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How work disability is managed in different countries

At a glance:
Management of workplace disability
A condition or function that leaves a person unable to do tasks that most other people can do.
 is an international issue. Countries around the world have adopted different ways of addressing the issue. Learning about different systems helps policy makers and employers implement better systems for management of return to work and work disability.
Assisting people with health problems to remain at work or return to work is an international issue. Countries adopt different approaches to deal with this issue.

Whilst there are many different systems in place around the world, many key factors are the same in each country. Communication, a professional approach, improvements in company and government systems, and encouraging workplaces to understand how to assist people remain in the workplace.
Companies generally respond to the regulations, laws, and differing financial incentives put in place in their country. A range of studies have demonstrated that return to work systems can be improved. This study reports on recent positive international trends including:

  • The certification of professionals who manage return to work
  • Improved training for people who manage return to work.
  • Tools to help employers assess their workplace disability strategies, including their corporate culture and effectiveness in work disability management
Most countries regulate and legislate employers to manage work disability. Whilst many different approaches are used internationally the authors note all countries have difficulty with the ‘gatekeeper' role. This role has been given to medical practitioners. It is universally agreed that treating practitioners
treating practitioner
A health professional that treats patients. In return to work this may include doctors, physiotherapists, chiropractors, osteopaths, psychologists, masseurs, etc.
 find it difficult to objectively and validly determine an individual's ability to return to work. Further, most treating practitioners do not have experience of workplaces.

A person's return to work will depend on their physical capacity, as well as their beliefs, attitudes and motivations. The authors note that around the world treating practitioners have difficulty balancing the physical and medical condition of the worker, knowledge of work duties, and making appropriate decisions about return to work.

Attending the worksite can be of great benefit in understanding the job, and working with all parties to identify duties that are suitable for return to work is a positive response.
Australia has a workplace based system for management of work injuries. This is not a universally adopted approach. Other countries have a government based approach, with incentives for hiring workers with a disability. Some rely on third parties to help the person find a new job. The Australian system of managing work injuries at the workplace has proved to be an effective approach.

This study advocates improved management programs that include training of return to work managers and corporate structures that thoroughly evaluate their systems for continuous improvement.

Tools to audit company return to work systems, plus training and accreditation of those managing return to work are useful ways of improving companies' management of return to work.
Original Article, Authors & Publication Details:
Donald E. Shrey1 and Norman C. Hursh2

Workplace Disability Management: International Trends and Perspectives. Journal of Occupational Rehabilitation 1999; 9(1):45.

1 Department of Physical Medicine and Rehabilitation, University of Cincinnati Medical Center, Cincinnati, Ohio.
2Department of Rehabilitation Counseling, Boston University, Boston, Massachusetts.
Background, Study Objectives, How It Was Done:
Management of workplace disability is an issue for many countries around the world. The authors of this paper had experience in dealing with worksite disability management in several countries. Their involvement had been through research, consultation, and training activities. The author ought to examine international trends in work site disability management policies and practices. This was part of a research project supported by the International Labor Organisation of the United Nations.

Participants in the study were from Australia, Canada, France, Germany, the Netherlands, New Zealand, Sweden, the United Kingdom, and the United States. The study information came from:

1.Questionnaires about

employment practices
job retention practices

2.Examining government policies and legislative framework that defined the roles and responsibilities and actions of:

the employers
insurance carriers in relation to return to work

The authors then categorised these systems, according to their analysis of the questionnaire information.
Study Findings:
The European approach is to regulate labour markets. France and Germany had a quota - levy system. All employers were required to fill 6% of the positions with disabled people, and if they do not do this they pay a compensatory levy for the positions that are not filled. The German system was set up to be a support system rather than a coercive regulation.

In North America and other English-speaking countries hiring, employment, and dismissal practices for individuals with disabilities were encouraged, however there was no statutory obligation to employee people with disabilities. Discrimination on the basis of disability was in contravention of the laws in most of these countries.

People with illnesses and disabilities were addressed under three different categories:

1. The person with work-related injuries and disabilities, i.e. workers compensation beneficiaries
2. Working people with non-occupational injuries, illnesses, or disabilities
3. Nonworking Persons with disabilities, such as people receiving other government assistance

The employers have varying levels of responsibility, depending upon the category.

In New Zealand individuals who are disabled through a non-work accident are covered under the National compensation program. In the United States private insurance companies and state workers compensation boards generally administer workplace injury benefits and services. In the United States and Canada there are separate health care and social security benefits available for workers who become injured or disabled out of work. Only workers injured on the job are covered by workers compensation schemes. This group generally receives a higher level of benefits.

European countries typically provided an integrated or universal insurance system.

The authors noted that it was a common theme amongst the countries surveyed for the primary motivation for work retention among employers to be legal or economic. Compliance
Compliance in a medical context refers to a patient adhering to their treatment program as advised by their doctor or other healthcare worker. In the context of return to work this usually means following the return to work plan.
 with regulations, reduced cost burden, and increase productivity were cited as key aspects of employers' management.

A regular problem amongst the various countries is the role of medical practitioners. All countries have appointed medical practitioners as the gatekeepers for return to work assessments. It is universally difficult for physicians to objectively and validly determine an individual's ability to return to work, many doctors do not have experience of workplaces.

Workplace based disability management programs are becoming more common. The authors indicated that many North American workplaces have implemented disability management programs to assist people with an injury or disability to return to the workplace. They cite programs that are managed cooperatively in consultation with workers, unions, management and rehabilitation
The process of helping a person back to their former abilities and quality of life (or as close as possible) after injury or a medical condition.
 providers. The authors refer to a range of international studies to demonstrate the effectiveness of disability management programs.

Canada's National Institute of Disability Management and Research was cited as an organisation developing strong international systems in return to work management. These include:

1. Disability management coordinator certificate training program.

Canada's, National Institute of Disability Management And Research (NIDMAR) is labour-management collaboration. It was established by the Disabled Forestry Workers Foundation of Canada in partnership with major employers and government.

The Institute developed a certificate program in disability management, covering:

Disability management theory and practice
Professional conduct
Legislation and benefit programs
Organisational behaviour
Intake and information systems management
Communication and problem solving
Labour management relations
Promotion and marketing
Rehabilitation management and returned to work planning

The program is competency-based and competencies are assessed through participation and grading of assignments.

The authors report on improvements in Canadian companies that have implemented disability management programs. Staff trained in return to work management achieved better outcomes. Workers compensation costs were reduced as a result of improved return to work management systems.

2. The worksite disability management audit

A thorough evaluation of a company's work disability management provides an understanding of the systems strengths and weaknesses. Identifying gaps in effective management allows a company to identify the steps needed to improve practices. A work disability audit tool has been developed by NIDMAR. Validation studies were conducted across a large number of work sites to check the effectiveness of the tool. Information is gathered and arranged under relevant categories, and organisations are rated on their effectiveness in each component. The authors of this paper used the audit tool for:

To work with companies to develop and implement return to work programs
Evaluation of return to work programs.

The strength of the tool is its consensus base. The consensus approach supports a partnership between labour and management. The authors describe the major components of the audit tool as:

a. Joint labour management support and empowerment. Work disability outcomes are improved when there is a partnership between employees and management. When both parties contribute as planners and coordinators to influence the process, the results are improved. The audit tool assesses the level of partnership.
b. Responsibility and accountability. Effective workplace disability management programs have superior levels of communication and coordination. The effectiveness often depends upon the responsibility, accountability, and authority, vested in the individual coordinating and overseeing the program. This is evaluated in the audit tool.
c. Corporate culture. Effective programs set appropriate expectations for managers, supervisors, and employees. They have adequate orientation and training regaining worksite disability management.

Other facets of the workplace disability program evaluated include:

Internal and external communications
Knowledge and skills of the disability management coordinator
Accidents prevention and safety
Occupational ergonomics
Health promotion and wellness
Injury, disability, and lost time patterns
Disability costs
Early intervention
A treatment or management program. Interventions often combine several approaches. In this field approaches include training in problem solving, adaptation of work duties, graded activity, an exercise and stretching program and pain relief.
 and worker
Workplace accommodations
Case management procedures

Other results:

The authors cite a range of case studies from the United States, Australia, and New Zealand showing significant improvement in return to work outcomes and compensation costs after a comprehensive management program was introduced. The authors did not go into detail about the case studies; the paper's focus was that substantial improvements are possible.
Disability management is an international issue. Countries tackle this issue with different legislation frameworks. Increasing international collaboration allows countries to learn from each other.

Development of practice standards and training for return to work managers improves outcomes. Collaboration between employees and employers underpin better systems. The authors consider management of workplace disability is a global issue and that improved work programs are achievable.
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