Memorandum submitted by the Association
of British Insurers
Vocational Rehabilitation and Occupational Health
are different but extremely valuable tools in prevention, promotion,
and improvement in the health of the working population.
At present, UK employers don't make enough provision
for their employees' health. This is due to both economic reasons,
and a lack of understanding and information. A significant increase
in employee health interventions would make a huge difference
to the wellbeing of individuals, businesses, and the UK as a whole.
The Health & Safety Executive and Commission
should have a duty to encourage and promote the growth of vocational
rehabilitation in all sizes of business in the UK. They should
also actively promote other occupational health interventions,
ensuring that both preventative and reactive approaches to good
health are taken.
The Association of British Insurers (ABI) represents
nearly 400 member companies, which between them provide 94% of
the UK's domestic insurance. It works on behalf of the UK insurance
industry to keep standards high and to make its voice heard.
1. There is a great deal of evidence from
around the world about the benefits of vocational rehabilitation
(VR) in returning people to work quickly and cost effectively.
While these results cannot always be directly translated to the
UK, due to the difference in systems of employer liability and
workers' compensation, it is clearly the case that VR could make
a very significant contribution to improving health, productivity,
economic performance, and lessening the burden on the State of
ill health and workplace absence.
2. At present too many people leave the
workplace permanently due to ill health or injury. There are a
number of reasons for this. The NHS does not recognise work as
a contributor to good health, as identified by Waddell & Burton
in their 2006 report, Is work good for your health and wellbeing?
GPs are often unaware of the importance of work.
Employees are too often repeatedly signed off, and end up "convalescing"
at home while either waiting for further treatment or recovering
from an injury. This can lead to isolation, decline in self-confidence
and worsening of mental or physical conditions. Often they will
never return to work, and instead move onto benefits, leading
in part to the 2.64million people now on Incapacity Benefit.
3. A further reason for the UK's sub-optimal
performance is the lack of understanding and engagement from the
employer. Few employers make provision for preventative healthcare,
nor provide those interventions that could get employees back
to work quickly. There are a number of causes of this, including
lack of understanding of the costs of ill health to their business,
lack of knowledge of the interventions that are available, and
the belief that such provision would be too expensive.
4. VR encompasses a series of measures that
can help a person get back into work after an injury or illness.
Among these are health advice, career counselling, workplace adjustments,
goal setting, assessment and appraisal, support for self management
of conditions, case management, information about and access to
rehabilitation technology, among others.
VR differs from medical rehabilitation as it focuses on the individual
and their work, rather than the individual and their condition.
VR can enable individuals to go back to work while they are undergoing
medical treatments, and it encourages them to get back to a form
of normality, rather than slowly withdrawing from day to day life
as many who stop working through illness or injury do now.
5. VR is often provided by insurers as part
of the Employers Liability insurance, or other policies, such
as Group Income Protection. This can cover employees for injuries
or illness suffered as part of their job. Insurers report that
this can result in speeding up of notification of claims under
Employers Liability insurance, and can accelerate return to work.
6. There are currently a number of barriers
to the extension of the availability of VR. SMEs are less likely
to show interest in, or have knowledge of, the potential of VR,
and often believe that it won't make any difference to them, due
to their size. Furthermore, the current tax system means that
offering VR to people who suffer illness or an injury away from
the workplace will be taxed as a benefit in kind. 175 million
days per year are lost as a result of ill health in total, with
HSE figures showing that 30 million of these are illnesses or
injuries suffered at or caused by work. HSE figures show that
1.3 days per worker were lost in 2005-06 as a result of work-related
ill health and workplace injuries.
However, the total days lost per worker (for all types of absence)
was found to be 8.4 days in 2006, in the Chartered Institute of
Personnel Development study,
and seven days per employee in the CBI/Axa survey.
These figures illustrate the importance of not just concentrating
on the injuries and illnesses that happen at work.
7. Occupational Health (OH) is a term generally
used to cover those interventions that are largely preventative
in nature. Among the measures that fall under OH are: the provision
of OH doctors and/or nurses; health and safety professionals;
occupational hygienists; OH technicians; ergonomics; physiotherapy;
Employee Assistance Programmes (EAPs); health surveillance.
Comprehensive absence management systems also fall into OH, and
these can provide extremely positive impacts on levels of absence,
and improved rates of return to work.
8. Insurers can provide occupational health
services as part of Private Medical Insurance packages, as well
as other insurance products, recognising that the preventative
elements of good OH can lead to a reduction in incidences of ill
health, both caused by work, and that in society at large.
9. The importance of OH services are their
preventative character. By carrying out screenings, checks, conversations,
and practical contributions to the day to day business activity,
OH makes it easier to avoid the accidents, the injuries and the
illnesses that can arise in the workplace. The outsourcing of
many human resources functions to remote locations by many businesses
has contributed to the difficulty in having an active OH presence
in more companies.
10. Given the pressures on the NHS to provide
a large range of universal services, it is unrealistic to expect
it to prioritise all that we may wish for, and even more unrealistic
to believe that it can know and understand the needs of all the
UK's 29 million employees. The most effective way to improve employee
health would be to encourage and incentivise businesses to make
more provision for the health of their own employees, regardless
of their sector or the size. An individual relationship between
an employer and its VR or OH provider is an extremely effective
way of ensuring that the exact nature of the work undertaken by
the employee can be understood, and vocational rehabilitation
can take place.
11. Most healthcare professionals are understandably
focused on the medical needs of their patients. It would need
major reforms to the training of GPs, nurses and other healthcare
professionals to change this. VR and OH professionals are focused
on the interaction between the individual and their work, whether
that be in ensuring that the workplace is properly adapted to
the individual, that good procedures are in place, that the wellbeing
of the employee is being monitored, or that screening is in place
for any typical conditions that may arise.
12. The common goal, to reduce the frequency
and length of absences, improving employee health and wellbeing,
improving business performance, reducing the burden on the state
of ill health, is most likely to be achieved through encouraging
employers to understand the costs and causes of absence in their
own business, and take appropriate steps.
13. The ABI is a member of the Vocational
Rehabilitation Task Group, set up by the DWP in 2007 to address
a number of factors obstructing better provision of VR.
The ABI is currently looking at the incentives and disincentives
existing in the VR market, and will make recommendations in the
first quarter of 2008. The task group is also looking at good
practice in VR, and how the benefits can be communicated to employers
through advice and guidance.
14. The ABI supports the amendment of the
Health and Safety at Work Act to give the HSE a statutory duty
to promote rehabilitation, and to promote good practice when illness
and injuries occur, including producing return to work plans by
employers. HSE is well placed to encourage employers to make such
provision, interacting as it does with many businesses which are
prone to higher risks in the workplace. The ABI finds that many
employers are not knowledgeable about the impact that VR can make,
and HSE could reinforce the messages coming from elsewhere.
15. The HSE should work more closely with
the NHS to ensure that its services are better aligned with the
needs of UK employers. HSE PSA targets to reduce the number of
days lost due to injuries and illness could be shared with the
16. The HSE produces some very valuable
and useful guidance on managing specific types of illness in the
workplace, especially mental health, and these should be promoted
17. Delays in reporting claims to insurers
can impair the operation of the Employers' Liability (EL) insurance
market. On average, it takes 400 days to report a claim to an
insurer. This increases costs significantly, makes it more difficult
to provide effective rehabilitation, and can contribute to higher
costs for EL insurance itself. The HSE should examine the RIDDOR
system of reporting injuries to see if it can be used to accelerate
the notification of claims, flag up potential claims, and speed
up VR, and potentially speed up the return to work, improving
outcomes for all involved.
Association of British Insurers
61 Is Work Good for your health and wellbeing?
Waddell & Burton, TSO, 2006. Back
Occupational Health 2008, making the business case. Thornbury/Workplace
Self-reported work-related illness and workplace injuries in
2005-06: results from the Labour Force Survey. HSE/National
Statistics. July 2007. Back
Absence Management, CIPD, 2007. Back
Attending to Absence, CBI/Axa, May 2007. Back
Thornbury/Workplace Law. Back