Why is this important?

Early intervention means assisting an employee before a symptom develops into an injury, or helping them as soon as possible after an injury. Responding early can often prevent the employee from becoming ill, taking long-term sick leave or needing to submit a workers' compensation claim. Having clear procedures and ensuring that employees are aware of them will enable early reporting and response to injury or illness.

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• Documented procedures for early intervention exist 
• Funding is allocated for early intervention
• Communication encourages early reporting

Case study⁸

Centrelink has a policy on early intervention to complement its rehabilitation case management policy. The comprehensive policy outlines the objectives and benefits of early intervention. It also provides practical guidelines on how the policy is put into effect.

The policy deals with both work and non-work-related incidents that could lead to absenteeism or reduced work performance. These include incidents, both physical and psychological, related to work, playing sport, motor vehicle accidents and bereavements. The policy outlines a staged procedure for intervention, beginning with initial local management activity, through to case management involvement and commitment of corporate funds for rehabilitation. The final stage would be lodging a claim. The policy is consistent with Centrelink's commitment to a holistic approach to managing people and the welfare of its staff.

Better practice tips

• Part of early intervention is to have policies and procedures that encourage people to report illness or injury early and achieve a timely return to work.
• Early intervention budgets should be kept separate from team budgets to ensure that budgetary restraints don't affect early intervention. Access to early intervention budgets is not dependent on determination of a claim. Funds should be accessible for compensable and non-compensable injury and illness.

Resources/tools

• Recognition, resolution and recovery: Early intervention to support psychological health and wellbeing (Pub 46)
• Body stessing injuries - Key messages for rehabilitation providers (Pub 88)
• Early intervention checklist
• More information on early intervention and return to work can be found at the Return To Work Knowledge Base. 

⁸ Rehabilitation: Managing Return to Work. A Better Practice Guide for Senior Managers and Supervisors, 2001. Joint ANAO and Comcare publication.

Why is this important?

Organisations need employees to notify them of workplace injuries and submit completed workers’ compensation claims as soon as possible.

Employers need to ensure that procedures are developed to manage any claims they receive. Employers must also make sure their employees are familiar with any procedures they need to use.

An organisation’s workers’ compensation procedures should:

• inform employees about how to notify their employer about an injury and how to make a claim
• be in a readily accessible place
• display the name(s) of the case manager(s)
• encourage the injured worker to initially see their GP for a diagnosis and to confirm the relationship of the injury to the workplace. 

Employers need to have systems in place to make sure that claims for workers’ compensation are forwarded to Comcare or the relevant authority as soon as possible. As stated on the Comcare claim form this should be done within five working days of the worker providing a completed form to the organisation case manager or other nominated employer representative.

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• There are reports demonstrating that lodgement timeframes have been met
• Staff have procedures for notifying their employer of a workplace injury and submitting a workers' compensation claim
• Staff have completed survey/questionnaire to measure their knowledge of procedures, requirements and accountabilities

Better practice tips

• Provide information packages to employees to make sure they are fully aware of workers' compensation processes
• Foster and maintain positive working relationships between workers' compensation staff, line management and the injured worker.

Resources/tools

• All about workers' compensation: A guide for employees injured at work on or after 13 April 2007 (Pub 71)
• Information on making a claim for compensation
• Comcare training calendar

Why is this important?

The Rehabilitation guidelines for employers (the s. 41 guidelines), issued by Comcare under s41 of the Safety, Rehabilitation and Compensation Act 1988, require employers to have procedures that describe how return to work processes will be managed. The procedures should form part of a rehabilitation management system. The rehabilitation management system needs to include appropriate documentation, procedures and contractual arrangements to provide for effective rehabilitation, including the communication of these procedures to employees. Effective communication with employees of procedures, rights and obligations enables them to participate more in rehabilitation.

Although there is flexibility around how employers manage rehabilitation in their organisation, better practice rehabilitation procedures will document an organisation’s approach to:

• assessing an injured worker’s capability to undertake a rehabilitation program
• documenting the process for providing information to employees about their rights and obligations 
• working with approved rehabilitation providers
• developing, monitoring and reviewing return to work plans
• making suitable duties available for injured workers, or modifying their work environment
• communicating with all people involved in the return to work process
• collecting and releasing information in compliance with the Privacy Act 1988
• managing disputes arising from return to work issues
• defining the roles and responsibilities of stakeholders.

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• The return to work procedures and management of rehabilitation procedures have been documented
• Records demonstrating that staff have been advised on how to access return to work support
• Service level agreements with approved rehabilitation providers
• The Commission's rehabilitation indicators have been used
• Internal key performance indicators for rehabilitation targets
• The procedure for managing suspensions identifies who is responsible for managing suspensions (e.g. a senior manager) and what constitutes a reasonable excuse for the purposes of sections 36(4) and 37(7) of the Safety, Rehabilitation and Compensation Act 1988
• Copy of instrument of delegation
• Senior manager duty statement outlines who is responsible for the management of suspensions
• Survey/questionnaire of staff to demonstrate awareness and knowledge of procedures and their location

Case study⁹

BHP's Transport and Logistics section has instituted better practices in the management of the return to work of seafarers. This has led to close to 100 per cent success rates over the past three years. BHP has identified the following critical success factors:

• establishing immediate contact with the injured worker
• starting the rehabilitation process immediately
• developing strong relationships with the injured worker and the treating doctor, which focus on occupational rehabilitation
• identifying suitable duties for the injured worker
• returning the employee to work safely, as soon as possible.

These factors are implemented in a seven-phase approach.
 
1. Establish contact with the injured worker. Immediately after the injury occurs establish contact with the injured worker. Discuss the incident, encourage a visit to the doctor and introduce the concepts of having a rehabilitation plan and involving a rehabilitation provider.

2. Set up a rehabilitation relationship. Develop a personal relationship with the injured employee and brief the rehabilitation provider, who will then contact the injured employee to arrange a home visit.

3. The rehabilitation provider conducts a home visit. A short, medium and long-term strategy is discussed between the injured worker and the rehabilitation provider.

4. A rehabilitation plan is developed. The rehabilitation provider meets with the employee's doctor (with the employee’s permission) and a plan is developed between the worker, rehabilitation provider, doctor and employer. In this case, BHP approves the plan.

5. Return to work is discussed. The scope of suitable duties is discussed with the employee, the rehabilitation provider and the employee's doctor, and the doctor approves the return to work. A work plan is developed for implementation in a supernumerary capacity.

6. Return to work occurs. In this case, the return to work plan is signed off by the ship manager and master of the vessel. The rehabilitation provider meets the employee at the airport to help with transfer to the vessel. There is an introduction to the master and a walk-through of suitable duties and the work plan. There is active participation by the officers and crew on the process. The employee will then embark on a two-week voyage on the nominated coastal vessel.

7. Voyage end. When the voyage is complete, the employee is contacted at home to discuss the process. The doctor is contacted for an opinion about the employee's fitness for work. Consideration is given to whether the employee should complete another voyage in a supernumerary position. The rehabilitation and return to work plan is reviewed.

Resources/tools

• Comcare guidance on injury management
• Rehabilitation guidelines for employers (Pub 19)
• See Appendix 3 for an example of a survey for rehabilitation personnel, managers and supervisors [doc]. 
• See Appendix 6 for essential information for rehabilitation case managers [doc].

⁹ Rehabilitation: Managing Return to Work. A Better Practice Guide for Senior Managers and Supervisors, 2001. Joint ANAO and Comcare publication.

Why is this important?

Organisations should identify what training their staff should do to ensure that they are able to perform return to work activities competently. Personnel involved in the management of return to work processes (in most organisations this is the case manager) should undertake appropriate training, carried out by trainers with appropriate knowledge, skills and experience in rehabilitation training.

Organisations need to have procedures to make sure rehabilitation competencies are developed and maintained.

Line managers need to be trained to recognise early warning signs, support employees at risk of injury or illness and manage return to work for employees who are off work with an injury or illness.

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• Training needs analysis of relevant personnel
• Job descriptions which detail required skills/competencies
• Proposed training schedules
• Personal development plans for individuals
• Training matrix
• Training records for competency-based training that demonstrate skills acquired

Resources/tools

Better practice tips

• Rehabilitation case managers should be familiar with the Safety, Rehabilitation and Compensation Act 1988 (SRC Act) and should refer to it on a regular basis. In order to do this it is recommended that they have a copy of the SRC Act on their desk or near their workstation
• See Appendix 7 for an example of a training needs analysis [pdf]
• Relevant Comcare training (including Certificate IV in Government – Injury Rehabilitation Management) 
• More information on training and return to work can be found at the Return To Work Knowledge Base. 

Why is this important?

Organisations need to develop plans to support their rehabilitation management system. In doing so, they need to consult with the relevant stakeholders. These plans must identify how the organisation will ensure that they comply with the Safety, Rehabilitation and Compensation Act 1988, Safety, Rehabilitation and Compensation Regulations 2002 and all relevant guidelines.

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• Business management plans
• Rehabilitation management system manual
• Service level agreements with approved rehabilitation providers
• Rehabilitation procedures that refer to the Safety, Rehabilitation and Compensation Act 1988 and reflect the requirements of the s41 guidelines
• Policies and procedures for suspension of rehabilitation take account of natural justice principles

Resources/tools

• Legislation relevant to the Comcare scheme

Why is this important?

Rehabilitation authorities can delegate powers and functions stemming from Safety, Rehabilitation and Compensation Act 1988 (SRC Act) to individuals within the organisation.

Section 41 of the SRC Act allows the secretary of a department, or the principal officer of a Commonwealth authority, to delegate any of these powers and functions to an officer or person employed by that department or authority. These functions and powers cannot be delegated to contracted providers of case management services.

Part III of the SRC Act gives employers the powers and functions of a rehabilitation authority. These functions and powers relate to providing rehabilitation programs to employees and include the:

• function and corresponding power to arrange for an employee to be assessed to determine whether they can undertake a rehabilitation program
• power to require an employee to undergo an examination for assessment purposes
• power to determine that an employee should undertake a rehabilitation program
• power to arrange a rehabilitation program for an employee with an approved rehabilitation provider.

In the list below are some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, who is responsible and by when.

Download the Examples of success template [doc]

Examples:

• Documentation outlining the delegation of powers and functions
• Position/role description of the person who is responsible for delivering the rehabilitation functions

Resources/tools

• Legislation relevant to the Comcare scheme

Why is this important?

Injured workers need to be advised of their rights and responsibilities in relation to return to work.

Injured workers have the following rights and responsibilities in relation to return to work:

• injured workers must undergo an assessment of their capability to undertake a rehabilitation program when a referral is made. Refusal to participate in the assessment can result in a suspension of rights to compensation (see s. 36 of the Safety, Rehabilitation and Compensation Act 1988 (SRC Act))
• injured workers must participate in a return to work program unless they have a reasonable excuse. Failure to participate without reasonable excuse may result in suspension of rights to compensation (see s. 37 of the SRC Act)
• injured workers may disagree with their return to work plan and have a right to ask that the determining authority (e.g. Comcare or the licensee)reconsider the employer's determination that they undergo a return to work program (see ss. 38 and 62 of the SRC Act).

Employers are obliged to advise injured workers of their rights and responsibilities.

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• Evidence of rehabilitation assessment occurring in the appropriate timeframe
• Evidence on return to work plans that a written notice of rights was provided to the injured worker
• Other evidence that rights of injured workers are made available to staff (e.g. a copy of the intranet page where these are available)
• Evidence of surveys/questionnaires demonstrating injured worker and manager knowledge of the rights and responsibilities, location of the information, and consequences of non-compliance

Resources/tools

• Rehabilitation guidelines for employers (Pub 19)
• Return to work - Easy reference guide (Pub 22)
• Legislation relevant to the Comcare scheme
• Employees' rights and responsibilities An explanation of employees' rights and responsibilities under the Comcare scheme.

> Next page - Management accountability

Why is this important?

Managers and supervisors need to be held accountable for return to work performance in the work areas they manage. They have a key role in creating a supportive workplace and ensuring open communication exists in the management of the return to work process. They are also accountable for providing suitable duties for the injured worker and preventing re-injury.

These responsibilities need to be clearly communicated to managers and supervisors. Workers' compensation and return to work performance in the manager's work areas should be considered as a part of performance feedback discussions.

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• Manager and/or supervisor position descriptions
• Organisation agreements that specify management responsibility
• Performance agreements that specify management responsibility
• Premium arrangements devolved to line managers to establish accountability
• Copies of reports provided to managers and supervisors highlighting workers' compensation and return to work issues in their workplaces
• Training records demonstrating managers and supervisors have been informed of their return to work responsibilities
• Surveys/questionnaires demonstrating supervisor/manager knowledge and capacity

Resources/tools

• Safe and Sound. A discussion paper on safety leadership in government workplaces (Pub 35), a joint publication by the Australian Safety and Compensation Council and Comcare 
• Leadership Commitment - Early rehabilitation assistance to employees (Pub 31)
• Rehabilitation guidelines for employers (Pub 19)
• Rehabilitation: Managing return to work (Pub 16)
• Return to work – key steps for supervisors and line managers (Pub 21)
• Legislation relevant to the Comcare scheme

Why is this important?

It can be necessary to have specialist advice and guidance when developing effective return to work programs. This advice can be sought from a range of experts including approved rehabilitation providers, the injured worker’s treating practitioner and other experts such as occupational physician.

If this advice indicates that a rehabilitation program is required, and that an external provider is needed, rehabilitation authorities may only engage a rehabilitation provider approved by Comcare. This is a requirement under s. 37(2) of the Safety, Rehabilitation and Compensation Act 1988 (SRC Act).

While Comcare monitors overall provider performance, rehabilitation authorities are responsible for managing individual contracts for services delivered by approved rehabilitation providers. This includes monitoring the quality, timeliness and cost of services provided under contract.

The list below features some ways to demonstrate success in this element. You can also add other examples.  When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• A register/list of preferred approved rehabilitation providers is maintained – consistent with providers approved by Comcare
• Contract/service level agreement between an organisation and the approved rehabilitation provider
• Records/reports of advice received from the approved rehabilitation provider(s)
• Documentation of approval for in-house providers
• Reports demonstrating cost effectiveness and outcomes achieved by approved rehabilitation providers as measured against Comcare's operational standards
• Survey/questionnaire of injured worker and employer knowledge of approved rehabilitation provider arrangements
• Documented feedback on the quality of the approved rehabilitation provider service
• The contract/tender process includes a documented evaluation process.

Case study¹⁰

A Western Sydney manufacturing company's existing work practices had no occupational health and safety (OHS) or injury management systems in place. Consequently they had over 15 workers' compensation cases.

Staff morale was low and absenteeism was gradually increasing. The employer's premiums were increasing and exceeded $1 million. An approved rehabilitation provider conducted an OHS inspection to identify hazards, assess the risks associated with those hazards and recommended appropriate control measures.

Staff were trained in OHS policy and procedures in line with current legal obligations. Poor manual handling techniques were identified as being a major risk factor, so all staff were provided with manual handling training. An OHS committee was developed and trained. Employees and management were also trained in risk management strategies.

The company then developed and implemented injury management processes and compliance was recommended in a number of areas. Our consultants were used for injury management services to implement effective management of workers' compensation claims. The result was that speedy and durable return to work outcomes were achieved. Workers' compensation claims reduced to two; staff morale increased and there was a noted reduction in absenteeism.

The expedient and sustained return to work of their injured employees resulted in the nullification of wages estimates in their second and third year gross claims costs. 

When gross incurred costs were adjusted against factors in the premium experience adjustment calculation, this resulted in overall premium reduction and a cost saving of $350 000.

Case study¹¹

In March 2005, NAB was undergoing a significant rebuilding process. Within its People Support function, this included a review of its health and safety strategy and a focus on improving its management of workers' compensation claims and return to work outcomes.

It was identified that there was minimal focus on return to work before claims were submitted. Incidents resulting in injuries were not being managed with a clear and consistent process and there was limited focus on early management of injuries.

To tackle the growing issues, NAB developed an early intervention procedures manual to equip people leaders with appropriate tools and tips. They also engaged a rehabilitation provider to help with both early intervention and rehabilitation strategies. Konekt, an organisation providing workplace health solutions, was engaged to provide workplace assessment services under a service level agreement.

Konekt provided NAB with access to a 1300 contact number to accommodate all referrals, which are allocated to a consultant within 24 hours. Any absence (work-or non- work-related) beyond seven working days requires a referral to Konekt to help with the return to work process.

A relationship manager was appointed to oversee the external provider services and quarterly reviews are held between Konekt and NAB to ensure that progress is on track.

Injury trends and 'hot spots' are identified and discussed with health and safety consultants to enable development of preventative strategies.

Following the launch of the early intervention program in June 2006, NAB now has an injury management team who have extensive experience and delegated authority to make rehabilitation determinations. This means that injuries can be managed with a seamless approach from incident to claim. Through effective early intervention on reported incidents, NAB has achieved the following results:

• a significant reduction in claims incapacity payments from $1.74 million (April 2003 to March 2004) to $0.56 million (April 2007 to March 2008) 
• overall rehabilitation costs on all claims has reduced from $0.45 million (April 2003 to March 2004) to $0.21 million (April 2007 to March 2008) 
• fewer new claims received for the year (April 2007 to March 2008), reduced to 177 from over 350 before the early intervention program was implemented
• a reduction in overall claims payments from $5.785 million (April 2003 to March 2004) to $2.382 million (April 2007 to March 2008).

Better practice example

The Australian Taxation Office routinely sends letters to approved rehabilitation providers with assessment referrals with under s. 36 of the SRC Act which clearly detail its expectations of the service being requested. This includes expectations around:

• timeliness of advice and paperwork
• a close working relationship with the treating doctor(s)
• communication with the consultant, the employee and Comcare
• billing procedures
• choice of ergonomic equipment
• structure of the return to work.

For a copy of this letter template [doc] see Appendix 8.

Resources/tools

• Legislation relevant to the Comcare scheme
• Working with approved rehabilitation providers
• Customer Information System report 64, Provider Performance Report CIS, can be used to monitor ARP performance
• See Appendix 9 for other qualitative and quantitative measures [doc].

¹⁰ Case study located on rehab management website at www.rehabmanagement.com.au

¹¹ 2008 SRCC Safety Awards

Why is this important?

Organisations should establish, implement and maintain documented injury management objectives and targets in their rehabilitation management system. These objectives are the organisation's goals for managing injury in the workplace, and enable an organisation to evaluate its injury management performance at the strategic level.

Objectives should be aimed at improving the prevention and management of injuries in the workplace and should be supported by SMART targets:

S – specific
M – measurable
A – achievable
R – realistic
T – timely.

SMART objectives (see Appendix 10) focus on outcomes as well as activities.

Operational plans to address an organisation's specific return to work issues need to be developed and implemented. Procedures need to be established to ensure that current plans are reviewed and if necessary, amended to address required changes. The results of these reviews should be appropriately documented and reported to the senior executive and other relevant personnel, and to Comcare and the Safety, Rehabilitation and Compensation Commission (SRCC) if necessary.

Organisations should also consider the frequency and duration of workplace injuries when developing, monitoring and evaluating their rehabilitation management system. At a minimum, internal targets should include:

• time to commence early intervention
• return to work outcomes
• cost and effectiveness of any approved rehabilitation providers used.

The organisation also needs to consider the external indicators and targets (e.g. those set by the SRCC).

The list below features some ways to demonstrate success in this element. You can also add other examples. When you identify areas for improvement, include an action, when it needs to be completed and who is responsible.

Download the Examples of success template [doc]

Examples:

• Document outlining objectives and targets for the organisation
• Reports showing measurement/performance against the targets
• Service level agreements with approved rehabilitation providers
• Commission indicators
• Survey/questionnaire demonstrating staff knowledge and awareness

Case study¹²  

Comcare's Leadership and Accountability Strategy features the promotion of target setting as a key activity, with all targets linked to the National Occupational Health and Safety Strategy 2002-2012. Government agencies like Defence have signed up to two additional rehabilitation targets:

1) reduce the average lost time rate by 40 per cent by 2012
2) reduce the average time taken for rehabilitation intervention by 90 per cent by 2012.

To position itself to achieve these targets, Defence Support Group (DSG) set about developing a system that would ensure successful results.

A case management module encompassing an e-injury matrix was introduced to record and provide an enhanced tracking system of return to work programs for all ill or injured Defence civilians. The e-injury matrix is a technology-based rehabilitation case management tool that allows DSG to assess return to work processes through liability mapping.

DSG also developed a pathways mapping initiative that streamlines all current processes into an e-injury model. The objective is to specify timeframes for the input of information into the case management module from initial contact to closure of claims—making the process simpler for the department's case managers and approved rehabilitation providers (ARPs).

To make sure the e-injury model can accommodate ARP processes, consultants streamlined the required activities into the e-injury matrix. Following this, each phase of the return to work process was deemed acceptable for integration into the e-injury model. All reports, letters, plans and records were encrypted and password protected using email before being sent to an employee. When sent, all information would simultaneously upload to the employee's record on the case management model.

DSG also designed a civilian absence management program for its internal managers. The objective of the program is to improve referral times and encourage managers to seek early intervention for ill or injured employees.

With the e-injury matrix, DSG has developed an efficient system to support its staff in the return to work process and has positioned the department to achieve its desired rehabilitation targets. In combining this approach with the civilian absence management program, staff members playing a key role in the process are now more proactive and have the necessary support to help them in their work.

Resources/tools

• Comcare scheme performance
• National OHS Strategy 2002-12
• Leadership Commitment – Early rehabilitation assistance to employees (Pub 31)
• Positive Performance Indicators: Measuring safety, rehabilitation and compensation performance (Pub 10)
• See Appendix 9 for qualitative and quantitative measures for rehabilitation [doc]
• See Appendix 11 for an agency rehabilitation performance template [doc].
  

Data

The following CIS report can be used to set and monitor performance targets:

• PI.1 T1 Incidence rate of claims resulting in one week or more of lost time per 1000 employees CIS. 

¹² 2007 SRCC Safety Awards