It is imperative that the Comcare scheme performs both efficiently and economically, whilst protecting the wellbeing and interests of the employee. Currently, it does not meet these requirements. Whilst some of the proposals made by the Department suggest, in principle, a move in the right direction, many of the proposals represent a further diminution in the rights of the injured claimant without providing any meaningful improvement in the economic viability of the scheme for the Commonwealth authority or licensee employers.

We note that, despite the Summary of Proposals and RIS purporting to be made in relation to the Safety, Rehabilitation and Compensation Amendment (Early and Effective Rehabilitation) Bill 2017 (2017 Bill) we have not been provided with a copy of the proposed 2017 Bill.

The Summary of Proposals provided is lacking in detail and clarity. This significantly impacts our ability to undertake adequate consideration of the issues.