANU intranet pages related to injury management and workers compensation are to be reviewed to ensure that information is provided on employee rights as well as links to appropriate Comcare documentation. through spot file checks. Audit findings to be documented. Proposed claims management system (Figtree) information technology systems are to be developed with access to employee notice of rights and for these to be generated and attached to appropriate documentation as required. 31/10/2016 Attachment B: RCM Training Events 31/10/2016 Attachment C: Intranet pages 31/10/2016 Attachment D: Internal file audits 31/03/2017. Figtree Attachment E: implementation by Figtree specifications Revision: Version 2.0 Page 1

2 Non Conformance Corrective action Criterion 3.3. The rehabilitation authority communicates relevant information regarding the rehabilitation process to its employees including their rights and obligations. 31/03/2017. External audit scheduled for Attachment F: BRM Revision: Version 2.0 Page 2

3 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 and the Guidelines. ANU Manual, template letters and flow charts to be 31/07/2016 Attachment A: reviewed to ensure that the provisions for section 36 are effectively and appropriately used. Manual ANU does not effectively use the provisions of section 36 to conduct rehabilitation assessments in accordance with the SRC Act and the Guidelines. Example s36 assessment medical specialist questions are to be stored in a central location to assist with maintaining appropriate and best practice correspondence. Case Management training session to be conducted to review requirements, process and issues for s36 assessments. ANU Intranet pages related to injury management and workers compensation are to be reviewed to ensure that information regarding s36 assessments is appropriate and provides links to further Comcare documentation. through spot file checks. Audit findings to be documented. 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 Attachment G: Draft s36 question list 31/10/2016 Attachment B: RCM Training Events 31/10/2016 Attachment C: Intranet pages 31/10/2016 Attachment D: Internal file audits 31/03/2017. Figtree Attachment E: implementation by Figtree specifications 31/03/2017. External audit scheduled for Attachment F: BRM Revision: Version 2.0 Page 3

4 Date to be Current Status Non Conformance Corrective action Criterion 3.9. The rehabilitation authority makes determinations in accordance with the SRC Act and the Guidelines: Evidence (i) (ii) (iii) ANU does not in all cases follow its procedures when making determinations. that are in writing and give adequate reasons that are signed by the delegate that are not retrospective ANU Manual, template letters and flow charts to be reviewed to ensure this requirement is detailed at each point of the process when Case Managers are making determinations. Case Management training session to be conducted to review requirements, process and issues to ensure this occurs. ANU Intranet pages related to injury management and workers compensation are to be reviewed to ensure that information provided re rehabilitation determinations is appropriate, and that links to further Comcare documentation is provided. through spot file checks. Audit findings to be documented. 31/07/2016 Attachment A: Manual 31/10/2016 Attachment B: RCM Training Events 31/10/2016 Attachment C: Intranet pages 31/10/2016 Attachment D: Internal file audits 31/03/2017. External Attachment F: BRM audit scheduled for Revision: Version 2.0 Page 4

5 Non Conformance Corrective Action Criterion 4.3. The rehabilitation authority conducts and audit program performed by competent personnel and in accordance with the requirements of the Commission and Comcare to measure performance of its rehabilitation management system. ANU does not have an audit program. Audit procedure to be developed and approved following consultation to encompass the safety, rehabilitation and claims management systems. 31/10/2016 Attachment H: Audit Procedure Internal and external audit schedule to be developed and approved following consultation to encompass the safety, rehabilitation and claims management systems. audit program elements to be designed and implementation co ordinated. 31/10/2016 Attachment I: Audit schedule 31/10/2016 Attachment D: Internal file audits External auditor options to be identified and requirements discussions to be conducted with each company. Quotes for services to be obtained. Service level agreements to be completed for the use of external auditor services. 31/07/2016 Attachment F: BRM Attachment J: Niche external auditing quote 31/10/2016 Attachment F: BRM Attachment K: Service level agreement Revision: Version 2.0 Page 5

6 s Corrective Action Date to be Criterion 1.2. The rehabilitation management system provides for internal and external accountability. While ANU has a External auditor options to be identified and requirements number of internal discussions to be conducted with each company. Quotes for services accountability to be obtained. measures, it does not have external measures, such as an audit program and a service level agreement with a firm Service level agreements to be completed for the use of external of auditors. auditor services. Current Status Evidence 31/07/2016 Attachment F: BRM Attachment J: Niche external auditing quote 31/10/2016 Attachment F: BRM Review of external auditor service provision to be conducted annually to ensure that service level provision standards are meet. Attachment K: Service level agreement 31/03/2017 Attachment F: BRM Revision: Version 2.0 Page 6

7 Date to be Corrective Action Criterion 1.2. The rehabilitation management system provides for internal and external accountability. Current Status Evidence Attachment K: Service level agreement Revision: Version 2.0 Page 7

8 Corrective action Criterion The rehabilitation authority makes determinations in relation to employee non compliance in accordance with the SRC Act, Guidelines and their written policy and procedures. ANU Manual, template letters and flow charts to be 31/07/2016 Attachment A: reviewed to ensure this requirement is detailed at each point of the process when Case Managers are addressing issues of Manual non compliance. Case Management training session to be conducted to review requirements, process and issues to ensure this occurs. 31/10/2016 Attachment B: RCM Training Events ANU s procedures regarding noncompliance do not reflect the provisions of sections 36 and 37 of the SRC Act. ANU Intranet pages related to injury management and workers compensation are to be reviewed to ensure that information is provided on employee non compliance as well as links to appropriate Comcare documentation. through spot file checks. Audit findings to be documented. Proposed claims management system information technology systems are to be developed with access to proforma noncompliance letters as examples for Case Management use. 31/10/2016 Attachment C: Intranet pages 31/10/2016 Attachment D: Internal file audits 31/03/2017. Figtree Attachment E: implementation by Figtree specifications 31/03/2017. External audit scheduled for Attachment F: BRM Revision: Version 2.0 Page 8

9 A number of files lacked evidence of any feedback with rehabilitation providers. Nature of corrective action Criterion 4.2. The rehabilitation authority monitors rehabilitation providers performance in terms of quality of service delivery, costs, progress reports and outcomes. ANU Manual, template letters and flow charts to be 31/07/2016 Attachment A: reviewed to ensure this requirement is detailed at each point of the process when Case Managers are monitoring Manual rehabilitation provider performance. Quality standard document to be produced for provision to external Workplace Providers at time of referral for s36 assessment and s37 program commencement. Service Level (SLA) document to be developed and 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 and 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. 31/10/2016 Attachment L: Letter to Workplace Providers 31/10/2016. Service standards specified in letter. SLA not appropriate due to limited number of cases referred to each WRP organisation. Attachment L: Letter to Workplace Providers 31/10/2016 Attachment B: RCM Training Events Revision: Version 2.0 Page 9

10 Nature of corrective action Criterion 4.2. The rehabilitation authority monitors rehabilitation providers performance in terms of quality of service delivery, costs, progress reports and outcomes. WRP evaluation feedback forms to be completed at the end of service provision and evidence of this feedback to be retained on file. Complete a case review / key learnings discussion at major review periods and closure. Provide feedback to the WRP on their performance in managing the case. Ongoing Attachment M: Example feedback to WRPs Comcare to be notified of WRP poor performance standards or quality assurance issues identified in service provision. through spot file checks. Audit findings to be documented. Proposed claims management system information technology systems are to be developed with access to proforma Workplace Provider letters as examples for Case Management use. Ongoing Not applicable. No instances have occurred. 31/10/2016 Attachment D: Internal file audits 31/03/2017. External audit scheduled for 31/03/2017. Figtree implementation by Attachment F: BRM Attachment E: Figtree specifications Revision: Version 2.0 Page 10

11 ANU does not have an audit procedure that sets out how audit results will be documented, actioned and reported to senior management. Nature of corrective action Criterion 4.4. Audit outcomes are appropriately documented and actioned. The rehabilitation authority reports to senior executive on its rehabilitation management system performance, including audit outcomes. Audit procedure to be developed and approved following 31/10/2016 Attachment H: consultation to encompass the safety, rehabilitation and claims Audit Procedure management systems and how audit result will be communicated to senior management. Summary of Management System audit results and corrective action plan to be made available to the WHS Policy Committee Meeting. through follow up of reporting requirements to senior executive. 31/10/2016 Attachment N: University Council Report 31/10/2016 Attachment I: Audit schedule 31/03/2017. External audit scheduled for Attachment F: BRM Revision: Version 2.0 Page 11

12 Nature of corrective action Criterion 4.5. The rehabilitation authority communicated the outcomes and results of rehabilitation management system audits to its employees. Audit procedure to be developed and approved following 31/10/2016 Attachment H: consultation to encompass the safety, rehabilitation and claims Audit Procedure management systems and how audit result will be communicated to employees. ANU does not have an audit procedure that sets out how audit results will be communicated to its employees. Summary of Management System audit results and corrective action plan to be made available to WHS Committee Meeting Chairs for communication to employees. through follow up of communication requirements to employees. 31/10/2016 Attachment N: University Council Report WHS Annual Report Intranet page 31/10/2016 Attachment I: Audit schedule 31/03/2017. External audit scheduled for Attachment F: BRM Revision: Version 2.0 Page 12