Staff Report #4
February 26, 2025
To All Commissioners
Re: 2024 Attendance and Disability Management Programs
Recommendation
That the report be NOTED and FILED.
Background
Absenteeism and disability management represent an onerous and costly challenge for all organizations. Success in meeting the challenge is dependent upon understanding and managing the many complexities and competing elements associated with absenteeism and disability management, including:
- trends and factors impacting the type and nature of illness leading to absenteeism. The global pandemic significantly affected employee attendance from 2020 to 2022; starting in 2023, a gradual return to more familiar attendance rates was observed.
- workplace demographics, e.g., aging workforce, availability and extent of health benefits, work/family issues.
- the organizational culture around mental health, disability, and absence, including encouraging employees to “stay home if they are unwell”.
The chart below lists London Transit’s four distinct tracking and managing lost time categories. The associated bullets represent the various programs and strategies currently in place to mitigate the lost time in each category. These programs and strategies comply with requisite legislation (e.g., AODA, OHRC, OHSA, ESA, etc.) and best practices and have been successful to varying degrees.
| Short Term Disability | • Return to Work Program via LTC and/or insurance carriers
• Employee Assistance Program & Peer Support Program • Employee Wellness / Mental Health Resiliency Training • Employer-sponsored functional abilities and independent medical evaluations • External support services (e.g., Ergonomist, Occupational Therapist, targeted counselling services, etc.) |
| Long Term Disability | • Return to Work Program via LTC and/or insurance carriers
• Employee Assistance Program & Peer Support Program • Employer-sponsored functional abilities and independent medical evaluations • External support services (e.g., Ergonomist, Occupational Therapist, targeted counselling services, etc.) • Long-Term Medical Placement Program |
| Work-Related Disability | • Health & Safety Annual Work Program
• Hazard Recognition & Injury Investigation Process • Return to Work Program via LTC and/or WSIB • Employee Assistance and Peer Support Programs • Employee Wellness / Mental Health Resiliency Training • Employer-sponsored functional abilities and independent medical evaluations • External support services (e.g., Ergonomist, Occupational Therapist, targeted counselling services, etc.) |
| Other Lost Time | • Attendance Management Program, including a dedicated medical stream of the program
• Culpable Absenteeism Program • Management Outreach to Employees • Employee Assistance and Peer Support Programs • Employee Wellness / Mental Health Resiliency Training • External support services (e.g., Ergonomist, Occupational Therapist, targeted counselling services, etc.) |
The table below sets out the total lost time by category accumulated for 2021 through 2024.
| Summary of All Lost Time – Average Days Per Employee 2021-2024 | |||||
| Year | Short Term Disability | Work-Related Disability | Long Term Disability | Other Lost Time | Total |
| 2021 | 8.9 | 1.8 | 1.7 | 6.6 | 19.0 |
| 2022 | 8.7 | 0.7 | 1.8 | 6.6 | 17.9 |
| 2023 | 7.9 | 0.6 | 1.1 | 7.2 | 16.8 |
| 2024 | 10.2 | 0.3 | 1.1 | 6.2 | 17.8 |
The average number of lost days per employee has remained consistent over the four year period. The distribution of this lost time across absence categories will be discussed further in the related sections of this report.
Administration continues to manage absenteeism and disability management through dynamic approaches, strategies, and evolving initiatives. Such ongoing initiatives include:
- greater emphasis on management responsibilities in terms of supporting London Transit’s Mental Health Strategy;
- encouraging employees to stay home if unwell, and reducing the stigma of same;
- London Transit’s Attendance Management Program, including a dedicated stream for chronic and/or acute medical conditions;
- ongoing communication to employees regarding related policies and programs consistent with practical and legal realities;
- analysis of incidents, causes of disability and absenteeism, as well as identification and implementation of initiatives to reduce same;
- effective integration of the duty to accommodate within the organization’s culture, relevant policies, and programs; and
- promoting a culture that encourages all parties to work cooperatively and effectively respond to collective attendance issues.
Disability Management
Disability management encompasses both compensable sickness and injury (i.e., job-related, and therefore subject to the Workplace Safety and Insurance Act) and non-compensable (i.e., non-job-related, and subject to the terms and conditions of London Transit’s wage replacement insurance program as provided under the current insurer, Desjardins Financial Services – DFS).
Disability management is an increasingly important and complex area to manage given the significant financial exposure associated with actual claims and the myriad of legislation (i.e., Workplace Safety and Insurance Act, Occupational Health and Safety Act, Ontario Human Rights Code, and the Employment Accessibility portion of the Integrated Accessibility Standards Regulation under the AODA). Additionally, the Collective Agreement includes provisions pertaining to the Return-to-Work program, which is critical to disability management.
London Transit’s Return to Work Program
A progressive Return to Work (RTW) program for both compensable and non-compensable disabilities is a key element of London Transit’s Disability Management Program. Employees who are off work are required to provide information on functional abilities from their attending healthcare practitioner. This information is compared to the physical and cognitive demands of the employees’ pre-disability positions. If the employee cannot be accommodated to return to their pre-disability position, temporary alternative work is explored. A range of value-added temporary alternative work, such as interior bus cleaning, bus stop audits, fare media audits, light-duty work in Fleet and Facilities and/or administrative areas, is considered. Costs and progress are monitored with the ultimate objective of returning the employee to full and normal duties.
The RTW program is critical in providing an alternative to employees remaining on income replacement benefits pending a return to full and normal duties. The program supports employees performing productive work (versus not working) even if it is outside their normal classification. The RTW program offers benefits to both the employee (e.g., reduces or eliminates lost earnings, helps reduce social isolation, helps maintain a sense of confidence and value, eases the transition back to regular duties) and the employer (e.g., retention of experienced employees, better productivity, effective management/containment of non-attendance cost).
The RTW program was implemented in response to the duty to accommodate disabled employees arising from the Ontario Human Rights Code. The program continues to evolve as case law in this area expands in terms of what is considered a reasonable and suitable accommodation for a disability. Managing these programs while complying with legislative requirements can be challenging. Three component parts define the RTW program:
- Modified work – any job or bundle of tasks within an employee’s pre-disability position which the employee may perform without the risk of re-injury to themselves or others. This work may consist of regular tasks that have been changed, redesigned, or physically modified. If necessary and if it can be reasonably accommodated, there may be a reduction in the time or volume of work performed.
- Work Hardening – involves tasks within an employee’s pre-disability position designed to condition the body and gradually improve strengths and tolerance to the point where an employee can once again be considered able to perform the essential duties in their pre-disability position.
- Alternate work – involves temporary short-term alternate work, which will be considered for employees who cannot perform the essential duties of their pre-disability position or cannot be accommodated by way of modified work and/or work hardening. Alternate work that may be available temporarily will not exceed 12 weeks, except with the approval of the General Manager in consultation with Human Resources.
There continues to be increased reliance on London Transit’s RTW program for both compensable and non-compensable disabilities, and it is anticipated that this trend will continue. The program’s annual costs in 2024 were $384,000, which is consistent with 2023.
Short-Term Disability (STD)
The following table summarizes the change in lost time associated with Short Term Disability (STD) claims over the past four years.
| Short-Term Disability and Employment Insurance (1) Lost Time 2021-2024 | ||||||||
| Year | Operations | Fleet & Facilities | Admin & Mgmt | Total | ||||
| Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | |
| 2021 | 5,316 | 10.4 | 447 | 3.7 | 507 | 7.1 | 6,270 | 8.9 |
| 2022 | 5,204 | 9.8 | 643 | 5.3 | 469 | 6.2 | 6,316 | 8.7 |
| 2023 | 4,416 | 7.6 | 1,453 | 12.4 | 171 | 2.4 | 5,770 | 7.9 |
| 2024 | 6,137 | 11.6 | 843 | 6.9 | 415 | 5.5 | 7,395 | 10.2 |
| (1) under the wage replacement program, employees have a period between eligibility for STD benefits and LTD benefits which they are eligible for Employment Insurance sick benefits | ||||||||
As with previous years, diseases of the skin, bones and skeletal muscles accounted for the greatest portion of approved STD claims in 2024. In addition, these claims represented the costliest category of short-term claims as they were longer in duration. Data also confirms that the distribution of overall STD claim costs has shifted to a higher age band (i.e., 50 and 64 years old) over the prior year.
The number of mental health STD claims remained stable in 2024; however, the data indicates that mental health claim duration is also trending higher. In 2024, mental health represented the second costliest category of all disabilities. The ability to seek appropriate and ongoing medical attention in the early stages of mental illness is imperative to facilitate a successful recovery and subsequent return to work. The mental health coverage offered through London Transit’s benefit plan was improved in 2023 to assist with access to appropriate resources. As a result of this change, there has been a dramatic and positive uptake in mental health resource usage. This additional support is expected to positively impact mental health in coming years. London Transit also continues to implement its Mental Health Strategy and related initiatives in an effort to support employees in maintaining good mental health.
Long-Term Disability (LTD)
The following table summarizes the change in lost time associated with Long Term Disability (LTD) claims over the past four years.
| Long-Term Disability (1) Lost Time 2021-2024 | ||||||||
| Year | Operations | Fleet & Facilities | Admin & Mgmt | Total | ||||
| Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | |
| 2021 | 558 | 1.1 | 205 | 1.7 | 407 | 5.7 | 1,170 | 1.7 |
| 2022 | 1,016 | 1.9 | – | – | 321 | 4.2 | 1,337 | 1.8 |
| 2023 | 425 | 0.8 | 320 | 2.7 | 37 | 0.5 | 782 | 1.1 |
| 2024 | 363 | 0.7 | 191 | 1.6 | 263 | 3.5 | 817 | 1.1 |
| (1) Cases, where COD has been approved and no likelihood of RTW are not included in the above Stats | ||||||||
The number of approved LTD claims and corresponding lost time has been relatively consistent over the four year period. When reviewing the average days per employee in the table above, consideration needs to be given to the relative size of the employee group; noting a long claim in a small group can significantly skew the average days per employee.
Compensable Injuries and Illness – Workplace Safety Insurance Board
London Transit’s Health and Safety Program has a clear mandate/objective to prevent work-related injuries, illnesses, and related absences. Notwithstanding the program and various initiatives, compensable injuries and illnesses do occur. Such claims must be promptly and properly investigated, processed, and monitored.
This begins with a feedback loop to the Joint Health and Safety Committees in terms of investigating and understanding the event giving rise to the injury or illness, taking preventative steps in the future, and where warranted, enlisting the assistance of an ergonomic consultant. It also includes active management of claims, including liaising with the Workplace Safety Insurance Board (WSIB) and appealing approved claims that administration feels are not compensable under the Act. In addition, London Transit utilizes an outside consultant for more complex claims management and representation when claims appeals are heard.
The following table summarizes the change in lost time associated with compensable injuries and illnesses over the past four years.
| Workplace Job-Related Injuries/Illness (1) Lost Time 2021-2024 | ||||||||
| Year | Operations | Fleet& Facilities | Admin & Mgmt | Total | ||||
| Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | |
| 2021 | 1,280 | 2.5 | 7 | 0.1 | – | – | 1,287 | 1.8 |
| 2022 | 474 | 0.9 | 19 | 0.2 | – | – | 493 | 0.7 |
| 2023 | 359 | 0.7 | 50 | 0.4 | – | – | 408 | 0.6 |
| 2024 | 117 | 0.2 | 67 | 0.5 | 21 | 0.3 | 205 | 0.3 |
| (1) Cases, where there is no likelihood of RTW are not included in the above stats | ||||||||
The employer has the most control over this area of lost time through safe work practices and procedures and the effective implementation of annual Joint Health and Safety Work Programs. In addition, the existence of a progressive RTW program and a significant investment in claims management, assessment, and prevention has helped keep these numbers down.
WSIB Premiums
Under WSIB’s Rate Framework Program, London Transit’s 2025 WSIB premium rate remains unchanged. The urban transit industry experienced a 5% reduction due to the overall performance of the rate group; unfortunately, London Transit was unable to realize the reduction primarily due to higher-than-normal claim costs associated with the 2019 and 2022 accident years.
In reviewing the claims from 2018 to 2023 the predominant claim cost drivers that have had the highest costs and the greatest impact on organizations premium rates are psychological disabilities arising from workplace violence and/or psychological impairment arising from being involved in or witness to a traumatic event. The majority of London Transit employees deal directly with customers on a daily basis; as such, ongoing training in conflict resolution, customer service, de-escalation techniques, and mental health resiliency are essential to help them manage these challenges while protecting their well-being.
Other Lost Time – (No Short-Term Disability, Long-Term Disability or WSIB Benefits are Payable)
Non-attendance, where benefits are not payable (deemed non-Short-Term Disability, Long Term Disability, WSIB and non-legislated) captures single-day illnesses and/or sporadic illnesses, non-job-related injuries, personal book-offs, absences without leave, late to work, etc. This category also includes lost time where benefit approval may be pending, denied and/or no further action is taken regarding STD, LTD, or WSIB claims. Absences in this category have a negative impact on the organization’s ability to provide service.
The following table summarizes the lost time associated with this category for the period of 2021 through 2024.
| Other Lost Time – No STD, LTD or WSIB Benefits Payable 2021-2024 | ||||||||
| Year | Operations | Fleet & Facilities | Admin & Mgmt | Total | ||||
| Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | Total Days | Avg. Per Employee | |
| 2021 | 3,968 | 7.8 | 283 | 2.3 | 393 | 5.5 | 4,644 | 6.6 |
| 2022 | 3,738 | 7.0 | 612 | 5.1 | 491 | 6.5 | 4,841 | 6.6 |
| 2023 | 3,934 | 7.2 | 1,053 | 9.0 | 299 | 4.3 | 5,286 | 7.2 |
| 2024 | 3,811 | 7.2 | 327 | 2.7 | 336 | 4.5 | 4,473 | 6.2 |
A high proportion of absences in this category are managed through a non-disciplinary and supportive Attendance Management Program (AMP) as “monitored absences”, separate and apart from the disability management process noted earlier in this report. Due to the pandemic, the AMP was paused from 2020 to 2022 and reintroduced in 2023. As expected, with the reintroduction of the AMP, a reduction of lost time in this category was observed in 2024. Other absences in this category are culpable (i.e., blameworthy) and subject to progressive discipline.
Leave of Absences (LOA) per Statue and/or Employment Contract/Agreements
A fifth category of lost time relates to legislatively protected leaves, where the employer has little or no control over lost time. Lost time in this area is monitored and utilized to determine complement levels required to meet daily service requirements. Over the past several years, the Ontario Government has expanded the definitions of approved Leaves of Absence, and as a result, lost time in this area has increased. Further, a new leave will come into effect in July 2025, which is part of Bill 229, the Working for Workers Six Act, 2024, passed into law in December 2024. The leave is one of the most extended provincial leaves in Canada. It is a job-protected 27-week Long Term Illness Leave for employees with serious medical conditions. It is anticipated that the new leave will impact this category of attendance going forward. There is limited influence organizations have in reducing such types of absences; therefore, lost time associated with same is not tracked in the above overall statistics.
The Cost of Non-Attendance
The cost of absenteeism is generally defined from three perspectives:
- productivity cost, i.e., impact on available productive hours, workload allocation issues and related opportunity costs addressing the allocation issues.
- administrative cost relating to staff time managing absences and the impacts of same; and
- financial costs relating to increased complement requirements, overtime costs and impact on employee benefit costs.
The annual cost associated with non-attendance, considering the above, ranges between $2.6 million and $3.5 million. The estimated cost accounts for approximately 5% of the $64.7 million annual personnel expenditure, including all earnings and employee benefit costs. Personnel costs account for approximately 57.4% of the $112.8 million total operating budget for conventional and specialized services.
Given the nature of the service provided, an average of approximately 80% of all non-attendance is managed via increased complement, with the balance being replaced as overtime or not replaced at all. The need to replace lost time defines the nature of public transit, i.e., providing scheduled service to customers, noting that most employees are operators responsible for delivering on-road service. The decision to replace non-attendance with the hiring of additional staff or replace as overtime is predicated upon an assessment of key inputs, namely:
- the nature and extent of service requirements, which are variable by time of day, day of week and time of year;
- the number, timing and duration of periods of absences;
- the impact on efforts and capacity to fill work assignments;
- efficiency considered work rules/requirements – the cost of hiring/employing replacement staff vs. applying overtime;
- the impact of legislative changes, and
- the impact on the quality of work life.
A complement assessment is undertaken on an annual basis to determine the appropriate Operator complement to ensure service requirements can be met while mitigating the extent of the need for personnel to be available to fill shifts for same day absences.
Conclusion
London Transit has clearly defined processes for managing lost time, and while trends in lost time experience are disruptive, they represent an opportunity to implement innovative and dynamic responses to mitigate the lost time going forward. London Transit will continue to ensure the appropriate programs and policies are in place to allow the employer to impact lost time while continuing to support employees positively. Where warranted, London Transit is also supported by industry experts in related fields and it is anticipated that this support will be required on a go-forward basis, as elements of the program are the subject to ongoing review and adjustment as necessary.
Recommended by:
Julie Hall, Manager of Human Resources
Joanne Galloway, Director of Human Resources
Concurred by:
Kelly S. Paleczny, General Manager