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The EUROPEAN COMMISSION DIRECTORATE-GENERAL PERSONNEL AND ADMINISTRATION ADMIN. C |
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DRAFT
(23/01/06)
A
MANAGEMENT POLICY ON ABSENCE FOR MEDICAL REASONS AND INVALIDITY
Communication from Vice-President
S. Kallas
1.
Context
At present, about
25.000 active members of staff are working for the Commission in various
locations, most of them in
As a modern employer,
the Commission makes every effort to implement internally the standards set
through Community legislation in the employment area. In order to enhance staff
overall well-being, it appears now necessary to further develop the traditional
social policy into a more comprehensive and coordinated instrument, which takes
into account all the different psychosocial factors affecting active staff, and
focusing on prevention.
This Communication focuses on strategies aiming
at preventing absences for medical reasons and invalidity. Although available data shows that the level of
absences for medical reasons in the Commission is consistently below the
average level of the other European institutions, there is evidence that the
working environment affects some staff, which may experience sickness and eventually
retire on grounds of ill-health. Invalidity
is often the outcome of a sequence of apparently insignificant shorter absences
which have been overlooked. Although sickness is above all a private matter,
the Institution must — in the interests of its staff and its own organisation —
concern itself with sick leave and take steps where possible to improve the
situation, particularly with regard to emerging diseases with a work-related
cause, such as the diseases of psychological nature. The psychosocial working
environment encompasses a number of factors related to work organisation and
interpersonal relations at the workplace. Recent changes in the world of work
and the emergence of new psychosocial risks are the result of a changing
society. This is particularly reflected in changing attitudes to work and the
way of working, in changes in the respective roles of men and women and in the
increasing need to reconcile private and professional life.
In order to gauge the
extent of the problem and provide recommendations, a working group of the
Commission services was convened in 2003.
The working group produced a report containing guidelines on a comprehensive
and consistent policy for preventing sickness absences and invalidity.
The working group also
took into consideration the audit of the invalidity pension scheme of the European
institutions conducted in 2002 by the
Court of Auditors. Its report[1],
while stating that there were no irregularities, nonetheless noted a number of
shortcomings in the management of cases leading to invalidity. It pointed to lack of clarity regarding division
of responsibilities and coordination between departments, lack of computer
tools, approach too exclusively based on medical data. The working group agreed
with the analysis of the Court, by recognising the need:
- to
introduce a consistent policy for managing absences for medical reasons and
invalidity, focusing on prevention and rehabilitation; and
- to
introduce a monitoring and control system involving the management hierarchy;
This Communication is
based on the report of the working group, taking over and developing its main
conclusions. Its overall aim is to
integrate improved risk management into managing staff health and safety issues. A multidisciplinary approach is proposed, which places the emphasis on
prevention rather than on the subsequent resolution of existing problems and dovetails with the policy
for well-being in the work place.
2. a policy based on prevention
The aim of this policy is to reduce as much as
possible the number of work-related absences linked, in particular, to
psychological causes and demotivation.
The policy should be based on three
main pillars:
Prevention, through measures to promote the
conditions for a healthy workforce in a healthy workplace.
Assistance, through multidisciplinary,
individualized assistance and follow-up for active staff members in difficulty.
Rehabilitation and reintegration of staff after a
long illness or on invalidity.
2.1 Creating
the conditions for a healthy workforce in a healthy workplace.
In the last decade, mainly because
of technological developments and administrative reforms, changes in the
working environment have accelerated. Some staff experience difficulty, and
this has contributed to the fact that the number of departures on invalidity
has increased in the period 2000-2003 prior to the adoption of new Staff
regulations. Since 2003 however the
number of invalidity is rapidly declining[2]. Statistics show that almost half the invalidity
cases in the Commission have a major psychological component, 20% are linked to
musculoskeletal origin, and 15% to cardiovascular problems. The sequence of
events leading to invalidity needs to be examined more closely, in an attempt
to establish risk profiles in particular work environments. More information‑gathering
and analyses is needed in order to enable the adoption of a systematic preventive
approach, and to support
the identification of risk situations. The Commission services have launched an
external evaluation of the medical services which will provide data in this
sense (see chapter 5.1).
In line with the communication on “A new Community strategy on health and safety at work[3]”, in order to avoid the development of scenarios
that lead to absence, policies will
have to be introduced which increase job satisfaction, reduce the causes of
stress, and eliminate every type of violence (physical and psychological) in
the workplace.
Working conditions, including the
scope for better reconciling professional and family life, also influence
psychological balance and motivation. The reform has introduced a number of measures (modernisation of
parental and family leave, improved access to part‑time working, social
policy, etc.) which should have a positive effect in the medium term in favour
of reconciling professional and family life.
Job satisfaction is a key factor in maintaining a good state of health. While
it is true that the official’s own attitude and perception remains essential to
maintaining his/her motivation, there are other important factors which include:
training, workload distribution, appraisal, career development, and the
physical and human working environment. Relations with colleagues and immediate
superiors are key to a successful progressive adaptation to the workplace.
Raising the management’s awareness
of this aspect of prevention is fundamental, as highlighted in the Commission’s
reform programme. This will be achieved also through ad hoc conferences and
training programmes. When changed behaviour is observed, early direct action
must be taken without waiting for the problem to worsen and lead to
psycho-somatic conditions. Such early action should be undertaken with the support
of the social network (Social Interface Network[4]) established
in the DGs.
The development of a policy on
well-being at work and its Multi-Annual Action Plan[5] will provide a framework to support
staff by approaching the issues from different angles and will constitute an
important basis for prevention, with the cooperation of the relevant responsible
units throughout the Commission (see decision on well-being at work).
The Memorandum to the Commission of
New technologies and work intensification have
created other occupational risks, which need to be prevented by developing a
more proactive health and safety policy in the work‑environment. A draft decision on the
implementation of a harmonized policy for health and safety at work for all Commission
staff, among other safety measures, addresses this particular problem and is also
an integrated part of the Multi - Annual Action Plan on Well-being.
2.2. Multidisciplinary
individualized assistance and follow-up for active staff members in difficulty.
In addition to preventive measures for all
officials, there should be measures targeted at officials whose repeated
absences threaten to lead gradually to invalidity. This will require improved
coordination between the departments involved, clearer separation of medical
control from occupational medicine, and the establishment of an independent
structure for assisting and monitoring officials in difficulty and undergoing
rehabilitation.
An ad hoc multidisciplinary
structure, COMPASS (Coordination
of medical, psychological, administrative and social support), will be created to coordinate an
early warning system for officials in difficulty, on the basis of inputs coming
from different services These should
include the social service, psychology service, human resources (HR) units, the
Medical Service, the medical control staff, the Central Career Guidance Service (SCOP), the Commission mediator and
the official’s direct superiors. The secretariat should identify the difficult
cases, support staff and if appropriate, organize their return to work after a
long term absence due to illness. To obtain the necessary synergy between proactive
and preventive measures, specialized personnel[8] will need to work together on a
professional assessment of the situation, based on medical, social and
administrative criteria. The aim should be to find the most suitable individual
solution for the official in difficulty, within the existing structure of the
Institution. The COMPASS secretariat will therefore convene ad hoc meetings of
relevant specialized personnel to discuss individual cases at the request of HR
department or others and issue recommendations for action to be taken by the
AIPN. Ideally COMPASS should deal with all cases needing support including
those in Delegations.
If necessary and only on basis of
the recommendations of the COMPASS, the Director-General of DG Admin shall have
the authority to facilitate a change of post, and SCOP will be used to assist
in the implementation of decisions taken.
The Head of Human Resources in the
DG will also have to be involved. He/she
may be required to assist in adapting the work place and, if specifically so advised
by the experts who have access to details of the case, in obtaining a change of
post for the official concerned.
In combining the involvement of
specialized professionals with a multidisciplinary approach, the intention is
to make the COMPASS a One-Stop-Shop.
2.3 Reintegration
of staff after long-term absence and invalidity.
Returning to work after a long absence or after
invalidity entails major administrative obstacles which need to be overcome, as
well as difficulties in adapting for the staff member involved. Through its
multidisciplinary structure and active involvement in the direct work
environment, it is expected that COMPASS will be able to anticipate the
administrative difficulties and focus on the possibilities available in order
to facilitate the reintegration (with the assistance of SCOP) process of the
official returning to work.
Staff returning to work from sick leave or
invalidity could be assigned a mentor. A
network of mentors to support those colleagues could be created on the model of
what has been done with the confidential counsellors network (réseau de
personnes de confiance) for moral harassment.
They would be volunteers, receive specific training, exchange good
practices and report to COMPASS secretariat.
Staff returning to work from long-term absence
or invalidity should be granted preferential access to specific training
courses to get them restarted.
The current Staff Regulations recognise
only one level of invalidity[9], and some officials are placed on invalidity
although their health condition would enable them to work part‑time or in
a less demanding post. It is worth examining the possibility of applying part-time,
flexi-time or other modern working arrangements introduced by the Reform.
Unlike medical part time, which is granted for a very limited period – maximum
3 months with full salary – in order to facilitate a return to work, these
new arrangements would offer the official the chance of continuing to work at a
different place for a longer period, and give him of her long-term prospects.
Whilst no spectacular results can be expected
through the implementation of this new approach in the short-term, a number of improvements should be noticeable
within the medium to long-term. For this reason, we suggest carrying out a
first interim re-assessment by 2008 and drafting an overall report on the
implementation of this approach by 2010.
3. tools for the implementation of the policy
As part of the reform, DG ADMIN undertook
to develop a new integrated personnel management system (Sysper2), which will
integrate all data relevant to an official. Data from this system could
facilitate the management of difficult situations and assist COMPASS’
secretariat in setting criteria to identify officials in difficulty. One
approach could be to establish risk profiles and an early warning system
drawing attention to situations which should then actually be assessed on the
ground.
A critical first step is to ensure that
absences are duly recorded, consistently and in a harmonised manner. Since the
medical certificate is the main source of information, a priority action is to
improve its quality e.g. by developing a standardised model which officials and
their doctors would be asked to use.
Clearly, use of all the tools mentioned must be
in full compliance with the rules on personal data protection[10] (namely when data is extracted from SYSPER 2
only limited and pertinent data will be retrieved in the interest of the
person).
4. Application and
valorisation of the new staff regulations
Several changes in the Staff
Regulations introduced under the reform in order to provide better working
conditions, also contribute to preventing absences. Other changes have
addressed the financial conditions of invalidity and certain procedural rules
relating to medical controls, and these need to be better implemented.
It appears that, with invalidity now
imposing some financial disadvantage compared to the pre-reform situation, some
people might seek to offset that loss through paid work carried out outside the
European Commission. It is necessary to question whether such work is
consistent with invalidity[11].
As part of the new rehabilitation policy, the Institution needs to
examine the option of not authorizing anyone on invalidity to perform work elsewhere,
other than in very exceptional cases.
At present, the invalidity procedure
may be launched on the Institution’s initiative only if the official records
365 days of absence over a 3-year period. In cases of manifestly irreversible
incapacity, this period should be shortened in order to assess the situation paying
regard both to the official’s and the relevant Commission department’s needs. In
such a case, it would be up to the Medical Service to take the initiative and
request that an invalidity procedure be launched earlier. In addition,
administrative measures will have to be improved in order to accelerate the
procedure once it is decided to start it.
5. A Medical Service prepared to face new
challenges
In addition to the individualized assistance to staff members in
difficulty described above, and with the objective to better implement
well-being and prevention policies through improved services, the following
measures are envisaged:
5.1 Evaluation of the medical services.
In order to identify how the Commission’s
Medical Service can be better equipped to face the new challenges of
occupational medicine, in particular the increase of psychosocial illnesses, an
evaluation of the Medical Services is currently ongoing. An improved approach will
need to focus on examining existing procedures and developing preventive
strategies in synergy with the policy on well-being and with the creation of
COMPASS, so as to coordinate with other relevant actors in the field of
prevention. Special efforts and targeted campaigns to educate and raise
awareness about health issues will need to be planned. Following the results of
this on-going evaluation, a final report and an Action Plan will be presented
to the
5.2 Improving the organisation of medical
controls and their separation from preventive medicine.
The medical officer responsible for control is
required to assess, in complete independence, whether the sickness-related
absence is justified. Such checks must relate to the absence at the time of the
examination, and not to the preceding period. It is important that these examinations
be conducted in a more systematic way, particularly with a view to the
Institution’s duty to deal promptly and carefully with its officials (its “obligation
de solicitude” or duty of care – special attention should be given to officials
living alone), and should – as far as possible – take place at the official’s
home; Clear rules on the nature, frequency and reporting of such controls will
be drawn up and communicated to staff. The qualified person in the social
service could be asked to intervene if the conclusion is that additional aid
and further assessment is necessary. The controlling medical officer’s role must be
separate from that of the medical officer responsible for occupational
medicine, although a certain amount of cooperation regarding the officials past
medical history is desirable, but only as far as it is relevant for that
specific absence. As part of the present evaluation of the
Medical Service, an overall review of the control system of absences is planned.
This training should also be offered to staff working in HR units and in SCOP.
The foreseen development of a
psychosocial medical sector in the medical service should allow specifically
qualified doctors to deal with officials displaying psychological disorders.
5.3 Better cooperation between Human Resources
Managers and the Medical Service.
Although absence for medical reasons is clearly
linked to issues to be examined by the Medical Service, improved management of absences must rely on the involvement of the human
resources managers. Management should be made aware of its role and
responsibilities and provided with the necessary guidance and a specific centrally-organised training course on
absences – for sickness or other reasons – and invalidity. Such course could be developed around the
following key elements: understanding of rules and procedures; role of the
manager in preventing and managing absences; conducting an interview with staff
about their absence; keeping in touch with long-term absentees; managing the
return to work process; conducting a back to work interview; workplace
management of alcoholism and other addictions.
5.4 Pre-assignment health check and annual
check-up (visite d’embauche et visite annuelle).
As one of its core tasks, the Medical Service
is responsible for health check of new staff before they are assigned to a
Commission post. With reference to the changed work
environment and demands on staff, it is recommended that psychological tests (such
as for example tests for emotional intelligence, flexibility, and resistance to
frustration), should be performed at an early stage, together with tests for
capacity to adapt to a multicultural and expatriates’ environment. Such an
evaluation should take place ideally at the interview preliminary to
recruitment, it should be always be conducted and evaluated by a specialist
(work psychologist –psychologue du travail) and should not be eliminatory.
Although annual medical check-ups
are mandatory[12], evidence shows that only 30% of
the staff attends.
The objective is to increase the percentage of
staff attending the annual medical check up from 30% to 100% over four years.
In order to achieve this objective, additional human and financial resources
are necessary. Given the budgetary and operational constraints, this increase
is spread over four years, namely 2006-2009, as detailed in the attached
financial statement. As from 2010, the recurrent annual expenditure in this
area will amount to 2.7M€ (in addition to the current Medical Service budget).
5.5 Improving Workstation
environment.
This action, which will have to be
developed through cooperation between the medical services and the health and safety
services, should have two main objectives:
-
improving workstation
ergonomics: the specific information campaigns to date have proven limited due
to lack of specialised medical staff. The Medical Services will have to improve
their educational capacity by all appropriate means, including demonstrations,
with emphasis on newly‑available technological equipment. Training
sessions must also be held and offered to officials.
-
increasing
inspection by the Medical Service of office working conditions under a
programme of regular visits. Special attention should be given to avoiding,
preventing and evaluating risks at work.[13]
The medical services will work in
close collaboration with DG DIGIT in the area of IT-equipment procurement and
will consult DG DIGIT before recommending the usage and/or acquisition of
IT-equipment.
6.
Evaluation
The new policy to prevent absences
for medical reasons and invalidity constitutes an important element of the Commission’s
well-being policy. It has to be part of
a continuous process, with clear objectives which needs to be regularly evaluated
and adapted. Progress in its implementation will have to be carefully monitored.
The following aspects need be taken into particular account:
° the
extent to which the new policy can be integrated within the existing management
system
° the
extent to which the short, medium and long-term indicators are achieved.
In the short term, a better
pre-assignment assessment should be introduced, at the selection stage. Another short-term objective is to increase
the number of annual check-ups.
In the medium term, the objective is
to reduce the number of cases of invalidity due to psychological reasons.
In the long term, the objective is
to reduce the number of absences on medical reasons.
° the
extent to which statistics can be used to indicate significant changes resulting
from the policy
A first evaluation report will be established half way through the term of the present Commission
(2007-2008); the final report will be ready by 2010.
