CA ANZ supports a transparent, sustainable and fair ACC system and acknowledges the importance of striking a balance between the long-term sustainability of the ACC levy system, ensuring sufficient funds to meet future claim costs, and fairness to levy payers.

The levy rate consultation document discusses fairness in the context of levy setting and describes it, in essence, as follows: 

• Keeping levies as affordable as possible
• That levies stay as stable as possible over time
• Levy payers exposed to similar risks of injury pay the same levy, and 
• Levy payers in the same groupings pay for the costs of the claims without subsidisation by others whenever possible.

Additionally, CA ANZ believes that fairness as to the degree of costs borne by levy payers over time is important. It is noted that the motor vehicle and work accounts are currently in surplus funds and that these surpluses are proposed to be used to pay claim costs, reducing the amount required to be collected from levy payers.

While CA ANZ supports smoothing in the short term to keep levies as stable as possible, longer term smoothing raises equity issues. Similar issues arise with cross subsidisation of accounts (the earners account currently being underfunded). In terms of sustainability, it is important that the earners account is returned to full funding as soon as possible.

The overall performance of ACC, including cost savings in treatment, injury prevention, and investment returns, will also affect the system's sustainability and the amount required to be collected from levy payers across all accounts.

CA ANZ recommends that certain aspects of the proposals be reviewed and reconsidered.