Purpose

Licensed  self-insurers  must provide an Annual Return regarding statutory OHS performance information to the state regulator. The annual return is also benchmark information used as both raw data and to ensure that the self-insurer organisation has an effective program in place to evaluate its own OHS program effectiveness.

NOTE:A WorkCover audit does NOT replace the self- insurer’s annual self-audit and reporting requirements under section 189 of the Workers Compensation Act 1987.

Reporting requirements are defined under Section 189 of the Workers Compensation Act 1987 and allow for the regulator to require administrative practices to be conducted according to appropriate OHS reporting criteria.

The OHS annual return information is based upon:

• Outcomes of an OHS self-audit program
• OHS reporting requirements

OHS Self-Audit Program

Self-Insurers are required to conduct self-audits as part of their OHS  assurance and continuous improvement framework. This requirement is consistent with auditable criteria contained within the WorkCover National Audit Tool (NAT) for audit verification activity to occur.

Administrative criteria for Annual Returns (in relation to OHS self-audit programmes) also define a requirement for appropriately qualified and experienced audit teams to conduct audit activity in accordance with AS/NZS ISO 19011 – Guidelines for quality and/or environmental management system auditing. This standard defines minimum qualification, performance and process criteria requirements for persons to conduct audit activity.

IMPORTANT issues with self-audits:

Reporting requirements are based on essential elements of best practice for self-insurers. If a self-insurer is unable to provide sufficient information to meet subject criteria, that may indicate an inability to meet the associated NAT criteria.

That situation may in turn impact on the self-insurer’s licensing requirements. In such cases, self-insurers should seek assistance from OHS consultants to deal with the administrative problems, and may also request assistance from the regulator in dealing with the statutory issues.

Self-insurers must submit self-audit results to WorkCover in their annual returns. The results of the audit activity are stated in the form of an executive summary which provides a clear and concise overview of the outcomes and information arising from the audit/s that have been conducted.

NOTE:This annually supplied information is based on the organisation’s current specific requirements for self-insurance audits and licensing issues for the period covered by the report and may be highly diverse and variable in different years, depending on the nature of matters like implementation of OHS practices, administration issues, etc.

Common Problems

There are several typical problems that are common with annual returns.

1. Continued failure to provide the annual return within the pre-determined timeframe This is an indicator to the statutory regulator that the self-insured organisation lacks resources and/or capacity to manage the self-audit and related functions.
2. Inability to provide, or insufficient information to meet reporting criteria requirements. These issues may indicate that there is a lack of understanding or implementation in relation to OHS management systems.
3. The correlation between management review, objectives and targets and health and safety plans do not demonstrate a systemic approach. It’s naturally important that information regarding these interrelated issues is properly structured at each stage of the annual return.
4. Inability to conduct the necessary functions and information gathering required to supply necessary information. In order to schedule materials required for an annual return, adequate resources should be allocated to provide information of sufficient scope and depth to cover organisational activities and prove that self-insurers are able to meet the essential verification activity requirements.

Anomalies within the annual return (e.g. reduced audit cycles or mid-term additional verification activity, or information indicating non-conformance with statutory requirements) may indicate a requirement for additional oversight by the regulator.

These problems can be corrected by seeking advice from OHS management system consultants. It is strongly recommended that organisations which are experiencing any administrative difficulties or having doubts about how to approach information requirements ensure that these issues are clarified ASAP.

It’s also advisable to inform regulators of any difficulties involved in preparation of reports. The regulator’s sole objective is to ensure self-insurers are fully functional and able to comply with statutory requirements. Regulators can also provide useful support and guidance with procedural and statutory issues.