As a corporate Commonwealth entity under the PGPA Act, Comcare aims for excellence in its governance to promote public trust and confidence. Good governance for Comcare focuses on two key requirements:

  • performance—governance procedures and practices are designed and operate to shape our results
  • accountability—governance procedures and practices are designed and operate to demonstrate results to Comcare leadership, the government, the Parliament and stakeholders, and conform with applicable legislative and policy requirements in addition to the public expectations of openness, transparency and integrity.

Comcare has adopted the governance principles and better practices recommended by the Australian National Audit Office (ANAO). The key principles are:

  • we are performance orientated—we plan for high performance
  • we are open, transparent and demonstrate integrity in our decision making processes
  • we collaborate effectively.

Comcare hosts a number of external consultation forums and participates in a range of external meetings to provide expert advice or gain insight and perspective.

Strategic planning

The Comcare 2016–17 Corporate Plan (Corporate Plan) has been developed to align with requirements in the Public Governance, Performance and Accountability Act 2013 (PGPA Act). The Corporate Plan sets our direction to deliver healthy and safe workplaces that minimise the impact of harm. It sets a clear path to transform our business and deliver our four purposes:

  • leading insurer
  • national regulator
  • excellence in scheme management and design
  • efficient and effective operations.

Internal operations are guided by the Corporate Plan, with a direct line of sight from the Corporate Plan through the operational and group business plans, to team and individual performance plans.

In 2016, Comcare embarked on an ambitious project to align our business and financial planning frameworks. This project has ensured that the principal planning documents—the Corporate Plan and the Portfolio Budget Statements—are more closely aligned and provide greater transparency and accountability. Comcare has also taken into consideration the findings from the ANAO Audit: Corporate Planning in Commonwealth Entities [see External scrutiny on page 53] in maturing its Corporate Plan into 2017–18.

Performance against the targets set out in the Corporate Plan and Portfolio Budget Statements is monitored by the Executive Committee and the Audit and Risk Committee.

Senior management committees

For the purposes of the PGPA Act, the Chief Executive Officer (CEO) is the Accountable Authority of Comcare. The CEO is assisted in the corporate governance functions by Comcare’s Executive team:

  • Deputy CEO/General Manager Corporate Management
  • General Manager Regulatory Operations
  • General Manager Scheme Management
  • General Manager Claims Management
  • General Manager Insurance
  • General Manager Strategic Research and Innovation.

Executive Committee

The Executive Committee, comprising the CEO and general managers, is directly responsible and accountable to the CEO in relation to:

  • statutory obligations—recommending to the CEO or delegating the exercise of their legislative delegations for the administration of Comcare
  • corporate administration—making decisions on policy or actions to be taken with regard to Comcare’s:
    • people and culture
    • assets and property
    • information systems and records management
    • compliance issues—including legislative and government policy obligations
    • marketing and communications
    • finance
    • external scrutiny
    • corporate governance, including reports from subsidiary committees
    • external relationships, including the Minister, Department of Employment, Australian Public Service Commission, and Department of Finance.

Other committees directly responsible to the CEO, reporting through the Executive Committee, are:

  • People Committee
  • Technology and Information Management Committee
  • Finance and Investment Committee
  • National Health and Safety Committee
  • Security Committee.

Audit and risk committee

The CEO has established the Comcare and Seacare Authority Audit and Risk Committee in accordance with section 45 of the PGPA Act. The objective of the committee is to provide independent assurance and assistance to Comcare’s CEO on risk, the control and compliance framework, and external accountability responsibilities.

The Audit and Risk Committee consists of between three and five independent members. Members are appointed by the CEO for an initial period of two years after which they are eligible for extension or re-appointment.

From 1 July 2016 to 30 June 2017, Comcare’s Audit and Risk Committee comprised of four members, including the Chairperson. Comcare’s senior executive, the Chief Financial Officer, internal audit officers and the ANAO regularly attend as observers.

Table 18: Attendance at Audit and Risk Committee meetings 2016–17

Name Position in Comcare Eligible to attend Attended
Sean Hughes Independent Chair of the Audit and Risk Committee 5 5
Graham Bashford Independent Member of the Audit and Risk Committee 4 4
Lisa Woolmer Independent Member of the Audit and Risk Committee 5 5
Dr Mike Vertigan Independent Member of the Audit and Risk Committee 5 4

Sean Hughes (Audit and Risk Committee Member and Chair)

Sean Hughes is a senior governance executive with over 25 years’ experience across the financial services, funds management, insurance, regulatory, government and professional services industries. During the course of his term, Sean was the Chief Risk and Legal Officer for UniSuper, one of the largest superannuation and pension funds in Australia. Prior to his UniSuper role, he was the inaugural CEO of the Financial Markets Authority in New Zealand from 2010.

Previously he held senior executive, senior legal counsel and general manager roles at the Australian Securities and Investments Commission, National Australia Bank and ANZ Bank. Sean has a Masters of Law (First) from Cambridge University, Bachelor degrees in Law (First Honours) and Arts from the University of Canterbury in Christchurch, New Zealand, and a Graduate Diploma from the Australian Institute of Company Directors.

Sean is the Australian representative on the global Ethical Alliance Advisory Council.

Graham Bashford (Audit and Risk Committee Member)

Graham Bashford is the Managing Director of Bashford Consulting, a company specialising in strategic advice and business development to both private sector and public sector organisations. Before this, Graham was the Deputy CEO of Centrelink for many years, with responsibility for running its network of 26,000 employees, delivering $64 billion worth of benefits to six million customers annually.

Graham has worked for the New Zealand Accident Compensation Corporation (ACC) and has expertise in the government insurance sector. His contribution to the Audit Committee is from a government insurance operational perspective, having led the operational recovery of the ACC for two years. Graham is the independent chair of the Audit and Review Committee of the Community Services Directorate of the ACT. He also holds a Bachelor of Science Honours in Physical Metallurgy.

Lisa Woolmer (Audit and Risk Committee Member)

Lisa Woolmer was appointed to the Audit and Risk Committee in May 2015. She has a background in audit and accounting, including 22 years of professional services experience advising on governance, risk and assurance frameworks.

In her professional services career, Lisa worked extensively with federal, state and local government agencies, and across areas such as health, education, emergency services, water, gas and financial services. In addition to the ACT and Victoria, Lisa has worked in Tokyo and New York.

Lisa is a Graduate of the Australian Institute of Company Directors and qualified accountant. She holds a Bachelor of Economics and Diploma in Japanese Business Communication from Monash University, and a Graduate Diploma in Employment Relations from the University of Canberra.

Lisa is also an Independent Audit Committee member for the Office of Public Prosecutions (Victoria), and the Cities of Glen Eira and Bayside (South Eastern Melbourne). Lisa chairs the Audit and Risk Committees for the Mornington Peninsula Shire and Adult Community and Further Education Board (Victoria).

Dr Michael Vertigan AC (Audit and Risk Committee Member)

Dr Michael Vertigan brings a wealth of experience and high level expertise in the private and public sector finance and superannuation markets, as well as significant public administration experience. Mike has held numerous senior financial and state public service positions in Tasmania and Victoria, and is a former secretary of the Treasury and Finance departments in those states, secretary of Tasmania’s Department of Premier and Cabinet, and former Chancellor of the University of Tasmania.

Since 1998 Mike has held a variety of senior board appointments, including the Chair position, across different business areas, and has also chaired a number of Government expert panels. In 2004 Dr Vertigan was awarded the Companion, Order of Australia Medal for his service to public administration, education and business and industry. Dr Vertigan is currently Chair of the Gas Market Reform Group appointed by the COAG Energy Council.

Fraud control

Comcare is fully committed to complying with the Commonwealth Fraud Control Framework 2014 (Fraud Control Framework) (in particular section 10 of the Public Governance, Performance and Accountability Rule 2014) to minimise the incidence of fraud.

Comcare’s CEO has certified that we:

  • prepare fraud risk assessments and fraud control plans
  • have in place appropriate fraud prevention, detection, investigation, reporting and data collection procedures and processes that meet our specific needs
  • take all reasonable measures to minimise the incidence of fraud and investigate and recover the proceeds of fraud against Comcare.

Fraud prevention

Comcare’s Compliance Investigation Team investigators are authorised by the CEO to undertake investigations of criminal fraud and non-compliance regarding the claims and liability management functions of Comcare. All criminal fraud investigations are conducted in compliance with the Commonwealth Fraud Control Framework and the Australian Government Investigations Standards 2011.

During 2016–17, the Compliance Investigation Unit received 146 referrals for investigation. This is compared with 147 notifications in 2015–16 and a historical average of 110 notifications. The matters that were finalised in the 2015–16 year resulted in a reduction of $1.5 million in ongoing claim liabilities.

There were three matters before the Commonwealth Director of Public Prosecution (CDPP) for prosecution and sentencing during the reporting period. One matter was finalised, with the offender receiving a 12 month good behaviour bond. The second matter is still before the courts. The third matter is with CDPP for assessment.

Comcare continues to actively participate in the annual Commonwealth Fraud Liaison Forum. The forum is jointly managed by the Attorney-General’s Department and the Australian Federal Police.

Covert surveillance

Comcare acts in a lawful manner that is consistent with relevant legislation and guidelines. A cost/benefit analysis is used to determine whether covert surveillance should be used, taking into account the subject’s right to privacy.

During 2016–17, covert surveillance was undertaken on 13 APS employees. Of the matters that were finalised during the year, surveillance contributed to three employees having their liability on workers’ compensation claims ceased.

Internal audit

The internal audit programme is a key element of the Comcare corporate governance framework. The internal audit programme provides assurance to the Audit and Risk Committee, the CEO and senior management. It adds value to what Comcare does by highlighting opportunities for improvement in statutory compliance, internal control, and efficiency and effectiveness of business processes.

Internal audit topics are typically identified through consultation with senior management and the Audit and Risk Committee. In deciding the final programme of internal audit work for the year, the Audit and Risk Committee takes into account the strategic and operational risk profile of Comcare and relevant audit reports published by the ANAO.

Risk management

Comcare has embedded systematic risk management as part of its governance and planning processes and organisational culture. Comcare’s particular focus is on:

  1. establishing a high quality agency-wide risk management system
  2. providing comprehensive training and development on risk
  3. evaluating and improving risk performance
  4. strengthening engagement with stakeholders on risk issues.

Comcare’s business planning framework is underpinned by corporate and group risk assessments. Ongoing risk management is the responsibility of all Comcare Executive members as part of their normal operations. The Audit and Risk Committee reviews the risk management framework annually.

In 2016, Comcare commissioned an internal audit to review how well the framework has been integrated into business practices. The audit report identified a number of improvements, which are being implemented into the risk management framework for the 2017–18 financial year.

Comcare relies on a range of strategies to address risks, including managing stakeholder relationships, implementing sound project management and contract management practices, and building workforce capability. Comcare has seen sustained reductions in its insurance premiums due to its increased focus on risk management.

Freedom of information

Comcare is required to publish information to the public as part of the Freedom of Information Act 1982 (FOI Act) Information Publication Scheme (IPS). The IPS replaces the former annual report publication requirements in section 8 of the FOI Act.

Comcare’s Agency Plan and other categories of information specified by the IPS are available at, via the Access to Information logo on the bottom of the homepage.

During 2016–17 Comcare received 145 freedom of information requests, which is a 16 per cent increase on the previous financial year. Comcare received two requests for amendment and/or annotation of personal records.

Comcare received eight requests for internal review of access and amendment decisions. The original decision was affirmed in three of the reviews completed, with three being varied with greater access provided. One was withdrawn and one invalid.


Comcare is committed to meeting the highest standards when collecting, storing, using and disclosing personal information with all staff completing privacy training annually. Comcare primarily collects, uses and discloses personal information as reasonably necessary for, or directly related to its functions and activities under the SRC Act and the WHS Act.

Business areas are required to notify the Privacy team of any potential privacy breaches. During 2016–17, 241 notifications of potential breaches were received. Investigations concluded that breaches had occurred in 168 cases.

Comcare notified two breaches of the Privacy Act 1988 to the Office of the Australian Information Commissioner (OAIC).


Comcare’s feedback team receives compliments and investigates complaints from stakeholders about its service provision. During the 2016–17 financial year Comcare received 468 complaints compared to 586 in 2015–16. This represents a 20 per cent reduction from the previous financial year.

Table 19: The three most frequent areas of complaints during 2016–2017

Area Percentage of 468
Communication 20
Determinations and reconsiderations 19
Claims management process 18

Claims Management Pilot complaints

In February 2016, Comcare commenced the Claims Management Pilot programme with the Department of Human Services (DHS) and Australian Taxation Office (ATO). The pilot devolved claims management and decision making responsibilities to officers of ATO and DHS for an initial period of 12 months and was later extended for a further 12 months to allow for a greater capture of claims management related data.

During the first year of the Claims Management Pilot Comcare retained responsibility for complaints relating to inclusion in the pilot programme, however during its second year, complaints were managed directly by those agencies. Comcare is kept abreast of the resolution to each complaint.

During 2016–17 Comcare received 68 complaints relating to the Claims Management Pilot, which accounts for 15 per cent of all complaints received in 2016–17.


During 2016–17, Comcare received 73 compliments on the services provided compared to 86 in 2015–16. This represents a 15 per cent decrease from the previous year.

Table 20: The two most frequent areas of compliments during 2016–2017

Area Percentage of 73
Claims Services Officer’s conduct 49
Communication 18

Ministerial directions

Comcare received no Ministerial Directions in 2016–17.

Government general policy orders

There were no General Policy Orders issued by the Minister for Finance in 2016–17 that impacted Comcare.

Significant non-compliance with finance law

In 2016–17, there were no reports of any significant issues reported to the Minister by Comcare under paragraph 19(1)(e) of the PGPA Act.