Psychological health and safety series #10: Creating an effective return-to-work and disability management policy

Credit: Adobe Stock/Nopadon.

In our ongoing series on psychological health and safety policies, we now address the return-to-work and disability management policy. This policy is crucial for supporting employees through the challenging back-to-work transition after an absence related to mental health conditions or other disabilities.

Why a person is off work is not as important as how their employer will help them get treatment and support while they are off work, and support them when they return to work.

A return-to-work and disability management policy establishes a structured, supportive framework for helping employees reintegrate into the workplace after an absence.

This policy serves multiple purposes. It supports employees’ recovery and well-being, facilitates a smooth and sustainable return to productivity and reduces the duration and impact of disability leaves. If not handled well, many aspects of a return to work can create significant distress for a worker returning after an extended absence. This policy recognizes the unique challenges in these situations and provides direction for appropriate accommodations and support.

While developing a return-to-work and disability management policy and the procedures and supports to execute it, consider the employee’s experience and define the standard of care expected. This includes the service level agreements for employees being paid when off work, procedures for accessing medical professionals, how employees are expected to or can pay for treatment (i.e., substance use disorder), how employees will be engaged by case workers (i.e., standard of care) and balancing a rapid return-to-work for fiscal reasons with readiness and health.

Before writing a policy, create the standards of care to ensure that humanity is considered. Too often, employees feel they are just numbers, and the only focus is on getting them back to work fast, regardless of their circumstances.

An effective policy balances the needs of returning employees with the organization’s operational requirements while maintaining a primary focus on sustainable recovery. Flexibility should also be built into the policy.

Recovery from a psychological health issue is rarely linear. Unlike many physical conditions, mental health recovery often involves fluctuations. The policy should allow for adjustments based on employees’ good and difficult days.

Stigma remains a significant barrier to returning to work. All aspects of the policy should consider measures to address potential stigma and ensure returning employees are not subjected to inappropriate questioning or assumptions. Though employers do not have a right to know why an employee is off work due to a disability, the accommodations and return to work must be written in a way that demonstrates clear guardrails for employers so they can increase the likelihood that an employee will have a safe and productive return to work.

Essential elements to include in a return-to-work and disability management policy are:

Statement of purpose and commitment: Begin with a clear declaration of the organization’s commitment to supporting employees through the return-to-work process. Emphasize that the policy aims to facilitate successful, sustainable returns while respecting individual needs and circumstances.
Definitions: While not all policies require definitions, this policy should be clear on terms that can be interpreted in many ways, depending on a person’s background or legislative frame of reference. Define key terms, including disability, accommodation examples, modified duties, gradual return, essential job functions, undue hardship, stay-at-work programs and functional abilities. These definitions create a shared understanding and support consistent application. Ensure the policy addresses how disability claims are facilitated and how employees can learn what their benefits cover for short- and long-term disability and workers’ compensation claims to set expectations around standards and what compensation and support they can expect for their condition or situation.
Early and ongoing intervention approach: Most employers understand that the longer a person is away from work, the harder and less likely it is for them to return, so the organization’s approach to early intervention should be detailed to avoid feelings of being rushed back. The policy should include expectations for maintaining appropriate contact during absence, initiating return-to-work planning at a proper time, defining the employees’, employers’ and insurance providers’ roles, and clarifying support resources and coverage amounts during an absence. The policy should define medical doctors’ roles regarding accommodations and the employer’s rights when they have concerns about medical accommodations, up to and including individual medical evaluations. Early education and supportive communication set the stage for successful interventions and facilitate return-to-work experiences.
Return-to-work planning process: Every employer is likely to adopt a different return-to-work process. The policy should outline a structured process for employees’ return, including an initial assessment of readiness to return, collaborative planning meeting procedures, and identification of potential barriers. Development of individualized return-to-work plans, accommodation determination, implementation timelines and monitoring and adjustment mechanisms should also be covered. Good policies will ensure the process is collaborative, involving the employee, supervisor, health professionals, unions and HR representatives as appropriate. Provide clarity on how the process will be evaluated, how employees can provide feedback on their experience and a support system for employees to report feeling the process is unfair or unjust.
Accommodation options: Employers have a duty to accommodate up to the point of undue hardship. It is helpful to provide examples of potential accommodations for mental health-related returns, such as gradual return schedules, modified duties or responsibilities, flexible work arrangements, environmental adjustments, additional supervision or support, technology aids, schedule modifications and workload adjustments. Emphasize that accommodations are individualized, based on specific needs.
- Note: Accommodations were covered in detail in the sixth article in this series.
Confidentiality and privacy: Confidentiality is critical for a successful return to work, especially when accommodations are involved. Physical and mental health issues need to have the same standard. Detail how medical information will be handled during the process, including information collection limitations, storage and protection measures, access restrictions, sharing limitations and consent requirements. This section should reassure employees that their privacy will be protected and that they are not required to provide medical information unrelated to their return or accommodation. Note what documents may be needed and how they should be transmitted to avoid accidental disclosure.
Monitoring and follow-up: The return-to-work process doesn’t end when an employee returns to the workplace. The policy must detail the process for monitoring the return’s success through regular check-in meeting schedules, progress evaluation metrics, adjustment procedures, duration of monitoring, transition to regular performance management and, in the case of substance-related issues, relapse prevention measures. This monitoring should be supportive rather than punitive.
Dispute resolution process: Not all return-to-work situations will be seen the same from the viewpoint of the employee who is away and that of the employer. It can be helpful to establish a transparent process for addressing concerns or disagreements with steps for raising concerns about the return process, mediation options, appeal procedures and external resources when needed. This process should emphasize collaborative problem-solving.
Return-to-work committee: Many employers establish a return-to-work committee and integrate its membership with the health and safety committee. If this is a consideration, ensure the committees’ roles and terms of reference are covered. These committees can help define the training and support that could be helpful for employees and leaders, based on the sector. The committees could also recommend support to help employees who are off work feel connected to the workplace.
Training: To ensure a return-to-work and disability management policy achieves its intended purpose, consider providing comprehensive training for managers and supervisors on supporting returning employees, particularly those with mental health conditions. Ensure the policy has clear service level agreements that speak to the standard of care and support expected for employees off work.
Prevention and stay-at-work measures. Not all conditions require employees to be absent from the workplace. Employers should include provisions for identifying and addressing issues before they lead to absence through early identification of struggling employees, preventive accommodation options, support resources for managing mental health challenges and stay-at-work programs as alternatives to leave. These measures recognize that prevention is preferable to remediation.

As with all the policies covered in this series, ensure that this policy’s goals are aligned with the other workplace psychological health and safety policies. You should also detail how the policy will be regularly reviewed and improved, following the Plan-Do-Check-Act framework discussed in the second article in this series.

A well-crafted return-to-work and disability management policy demonstrates an organization’s commitment to supporting employees through difficult transitions. Whether for physical or mental health absences, organizations are encouraged to look beyond fulfilling their legal obligations and create policies and processes with clear and compassionate reintegration that demonstrate they care about employees’ well-being by allowing them to remain in the workplace or return safely after an absence.

Want to learn more about psychological health and safety? Register for our Psychologically Safe Workplaces Summit on June 25, 2025.