Review of implementation of the proposed self-insurance licensing framework

Submission cover sheet

  • Name of organisation or individual making this submission

    Fairfield Council

  • Authorised delegate/contact person

    Michael Milczarek

  • Position

    Human Resources Cooedinator

  • Organisation

    Fairfield City Council

Questions on possible options

  1. What is your view of the proposed standard licence conditions?

    Fairfield City Council supports in principal SIRA decision to endorse the 16 recommendations made by PwC independent review regarding Self Insurer licensing conditions. Council has concern that SIRA would consider industry views, injured workers experience when assessing Self Insurer performance. The ability to hold a license should be in consultation with self-insurer and SIRA. On review of the proposed standard license conditions, Council seeks clarity regarding the terminology ‘Significant Matter’. In additional where the licence condition stipulates a standard, condition, time frame and content, Council requires more detail regarding expectations (KPI), in order to determine the reasonableness of meeting the licencing conditions. Consultation on the standards (KPIs) should occur.

  2. What is your view of the appropriateness of the draft top tier measures for conduct and claims management to set SIRA’s expectations of insurance performance?

    The focus on performance and outcomes orientated approach is supported by Fairfield City Council. The three proposed themes Conduct, Claims Management and Financial ability is a variation on the current SI requirements. Conduct - The inclusion of fairness is consistent with Councils current operations, the treatment of staff and the focus on positive RTW outcomes. Compliance - The removal of SI WHS audits is supported as it embraces sustainability, while still ensuring continued compliance with the WHS Act and Regulations. Council will continue to be committed to WHS and will allocate funds to initiatives that lead to proactive and practical safety improvements which result in the reduction of workplace risk and injuries. Reporting - Timely notifications of significant events and the data quality audit is supported by Council. Claims Management - Council understands and adheres to the Claims Management Principles to ensure positive and proactive outcomes. Council has concerns and would like clarity about what would be deemed as an ‘Acceptable Percentage Overturned’ for a top tier performer. Consideration needs to be given to that fact that the majority of cases considered by the Tribunal appear to favour the injured worker. Financial - Supported (financial ratios and benchmarks, security and financial protection to be considered as part of the prudential consultation). Council would like transparency in regard to financial contributions by organisations and how funding is distributed and utilised.

  3. Are there any other areas or measures that should be considered?


  4. What is your view on applying the same assessment criteria to applications for a new self-insurer licence?


  5. What is your view of the allocation of new self-insurers to the mid-tier for their first year under licence?

    Support – in part. As long as all the requirements have been met over the first 12 months of the licence term. They should have to submit data to determine the entry level; the mid-tier level should be the maximum entry level available to new self-insurers.

  6. What is your view on the requirement for self-insurers to submit a business plan to outline their strategic direction consistent with licensed insurers?

    Supported. Council suggests this document be a Strategic Plan, rather than a Business Plan. The Local Government Act 1993, requires Councils to develop a series of strategic documents known as the Integrated Planning and Reporting Framework (IP&R). The Framework requires all NSW Council to have a 10-year Community Strategic Plan, 4-year Delivery Program, 1-year Operational Plan and a series of Resourcing Plans (Long Term Financial Plan, Workforce Management Plan and Asset Management Plan). Fairfield City Council WHS Corporate Strategic Plan is aligned to this Framework and includes indicators to ensure WHS and compliance. Council continues to reviews the WHS Plan and its performance annually. Council undertakes a formal review of the WHS Corporate Strategic Plan every 4 years, in line with the development of the Delivery Program. Any SIRA requirements for Local Government should align to current IP&R legislative requirements. Results will continue to be submitted to SIRA via the S189 return.

At our discretion we may remove parts of submissions because of length, content, appropriateness or confidentiality (privacy) reasons.

Catalogue no. SIRA 08056
State Insurance Regulatory Authority
Motor Accidents Insurance Regulation,
Level 25, 580 George Street, Sydney NSW 2000
General phone enquiries 1300 137 131 or
Claims Advisory Service 1300 656 919


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