Roadmap for the Improvement of the Gatekeeper Act for employers

The Improvement of the Gatekeeper Act (Wet Verbetering Poortwachter) obliges employers to start reintegration immediately when an employee falls ill. As an employer, you are fully responsible for the process, the planning and the contact with the employee. Collaboration is mandatory: the employee must actively cooperate, but you are in control.

Below is a clear overview of the mandatory steps that you must take as an employer under the Gatekeeper Act.

Gatekeeper Act timeline: overview by week

This timeline shows all mandatory steps under the Improvement of the Gatekeeper Act at a glance, from the sick note to the WIA decision. Each step is explained below the table.

Week 1: report the illness to the arbodienst or company doctor

On the first day of absence, you register the sick employee with your occupational health service or company doctor (bedrijfsarts). This is the starting point of the reintegration process. At the same time, you start collecting information for the absence file. You are obliged to continue paying the salary throughout the entire process.

Week 2 - Keep in active contact

You stay in active contact with the employee. Ask regularly about their recovery and record it. Is there no response, or is the employee not cooperating? Then the UWV can impose sanctions. Is the employee still unfit for work after two weeks? Then schedule an appointment with the company doctor.

Week 4-5 - Advice from the company doctor

In the event of probable long-term absence, ask for a professional opinion from the company doctor around week 4/5. This forms the basis for the further approach.

Appointing a case manager (part of the Plan of Action)

Appoint a case manager who is responsible for the process and the communication. This is not a separate statutory milestone in week 5: you usually record the case manager in the Plan of Action (Plan van Aanpak, by week 8 at the latest). This can be a manager or an external party, such as a reintegration agency. The case manager monitors progress and coordinates the steps.

Week 6 - Problem analysis

The company doctor draws up a problem analysis (probleemanalyse). This sets out whether and how the employee can reintegrate. This can be within your organisation (Track 1), or with another employer (Track 2).

Week 8 - Plan of Action

Together with the employee, you draw up a Plan of Action (Plan van Aanpak). In it you set out concrete reintegration steps. The case manager supervises the implementation. Every 6 weeks you evaluate the plan and make adjustments where necessary.

Week 42 - Report to UWV

Has the employee not fully recovered after 42 weeks? Then report the long-term absence to the UWV no later than the first working day of week 42. Do this on time, otherwise you run the risk of a wage sanction (loonsanctie).

Week 52 - First-year evaluation

After one year of illness, the first-year evaluation (eerstejaarsevaluatie) takes place. Together you assess whether the reintegration is still on track. Use the UWV form for this. If necessary, you adjust the Plan of Action.

Week 87 - Start of the WIA application

In week 87, your employee receives an invitation to apply for a WIA benefit (WIA-uitkering). At this point you prepare the reintegration report and provide a copy to the employee.

Week 91 - Final evaluation

You and the employee fill in the Final Evaluation form (Eindevaluatie) together. This becomes part of the reintegration report.

Week 93 - Reintegration report complete

By week 93 at the latest, you must ensure that your employee has the complete reintegration report for the WIA application.

Week 104 - End of the waiting period and WIA decision

After 104 weeks of illness, the UWV assesses the application. Upon approval, the employment contract can end. Note: are your efforts insufficient? Then a wage sanction follows and you continue to pay up to one additional year of salary.

Two employers, the same schedule

At a professional services firm with around one hundred and ten employees, an employee was absent for a long period and, after several attempts to build up hours, could not fully resume his own role. From the outset the employer kept the problem analysis, the plan of action and the periodic evaluations up to date. When doubt arose around week 44 about a sustainable return, an occupational assessment was scheduled; around week 50 the conclusion was that there was insufficient sustainably suitable work within the organisation. The second track started shortly afterwards. At the later WIA claim both the internal efforts and the external labour market activities were therefore demonstrably present in the file, and the UWV assessed the reintegration efforts as sufficient.

At an employer in hospitality and catering with around eighty employees, attention stayed focused on a return within the organisation for a long time. The plan of action was in place, but evaluations were recorded only sparsely and the second track did not start directly after the occupational advice. Around week 68 a file review made clear that hardly any demonstrable external activities had been carried out. The second track started after all, and from that moment applications, labour market activities and evaluations were recorded systematically. The late start nevertheless remained visible in the reintegration report and weighed on the assessment.

Prevent mistakes, avoid sanctions

Many employers unknowingly make mistakes during the process:

• Plan of Action drawn up too late
• Absence file incomplete
• Case manager missing
• Track 2 started too late
• No expert advice obtained

These mistakes can lead to high costs and additional obligations. Expert guidance prevents that.

More information at the UWV

The official rules and current amounts or deadlines are available at the UWV Werkwijzer Poortwachter. These can change, so always check them at the source itself for a concrete situation.

Need help with the Gatekeeper process?

At Care4Careers we specialise in Track 2 programmes, absence counselling and career scans. We proactively think along with you, help you meet all obligations and guide your employee towards a new perspective.

• Less chance of wage sanctions
• Faster clarity
• Tailored work, not a standard programme

Want to know more? Schedule a no-obligation advisory conversation right away

Download the Gatekeeper roadmap here: Gatekeeper Act roadmap

It is essential for employers to follow the Improvement of the Gatekeeper Act roadmap so that second-track reintegration (re-integratie tweede spoor) can be carried out effectively.

Do you want to implement this within your organisation? Take a look at the page on second-track reintegration for employers.