Submission to the Accident Compensation Corporation

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1 New Zealand Secretariat PO Box Glen Eden, Auckland Ph: Fax: RECRUITMENT AND CONSULTING SERVICES ASSOCIATION LTD Submission to the Accident Compensation Corporation Regarding 2006/07 Levy Rates for Employers Date: 2 November 2005 Via Contact: Andrew McComish Ph: or Julie Mills Chief Executive Officer Recruitment and Consulting Services Association PO Box Collins Street East MELBOURNE VIC 8003 Ph:

2 Contents Introduction... 3 Submission Issues... 4 The Recruitment And Consulting Services Association Ltd... 4 The Flexible Workforce... 6 Injury and Risk... 7 Proposals : CU Definitions : Incorrect Industry data held by ACC : Prudential Margins : Levies for 2006/07 Claims Pricing Model One : Classification Unit Moves : LRG Decrease : Tail LRG s : Partnership Programme : Safety Discounts : Invoicing : WSMP : ANZSIC Codes : Levy Rates for Pre 1999 claims...16 Recommendations...17 Appendix One: Pricing Option One November 2005 Page 2

3 Introduction The Recruitment and Consulting Services Association (RCSA) welcomes the opportunity to present its concerns and recommendations to the Accident Compensation Corporation regarding the 2006/07 levy rates for employers. According to ACC data the Employment Services industry, as a whole, has an average Entitlement Claim Frequency of 0.83, a little higher than ACC s average of However the average Claim Cost of $8,923 is significantly lower than ACC s model average of $12,717. The industry will contribute approximately 1.3% of ACC s required Employer Account levy income. The industry is also experiencing an average growth rate of 5.2%. The industry s average levy rate to fund cost of claims is $0.78 against ACC s average of $0.74 however our final average premium proposed by ACC is $1.16 against ACC s employer average of $0.86. ACC is proposing the following changes: 78610: Employment services (candidate or contractor placement - no on-hired employees) Employment services (on-hired employees - only office work assignments) Employment services (on-hired employees - non-office work assignments, including up to 30% office work 78622: Employment services (on-hired employees - mixed classification assignments, minimum 30% office work) Proposed Fully Funded Levy Current Fully Funded Levy Proposed Residual Claims Levy (Pre 1999 injuries) Current Residual Claims Levy (Pre 1999 injuries) $0.21 $0.23 $0.35 $0.33 $0.21 $0.23 $0.19 $0.19 $2.80 $2.71 $0.62 $0.58 $1.22 $1.23 $0.35 $ Nursing Bureau $1.36 $1.27 $0.17 $ November 2005 Page 3

4 Submission Issues Specifically, this submission will address: 1. CU Definitions 2. Incorrect Claims Data 3. The proposal to reduce prudential margins from 15% to 10% ( Prudential Margins ) 4. The proposal to hold the 2006/07 average employer levy rate at the current rate of $1.21 for every $100 of payroll ( Levies ). 5. The proposal to move five classification units to new risk groups that more closely reflect their emerging claims experience. ( CU Moves ) 6. The proposal to decrease the number of risk groups for the employer work levy by two, from 129 to 127 ( LRG Decrease ). 7. The proposal to maintain the 41 risk groups for the pre-1999 claims levy and to freeze the relativities applicable to each risk group to alleviate ongoing volatility in levy rates. ( Tail LRG s) 8. The proposal to update Partnership Programme discounts and fees to reflect the latest experience and costs. ( Partnership Programme ) 9. The proposal to introduce workplace safety discounts for employers with fewer than 20 staff. ( Safety Discounts ). 10. The proposal to maintain the minimum amount for a levy invoice at $20 (including GST) ( Invoicing). 11. The proposal to make no changes to the Workplace Safety Management Practices and Workplace Safety Evaluation programmes, except for the impacts of the above levy rate proposals ( WSMP ). 12. The proposal to introduce a new classification system for the 2007/08 levy year, based on upcoming changes to the Australia and New Zealand Standard Industrial Classification (ANZSIC) system. (ANZSIC Codes The Recruitment And Consulting Services Association Ltd The RCSA is the peak body for the recruitment and consulting services industry throughout Australia and New Zealand. It is a not-for-profit association that is managed by a Board of Directors. The central focus of the RCSA is to represent and serve the interests of members for the increased profile and professionalism of the industry. The RCSA has more than 3,200 members in Australia and New Zealand comprising multi-national companies, single consultancies, and individual practitioners operating within a recruitment consultancy. This includes the majority of recognised Agency names within the industry in New Zealand. 1 November 2005 Page 4

5 The association is instrumental in setting the professional standards, educating and developing member skills, monitoring industry participant performance and working with legislators to formulate the future. Members are kept up-to-date on information regarding best practice techniques, resources and technological innovation, along with legislative changes impacting on employment. The RCSA also acts as a lobbying voice, representing its members on issues that impact upon the industry. It has a strong relationship with the public and private sector. Members offer the following capabilities:? On-hired employee services? On-hired contractor services? Recruitment services? Employment consulting services As an industry that provides employment to every other industry in New Zealand from manufacturing to agriculture, we have an insight into the impact of changes to accident compensation levies and welcome the opportunity to respond to proposed Levy changes. RCSA New Zealand Corporate members directly employ over 2,000 staff within their own businesses and represent the following numbers of workers:? Temporary/on-hire employees working on any single day: 15,000? Candidates registered seeking temporary/on-hire employment: 40,000? Contractors working on a contract on any single day: 2,000? Candidates registered as seeking contract work: 8,500 It is important to note that member companies of this Association have combined earnings in excess of $600 million and their self employed independent contractors will earn in excess of $50 million. 1 November 2005 Page 5

6 The RCSA mission is to be recognised as the professional representative body and recognised authority for recruitment, on-hire and associated consulting services in New Zealand and Australia by:? ensuring members provide high value, high quality and responsive recruitment and consulting services to clients? ensuring members deal with candidates in a professional and honest manner? being the recognised voice of the profession on recruitment issues? advancing the professional development of the Members so that the profession of recruitment is advanced and continues to deliver services to the community of the highest standard. RCSA members are required to meet stringent professional standards as established in the Constitution, Membership Rules and Code for Professional Practice. There is access to a formal complaints process for clients and candidates if there is any dispute regarding the provision of services. This established framework ensures RCSA members are socially responsible and we recognise the need for employees to access ACC entitlements and to entitlements which cover periods of sickness, bereavement and holidays at a standard that society as a whole considers acceptable. The Flexible Workforce To guarantee New Zealand s economic growth it is essential that ACC levies properly reflect the risk individual industries pose. To encourage economic growth, business compliance costs need to be minimised and employers need assurances they are getting value from the payment of any ACC levies. A flexible workforce is now an economic and social reality. People are choosing diversity in work patterns that suit their individual circumstances. This includes:? employment that is permanent,? employment that provides for time off in school holidays,? employment that allows late starts and early finishes,? employment that is a stop-gap between opportunities,? employment that is seasonal and able to be carried out by visitors on short term work-permits.? employment that provides for greater and diverse work experiences? employment of a fixed short-term nature, and? employment with one employer in one week and employment with other multiple employers the following week/s at a greater or lesser rate of pay. This may include returning to the original employer within a 12- month period. 1 November 2005 Page 6

7 Clients and jobseekers work in partnership with RCSA members to access any combination of the employment patterns indicated but the three primary services can be summarized as:? the provision of temporary or on-hire staff for short term employment where the employee remains on the payroll of the member but works in the client s workplace. In this situation the employee is managed by the Agency but the day-to-day supervision is carried out by the client at the client s workplace.? the provision of contract staff for fixed term employment where the person is a self employed contractor but works in the client s workplace? the identification of candidates who best suit the client s vacant permanent positions and will therefore be on the payroll of the client and work in the client s workplace. Injury and Risk The RCSA notes that each of the employment patterns mentioned above creates its own injury risk profile and we endeavour to provide our Members with the tools to assist them with managing the risks associated with each pattern. The RCSA membership represents the many varied employment relationships that reflect current diverse patterns, and associated injury risk, in a flexible workforce. Our members have employees working in virtually every type of industry in New Zealand and we have known some of our members to place employees into short term work opportunities in Australia We also recognise the injury risk to people working in each industry and the associated social and economic costs of short-to-long term claims for such injuries. We are committed to a risk management strategy which focuses on injury prevention and this is evidenced by our commitment to the On-Hire Industry Injury Prevention Forum. This, along with many other initiatives places the industry in a unique position to comment on ACC levies that impact on the industry. We would like to take this opportunity to commend ACC for supporting the On-hire Industry Safer Industry initiatives. We see resultant forum and activities as a significant investment which will pay dividends to not only the employees in this industry but also the wider employer community as a whole and NZ society in general. 1 November 2005 Page 7

8 The RCSA has reviewed the proposed ACC levies and the following represents our views on those proposals Proposals 1: CU Definitions The recent definition changes to the 78610, 78620, and CUs has, we believe, made it easier for employers to properly determine if their business activities truly belong to these CUs. However we are aware that problems may still exist with employers endeavouring to properly classify themselves. The RCSA is also aware of a growing number of businesses who believe they are in the business of hiring out labour however their business activities differ from the recruitment or employment services industry in two significant ways: Firstly such contractors tend to work in the industry in which their skills apply eg grape vine pruners will work in the horticultural industry. Where as in the On-hire industry the worker will work in any industry in which their competencies can be recognised. For example a person with skills in grape vine pruning (ie having an attention to detail and able to do repetitive work) could be placed in horticulture or electronic component manufacturing or pick/pack distribution. Secondly, in the Recruitment Industry on-hire agencies are responsible for the management of their on-hire workers BUT the day to day supervision of their workers falls to the client to undertake. Other enterprises who feel they on-hire labour (for example shearing gangs, or grape vine pruners) continue to supervise their workers on the client site. We recommend that the definitions for the 78620, 78621, and CUs be amended by adding the words where the employee is managed by the agency and supervised by the client 1 November 2005 Page 8

9 2: Incorrect Industry data held by ACC Through the On-hire Injury Prevention Forum, the RCSA is aware that an analysis of all recruitment industry claims data for claims from (entitlement plus other claims) shows claims for the industry have potentially been overstated and potentially attributed to incorrect CUs. It is understood that if ACC accepts all the recommendations of a taxonomy report:? overall claim numbers will reduce by 1,353: from 7,959 to 6,546? costs will reduce from $7.782m to $6.393m (Entitlement costs going down from $7.177 m to $5.923m)? CU claims will reduce from 1,177 to 21 ($1.14m down to $39k)? claims will go up from 257 to 359 ($324k to $529K)? claims will go up from 402 to 758 ($605k to $693K)? claims will go up from 4,702 to 5,068 ($3.78m to $4.56m)? claims down from 1,421 to 340 ($1.6m to $564k) The correction of claims data is critical given that past premiums have been set on the basis of data available at that time. It has been the RCSA s view that industry levies have been too high relative to the risks posed by our sector. If claims are going to the wrong CU the RCSA recommends that ACC reviews the Reserves Adjustments as they apply to the on-hire industry CUs. The correction of this data is also important if ACC is considering increasing the funding horizon from three years to five years for full funded rates. Furthermore the RCSA believes that the earnings data for the CU is incorrect. Rather than the stated $17m, the RCSA believes this figure should be closer to $100m. The implications of this view is that the Earnings, Claim Numbers and Claim costs for the CU are too low and do not properly reflect the risk posed by this part of the industry. Additionally it is possible the missing figures can be found in the and other CUs thus distorting the base data for these CUs. The RCSA recommends that ACC consult with the RCSA to assist in reviewing the earnings data to ensure the data is valid and reliable. Last year the RCSA submitted that the On-Hire Industry Injury Prevention Forum had been provided with the following statistics:? New Claims: 2004 down to 397 from 456 in 2003? New Claim Costs: 2004 down to $976,153 from $1,364,763 in November 2005 Page 9

10 This year the RCSA has a set of claims data from ACC which shows that: New claims 2004 down to 475 from 477 in 2003 and 2005 up to 499 from 475 the previous year New Claim Costs 2004 down to $3.362m from $4,690 in up to $4.224m from the previous year. We do not have an explanation for the differing statistics however we have used the following data provided to the RCSA by ACC in October 2005 as the basis of this submission. LRG CU 2004/05 Earnings Employment services (candidate or contractor placement - no on -hired employees) Entitlement Claims Cost Claims $146,355, $200,097 Employment services (on -hired employees - only office work $105,150, $397,051 assignments) Employment services (on -hired employees - non-office work assignments, including up to 30% $16,928, $286,762 office work) Employment services (on -hired employees - mixed classification assignments, minimum 30% office $277,120, $2,443,274 work) Nursing bureau $89,589, $896,930 TOTAL $635,144, $4,224,114 of 3: Prudential Margins ACC believes the prudential margin need not be as high as 15% and is proposing that it be reduced to 10%. Reducing the prudential margin to 10% has the effect of reducing levy rates The RCSA supports this proposal and recommends that ACC proceed with reducing the prudential margins to 10% 4: Levies for 2006/07 Claims ACC is proposing to reduce the 2006/07 levy rate from $0.88 to $0.86 for every $100 of payroll. We note that government Bond rates are between 6% and 8% with the OCR trending upwards. We believe ACC s interest income is particularly conservative however we have not based our assumptions on these details. 1 November 2005 Page 10

11 We are also pleased to see an increase in Injury Prevention investment to $22m. However we are concerned that given the primary emphasis of the Injury Prevention, Rehabilitation, and Compensation Act so little (in relation to overall expenditure) is invested in this area. Our concerns are heightened when we consider that the costs of levy collection has been set at $13m The RCSA is concerned that industry levy rates properly reflect the risk posed by those business activities included within the industry. We have already discussed challenges with the raw data contained relative to the CUs however we would like to offer an alternative pricing option for the fully funded levies. Please note that these suggestions are based on the industry data provided to the RCSA by ACC as part of this consultation process it does not attempt to reflect amended data as suggested previously. 4.1 Pricing Model One Please refer Appendix One for the details of our suggested Pricing Model. The risks posed by the CU apparently are more than those posed by the CU therefore the levy rates should not be the same. In arriving at its average employer levy rate ACC appears to be using a flat $x.xx rate applied to Earnings. The RCSA suggests that some of the pricing requirements be based on a mix of a ratio to earnings and also a ratio to claims costs. The rationale for this view is that, for example the contributes approx 0.31% of ACC s total expected Earnings Pool however it is expected to contribute only 0.16% of all entitlement claims and the average Claim Cost is 0.34% of ACC s average expected claim Cost. After all, if an industry has no claims the cost of running the ACC Scheme for this industry is virtually nothing. At the other extreme, if another CU is contributing 50% of all claims it is likely that approx 50% of all ACC s operating costs will be directed at that CU. The RCSA suggests that ACC s Expense Loading Reserve Adjustments and Bad Debt Loading be based on the Cost of Claims as a percentage of Funding requirements. Furthermore the WSMP Loading should be based on the Pre-Loading Total and finally the Adjustment for Levy Stability should be based on the Central Estimate. 1 November 2005 Page 11

12 If these suggestions are taken up we would expect the industry s levy rates to be: Proposed ACC Work Proposed RCSA levy Levy $0.21 $ $0.21 $ $2.80 $ $1.22 $ $1.36 $1.10 We recommend, as a preferred alternative to the ACC proposed levies the levies as shown in Pricing Model One. 5: Classification Unit Moves ACC is proposing to move five classification units to new risk groups that more closely reflect their emerging claims experience. The RCSA supports the move of 96100, 95240, 86390, and CUs to alternative Risk Groups. 6: LRG Decrease ACC is proposing to decrease the number of risk groups for the employer work levy by two, from 129 to 127 The RCSA supports the redundancy of the 651 and 656 risk groups. We note that the ACC operates 129 Levy Risk Groups and 554 CUs and that part of this year s proposals is the close of two of these LRG s 651 and 656. The on-hire industry has five CUs which are spread across 4 LRG s 585,440, 467 and 653 The RCSA wonders if now is a good time to place all the employment related service activities into one LRG. We note that the 690 LRG has a number of CUs which have different levy rates and some LRG s have a small earnings base eg 653 has approx $330m in earnings. We expect that further consultation will need to be advanced through the industry to weigh up the pros and cons of this thought. Further analysis of the claim rates and injury costs will also be required before this could be progressed much further. We recommend that consideration be given to this, perhaps for future year changes. 1 November 2005 Page 12

13 The 440 LRG is one which appears primarily aimed at the building construction industries. This would appear to be a suitable LRG for some of the activities covered by our members using the CU however this would only be part of the overall activity. Our industry has grown in terms of breadth and depth so that we now have workers on-hired to virtually every industry in New Zealand and even some business operations in Australia. Defining Office only activities is challenging, but it appears that anything that does not fall into the Office Only definition is left to fall into the Non- Office definition. There was a time when our non-office members might have worked relatively exclusively in the construction and related industries. However the industry has now grown to an extent that our activities cover virtually every conceivable non-office activity from logistics and distribution through to roading, manufacturing, agriculture and hospitality. It is now clear that our Non-Office activities should not be held up alongside Construction related industries as covered by the 440 LRG. The RCSA recommends that another LRG be found for the CU which better defines its business activities and its injury risk. The 653 LRG is one that appears to be primarily used for Community Care operations. The CU includes both Nursing Bureau and Hospice operations even though it is labelled Nursing Bureau The RCSA recommends that these two business activities be separated and that the Hospice Operation remain in the 653 LRG. The Nursing Bureau activity should have its own separate CU; however, it could go to another LRG which better reflects the injury risk once these new details are known. 7: Tail LRG s ACC is proposing to maintain the 41 risk groups for the pre-1999 claims levy and to freeze the relativities applicable to each risk group to alleviate ongoing volatility in levy rates. The RCSA supports this proposal. 1 November 2005 Page 13

14 8: Partnership Programme The proposal updates Partnership Programme discounts and fees to reflect the latest experience and costs. ( Partnership Programme ) We are concerned that it appears that employers throughout New Zealand who are in the Partnership Programme are having a greater injury rate than standard employers. It appears that some employers are enjoying the benefits of lower levies while their workers are being exposed to greater risk of injury than if they were employed by non Partnership Programme employers. The RCSA recommends a review of the Partnership Programme, alongside safety incentive discount programmes to ensure discounts are available to employers who can show a real commitment to lowering injuries. 9: Safety Discounts ACC is proposing to introduce workplace safety discounts for employers with fewer than 20 staff. This discount programme would initially be available only in those sectors with high numbers of work-related injuries agriculture, forestry, construction, road freight, motor trades and fishing. The RCSA fully supports the concept of providing discounts to small employers who achieve certain safety standards. However we are very concerned that ACC is aiming this privilege at industries that already have a poor claims history. The RCSA has the view that levies should reflect the risk posed by that industry. Individual poor performers in an industry should be subjected to safety reviews and potential increase in individual levies and ACC already has a process to achieve this. Individual good performers should conversely receive positive recognition for their efforts though the implementation of a discount scheme. ACC s proposal appears to be at odds with this view. Furthermore the limit to 20 staff needs to be carefully defined. The RCSA is aware of many employers who have a small permanent staff of full and part timers but supplement their staff resources with on-hire or contracted workers. For example, a vineyard may have 5 full time equivalent workers but during different seasons could have over 100 workers engaged in vineyard activities. Additionally we note that our CU is part of the Construction LRG however this CU does not appear to be eligible under ACC s current proposals. The RCSA is concerned about this inconsistency. 1 November 2005 Page 14

15 The RCSA recommends that ACC implements a levy discount programme specifically designed to further encourage small businesses which have evidence of a safe workplace. Perhaps it is also timely to be considering an experienced based rating systems for all levy payers. 10: Invoicing The proposal to maintain the minimum amount for a levy invoice at $20 (including GST). The RCSA supports the minimum levy invoice procedures. Furthermore we would like to encourage ACC to maintain a range of payment options that will suit all business practices. 11: WSMP No changes are proposed for the Workplace Safety Management Practices and Workplace Safety Evaluation programmes, except for the impacts of the above levy rate proposals. The RCSA has few Members who belong to this Programme and we believe it is in the best interests of our Members that these companies submit their own views on this matter. 12: ANZSIC Codes The proposal to introduce a new classification system for the 2007/08 levy year, based on upcoming changes to the Australia and New Zealand Standard Industrial Classification (ANZSIC) system. The RCSA notes that ACC is proposing a new M ANZSIC code for Professional, Scientific and Technical Services We recommend that all recruitment and employment services CUs fall under this Code as we are of the view that these are precisely the types of services our Members are offering. Alternatively please note that our industry in Australia is included in Division L "Property and Business Services" and then under Subdivision 78 "Business Services" 1 November 2005 Page 15

16 13: Levy Rates for Pre 1999 claims The RCSA is concerned to see that ACC is proposing to raise the average levy from $0.33 to $0.35. The RCSA is also disappointed to see none of our CUs are experiencing a decrease in this particular levy. The control of these costs are outside our direct influence however we would encourage ACC to focus on developing strategies that would see cost reductions with subsequent reductions in this particular levy. To assist, the RCSA is happy to discuss with ACC ways in which the industry may be able to assist with the vocational rehabilitation of long term claimants. Furthermore we remain concerned that existing and new employers entering the economy are required to pay for work injuries that occurred prior to 1999 and for non-work injuries that occurred prior to We see this as a disincentive for foreign investors to set up much needed business in New Zealand. It is also a potential driver for employers to seek workers in the black economy where such workers do not enjoy the benefits of being an employee. We are concerned that the Residual Claim fund should be increasing over the years however projected investment income from this fund is budgeted to reduce. We are also concerned that ACC appears to be presenting investment income on available funds with a gross return of 8%. According to a 23 October 2005 media report, ACC s share portfolio has returned an average of 17.4% a year. We are concerned that the proposed levy for the is inconsistent with the current risk profiles of the industry s other CUs. We recommend that since this CU has the lowest risk profile it should have the lowest Pre-1999 Levy. Finally we are concerned at the increase in rehabilitation and treatment costs at rates well above the rate of inflation particularly as we consider there must be some attrition of Claimants with access to this fund. We recommend that further attention be given to revenues and costs associated with this fund and that levies be adjusted accordingly. 1 November 2005 Page 16

17 Recommendations The RCSA recommends that: 1. the definitions for the 78620, 78621, and CUs be amended by adding the words where the worker is managed by the agency and supervised by the client 2. that ACC reviews the Reserves Adjustments as they apply to the onhire industry CUs 3. that ACC consult with the RCSA to assist in reviewing the earnings data to ensure the data is valid and reliable. 4. that ACC reduce the prudential margins to 10% 5. that ACC give consideration to the alternative fully funded levies as shown in Pricing Model One (see Appendix One) Proposed ACC Work Levy Proposed RCSA levy $0.21 $ $0.21 $ $2.80 $ $1.22 $ $1.36 $ that consideration be given to have all Employment Services activities placed under one LRG in future years, after appropriate consultation. 7. that another LRG be found for the CU which better defines its business activities and its injury risk 8. that the two business activities in the CU be separated and that the Hospice Operation remain in the 653 LRG. The Nursing Bureau activity should have its own separate CU 9. that a review of the Partnership Programme, alongside safety incentive discount programmes be undertaken to ensure discounts are available to employers who can show a real commitment to lowering injuries. 10. that ACC implements a levy discount programme specifically designed to further encourage small businesses who have evidence of a safe workplace. 11. that all recruitment and employment services CUs fall under the proposed M ANZSIC Code. 12. that the CU have the lowest Pre-1999 Levy since it has the lowest risk profile. 13. further attention be given to revenues and costs associated with the Residual Claims / Pre 1999 Fund and that levies be adjusted accordingly 1 November 2005 Page 17

18 CONCLUSION The RCSA is the leading industry body for recruitment and on-hired employee services - that is we represent the experts in flexible employment solutions. We would like to thank the Accident Compensation Corporation for the opportunity to present our views on the issues. Given the proposed changes to levies to five LCUs for our industry, we believe we have a critical role to play in ensuring that this consultation remains balanced and its outcomes are sustainable for all parties. The implications of ill-considered levies could place New Zealand in a significant competitive cost disadvantage on a global scale. The RCSA has access to a wide variety of statistics and information relating to employment service provision, and would be willing to share this information to aid a more detailed consideration of the implications arising from the proposed levy changes. We are keen to work with the Government, and discuss our views further to develop a workable solution that gives both employers and employees choices and protections, and consequently builds our economy. 1 November 2005 Page 18

19 Appendix One: Pricing Option One ACC Funding Needs A Expected payroll $48,351,000,000 $149,282,413 $107,253,044 $17,267,284 $282,662,740 $91,381,566 B Entitlement claim frequency (per $m) C Expected number of entitlement claims (= A x B) 28, D Average claim cost 12,717 $4,270 $10,783 $10,708 $6,948 $11,908 E Estimated cost of claims (= C x D) ($1,000) 359,089,726 $193,779 $384,515 $277,708 $2,366,132 $868,611 F Average employer levy rate to fund the cost of claims (per $100 earnings (= E / A) 0.74 As a % of Cost of Claims 359,089, G Expense loading (0.2% or 26.9% levy rate) % 96,702, H Reserve Adjustment past (- 0.16) % -77,361, I Reserve Adjustment present (0.02%) % 9,670, J Bad debt Loading (0.01%) % 4,835, K As a % of Pre Pre - Loading total Loading Total 392,935, L WSMP Loading % 14,505, M Central Estimate As a % of Central Estimat e 407,440, N Adjustment for levy stability % 9,670, RCSA Proposed Levy rate ACC Proposed Levy Rate ,110, November 2005 Page 19

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