What the SIRA Return to Work Roadmap tells us about psychological injury and what it demands of providers
Michelle Klobas, Chief Commercial Officer
This is the final post in a nine blog series where Navigator Group will set out what we believe the current evidence tells us about psychosocial risk, recovery and workers' compensation, and where the open questions still are.
In 2025, SIRA published its Return to Work Roadmap 2026-28, a regulatory framework document that is, by any reading, a serious statement of system failure and the conditions required to address it.
The data it presents is not new to those working inside the NSW scheme. But seeing it assembled in a single regulatory document, attributed to identifiable structural causes and tied to explicit accountability expectations for providers, is significant. It sets out both a diagnosis and a set of demands. For organisations delivering psychological rehabilitation services in NSW, the implications are direct.
The data, plainly stated
The 13-week return to work rate across the NSW Workers Compensation Scheme has fallen from 88% in 2016-17 to 79% in 2024-25. SIRA estimates that this decline, sustained over nearly a decade, represents approximately 45,680 additional people not working who would have been working under previous performance levels. That is not a statistical abstraction, it is a cumulative human and economic failure of significant scale.
Within that decline, psychological injury claims are the most acute problem. They represent 10% of all claims in the scheme but account for 26% of total claim costs. The 13-week return to work rate for psychological injury is 40%, less than half the rate for non-psychological injury which sits at 85%. For workers under the Nominal Insurer, the largest insurer in the scheme by volume, the 13-week return to work rate for psychological claims is 34%.
These are not marginal variances, they are the signature of a system that does not have an adequate response to the clinical complexity of psychological injury.
What SIRA identifies as driving it
The Roadmap does not attribute poor psychological injury outcomes to a single cause. It identifies a set of interacting structural failures.
Early intervention practices across the scheme have deteriorated. Less than 25% of insurers are effectively assessing psychosocial risk in the early stages of a claim, which SIRA's own evidence framework identifies as the window in which most recovery-influencing factors are still modifiable. After 20 days off work, the probability of return drops to 70%. By 45 days, it is 50%. The early intervention failure is not a minor procedural gap. Instead, it is the mechanism by which manageable claims become complex ones.
The Roadmap also identifies that 70% of psychological injury claims are associated with preventable workplace factors such as work pressure, bullying and harassment. This means the majority of psychological injury claims in the NSW scheme are, by SIRA's own analysis, claims that should not have occurred. That figure warrants attention from employers, regulators and service providers alike.
Government sector employers are disproportionately represented throughout. They account for 49% of psychological injury claims while representing a significantly smaller proportion of the NSW workforce. Three large government agencies account for 95% of claims under the Treasury Managed Fund. TMF psychological claims have doubled over six years.
What the Roadmap demands of providers
The Roadmap is explicit about what it expects from workplace rehabilitation and health providers. SIRA states that it will promote evidence-based, high value intervention focused on recovery through work, clarify expectations and enhance capability, and hold Workplace Rehabilitation Providers accountable against their obligations through strengthened regulatory oversight.
That signals a broader shift across the sector toward demonstrated evidence and measurable outcomes, a shift Navigator's programs are already built around, given our position as a treatment provider delivering clinically structured, outcomes-monitored care.
The Roadmap calls for providers to deliver services that are earlier, more effectively targeted and demonstrably suited to the needs of people with complex claims.
For providers delivering psychological rehabilitation, that means being able to show that what they do is clinically warranted, matched to the individual's identified barriers and producing measurable outcomes. The 'reasonable and necessary' treatment standard being introduced through the NSW legislative reforms reinforces the same expectation from a different direction.
Primary psychological injury and the gaps the Roadmap exposes
The Roadmap's data on primary psychological injury, meaning claims where the primary diagnosis is a psychological condition rather than a physical one, describes a category of claim that the scheme has historically struggled to manage well. These claims have higher evidentiary thresholds at the point of acceptance, longer decision timelines and worse return to work outcomes than any other claim type in the scheme.
The Workers' Voice research confirms the worker experience of this: psychological injury claims are described as involving greater adversarialism, longer periods of uncertainty and less adequate communication than physical injury claims. The claim management process itself is a source of psychosocial harm for many workers with primary psychological presentations.
Against that backdrop, the question for a clinical provider is: what does an effective response to primary psychological injury actually look like? And how does it differ from the standard rehabilitation model that has produced a 40% return to work rate at 13 weeks?
What Navigator's Primary Psychological Program addresses
Navigator Group's Primary Psychological Program is designed specifically for workers whose primary claim is a psychological injury. It is not an adaptation of a physical rehabilitation model but a dedicated clinical response to the distinct presentation of this population.
The distinction matters because a worker with a primary psychological injury is navigating a different clinical reality than one with a physical injury and secondary psychological complications. Their relationship to the workplace is often more complex, the claim process itself is often a site of re-traumatisation and their capacity for work is variable in ways that do not map neatly onto standard certificate-of-capacity timescales. Their clinical needs include psychological stabilisation through evidence based psychological interventions, distress management and gradual re-engagement with functional activity in a sequence and at a pace that the standard claims timeline does not accommodate well.
The program draws on the same biopsychosocial framework that underpins the It Pays to Care matched care model, incorporating screening for psychosocial risk, structured assessment of individual barriers and matched evidence-based intervention, but applies it to the specific clinical complexity of primary psychological presentations. It operates with an explicit understanding of the claims environment in which workers are embedded and works in coordination with claims managers, treating practitioners and employers to manage the multiple stressors that accumulate within a psychological injury claim.
This same architecture underpins Navigator's broader program portfolio — the Navigator Support Program for psychosocial risk in physical injury claims, Active Recovery Clinics for coordinated musculoskeletal treatment, Early Intervention for pre-claim access, and the Chronic Injury Program for complex, long-term cases. Each is a distinct clinical response to a distinct presentation, but all are built on the same foundation: early identification, individualised assessment and matched, evidence-based care.
The SIRA Roadmap as a commissioning signal
Read alongside the data on psychological injury outcomes, the Roadmap's fourth pillar on RTW services and supports signals an intent to reshape how complex psychological claims are serviced within the scheme. The funding model for standard rehabilitation services was not designed for psychological injury. The referral pathways were not designed for psychological injury. The performance metrics built around 13-week return to work for a population where only 40% achieve that benchmark do not reflect what good looks like for this cohort.
The Roadmap creates a genuine opening for treatment models built specifically around psychological injury from the outset. Across our Primary Psychological Program and the rest of Navigator's programs, the same clinical architecture applies. Systematic screening, structured assessment and matched, evidence-based intervention. That's the standard we've built our programs around, and it's the direction we expect more of the sector to move toward as the evidence base becomes harder to ignore.
The scale of the problem and the scale of the response
The SIRA Roadmap is a document produced by a regulator under genuine pressur[MK1] e. Return to work rates have declined for nearly a decade. Costs are rising. Psychological injury claims are growing in volume, duration and cost. The NSW public sector, the scheme's largest employer cohort, is performing disproportionately poorly. SIRA is signalling that it intends to hold insurers, employers and providers to a higher standard of performance.
For Navigator, that context is familiar territory. The case for early, evidence-based, clinically specific support for workers with psychological injuries is one that the scheme data has supported for years. The Roadmap does not create that case, it instead validates it in regulatory language and attaches accountability expectations to it.
The gap between what is known and what is consistently delivered remains wide. Closing it requires providers who are not simply compliant with scheme requirements but genuinely capable of delivering the kind of clinically specific, outcomes-accountable care that the SIRA Roadmap is calling for.
Thank you for reading through Navigator Group’s blog series detailing what we believe the current evidence tells us about psychosocial risk, recovery and workers' compensation. We hope that you have found this series to be insightful, informative and helpful to your work in improving outcomes for injured people.
Source Materials:
Workers' Voice Solutions Series (Monash University, October 2025)
It Pays to Care: Early Systematic Psychosocial Matched Care - A Best Practice Guide (Wyatt, Garton, Nicholas & Iles, May 2025).
SIRA Return to Work Roadmap 2026-28. The SIRA Roadmap is a document produced by a regulator responding to a genuine and sustained problem.