21 Point Action Plan Update (as at 23 August 2021)
Following the Independent Compliance and Performance Review of the Nominal Insurer (managed by icare), on 13 December 2019 the SIRA Chief Executive issued a 21-Point Action Plan to drive fact-based and steady improvement in the Nominal Insurer.
SIRA is continuing to monitor icare’s performance against the 21-Point Action Plan and has been providing regular updates on progress in the interests of transparency and accountability.
As at 23 August 2021, 15 actions have been completed and six actions remain in progress.
Progress against each of the actions is below and the detailed actions are available in the 21-Point Action Plan
icare actions required by SIRA
Action 1: icare to resubmit its 2019/2020 business plan
Status: Completed
icare has now submitted the Nominal Insurer business plans for 2020/2021 and 2021/2022.
Action 2: icare to adhere to regulatory data requirements
Status: Progressing
icare has implemented data quality improvement measures that have resulted in more accurate and timely data submissions to SIRA. But despite significant improvements, icare data still does not fully meet the regulatory requirements. icare and SIRA continue to meet monthly to monitor data improvement activities.
Action 3: Review of icare premium calculation model
Status: Completed
icare has completed a comprehensive review of the Nominal Insurer premium formula, however implementation was delayed by the decision to defer premium increases due to COVID-19. Icare has subsequently determined the proposed rates for the premium year 2021/22.
SIRA and icare will continue to discuss any further premium calculation amendments.
Action 4: icare to report premium review arrangements to SIRA
Status: Completed
icare is reporting its premium review arrangements to SIRA in accordance with the Market Practice and Premiums Guidelines, as well as details of premium review complaints. In addition, icare has issued information to employers on how to review their premiums.
icare actions recommended by SIRA
Action 5: Dedicated case manager
Status: Completed
icare has implemented changes to its claims management model to increase the allocation of dedicated case managers.
Action 6: Remuneration incentives for return to work
Status: Completed
icare has provided SIRA deeds executed in 2020 with their agents. All included increased incentives as well as KPI targets for early RTW (4, 13 and 26 weeks) based on work status and weekly payment-based metrics.
icare have provided board approved RTW targets for FY2020/21 (4w 63%, 13w 79%, 26w 84%, 52w 86%) and FY2021/22 (4w 70%, 13w 85%, 26w 87.8%, 52w 89.8%).
Action 7: Small business employers claim management provider
Status: Progressing
Following delays due to the COVID-19 pandemic, icare advised SIRA that it will consider this recommendation later in 2021 as part of its service model provider review.
Action 8: SIRA Tripartite Reference Group
Status: Completed
SIRA continues to invite icare to the SIRA Tripartite Reference Group meetings to discuss progress of the 21-Point Action Plan and performance of the Nominal Insurer.
icare has now established its own Nominal Insurer Advisory Committee.
Action 9: Independent review of culture, governance and accountability
Status: Completed
On 1 March 2021, icare published its independent review of icare governance, accountability and culture on its website.
SIRA regulatory actions related to the NI
Action 10: Quarterly compliance and performance audits
Status: Progressing
The first and second quarterly reviews conducted in February and August 2020 found some improvements in the claims performance of the Nominal Insurer, however further improvement is required. SIRA has deferred the planned quarterly reviews to allow icare’s new leadership team time to implement improvements.
Action 11: Independent audit of the Nominal Insurer’s medical services
Status: Progressing
Following delays due to the COVID-19 pandemic, SIRA has undertaken a healthcare review and a detailed analysis of potential leakage in medical expenditure. SIRA has requested that icare provide quarterly updates against actions it had identified to improve its governance around medical payments.
Action 12: Advice to Government on prudential supervision
Status: Completed and ongoing
SIRA has and will continue to provide advice to Government on options to improve scheme performance and outcomes, including prudential supervision.
Action 13: SIRA and icare board engagement
Status: Completed and ongoing
SIRA and icare boards continue to constructively engage on matters relating to the performance of the workers compensation system.
Action 14: Advice to Government on legislative policy matters
Status: Completed and ongoing
SIRA has and will continue to provide advice to Government on legislative policy matters to improve scheme performance and outcomes as required.
SIRA regulator commitments
Action 15: SIRA to review performance indicators and compliance benchmarks
Status: Progressing
SIRA has refined its performance metrics and is developing a range of new measures to inform monitoring and supervision, with a focus on return to work and creating more consistency in regulatory monitoring. SIRA has commenced onboarding icare to the SIRA Insurer Accountability Portal so that it has greater regulatory oversight and icare can more quickly respond to emerging issues.
Action 16: Return to work measurement framework
Status: Completed
SIRA has developed a return to work measurement framework and enhanced return to work metrics.
The RTW measurement framework will be integrated with the RTW strategy and will be used to determine the success of the strategy, the performance of the entities SIRA regulates and monitor the performance of both personal injury schemes.
Action 17: Medical partnerships
Status: Progressing
SIRA is actively engaging with professional medical colleges to increase awareness of the Health Benefits of Good Work initiative among GPs and other health providers. SIRA has endorsed the Health Benefits of Good Work initiative and the supporting evidence has been included in SIRA’s training packages for physiotherapists and psychologists. SIRA is continuing to incorporate evidence of the Health Benefits of Good Work in its training and frameworks.
Action 18: Reviewing healthcare costs
Status: Completed
In December 2020, SIRA published its Healthcare Review Final Report. The review identified trends and drivers of rising healthcare costs and set the agenda for regulatory action in response. In August 2021, SIRAs’ value based healthcare outcomes framework was published on the website.
Once the framework is implemented, SIRA will be able to measure the value of healthcare – through the health and quality of life outcomes that are achieved - and report comparatively on insurer performance..
Action 19: Customer survey
Status: Completed
Following delays due to the COVID-19 pandemic, SIRA has now published its first customer experience survey and is undertaking its first repeat survey. Planning for an employer survey is also underway.
Agreed joint SIRA and icare actions
Action 20: Half-yearly board meetings
Status: Completed and ongoing
SIRA and icare boards continue to meet every six months.
Action 21: Escalated monitoring and communication
Status: Completed and ongoing
SIRA and icare are continuing the current level of escalated monitoring and communication through the Joint Premium and Prudential Oversight Committee and Joint Claims Assurance Committee.