1 Appendix A CHOICE IN THE ACC WORKPLACE ACCOUNT A slutin lking fr a prblem? Analysis f the Department f Labur ptins discussin dcument. A reprt prepared fr the ACC Futures Calitin Peter Harris 12 July 2011
2 Cntents Executive Summary Scpe f this reprt Main cnclusins The Wrk Accunt in the brader scheme f things Existing chice in the Wrk Accunt Wrkplace Safety Management Practices Prgramme Accredited Emplyer Prgramme Experience rating Take-up f existing chice ptins Evidence that chice delivers better results Issues assciated with widening chice Prpsal t increase chice within ACC Variatin in claims management perids Starting claims cver perid frm date f accident Changed audit requirements Reducing minimum levels f high cst and stp lss cver Intrducing chice f prvider f high cst and stp lss cver Allwing chice f excess Third party financial guarantees Grup participatin Cmpulsry take back by ACC at emplyer request Full and final settlement n take back Prpsal t increase chice frm ACC Ptential fr benefits frm private insurance ptin Particular features f the cmpetitive insurance ptin Detail still needing t be develped Funding f residual claims Funding f gradual prcess injuries Allcating csts f public health and emergency transprt services The prudential regime that will apply t insurers Unknwn dimensins f cst (partly derived frm the unknwn scheme detail) Pricing f risk Cst f the administratin and regulatry regime Cnclusin n private insurance ptin Is it brken?
3 Executive Summary The gvernment is cnsulting n tw ptins t change the funding f the ACC Wrk Accunt: extending the cverage f the Accredited Emplyer Prgramme, by reducing sme cmpliance bligatins and widening chice f the frm f partial self insurance that participating emplyers can select; intrducing the ptin f insuring with private prviders t cver emplyer bligatins fr wrkplace accidents. There is very little evidence that there is a prblem that either f these slutins needs t address, and less evidence that they will have psitive benefits. Between 2000 and 2009, AEP emplyers had better accident recrds (and therefre lwer ACC csts), but there is n evidence that AEP caused the better perfrmance. It is equally plausible (and mre likely) that emplyers with better pre-existing accident recrds tk advantage f the ptin f AEP t capture the benefits f their better systems and practices. Actuarial analysis dne during the recent Stcktake f ACC shws that there is n evidence t supprt the hypthesis that accredited emplyers shw greater imprvements in rates f claim ver time. If AEP was delivering better results the expectatin wuld be that claim rates wuld imprve ver time. Since 2006, the number f emplyers participating in the prgramme has declined steadily, by abut 6 percent a year. If it was delivering imprved results, it wuld, ver time, be pening up a gap between what the ACC charges fr cver and what self-insurance culd achieve, and the expectatin wuld be that participant numbers wuld increase, nt decrease. Over the last decade standard emplyers have had marked imprvements in the rate f weekly cmpensatin claims while accredited emplyers have been virtually static. The relative claim rate fr standard emplyers was 40 percent abve that f accredited emplyers in 2001, but by 2007 the relative standing reversed, and by 2010 their claim rates are abut 25 percent belw thse f accredited emplyers. If the AEP was delivering fewer claims and lwer csts, the expectatin wuld be that thse trends wuld g in the ppsite directin. 3 Any margin t lwer csts in cmparisn with paying ACC levies will have been further erded by the prbability that wrk accunt levies will fall by 22 percent in 2012/13. High-risk firms (which wuld tend t have mre pprtunity t lwer csts thrugh imprved systems, and wh wuld be mre likely t enter the AEP as a result), will receive larger prprtinate discunts than the average. Experience rating was intrduced frm 1 April Leaving aside pssible prblems that experience rating culd bring fr claimants, if it is applied accurately levies shuld mimic what emplyers culd achieve thrugh self insurance, and therefre remve the incentives f participatin in the AEP.
4 It is precisely the wrng time (falling participatin, falling levies, levies matching perfrmance) t be trying t expand AEP cverage. Private insurance is an even wrse ptin. There are a number f uncertainties abut hw private insurance will perate, and s it is difficult t evaluate what benefits it might bring. Key uncertainties are: the precise detail f the regulatry apparatus that will be needed t ensure that entitlements are met, and what it will cst t perate; the nature f the prudential regime that participating insurers will have t perate under; hw residual claims (i.e. all claims existing at the time f the intrductin f the insurance ptin) will be funded, especially if the cst f meeting residual claims rises in the future, fr example if assets in the Wrk Accunt are erded by anther finance sectr cllapse; if, when, and t what extent participants will need t pick up a share f the cst f meeting claim inherited frm failed insurers; hw the csts f gradual prcess injuries will be allcated, especially if the initial injury ccurred when the emplyee was cvered by anther insurer; hw the csts f public health and emergency transprt services will be allcated. These knwn unknwns are s fundamental that in advice t Cabinet, gvernment fficials cncluded that there is a high degree f uncertainty regarding the magnitude f bth csts and benefits (and in sme cases, even the sign i.e. whether they will have a net psitive r negative impact 4 Officials cncluded that better pricing signals t emplyers can be achieved thrugh experience rating and self-insurance arrangements. With all f the changes currently in train - the bedding in f experience rating, falling Wrk Accunt levies, a degree f turmil in the insurance industry in general, and fading enthusiasm fr the AEP change fr the sake f change cannt be justified.
5 1.0 Scpe f this reprt This reprt discusses the issues raised in the Department f Labur Discussin Dcument n ptins fr extending the Accredited Emplyer Prgramme and fr intrducing ptins fr emplyers taking ut private insurance cver t meet sme f their bligatins within the ACC Wrk Accunt. 1 (discussin dcument frm here n in). It des nt discuss the much wider suite f changes recmmended by the Steering Grup that carried ut the stcktake f ACC Accunts. 2 This is because the main structural features f that grup s recmmendatins: pening up all accunts t cmpetitive private delivery f services, and remving ACC as a cmpetitr in the resulting market; have nt been prgressed by the gvernment. The prpsals in the Discussin Dcument are the current live issues. 2.0 Main cnclusins This reprt cncludes that: the appetite amng emplyers fr additinal chice ptins t discharge their ACC bligatins has nt been established; there is n evidence that widening chice will imprve perfrmance under the scheme; there are a large number f cst and regulatry uncertainties that have yet t be determined, but that until these utstanding lse ends have been tidied up it is nt pssible t draw firm cnclusins abut the likely impact f any r all f the prpsed changes. 5 In shrt, the prpsals are slutins lking fr a prblem. 3.0 The Wrk Accunt in the brader scheme f things All csts f ding business are f cncern t rganisatins, be they in the private, public r nt-frprfit sectrs. Hwever, the relative imprtance f elements f verall csts will tend t shape the degree t which emplyers are incentivised t allcate time t reducing them. In New Zealand cmpensatin f emplyees (effectively the cst f labur) is abut 44 per cent f Grss Dmestic Prduct. There will be sme sectrs where labur is a very high prprtin f the cst f prductin (accuntancy, architecture, educatin etc.) and thers where it is very lw given the scale f plant and materials required, high cst f raw materials and energy intensity f prductin (fr example pulp and paper). 1 Increasing chice in wrkplace accident cmpensatin: discussin dcument n ptins fr extending the Accredited Emplyer Prgramme and intrducing chice in the ACC Wrk Accunt, Department f Labur, June Accident Cmpensatin Services in New Zealand: the perfrmance f the ACC scheme and pprtunities fr imprvement. Final reprt prepared fr the Minister fr ACC by the Steering Grup fr the Stcktake f ACC Accunts. 30 June 2010
6 The levy in the Wrk Accunt is currently, n average, $1.47 fr every $100 f liable earnings. Hence the Wrk Accunt adds 1.47 percent t 44 percent f the verall cst f prductin: abut 0.6 percent f the cst f ding business n average. Emplyers wuld need t reduce that cst by mre than they can under existing ptins within the wrk accunt t be incentivised t seek ut and use new ptins. 4.0 Existing chice in the Wrk Accunt Currently, emplyers can reduce their standard industry levy by chsing frm three main pathways. 4.1 Wrkplace Safety Management Practices Prgramme Discunts f 10, 20 r 30% are granted t emplyers wh have put safety management systems in place t a certified qualifying standard. 4.2 Accredited Emplyer Prgramme This is essentially a time limited, partial self insurance prgramme. An analysis f the ACC Partnership Prgramme (under which the AEP perates) was dne fr the Stcktake grup by actuarial cmpany Melville Jessup Weaver and cnsultancy firm Martin Jenkins 3. (Referred t as the Review frm here). It has limited appeal. Currently, nly 136 f the larger emplyers participate, but they d cver 15% f the wrkfrce and 23% f leviable earnings. (Mre detail n type f participant is prvided later in this reprt. Numbers f participating emplyers have been declining steadily by a little ver 6% a year since The discussin dcument attributes this t excessive cmpliance burdens and limited scpe fr innvatin in hw accidents are managed. The scheme has tw elements. 6 (i) Partnership Discunt Plan Participants meet current claim csts and the csts fr either the next year, r tw years. (ii) Full Self cver Participants meet current claim csts and hand back claims fr ACC t manage after an agreed perid: either tw, three r fur years. Insurance must be thrugh ACC, but participants are able t cntract third party agents t administer the management f claims. 3 Review f Emplyer-managed claims, MJW and Martin Jenkins, 4 June 2010
7 4.3 Experience rating This was intrduced frm 1 April 2011, and is mandatry. It is t early t judge hw experience rating will wrk, and whether it will have adverse cnsequences like emplyers pressuring staff nt t reprt wrkplace accidents r t reprt accidents as taking place utside f the wrkplace. What fllws makes n judgement n the efficacy f this levy setting methd. Experience rating (fr emplyers with ver $10,000 p.a. premiums) can alter premiums by up t + r 50%. The size f enterprise that faces levies f ver $10,000 will depend n the industry levy rate. Using a rugh measure, a firm facing the average levy f $1.47 will need t have a wage bill f arund $680,000 per annum. If wages in that cmpany average ut at the natinal average wage f $50,000, it wuld have t emply 136 wrkers t mve int this experience rating band. Statistics New Zealand data n Business Demgraphics d nt break dwn size f emplyer unit beynd thse emplying mre than 100 wrkers. Firms emplying mre than 100 wrkers emply 47 percent f the ttal wrkfrce. By definitin experience rating des nt apply t full self cver AEP, because participants there are taking respnsibility fr their wn claims management csts within the cver perid, and passing lnger term claims back t ACC at the end f that at an actuarially assessed cst. In thery, if experience rating is applied accurately, the levies shuld mimic the csts that emplyers can achieve under AEP. The nly incentive t g int AEP wuld be if emplyers thught that they culd d better than the maximum discunt:( i.e. beat the ACC by mre than 50 percent) 7 There is a n claims discunt (fr emplyers with under $10,000 premiums.) The discunt alters levies by either + r 10 percent, r zer. Smaller emplyers might be tempted t enter the AEP if they felt that self cver might allw them t beat the industry average by mre than 10 percent. Hwever, that incentive exists nw, and very few small emplyers seek t be accredited, (see later), s the incentive is nt, n the evidence, sufficient t change emplyer practice. 4.4 Take-up f existing chice ptins As nted abve, experience rating can reduce levies by up t 50 percent n standard industry levies, s it is nly a capacity t beat the industry average by mre than 50 percent that wuld incentivise emplyers t explre wider ptins than thse nw available. Lking back at the average levy making up 0.6 percent f ttal business cst, in an aggregate sense, that means that emplyers wuld need t be attracted t shaving the margin n 0.3 percent f ttal business cst fr new chices t meet any market need. Of curse that is an average, and averages cnceal as much as they reveal. In industries like accunting services, the labur cst is high but the levy is lw, s the incentive is likely t be remte.
8 In industries like pulp and paper, the levy is high but the labur cst is lw. Firms in these industries wuld fcus much mre n, say, electricity usage and tariffs as cre drivers f business perfrmance. It is nly in industries where there is a cincidence f high labur cst, high levies, and a capacity t manage accident and injury csts dwn that the incentive exists. Just where that cincidence f factrs exists, and hw pervasive it is, has nt been quantified in any f the backgrund research and analysis that sits behind the prpsals. Hence the cnclusin that there is n evidence n which t specify the prblem. A prxy measure fr the extent f the prblem wuld be emplyers wh have vted with their feet and entered the AEP. Currently, 136 emplyers are in the AEP and they cver 15 percent f the wrkfrce.(reprt, p15) 99.8 percent f the 228,497 wrk accunt levy payers have levies f less than $100,000 a year, and f thse, nly six are in the AEP. It is nly when ACC levies are big business that cst reducing ptins are taken up. It is nly when the wage bill exceeds $50 millin per annum that participatin is significant. There are nly tw AEP participants with a wage bill f less than $5 millin per annum. Fr thse with wage bills f between $10m and $50 millin, 7.8 percent f emplyers participate. Mre than half participate nly when wage csts exceed $100 millin per annum (80 percent f emplyers in this categry). The degree f the prblem is further illustrated by the fact that since 2006, AEP participant numbers have declined by 24 percent. All f this was befre experience rating was intrduced frm 1 April Experience rating enables emplyers with gd accident and claims recrds t reduce levies by up t 50 percent frm the industry standard levy. The degree t which mre flexibility and chice with AEP is needed after that new avenue has been pened has yet t be established. At the very least, until that regime has bedded in, it wuld be premature t base plicy change n the demnstrated need fr such additinal chice. 8 Since experience rating was intrduced,(but nt because f it) the ACC financial psitin has imprved, s that it is nw prpsing t reduce wrk accunt levies by 22 percent in 2012/13 4. Highrisk firms (which wuld tend t have mre pprtunity t lwer csts thrugh imprved systems, and wh wuld be mre likely t enter the AEP as a result), will receive larger prprtinate discunts than the average. Even withut experience rating, the margin within which self cver under AEP can beat the ACC average has cntracted significantly. 4.5 Evidence that chice delivers better results. Even if there is n demnstratin f need fr greater chice, a new regime culd be justified if there was evidence that self r private insurance prduced better results. There is, hwever, n such evidence. A stated aim f the prpsals utlined in the discussin dcument is t extend the cverage f the Accredited Emplyer Prgramme. A briefing given by DL fficials t CTU affiliates (22 June) indicated that the target cverage f AEP was fr emplyers f arund 50 percent f the ttal wrkfrce. 4 Cnsultatin n Prpsed 2012/13 Acc Levies, ACC, 12 July 2011.
9 This aim, thugh, begs the questin f whether there is any evidence that this wuld be a gd plicy result. In brief, there is n evidence that the AEP achieves a better result than the standard scheme administered by ACC. The fragment f evidence used in the discussin dcument is that AEP delivered safer wrkplaces with 12 percent fewer claims and mre effective rehabilitatin with 15 percent fewer csts (Ministerial frward t the discussin dcument). That statement is simply nt crrect. At n stage des the analysis cnclude that the AEP delivered (i.e. caused) fewer claims and lwer csts. It cncludes that AEP firms had fewer claims and lwer csts. But the directin f causality is nt established. It is equally plausible that firms that had pre-existing better than average accident recrds entered AEP t save n levies. Indeed the evidence in the Review strngly suggests that that was in fact the case. The cmparisn f accredited with standard emplyers was made ver the perid 2000 t Hwever, there is n evidence t supprt the hypthesis that accredited emplyers shw greater imprvements in rates f claim ver time (Review p35). If AEP was delivering better results the a priri expectatin wuld be that claim rates wuld imprve ver time. Since 2006, the number f emplyers participating in the Partnership Prgramme 5 has declined steadily, by abut 6 percent a year (Review p15). If it was delivering imprved results, it wuld, ver time, be pening up a gap between what the ACC charges fr cver and what participating emplyers culd achieve, and the expectatin wuld be that participant numbers wuld increase, nt decrease. Over the duratin f the study perid (i.e. nt the average fr the perid as a whle), standard emplyers have had marked imprvements in the rate f weekly cmpensatin claims while accredited emplyers have been virtually static, as illustrated in the fllwing chart (Review p36). The illustratin shws the relative claim rate fr standard emplyers being abut 40 percent abve that f accredited emplyers in 2001, but by 2007 the relative standing reverses, and standard emplyers have lwer relative claim rates. By 2010 their claim rates are abut 25 percent belw thse f accredited emplyers. If the AEP was delivering fewer claims and lwer csts, the expectatin wuld be that thse trends wuld g in the ppsite directin. 9 5 The Accredited Emplyer Prgramme falls under the umbrella f the ACC s Partnership Prgramme. The terms appear t be interchangeable in the MJ/MLW reprt.
10 The AEP might be assciated with ther gd injury preventin and management practice (such as reflecting gd health and safety systems and prcesses, effective return t wrk and scial rehabilitatin practices and the like), but there is n evidence that it causes them. When thse gd practices exist, fr whatever reasn (enlightened emplyer, unin engagement arund rbust preventin and rehabilitatin systems etc.), then emplyers are able t capture a secnd dividend by entering the AEP and cvering csts at less than levy rate Issues assciated with widening chice Thus far, this paper cncludes that the need fr wider chice has nt been demnstrated, and there is n evidence that it wuld generate benefits anyway. There is n prblem that has t be addressed. Hwever, a slutin like that prpsed in the discussin paper culd well intrduce cmplexity, add risk and add csts. The prpsal essentially divides int tw categries: making AEP mre flexible, and allwing emplyers t meet their bligatins by insuring privately in a cmpetitive market. 6.0 Prpsal t increase chice within ACC The elements f this categry are: Allwing mre chice n claims management perids under AEP: bth shrter (dwn t 3 mnths) and lnger (up t 10 years r even in perpetuity subject t meeting nging slvency tests). Taking claims histry int accunt when setting PDP discunts. This increases the risk f emplyers discuraging reprtage f accidents r mre likely encuraging their reprting as having been nn-wrk accidents. Hwever, the ptin is prbably
11 bslete because mandatry experience rating des exactly the same thing anyway. It wuld nly be if PDP discunts culd g beynd the bands set under experience rating that this ptin wuld again becme relevant, but that eventuality is better addressed by setting the experience rating bands at apprpriate levels than having parallel discunt systems. T start the cver perid frm the date f accident as ppsed t the start f financial year Changing audit requirements, prcesses and standards ( including the intrductin f new certificatin standards such as Directr declaratins). Reducing minimum levels f required high cst and stp lss cver (t allw AEP participants the ptin t increase levels f self insurance) Intrducing chice f prvider f high cst and stp lss cver insurance. Allwing emplyers t select types f excess (e.g.. they meet the first $x f claim cst as is standard with mtr vehicle and huse insurance) Weekly cmpensatin excess Medical cst excess 11 All csts excess, either time bund, r $ bund, r Bth. Creating an ptin fr third parties (like Banks) t ffer financial guarantees t meet bligatins t meet claims Allwing grups f emplyers (like franchise chains) t participate as single entities (i.e. accredited emplyers) Making it cmpulsry fr ACC t take ver the management f any r all claims (at actuarially assesses cst) at the request f a participating emplyer Creating an ptin fr full and final settlement when claims are handed back (t cver ff risk f reactivated claims, which wuld be priced int the hand back charge)
12 On the assumptin that there will still be a demand fr AEP cver even after experience rating beds in, each f these ptins intrduces risks f ne srt r anther, which need t be cvered ff by intrducing checks and balances int hw they wuld wrk At the end f the day, ACC has the statutry bligatin t meet emplyee entitlements t a preventin, rehabilitatin and cmpensatin regime with n fault, 24/7 cverage meeting the standards defined in statute. Any variatin within the schemes perated by ACC need t ensure that there is n residual liability that ACC will have t pick up, because in that event the csts are brn by an increase in the levy applied t all ther, cmplying emplyers, r the taxpayer. 6.1 Variatin in claims management perids The duratin f claims management perids can be flexible prvided flexibility des nt cmprmise the integrity f the 24/7 n fault ACC scheme by, fr example, encuraging participating emplyers t cut csts n rehabilitatin when the claims perids is shrt and they are sn t be handing claims back t ACC, r creating a risk when an extended claims management perid increases the chance that the emplyer may nt be able t affrd t meet the nging csts assciated with the claim when it is handed back. Over time, rganizatins even large nes like the Shell petrl cmpany get taken ver, merge, change their names and exit fields f business. An extended claims management perid increases the risk f the lnger term claimant being stranded: nt knwing where t g t fr cntinuity f entitlement, and nt being seen as their respnsibility by the new wner f a firm that was nt respnsible fr the accident in the first instance. 12 The best way f managing the risk t entitlements is t have a limit n the maximum term ver which a claim can be managed, and/ r t require the party seeking a lnger duratin t pst a bnd with ACC r t insure with ACC t cver ptential fr handing back nging claims in the event f emplyer inslvency, takever, r exit frm an industry. There is n evidence that the current fur year maximum fr full self cver is t shrt. Extending the perid alngside bnding r insurance arrangements intrduces cmplexity (and prbably cst), fr n apparent purpse. 6.2 Starting claims cver perid frm date f accident This prpsal des nt challenge the integrity f the scheme r increase risk in a material way, but des intrduce administrative cmplexity by requiring individual recrds t track claims management expiry perids. It shuld at least be ptinal fr emplyer participants in the AEP, because they will be the parties meeting the additinal cmpliance cst. 6.3 Changed audit requirements In thery, changing audit requirements des nt shift where residual risk lies (except fr risk assciated with emplyer inslvency). If mre flexible audit arrangements are translated int less rbust systems, emplyers meet the cst f higher claims, and pay mre when claims are handed back t ACC. The risk f emplyer inslvency des nt increase frm the status qu unless the term f claims management is extended (s this risk is linked t the issue f lnger duratin).
13 Hwever, flexible audit requirements d increase the chances f reducing the input f wrker representatives (health and safety representatives r unin delegates r fficials), which is a feature f the existing set f arrangements, especially at the systems design end f the prcess, and which culd dilute the effectiveness f bth preventin and rehabilitatin. 6.4 Reducing minimum levels f high cst and stp lss cver This wuld nt shift r increase risk prvided that the cver is purchased frm ACC. This is because ACC takes back the claim at the end f the self cver perid at an actuarially assessed cst, s any ver r under insurance washes ut in the take back price. If flexible cver is thrugh third party insurers, there is a need fr apprpriate prudential regulatin f prviders and a disputes reslutin facility t avid fflading underinsured cst nt the ACC, and effectively ther levy payers. 6.5 Intrducing chice f prvider f high cst and stp lss cver Chice f this srt adds risk t bth ACC and the claimant. If the integrity f the scheme is t be maintained, the change wuld need t be accmpanied by sme srt f regulatry interventin, s that the claimant can knw wh t seek the amunts abve the emplyer self cver maximum frm, r the impsitin f an bligatin n the emplyer t recver the extra payment, the impsitin f prudential standards n third party insurers, and prvisins t cater fr the cnsequences f insurer inslvency. It is imprtant t nte that it is precisely when high cst injuries ccur that emplyees are mst vulnerable. They are either absent frm the wrksite and d nt have access t peer supprt r direct cntact with management, r have injuries (such as head injuries) that diminish their capacity t advcate their entitlements Allwing chice f excess Vluntary excess is a standard feature f mst insurance prducts, and basically shifts rather than increases risk. The nly time when it increases risk t a third party (the claimant r ACC) is when the plicy hlder (in this case the emplyer) defaults. The mst efficient way t manage that particular risk t make sure that the claims management perid is nt excessively lng. 6.7 Third party financial guarantees Third part financial guarantees are standard practice, and sme frm f third party guarantee (such as frm a bank) can actually reduce risk fr the default prvider (ACC). Because the residual risk des nt shift, the nature f the third party guarantee needs t be acceptable t the bearer f that risk (i.e. ACC) 6.8 Grup participatin It is very difficult t assess the risk that wuld be assciated with this ptin: a lt wuld depend n the cllective capability f such grups. Accreditatin and audit systems need t be rbust, with sme frm f default guarantee if an individual franchisee fails r exits the franchise. Exit is much mre likely fr individual franchisees than fr the chain as a whle.
14 These grups wuld inevitably have t rely n third party administratrs t manage claims and there is strng evidence that TPAs deliver less satisfactry services frm the pint f view f claimants. 6 The discussin dcument raises the pssibility f TPAs being centrally accredited, instead f emplyer by emplyer. This prpsal culd help vercme the prblem prvided that this accreditatin prcess is als rbust. Wrkers experience f TPAs needs t be channeled int the accreditatin prcess. 6.9 Cmpulsry take back by ACC at emplyer request This ptin is theretically risk neutral, prvided that the take back is at full cst. There is risk f adverse selectin if the take back at emplyer request is accmpanied by a right f emplyers t pt fr full and final settlement, because the emplyer is typically better placed t assess whether r nt there is a risk f reactivatin f claim, and wuld tend t exercise the take back ptin right when that risk was likely but nt yet bvius t whever is assessing the csting f the take back Full and final settlement n take back Almst by definitin, reactivated claims cannt be predicted at the time f settlement, and s can never be accurately priced int the hand back charge. This will lead t selectin bias t the detriment f ACC and ther levy payers: the emplyer seeking full and final settlement is mre likely t be ne wh suspects that in the particular case reactivatin is prbable. 7.0 Prpsal t increase chice frm ACC The discussin dcument prpses that frm 1 Octber 2012, emplyers can chse t insure with either ACC r a private cmmercial insurer. Befre examining the specifics f the prpsal, this reprt examines the case fr intrducing this ptin and the benefits it might bring Ptential fr benefits frm private insurance ptin There is n evidence that there is a market pprtunity that private insurers culd meet. As nted earlier, emplyers have the ability t reduce levies thrugh experience rating by up t 50 percent n the industry standard levy, r by full self cver under the AEP if they feel that they can d even better than that. A private insurer has t reduce levies belw that, while at the same time earning a margin t generate a return n capital after having paid tax. Officials estimate this margin t be arund 25 percent ver the rate ACC charges because as a Crwn entity ACC des nt have t pay tax r dividends. The nly pssible rm within which private insurers culd cmpete wuld be fr them t bundle accident insurance with ther insurance prducts, because ACC wuld be prevented frm adding ther insurance prducts t the package f cver it delivers thrugh the Wrk Accunt. 6 Research New Zealand, Partnership prgramme: injured emplyees satisfactin with the service they have received. February June 2010
15 On any practical assessment f the margin insurers wuld have t wrk within, there is n realistic chance that they wuld ffer a prduct and a price that wuld generate net benefits t emplyers. That pricing cnstraint wuld bind regardless f insurance market cnditins, but in the current pst-earthquake envirnment insurance markets are under stress, and are unlikely t find high risk, lw margin market niches attractive. This view is shared by gvernment fficials. In the Cabinet paper n the prpsal, the Minister f ACC ntes that the regulatry impact statement prepared by his fficials suggests that the csts f the ptin I am recmmending may nt be utweighed by the benefits, that there is uncertainty regarding the benefits that may be achieved and that there are a number f assciated risks. 7 The full Regulatry Impact Statement released alngside the Cabinet paper is much mre explicitly critical f the evidential base f prceeding with the prpsal. Specifically, it ntes inter alia there is a high degree f uncertainty regarding the magnitude f bth csts and benefits (and in sme cases, even the sign i.e. whether they will have a net psitive r negative impact it is pssible that that there are ptential impacts r risks that have nt been identified r adequately cnsidered by fficials fficials have been unable, at this stage, t quantify the likely uptake f the mdified AEP by emplyers, which is critical t identifying the benefits f this ptin.. 15 it is nt pssible t prvide reliable, quantitative estimates f the size f likely benefits.. and, critically Better pricing signals t emplyers can be achieved thrugh experience rating and selfinsurance arrangements. In simple terms, fficials advice is that the cmpetitive insurance ptin is a sub-ptimal slutin. Nt nly is this a slutin lking fr a prblem, but it is nt even the best available slutin fr dealing with the prblem if ne was fund! 7.2 Particular features f the cmpetitive insurance ptin As nted, the prpsed cmpetitive arrangements are nt entirely cnsistent acrss ACC and the private sectr because: ACC will nt be allwed t bundle wrk injury cver with ther insurance cver t ffer a cmplete insurance package, but it des nt need t pay business tax r generate a return n capital. 7 Cabinet paper dated 29 Octber 2010, released under the Official Infrmatin Act. Para 64
16 ACC wuld be the default insurer and wuld cntinue t be the insurer if any emplyer did nt cntract with a private insurer. The discussin dcument ntes that a number f specific prblems were encuntered during the 1999/2000 perid f cmpetitive delivery f cver. Specifically, additinal administrative burdens saw sme GPs charging higher c-payments; claimants reprted nt knwing wh their insurer was; insurers were smetimes reluctant t apprve claims and were late in hnuring invices; there was cst shifting when emplyers pressured wrkers nt t ldge claims fr wrkplace accidents; and wrkers were deterred by the paperwrk invlved.(discussin dcument p32) Prtectins wuld therefre be intrduced t cver thse defects. The main additins are t have a central claims handling facility (t ensure treatment prviders knw wh t cntact fr recvery f csts and better regulatry supervisin t ensure entitlements are met); the creatin f bligatins n emplyers t infrm emplyees wh the insurer is and what t d in the event f wrkplace injury; The regulatry structures that wuld be needed t wrap arund chice f insurer are: 16 Register f emplyers alngside cntracted insurer Independent claims ldgement (handling and clearing) unit Independent disputes reslutin agency Market regulatr t mnitr and enfrce cmpliance Central data pl t gather infrmatin n histrical claims and csts t help insurers set prices and develp prducts. Default regime in event f insurer inslvency: ACC t take ver cst f claims management t be paid fr by levy n all insurers Prudential regulatin f ptential insurers (with adaptatins f the standard insurer regulatin t deal with circumstances specific t wrk related persnal injury insurance: such as having adequate reserves t meet the tail f claims)
17 7.3 Detail still needing t be develped It is difficult t assess the full range f risk assciated with the private insurance mdel because a number f details have nt been finalised, and until they are, the rbustness and sustainability f the eventual package has t be taken n trust. In the meantime, the inherent risk f failure if the regime is t permissive is carried by ACC: and ultimately emplyees wh will have difficulties in enfrcing entitlements and emplyers wh pay levies t ACC. There are fur critical areas where detail has yet t be develped. In cmbinatin, until these details are clarified, it is simply nt pssible t knw if a cmpetitive market can wrk, hw it will wrk, the csts that will be assciated with it, and the risks that injured wrkers will face if it des nt wrk Funding f residual claims When full funding f the wrk accunt was intrduced in 1999 (as ppsed t pay-as-yug) a levy was intrduced t cver the lnger term csts f pre-1999 injuries. Over time, this has prved t be an extremely vlatile cmpnent f levies because nt nly can liabilities fluctuate, but mre imprtantly s can assets that supprt them, given the instability in glbal and dmestic finance markets. By way f example, in 2009/10, the Residual Claims Levy was 38 percent f the ttal levy, but by 2010/11 it had drpped t (a still significant) 28 percent. There is n way f predicting the directin and amunt f future residual claims cst, because the term f the bligatin is lng, and asset prices are variable. If private insurance is intrduced, any unfunded claims that apply t the 1999 t 2012 perid will als have be paid fr in sme way. 17 The discussin dcument simply lists hw t fund and manage the nging cst f claims relating t wrkplace injuries suffered befre 1 Octber 2012 as a detail still t be wrked ut. DL fficials advise that the intentin is t recver csts f residual claims thrugh a levy n all emplyers, in much the same way that the fire service levy n husehlds is cllected by insurers and passed n t the Fire Service(briefing). They suggest that the liability is nw likely t be lw, s d nt see this as a majr prblem, but if that is the case the reductin frm the current 40 percent f levies t a small amunt has t be taken n trust Funding f gradual prcess injuries The matter f hw t handle csts f gradual prcess injuries and hw t recver these frm previus insurers (including ACC) is yet t be reslved. This is particularly prblematic in a cmpetitive insurance market because emplyees switch emplyers and emplyers can switch insurers. Just wh is liable fr the csts f a claim that might have riginated with anther emplyer r when the emplyer was with anther insurer is bund t be a matter that gives rise t cntinuus dispute Allcating csts f public health and emergency transprt services As with csts f gradual prcess injuries, the calculatin and allcatin f shares f cst f public health acute services and emergency transprt services are yet t be determined. The intentin is t allcate these thrugh a mechanism similar t that prpsed fr recvery f
18 residual claims csts (briefing), but that in itself wuld intrduce distrtins int an insurance market. A unitised cst f public health and emergency services wuld cut acrss the ability f insurers t price prducts t emplyers where the prbability f use f emergency services is lw (fr example in clerical wrk as ppsed t higher risk cnstructin r frestry wrk). The alternative f self prvisin f emergency services is nt viable because n private prvider can maintain a natinwide 24/7 netwrk t prvide them The prudential regime that will apply t insurers The adequacy f the prudential regime that applies t the insurance industry in general has been called int questin with the gvernment having t stand behind at least ne insurer in the aftermath f the Christchurch earthquakes. Persnal injury insurance is anther matter altgether because a rbust regulatry regime has t ensure that market participants have the reserves t cver extremely lng term nging treatment and earnings cmpensatin (r pay anther party t take ver the liability). The nature f that regime has still t be develped, but depending n hw it is structured, there will either be high risk t injured emplyees that they may be stranded, r a high entry cst t market participants t establish capital adequacy t meet all realistic estimates f liability. 7.4 Unknwn dimensins f cst (partly derived frm the unknwn scheme detail) As nted abve, the csts f meeting legacy residual claims, f prviding fr public health and emergency service, and f cvering csts f gradual prcess injuries will depend n the detailed prvisin fr these features f a cmprehensive accident cmpensatin system. 18 There are tw ther features f scheme design that can als raise cst and distrt where risk resides with a cmpetitive market Pricing f risk As a matter f plicy and prudent practice, the ACC sets Wrk Accunt premiums by adpting a 75 percent risk margin. In essence, levies are set abve the average expected level f claims liability t ensure that in 75 percent f the time, (nt n average) all claims will be met. The effect is t raise levies by abut 13 percent. The discussin dcument is silent n whether risk margins will be required t be priced int premiums as part f the prudential regime applying t insurers. The presumptin fr this analysis has t be that they will nt: a prudential regime tends t fcus n capital adequacy and des nt set prices. In this envirnment, the end result is that the industry is incentivised t lad risk back nt ACC (and therefre ultimately claimants, and/r emplyers insuring thrugh ACC, and/r ultimately the taxpayer). An individual insurer has the incentive nt t price a risk margin int premiums, because in the event f default any shrtfall is simply recvered by a levy n all ther insurers. But each individual private insurer is similarly incentivised, because there is an ultimate default insurer: ACC.
19 7.4.2 Cst f the administratin and regulatry regime The administratin and regulatry regime described in s 7.2 f this reprt is reasnably extensive. N detail has been prvided n what this will cst, and n assessment has been made f hw that cst cmpares with the expected benefits that might be expected t mitigate that cst. 7.5 Cnclusin n private insurance ptin This ptin is fraught with uncertainty: ver its csts, and what risks it will create and fr whm. It cannt be effectively evaluated because t much critical detail abut hw it will perate has nt been determined. The benefits it is suppsed t generate cannt be quantified, and there is even uncertainty abut whether they will be psitive r negative. The market niche that this slutin is designed t fill prbably des nt exist, at least if it is t be filled prfitably. Where fficials cmpare the ptin with the cunter-factual - self insurance and/r experience rating they find it t be inferir. There is n evidence t supprt the intrductin f this ptin and it cannt be justified n its analytical merit. 8.0 Is it brken? The evidence suggests that: a) internatinally, ACC is a lw cst, efficient and equitable way t deal with accident preventin, rehabilitatin and cmpensatin, and b) within ACC, the wrk accunt is the best perfrming cmpnent f a cst effective system. 19 In 2007 the ACC cmmissined Price Waterhuse Cper Australia t carry ut a cmprehensive review f the scheme, in terms f it prviding scial and ecnmic benefits, and in cmparisn with schemes in ther cuntries. The reprt was cmprehensive 8 and is nt reprduced here. Hwever, its cnclusins are unambiguus: we cncluded that the current ACC scheme is cnsistent with the Wdhuse principles, adds cnsiderable value t New Zealand sciety and ecnmy and perfrms well in cmparisn t alternative schemes in peratin internatinally. In the Cabinet paper, Treasury cmments that f all ACC accunts, the Wrk Accunt is in the best shape and is perfrming better than it was when cmpetitin was intrduced in Experience rating is being intrduced t augment the AEP. There is n evidence base t intrduce radical change. What is mre, this is precisely the wrng time t intrduce structural change: experience rating is nly three mnths ld, and has nt been given the chance t see if it makes a material difference, and the insurance industry is in turmil. 8 PWC Australia, Accident Cmpensatin Crpratin New Zealand: Scheme Review, March 2008
20 Sme fine tuning t existing prgrammes can always be made, but care needs t be taken t ensure that entitlements are prtected and risk is prperly assigned t thse wh ught t carry it, and are best placed t d s. 20
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April 2011 We wanted t take the pprtunity prvided by the AICPA s recent release f the expsure draft Practice Aid t share with ur clients and friends sme bservatins and best practice suggestins n this tpic.
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