2 Table of contents Page 1. TERMS OF REFERENCE 1 2. INTRODUCTION 2 3. ACTION ITEMS 7 4. SUPPORTING COMMENTS ON THE ACTION ITEMS LAWYERS AND LEGAL ADVICE MODIFICATION TO THE COMCARE WEBSITE CONCLUSION 26
3 1. Terms of Reference We are engaging a consultant to conduct a review of cases of injured workers who have long standing or ongoing concerns that relate to one or more of the following categories: Injured workers that have continued dissatisfaction with their entitlements under federal law after exhausting all appeal rights (for example, injuries before 1988 and the SRC Act, permanent impairment provisions, redemption provisions, lack of access to common law, incapacity provisions; Injured workers that have continued dissatisfaction with their rehabilitation and return to work outcomes and the support provided by their employer as the rehabilitation authority; Injured workers that have continued dissatisfaction with the support services provided by Comcare including errors in claim determinations, delay and poor communication even where specific issues have been redressed; and Injured workers whose dissatisfaction is based on the application of Comcare of policies and procedures in interpreting federal law. The review would examine specific claims at an individual level and make recommendations to resolve entitlement or service delivery issues. The number of claims reviewed would be less than 20. The review, taking account of learnings from the examination of specific cases, would also make recommendations for general improvements in the delivery of support services provided by Comcare. The review would also look at how other determining authorities within the Comcare scheme approach similar examples of long standing issues. Outcomes of these case reviews will be submitted to the SRC Act legislative review.
4 2 2. Introduction Comcare has provided 15 files for John Cain and Herbert Geer to review. We have reviewed each file and the relevant material involved, including claim forms, medical reports, correspondence from injured workers and Comcare, and investigative reports. Each case clearly has its own unique factual circumstances and we have been careful in drawing conclusions as the cases represent a very small sample of Comcare claims. We are informed that the claims we have received represent some of the more challenging and difficult cases with complex issues. Comcare is clearly concerned about these types of cases and is keen to review, and where appropriate, implement improvement to the processes and systems involved. What we have tried to do is, having considered the group of cases as a whole, ascertain whether there are any recurring themes or lessons learned that may allow Comcare to achieve improvements in the management of cases. These common themes are: (a) Disconnect: In many cases there appears to be a disconnection between the employer, Comcare and the injured claimant. Each party has different aims and sees their responsibilities differently. The injured claimant is trying to navigate a complex system and in some cases it appears that the differing aims and objectives of the employers and Comcare may create confusion and uncertainty for claimants. In some instances this has had an adverse impact on the determination of claimant s rights. Each stakeholder has their own agenda and they do not always work co-operatively to manage the claim. This disconnection leads to some difficulties.
5 3 (b) The Complexity of the law The complexity of the law in some areas may lead to confusion for claimants and in some cases for Comcare. This has an impact on injured claimants as multiple determinations and dealings with Comcare has the potential to lead to frustration. It also may impact on a claimant s ability to have his/her rights determined with any finality. In particular, three examples of this are the calculation of normal weekly earnings, permanent impairment assessments and non-economic loss payments. (c) Poor Communication: From a claims management perspective communication with the injured claimant can on occasions be unclear or incomplete. In particular, the progression of their claim and the prospect of it resolving in its entirety were not communicated with the necessary clarity. These themes were developed from a desk top review without the benefit of speaking to the claimants directly. Comcare subsequently wrote to a number of claimants inviting them to meet with us to discuss progress and management of their claim so that we could gain a better understanding and test the themes that we identified. We have had the opportunity to meet with a number of claimants. In the following section of the report we have provided a summary of the key issues that are relevant to the three themes previously identified that arose from the desk top review and were tested in interviews with claimants. Fourteen claimants were approached with a request for an interview (one claimant was living overseas and was not sent a request for interview). The following pro forma letter was sent to claimants.
7 5 Of the 14 claimants that were approached 7 agreed to meet to discuss their experience and concerns in the management of their Comcare claim. John Cain visited each claimant and interviewed them allowing them to tell their story and explain in detail the areas of concerns. All 7 claimants were very co-operative and spoke very frankly about their experience. Some claimants attended the meetings alone, others attended with a friend or advisor. Meetings were conducted in a very informal way and provided ample opportunity for claimants to speak freely about their experience in dealing with Comcare. At the commencement of each meeting the claimants were informed of the context for the discussion. A description of the work that had been completed already and the process that would be followed once all interviews had been completed was explained to each claimant. Claimants were given an explanation about the 3 themes that have been identified following the desktop review and that the purpose of the meeting was to test whether the conclusions that had been reached were appropriate and to identify further issues that may be relevant. Each claimant actively participated in the discussion by explaining the background and circumstances of their claim and the issues arising in the management of their claim. The 3 themes of disconnect, complexity of law and poor communication were discussed with each claimant. The claimants each shared their general experience and also provided specific examples to illustrate their points. In nearly all cases claimants had access to the written correspondence and were able to refer to and draw on this correspondence to provide an explanation and illustration of the points they were making. The conversations moved from the very specific details of particular claims to the higher level systemic issues. In each discussion the claimants were invited to reflect on their experience and indicate areas that they believe could be changed or altered to improve the claims process and the way they were dealt with by Comcare.
8 6 Each claimant understood that the purpose of the discussion was not to find a solution or resolve their particular matter but more to gain an insight into the claims experience with a view to trying to find ways in which it could be improved for future claimants. For the purposes of this report I have not provided a summary of the interview with each claimant. The information obtained from each claimant was detailed and broad ranging. Much of the discussion was specific to their particular claim. I have relied on the information provided by the claimants to inform the action items. In some cases examples have been provided but they are not attributed to any particular individual as in most cases the examples referred to are of experiences of a number of claimants who have highlighted the same or similar issues.
9 7 3. Action Items Arising from the review a number of actions items were identified for Comcare s consideration. The action items are: 1. Offer further education and training to employers that focuses on the rights and obligations of both employers and claimants. The education and +training should include: The obligation on the injured worker to seek treatment at first instance, make a report of injury, and if necessary, make a Comcare claim in a timely manner; The right of the injured worker to seek review of a decision by way of reconsideration and/or at the AAT, or by way of an eventual court proceeding; the obligation on the employer to forward the claim to Comcare where necessary; The obligation on the employer with respect to participating in the preparation of Return to Work plans and providing an offer of suitable employment where necessary. 2. Insist on early creation of case management plans which take account of all medical material and rehabilitation prospects. 3. Provide a mechanism by which the management of difficult cases can be escalated when necessary.
10 8 4. Consider amendments to the Act in relation to the operation of the permanent impairment lump sum, as follows: Impairments to multiple body functions arising out of the same event or circumstance should be able to be combined and assessed together. A claim should reflect all alleged impairments arising out of the same event or circumstance, with subsequent claims arising from the same event or circumstance being prohibited by a specific section of the Act. Calculation of entitlement to a permanent impairment benefit should be reviewed at a senior claims level prior to notification to the worker of the amount of the entitlement. Specialised teams could be created to review the entitlement to ensure it covers all injuries and the calculations are correct. Once the assessment of permanent impairment is completed, subsequent assessments should not be undertaken except in the case of further injury as defined in the Act. In cases where an aggravation injury to the same body function is claimed, the previous level of impairment as assessed by Comcare should be ignored when calculating any further entitlement arising out of the alleged aggravation injury. 5. Amend the Act to create certainty in respect of the calculation of Normal Weekly Earnings over time, for example, the modal average, or the figure that most fairly represents the worker s earning capacity;
11 9 6. Provide further education and training to claims service officers in respect of the calculation of Normal Weekly Earnings and redemption calculations. 7. Review case management models in order to ensure that the case management plans have the input of the treating health practitioners and are responsive to the needs of the injured worker in relation to rehabilitation and further medical treatment. 8. Ensure that employers and, where necessary, Comcare staff, receive education which details the range of treatment options available to injured claimants, the clinical framework within which maintenance treatment such as physiotherapy will be offered including length and frequency of treatment, what rehabilitation goals are realistic, and what range of duties are available to injured claimants who are to return to work in the organisation. 9. Ensure that Comcare staff receive appropriate education in relation to the engagement of lawyers, particularly the appropriate time to obtain legal advice, and providing appropriate and specific instructions where legal advice is sought. 10. Once advice is obtained it should be accessible via a centralised database, with staff trained on the common legal issues that arise and the ways in which legal advice has suggested the problem may be dealt with. 11. A practice should be introduced where at the time Comcare writes to a treating health practitioner, a letter is written to the injured worker to advise that access to the records is being sought by Comcare and the basis upon which access is being sought, to avoid claimants concerns in relation to their privacy being breached.
12 10 In addition to these 11 action items, this report makes three further recommendations; the first relating to obtaining legal advice and specifically in relation to in-house legal teams, the second in relation to access to legal advice for claimants and the third to the use and operation of the Comcare website.
13 11 4. Supporting Comments on the Action Items We have reviewed each recommended Action in the light of the information that we have gathered from the interviews we have conducted. 4.1 Action 1: Offer further education to employers that focuses on the rights and obligations of both employers and claimants. This education should include: (a) The obligation on the injured claimant to seek treatment at first instance, make a report of injury and if necessary make a Comcare claim in a timely manner; (b) The right of the injured claimant to seek review of a decision by way of reconsideration and/or at the AAT, or by way of eventual court proceeding; (c) The obligation of the employer to forward the claim to Comcare where necessary; (d) The obligation on the employer with respect to participating in the preparation of return-to-work plans and providing an offer of a suitable employment where necessary. In our interviews with claimants, some expressed a strong opinion that their employer did not fully understand the Comcare claims process and the various obligations imposed on claimants and employers. Concerns raised by claimants
14 12 highlighted issues such as the employer and/or Comcare did not ever explain or adequately explain the separate roles and responsibilities of Comcare, the employer and the rehabilitation provider. This lack of clarity creates confusion and results in information flows among the various bodies being inadequate. Some claimants stated that they thought that this hindered or slowed the resolution of their claim. The various views and opinions of the claimants interviewed support the proposition that more comprehensive information and training for employers directed to their role within the Comcare system and their duties and obligations to injured claimants would be valuable. Key areas to be covered in such training would include: (a) The initial claims management from submitting to claim to acceptance or rejection; (b) The process for lodging the claim and information required to be provided; (c) The initial decision, the right to internal review, AAT and Federal Court processes; (d) The employer s obligation to supply information, particularly around normal weekly earnings in a fulsome and timely manner; (e) The roles and responsibilities of Comcare, the employer, rehabilitation providers, treating doctors and the claimants in the rehabilitation and return to work process; (f) The vital role the employer plays in return to work plans. In summary, the additional information that we have obtained from the interviews with various injured claimants give further support for Action Item 1.
15 Action 2: Insist on early creation of holistic case management plans which take account of all medical material and rehabilitation prospects. Two claimants in different circumstances expressed frustration about the way in which their return to work was managed and they report a lack of co-ordination in the claims management process between Comcare, rehabilitation providers, employers and themselves. They believe that each should be involved in the preparation and management of the plan and have a clear understanding of what the plan involves and be prepared to implement it so that a satisfactory return to ongoing work with stable employment can be achieved. In addition, they expressed frustration that on some occasions their treating medical practitioner was not involved in the development of the plan. They both thought that this was critical to ensure that the program that was proposed and the job suggested were appropriate. Further, Comcare, the employer and the rehabilitation provider in their opinion should take a medium to long term approach to the rehabilitation process to ensure that return to work was sustainable in the long term. Claimants also suggested that long term claims should be managed differently to other claims. It was suggested that there may be some benefit in transferring their claims to a special group who have responsibility for dealing with long term complex cases. This adds support to the view that there is a need for employers to undergo training and possibly employ specially trained personnel to manage the return to work of Comcare claimants. There is a clear need for leadership. Comcare should perform a co-ordinating role and it is vital that they drive the process of developing and implementing the return
16 14 to work plan. Claimants were often left with the impression that Comcare took the view that once they had returned to work that the process was complete without further follow-up. This cannot be a sustainable position, as ongoing follow-up and support is essential to ensure that the return to work is successful in the long term. It is acknowledged that Comcare has not had the opportunity to respond to this issue but there seems to be some consistency in the issues raised by claimants and therefore supports the action recommended. 4.3 Action 3: Provide a mechanism by which management of difficult cases can be escalated when necessary: All of the injured claimants interviewed have for one reason or another had a difficult or complex matter. Whether it is the nature or circumstances of their injury, the length of the time they have had off work, particular idiosyncrasies that are unique to a particular individual or a combination of all or some of these things, these cases are complex. Almost without exception the injured claimants interviewed complained about the way staff within Comcare had managed their claim. In some cases multiple claims officers had been involved in the claim; for example one claimant dealt with no less than 30 different claims officers over the life of her claim. Whilst it is acknowledged that some staff were very competent and co-operative many in the opinion of some of the claimants interviewed were not. These injured claimants became frustrated that they would have to explain the circumstances of their case and current status almost every time they made contact with Comcare. They were also troubled that they were unable to get sufficient or adequate answers to their questions or an adequate explanation when they contacted Comcare. It is for this reason that we have suggested that there should be a process that allows for these more complex cases to be identified as long term or challenging
17 15 cases and be transferred to a specialist team of claims officers who are experts or specialists in dealing with complex matters. This team would be provided with additional training and support to assist them in dealing with the challenges presented by this group of cases. It would be hoped that this claims team would be made up of more senior claims officers and have a high level of understanding of the claims process and the management of these long term challenging claims. If implemented, this would assist in overcoming a significant number of concerns raised by many claimants we interviewed. Clearly more work would need to be done on developing the criteria for escalating claims and the recommendation would be for the team to be initiated as a pilot program, so that after a period of 6 or 12 months of operation it could be reviewed and refinements made to further enhance the operation of the specialist team. 4.4 Action 4: Consider amendments to the Act in relation to the operation of the permanent impairment lump sum, as follows: Impairments to multiple body functions arising out of the same event or circumstance should be able to be combined and assessed together. A claim should reflect all alleged impairments arising out of the same event or circumstance, with subsequent claims arising from the same event or circumstance being prohibited by a specific section of the Act. Calculation of entitlement to a permanent impairment benefit should be reviewed at a senior claims level prior to notification to the worker of the amount of the entitlement. Specialised teams could be created
18 16 to review the entitlement to ensure it covers all injuries and the calculations are correct. Once the assessment of permanent impairment is completed, subsequent assessments should not be undertaken except in the case of further injury as defined in the Act. In cases where an aggravation injury to the same body function is claimed, the previous level of impairment as assessed by Comcare should be ignored when calculating any further entitlement arising out of the alleged aggravation injury. 4.5 Action 5: Amend the Act to create certainty in respect of the calculation of Normal Weekly Earnings over time, for example, the modal average, or the figure that most fairly represents the worker s earning capacity; and Action 6: Provide further training in respect of the calculation of Normal Weekly Earnings and redemption calculations. In the interviews many injured claimants expressed the view that the legislation was very complex and difficult for them to understand. This was highlighted by Claimants who had disputes involving calculation of normal weekly earnings and impairment assessments. In addition, where a claimant worked significant overtime this added to the complexity of the calculation of weekly payments by Comcare. This area of the legislation is complex and difficult to navigate and relies on accurate information being obtained from the employer. Amendments to the Act to provide greater clarity and to simplify the calculation process are desirable.
19 17 The applicability and effect of Section 21 in relation to normal weekly earnings can be complex, and particularly may result in a need for claimants to obtain legal advice to understand its application. Comcare do make every effort to provide clear explanations however this Section is a clear example of a part of the legislation that is complex and claimants have struggled to understand its operation and impact. The suggested amendments, together with those in relation to the calculation of impairment benefits in Action 4, would create greater clarity and give claimants a higher degree of certainty in the management and calculation of their various entitlements. A number of claimants stated that they were completely overwhelmed by what they see as the complexity of many of the calculations and lack of clarity around the process for calculating levels of weekly payments and lump sum entitlements. This list is clearly not exhaustive and we note that the Hanks review has identified a number of areas for amendment. 4.6 Action 7: Review case management models in order to ensure that the case management plans have the input of the treating health practitioners and are responsive to the needs of the injured worker in relation to rehabilitation and further medical treatment. Action 8: Ensure that employers and, where necessary, Comcare staff, receive education and training which details the range of treatment options available to injured claimants, the clinical framework within which maintenance treatment such as physiotherapy will be offered including length and frequency of treatment, what rehabilitation goals are realistic, and what range
20 18 of duties are available to injured claimants who are to return to work in the organisation. The interviews have reinforced for us the importance of ongoing training for both Comcare staff and employers. The referral of some of these claims to a specialist unit is likely to assist, however, training with particular emphasis on developing case management plans and covering the role of the employer, rehabilitation providers, treating doctors and the claimant will be very valuable. This training should involve regular review of actual cases and how these matters have been managed. A number of claimants spoke about the lack of engagement with their treating medical practitioners in relation to their rehabilitation prospects. This lack of engagement with a valuable resource in all likelihood decreases the chance that the claimant will be returned to work at an appropriate time, in a suitable occupation and in a sustainable way. This disconnection also serves to confuse the claimant and limit the avenues from which they might obtain advice. The recommendation for obtaining and using legal advice has been reviewed and modified. This is dealt with under the specific recommendation set out below relating to lawyers and legal advice.
21 19 5. Lawyers And Legal Advice In our desktop review and in discussions with a number of claimants, concerns were raised about the lack of clarity around decision making, particularly where there were specific legal issues that needed to be determined. Some of these decisions were made with the benefit of obtaining legal advice and in other situations advice was not obtained until there was an internal review, an AAT hearing or proceedings in the Federal Court. Mostly the legal advice relied upon by claims officers was obtained from the Australian Government Solicitors Office or private law firm. Quite often the advice sought a response to a specific question. The advice would be provided to the claims officer who would then make a decision or review a decision based on this advice. In some instances the obtaining of legal advice delayed decision making and gave rise to further issues that had not been anticipated, or the advice provided was quite technical in nature and difficult to apply to the particular circumstances that a claims officer was dealing with at the time. Clearly this did not occur in all cases and in many cases advice was provided in a timely manner and was well understood by the claims officer and allowed for a good quality decision to be made. There is however a question as to whether the current model adopted by Comcare claims officers for identifying legal issues, obtaining legal advice and applying their legal advice is the best way to manage the claims. This is the traditional model of claims officers working with external lawyers at arms length; seeking advice on particular questions and having them run cases before Tribunals and courts on their behalf as required. In our initial report, we had suggested the following action items:
22 20 Action 9: Ensure that Comcare staff receive appropriate education in relation to the engagement of lawyers, particularly the appropriate time to obtain legal advice, and providing appropriate and specific instructions where legal advice is sought. Action 10: Once advice is obtained it should be accessible via a centralised database, with staff trained on the common legal issues that arise and the ways in which legal advice has suggested the problem may be dealt with. A number of organisations have from time to time considered and implemented alternate models. One model is to keep the majority of the legal advice in-house by having a pool of specialist highly trained and skilled lawyers working in-house for Comcare. This group of lawyers would develop particular expertise in the Safety, Rehabilitation and Compensation Act and be very experienced in internal review process, the AAT litigation process and in turn the Federal Court. They would in time develop good skills for identifying difficult issues and working to resolve them at an early date. In such a model a lawyer would be allocated to a group of claims officers to assist. This lawyer would work closely with the claims officers and become involved in the matter. If there were legal issues raised they would assist the claims officer by identifying the legal issues to be determined and providing advice in respect of these issues and ensuring that decisions made were in accordance with law and defendable if challenged in the AAT or the Federal Court. The lawyer and claims officers would work as a team and manage the claims, identify risk areas and drive the resolution of legal issues. In this model, the claims officer has ready access to advice and can interact with the in-house lawyer to discuss and debate issues and achieve the best outcomes.
23 21 External lawyers would still be used from time to time but this would be for high level specialist advice. The in-house lawyers would also work together. They would meet regularly discuss and debate issues and build their knowledge of the Commonwealth compensation scheme. Care would have to be taken to ensure that claims officers do not defer to the lawyers for all decisions but this can be managed by training and clear identification of roles and responsibility for claims officers and lawyers. It is acknowledged that a change to this model would be a significant departure from the traditional model that has been adopted by Comcare to date. Clearly much additional work would need to be undertaken to ensure that this model would work effectively, and that there is a sufficient pool of lawyers available to fulfil these functions. This involves considerable cultural change, and as such there would need to be a change management program prepared and implemented. We can provide more detail in respect of the operation and implementation of this model if required, but at this stage we recommend that Comcare gives careful consideration to the introduction of such a model, even if at the initial stage it was done as a pilot program. RECOMMENDATION Comcare should give careful consideration to implementing an in-house legal service model to assist in managing claims. CLAIMANTS ACCESSING INDEPENDENT LEGAL ADVICE Of the seven claimants interviewed, some had obtained independent legal advice and some had not. Many claimants did have a trusted advisor or friend who had assisted them through the claims process.
24 22 In some cases independent legal advice could have assisted claimants in understanding the legislative framework and helped them make more informed decisions about their specific legal rights. The claims officers generally do a good job in providing information, but for some claimants, advice from an independent lawyer would provide greater comfort and additional confidence in the outcome. The Legislation and review and appeal procedures can be complex in some circumstances and requires some specialist expertise. It is important that claimants who wish to obtain legal advice can easily identify suitable lawyers or law firms in their location who are specialists in Comcare claims. Law Societies and Law Institutes in each State and Territory operate referral services so that potential clients can be put in touch with lawyers with skills in the management of Comcare claims. The recommendation is that Comcare give consideration to establishing a lawyer referral arrangement. This could be done quite simply, by publishing on the Comcare website details of the Law Societies and Law Institutes referral services together with the contact details. Claimants should be advised of the right to obtain legal advice and encouraged to access it in appropriate cases. The alternate approach would be for Comcare to publish a list of Law Society or Law Institute Accredited Specialists who work in Personal Injury Law so that claimants can make their own choice as to who they contact. This list would need to be sourced in conjunction with the Law Society/Law Institute. Many law firms will act on a no win no fee basis and would provide an opportunity for claimants to obtain independent legal advice.
25 23 This would need to be done with care so that Comcare is not seen to be controlling the legal advice provided to claimants. If adopted the referral process would have to be transparent and at arms length In this regard, Comcare might also consider publication of literature such as pamphlets, to be held by employers, which explain a claimant s right to seek legal advice and review of decisions made by Comcare. In the current literature, All About Worker s Compensation - A guide for employees injured at work on or after 13 April 2007, there is a single comment on page 18 of a 20 page pamphlet, which simply says once a claimant receives a determination from Comcare, it will have advice about what to do if the claimant disagrees with the determination.
26 24 6. Modification To The Comcare Website In the course of discussions with the claimants we discussed the Comcare website and also spent some time reviewing the website. Clearly the website provides specific high level information in relation to the claims process. Many of the long term claimants are quite familiar with the claims management system via mechanisms set out in the Act and the entitlements under the Act. For many of these people the website is not designed to meet their needs as it does not provide information at the level of detail that they are seeking or requiring. They therefore contact their claims officer to discuss their matter. Claimants also raised concerns about dealing with individual claims officers and issues that arise when there are staff changes and their frustration of having to regularly call to find out the progress of their claim to see what action or steps are being taken by Comcare. We recommend that Comcare give some consideration to whether an interactive website could be created. It may be that in its early stages the interactive website would not be for all Comcare claimants. It could be set up for the long term claimants, those that have been identified in accordance with Action 3 who are long term claimants or have difficult and complex claims. An interactive website might have the following features: It may give them all the documents and correspondence held by Comcare. They may be able to file certificates and other documents electronically.
27 25 It may provide them with information about the progress of their claim and anticipated date that decisions would be made, when a decision is made what that decision is and generally keep claimants advised of the progress of their matter. Careful consideration would need to be given to information provided on the website and it would need to be sufficiently secure to protect claimants privacy. Clearly it would not contain documents that may be the subject of legal professional privilege. Generally it would contain information that the claimant would be entitled to receive under the Freedom of Information Act. Almost without exception every claimant interviewed had a large folder or folders with a significant volume documents, generally correspondence passing between them and Comcare. Some were better at keeping accurate records than others but almost without exception they were dissatisfied with the paper based process that they were involved in. It was acknowledged that a lot of the communication that takes place with claimants is by . The recommendation is to elevate that already electronic communication to an interactive claims management portal. A further advantage that this may achieve is that it would remove some of the pressure from claims staff as many of the questions that are commonly asked of the claims officers would be answered by the claimant looking at the portal. Another advantage is that it would allow any support people assisting the claimant easy access to a convenient and complete history of the claim. We are happy to discuss this recommendation further in terms of its implementation, at this stage we urge Comcare to consider carefully the development of an enhanced interactive website to assist in the management of long term complex claims.
28 26 7. Conclusion The meetings with claimants have given us the opportunity to test our suggested actions. This further work has affirmed some of our preliminary conclusions, and caused us to modify others and add some additional recommendations. The discussion with the claimants was invaluable and I would like to express my thanks to each claimant for their willingness to participate in the meetings and share their experiences in a frank and open way. Their contribution has greatly assisted the process. Further, I would like to thank the Comcare staff for their co-operation and assistance. I am more than happy to discuss any aspect of our report and provide additional information or clarification.