Commerce Commission 111 Contact Amended Code 2023

Age Concern New Zealand welcomed the opportunity to submit comments on the draft Commission 111 Contact Amended Code 2023.

Overall, Age Concern New Zealand supports the majority of the proposed amendments to the Code. 

Age Concern New Zealand does not support the proposed amendment in Clause 37 that if a consumer moves premise, but remains with their provider, the provider may check the consumer’s status and potentially require them to re-apply if something material has changed.

Recommendations:

1. Develop a national awareness campaign

2.  Section E Requirement on providers to inform all consumers about options available for vulnerable consumers: Clause 7.4. We recommend that information about where consumers can refer a dispute or complaint under the Code is also required to be highly visible and in accessible formats on relevant websites

3. Section E Requirement on providers to inform all consumers about options available for vulnerable consumers: Clauses 6.6 and 31. We recommend that the Commission consider the impact of some older people lacking confidence using technology in determining what is an appropriate alternative means of accessing 111.

4. Section J Requirement on providers to disclose information. We recommend the Commission considers requiring providers to also disclose the length of time it takes for each application to be processed from the date it is received.