Thursday · 12 December 2019

Sick leave in other countries

Posted by Call In Sick Tips Revealed · Filed under Sick Leave · Permalink

Sick pay looks natural from inside whichever system you grew up with, and comparing systems is the quickest way to see how many arbitrary choices are buried in it. The differences are not mainly about generosity. They are about who pays, who decides, and how the two are kept apart.

The main structural division is between schemes funded through social insurance and schemes carried by the employer. In an insurance model, contributions are collected centrally and a claim is assessed at arm's length, which keeps the assessment away from the person whose staffing is affected. In an employer-funded model, sick pay is a term of employment, and the employer is both payer and first assessor.

Waiting days and the shape they create

Many systems include unpaid or reduced-pay days at the start of an absence. The stated intention is to discourage very short absences; the observable effect is to lengthen them, since a person who has already lost the unpaid days has little reason to return before the paid portion begins. Systems without waiting days tend to record more absences and fewer long ones, which is a different picture rather than a worse one.

There is a similar effect around certification. Where clinical confirmation is required early, absences cluster at the length that makes obtaining it worthwhile. Where self-declaration covers the first several days, the distribution is smoother. In both cases the rule is shaping the behaviour at least as much as the illness is.

What travels and what does not

Comparisons are often used to argue for importing one feature of another country's system, which rarely works, because the features interact. A short waiting period is affordable where the state carries the cost and punishing where a small employer does. Generous entitlement paired with weak job protection produces different behaviour from the same entitlement paired with strong protection.

What does travel is the underlying design question, which every system answers somehow: how do you make the person best placed to judge whether someone can work, which is usually the person themselves, into a reliable reporter, without making the report worthless? Waiting days, certification, trigger points and return interviews are all answers to that one question, and none of them is obviously right.