Staff Report #4 – 2023 Attendance and Disability Management Programs

Staff Report #4

February 28, 2024

To All Commissioners

Re: 2023 Attendance and Disability Management Programs


That the report be NOTED and FILED.


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; in 2023, a gradual return to more familiar attendance rates has been 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 categories of tracking and managing lost time. The associated bullets represent the various programs and strategies currently in place to mitigate the lost time in each of the categories. While these programs and strategies have been successful to varying degrees over the years, the pandemic caused an unprecedented effect on lost time, specifically during 2020, 2021 and 2022.

Short Term Disability • Return to Work Program

• Employee Assistance Program & Peer Support Program

• Employee Wellness / Mental Health Resiliency Training

• Adjudication via third party for lost wages

Long Term Disability • Long Term Medical Placement

• Employee Assistance and Peer Support Programs

• Employee Wellness / Mental Health Resiliency Training

• Adjudication via third party for lost wages

Work-Related Disability • Health & Safety Annual Work Program

• Hazard Recognition & Injury Investigation Process

• Return to Work Program

• Employee Assistance and Peer Support Programs

• Employee Wellness / Mental Health Resiliency Training

• Adjudication via third party for lost wages

Other Lost Time • Attendance Management Program

• Culpable Absenteeism Program

• Management Outreach to Employees

• Employee Assistance and Peer Support Programs

• Employee Wellness / Mental Health Resiliency Training

• Absences are unpaid

In 2023, London Transit’s experience of lost time was more reminiscent of the years prior to the pandemic in most attendance categories. The table below sets out the total lost time by category accumulated for 2019 through 2023.

Summary of All Lost Time – Average Days Per Employee 2019-2023
Year Short Term Disability Work-Related Disability Long Term Disability Other Lost Time Total
2019 9.5 0.2 1.6 4.7 16.0
2020 12.2 0.2 2.9 5.4 20.8
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 7.1 16.6

The average lost days per employee has fallen by almost 4.2 days compared to 2020. Much of the improvement in overall lost time can be attributed to a less severe and prolonged impact of COVID-19 in 2023 compared to the prior years. The distribution of this lost time across absence categories has shifted throughout the past few years, primarily because of the pandemic and will be discussed further in the related sections in this report.

Aside from lost time associated with and/or affected by COVID-19, 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;
  • re-implementation of the London Transit’s Attendance Management Program as we transitioned away from the pandemic;
  • 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 employee’s pre-disability position’s physical and cognitive demands. 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 that it provides 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) 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. As such, 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 by 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 overall program’s annual costs in 2023 were $391,620, consistent with pre-pandemic costs.

Short-Term Disability (STD)

The following table summarizes the change in lost time associated with Short Term Disability (STD) claims over the past five years.

Short-Term Disability and Employment Insurance (1) Lost Time 2019-2023
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
2019 5,409 10.9 550 5.2 290 5.3 6,249 9.5
2020 7,019 14.3 803 6.3 549 8.0 8,371 12.2
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
(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

In 2023, short-term disability claims decreased by 34% compared to 2022. While a positive trend, the number of claims approved in 2023 is still 26% greater than that in 2019 (pre-pandemic). The overall decrease in 2023 is attributable to the waning of the pandemic and reflected in changes to both claim duration and cause from 2022 to 2023. From the insurance carrier, the number of short duration claims related to COVID-19 dropped from 161 in 2022 to 70 in 2023.

The number of mental health STD claims fell by 31% compared to 2022, suggesting improvements in employee’s ability to manage mental health at the early stages of onset. Contributing factors to this positive change may include the continued implementation of London Transit’s Mental Health Strategy, Mental Health Resiliency training rolled out to all employees at the onset of the pandemic, management’s increased focus on employee support, and restored and increased ability to obtain medical support.

However, the data indicates that mental health claim duration is trending higher with mental health representing the costliest category of all disabilities in the year 2023. 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. To assist with access to appropriate resources, the mental health coverage offered through London Transit’s benefit plan were recently improved, and it is expected that this additional support will positively impact mental health in coming years.

Long-Term Disability (LTD)

The following table summarizes the change in lost time associated with Long Term Disability (LTD) claims over the past five years.

Long-Term Disability (1) Lost Time 2019-2023
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
2019 840 1.7 192 1.8 1,032 1.6
2020 1,722 3.5 165 1.3 111 1.6 1,998 2.9
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
(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 years. Although, in 2023, lost time in this category was marginally lower than historically seen. During the pandemic, individuals experienced delays in their healthcare treatment, directly impacting the duration of claims. In mid to late 2022, healthcare services started to become more accessible again, and as such, the duration of some claims shortened as employees received appropriate medical treatment (e.g. surgeries, etc.), resulting in the ability to resume full and normal duties.

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 2019-2023
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
2019 135 0.3 25 0.2 160 0.2
2020 155 0.3 9 0.1 164 0.2
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
(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.

Notwithstanding the employer’s traditional control on these types of claims, in late 2020, the Province announced that a COVID-19 infection in the workplace was to be considered a WSIB claim and should be reported. As a result, there was an increase in approved WSIB claims in 2021 directly related to COVID-19. As the pandemic progressed, it became increasingly difficult for individuals to determine the source of contraction, and as a result, individuals filed their claims through short-term disability.

WSIB Premiums

Effective January 1, 2020, the WSIB NEER Program was replaced with a “Rate Framework Program”. The following provides a high-level summary of the “Rate Framework Program”, noting that until such time as the employer has further experience with this new program, the impact of same on annual costs will be difficult to estimate.

Under the Rate Framework Program, WSIB adjusts each employer’s premium rate in the fall of each year based on past experience and provides a projection as to whether the employer is trending upward or downward with their premium rate. Depending on their experience rating over a rolling six-year period, an employer’s premium rate will increase or decrease within the defined risk bands of the program.

London Transit’s premium rate for 2020 was $1.70 (per $100). In 2020, WSIB advised that all employer costs associated with COVID-19-related claims would not be allocated to the employer or at the “class level”. Instead, they would be allocated on a Schedule-wide basis. Further, WSIB advised that the premium rate for 2020 would not be subject to change in 2021. London Transit’s 2022 premium rate decreased to $1.52 and further decreased to $1.44 in 2023 based on overall positive performance.

At this time, London Transit’s premium rates are more favorable than the “class rates” for all years impacted, meaning that London Transit is performing better than the overall industry group. The performance is directly attributed to the number and cost of the claims in the last six years and the consistent application of London Transit’s RTW Program, details of which are outlined above.

Given that this program is relatively new, administration will continue to assess the potential impacts concerning the RTW Program, disability claims management, and the expanded active claim period from four to six years.

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) has risen over four years. Non-attendance in this category captures a variety of lost time, such as single day illnesses and/or sporadic illnesses, non-job-related injuries, book-off personals, absences without leave, late to work, etc. This category also includes lost time where benefit approval may be pending, denied and/or where no further action is taken, in terms of 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 2020 through 2023.

Other Lost Time – No STD, LTD or WSIB Benefits Payable 2019-2023
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
2019 1,883 3.8 275 2.6 13 0.2 2,171 3.3
2020 3,262 6.7 194 1.5 272 3.9 3,728 5.4
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 3,881 7.1 1,028 8.8 299 4.3 5,208 7.1

A high percentage 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 for 2020, 2021, and 2022 and reintroduced in 2023. The meetings for those who entered the AMP in 2023 are underway. It is, therefore, expected that lost time in this category may decrease in 2024. Other absences in this category are culpable (i.e. blameworthy) and subject to progressive discipline. There was a slight increase in this area in 2023 and further monitoring in this area in 2024 is required.

Leave of Absences (LOA) per Statute 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 this lost time. Lost time in this area is monitored and utilized for determining complement levels required to ensure daily service requirements can be met. Over the past six years the Ontario Government has expanded the definitions of approved Leaves of Absences and as the result, lost time in this area has increased. There is limited impact organizations can have in reducing such types of absences and as such lost time associated with same is not tracked in the above 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 $2.5 million and $3.0 million. The estimated cost accounts for approximately 5% of the $59.6 million in annual personnel expenditure, which includes all earnings and employee benefit costs. Personnel costs account for approximately 60.2% of the $99.0 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 the lost time defines the nature of public transit, i.e. providing scheduled service to customers noting most employees are Operators whose responsibility is to deliver 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 in an effort to determine the appropriate Operator complement to ensure service requirements can be met while at the same time mitigating the extent of the need for personnel to be available to fill shifts for same day absences.


Employers should see a return to more consistent and regular attendance as the impacts of the pandemic wane; however it is recognized that traditional work environments are going through a shift in dynamics, and London Transit will need to ensure the programs and policies in place provide the employer with the ability to impact lost time, while continuing to support employees positively.

Recommended by:

Julie Hall, Manager of Human Resources

Joanne Galloway, Director of Human Resources

Concurred by:

Kelly S. Paleczny, General Manager