07/05/2026
Following on from yesterday's post about the WA workers comp changes — here's the part that directly affects how we work as psychologists.
The expanded management action exclusion under the 2023 Act has a practical implication that I think deserves more attention in our field.
Previously, many of us were trained to document causation in relatively broad strokes: work was a significant contributing factor, the presentation is consistent with a stress-related injury, employment circumstances contributed materially. That framing was adequate under the old scheme.
Under the 2023 Act, it's no longer enough.
If a claim involves any element of performance management, grievance processes, disciplinary action, or workplace investigation — and many psychological injury claims do — the report now needs to actively engage with the management action exclusion. Not just document the symptoms, but address the question: was the employment factor that caused the psychological harm a reasonable administrative action by the employer, or was it something beyond that?
A concrete example:
Two clients, similar presentations, both develop PTSD following workplace events.
Client A: the injury arose from a traumatic incident on the job — a violent customer, a workplace accident, witnessing harm. Employment is clearly the significant contributing factor. No reasonable management action exclusion is relevant.
Client B: the injury arose after a protracted performance review process that the client experienced as hostile, demeaning, and disproportionate. They develop a major depressive episode and meet criteria for PTSD.
Under the 1981 Act, Client B's claim had a reasonable pathway. Under the 2023 Act, the question becomes: was that performance review process reasonable and proportionate, or was it harsh? The clinical report needs to address that — because if it doesn't, the insurer will use the exclusion and the claim stalls.
That's a clinical documentation task, not just a legal one. And from 1 July 2026, the eligibility requirements tighten further.
If you're doing this work and you're not sure whether your reports are addressing the right questions for the current Act, that's worth a conversation. The scheme has changed. Our documentation needs to reflect that.
Happy to discuss further — feel free to message me or drop a question below.