Drafting an employer sickness absence protocol

Drafting an employer sickness absence protocol means documenting what happens from the first sick report through reintegration, including when “track 2” (spoor 2) becomes relevant. In the Netherlands, the protocol should align with the Gatekeeper Improvement Act (Wet verbetering poortwachter) and make roles, deadlines, and communication steps unambiguous. A strong protocol reduces delays, supports consistent case management, and helps build a complete reintegration file for UWV review. This article provides a practical structure with an example focused on situations where returning to the original role is uncertain.

What should your absence protocol include when track 2 may apply?

Drafting an employer sickness absence protocol starts with a strict boundary: document the process, not medical content. Medical details belong with the occupational physician (bedrijfsarts) and should not be stored in HR notes or shared with managers. Your protocol should therefore focus on reporting lines, timelines, responsibilities, and which documents are created at each stage.

Drafting an employer sickness absence protocol also requires explicit alignment with statutory Gatekeeper steps that UWV expects to see reflected in the reintegration report. If “track 1” (reintegration within the employer) stalls, the protocol must explain when and how you escalate to track 2: reintegration towards suitable work with another employer.

Include at least the following building blocks:

• Sick reporting and availability: who is notified and how quickly?
• Role of the occupational physician/arboservice: when the first consult happens and how advice is followed up.
• File building: which meeting notes, agreements, and evaluations you record (without medical details).
• Gatekeeper milestones: problem analysis, plan van aanpak re-integratie, evaluations, and adjustments.
• Track 2 decision point: signals, responsibilities, and start criteria when internal return is not feasible.

Drafting an employer sickness absence protocol: steps and timelines

Drafting an employer sickness absence protocol becomes practical when you translate it into a clear timeline. The legal core is that employer and employee must actively work, reasonably and demonstrably, towards sustainable return to work. UWV reviews these efforts later during a WIA process; insufficient effort can lead to a wage sanction (extended wage continuation).

Define recurring milestones and attach each to: who does what, what output is expected, and how follow-up is ensured. This prevents the process from depending on one manager or a busy HR period.

• Week 1: sick report, registration, first contact, and process explanation to the employee.
• No later than week 6: occupational physician problem analysis (functional limitations and capabilities, not a diagnosis).
• No later than week 8: create and sign the plan van aanpak re-integratie.
• Ongoing: periodic progress meetings and documented agreements.
• Around the first year of absence: evaluate whether track 1 remains realistic and whether re-integratie tweede spoor is required.

If you work with fixed roles, formalize them. A casemanager verzuim, for example, monitors deadlines, schedules evaluations, and flags when track 2 risks starting too late. That improves continuity and file quality.

When do you start track 2, and how do you document the decision?

Drafting an employer sickness absence protocol is only complete when it clearly defines the trigger for track 2. Track 2 applies when returning to the original job or other suitable work within the organization is no longer feasible. “Suitable work” means work aligned with the employee’s functional capabilities, potentially with adjustments or training, and reasonably expected from the employer.

Add concrete signals that should trigger a track 2 assessment. Typical patterns include a persistent mismatch between capacity and available roles, or repeated stagnation despite adjustments. Document your internal reasoning: which roles were considered, what adaptations were tried, and why this does not lead to sustainable placement.

• The occupational physician indicates return to the original role is not expected in the foreseeable future.
• After investigation, sustainable suitable work within the organization is not available.
• Workplace or task adjustments do not result in structural build-up.
• There is a realistic expectation that opportunities exist outside the organization.

Also describe how you organize track 2 in practice: who initiates an external program, what cooperation is expected from the employee, and how progress is reviewed. It can be helpful to position a re-integratie tweede spoor traject as an explicit process step, rather than an ad-hoc measure.

Practical example and a checklist to prevent common mistakes

Drafting an employer sickness absence protocol is most useful when you add a realistic scenario. Example: an administrative employee is absent long-term. Over time, the occupational physician advises that prolonged screen work and high cognitive load are only possible to a limited extent. Internal exploration shows that available roles either have similar strain or require physical demands that also do not fit. In that case, starting track 2 in parallel with track 1 can be a logical and defensible step.

In such cases, UWV mainly wants to see structured action: deadlines met, suitable work explored, and the plan adjusted based on professional advice. A protocol keeps that line consistent even when managers or HR contacts change. Make sure your protocol reflects the practical requirements of the wet verbetering poortwachter steps and related documentation.

• Avoid medical details in emails and meeting notes; record agreements and availability only.
• Schedule fixed evaluation moments and define who owns follow-up.
• Define “suitable work” and how internal options are assessed.
• Make track 2 an explicit decision point with criteria and documentation requirements.
• Connect the protocol to pay and process rules around loondoorbetaling bij ziekte.

A concise takeaway: write the protocol so someone can execute it tomorrow without prior context. Clear roles, deadlines, and track 2 decision criteria improve speed, predictability, and file quality at the same time.