An action is an action is an action.
The nonsense of the Ombudsman's position, as explained by Glen, is that everything 'done' by 'CASA' is done by individuals - either the CEO or employees or board members or whatever. An artificial person created by a sentence in a piece of legislation cannot magically take any 'action', except through human officers.
That's why the Ombudsman Act has the deeming provision I quoted.
Otherwise Pip Spence can just sit there saying that everyone in CASA, including her, is an individual, and therefore the Ombudsman can't investigate any complaint about any action any of them take.