Audit of Long-Term Sick Leave

Final Report: February 2014

This report has been reviewed in consideration of the Access to Information and Privacy Acts. The published information is UNCLASSIFIED.

Questions and Answers

Table of contents

Acronyms and abbreviations

CHRO
Chief Human Resources Officer
GRW
Graduated Return to Work
HRMIS
Human Resources Management Information System
HSO
Health Services Officer
ISC
Integrated Service Committee
NISC
National Integrated Service Committee
RBAP
Risk-Based Audit Plan
RCMP
Royal Canadian Mounted Police
TEAM
Total Expenditure Asset Management (Departmental Financial System)

Executive summary

The Royal Canadian Mounted Police (RCMP) conducted an audit to assess the management of long-term sick leave. The audit focussed on the policy knowledge and awareness of Commanders, who are responsible for managing members on long-term sick leave, and the support provided by key personnel.

The results of the audit determined that there is a need for Commanders to fully exercise their responsibilities in order to ensure that accurate and timely information pertaining to long-term sick leave is available for decision making. In addition, performance measures should be established and monitoring and oversight activities need to be enhanced, to assist in the effective management of long-term sick leave and return to work.

Without accurate and complete information, it is difficult for the RCMP to assess the impact of long-term sick leave on operations force-wide. Until Commanders and other key positions responsible for assisting members on long-term sick leave, work in an effective manner to ensure all long-term sick leave is accurately and properly recorded, the true impact on resources remains unknown. Increasing monitoring and oversight activities will enable the organization to determine the causes of long-term sick leave and to identify any situations of abuse. Such activities will further support the implementation of early intervention practices with a view of a more timely return to work.

The audit includes recommendations that seek to improve information management and oversight activities that will lead to an effective disability case management process that supports members on long-term sick leave. We are encouraged that Senior Management has recently launched initiatives to review and improve disability case management within the force. Their Management Response demonstrates an ongoing commitment to address the findings and recommendations. A detailed management action plan is currently being developed. Once approved, RCMP Internal Audit will monitor its implementation and undertake a follow-up audit if warranted.

Management's response to the audit

I am pleased to offer my comments on the Audit of Long-Term Sick Leave. I would first and foremost like to thank the Audit Team for the professionalism and conscientiousness demonstrated throughout this most important process.

In an effort to give context to the findings and corresponding recommendations from the audit, it is important to note that as a result of the initiatives the Human Resources Sector had committed to in its Deficit Reduction Action Plan resulting from Budget 2012, specifically, the Health Modernization Project, many of them had previously been identified and are currently being specifically addressed in our Enhanced Disability Case Management model.

Steps have already been taken to address contents of the report. To illustrate, the Commissioner spoke with his Commanding Officers and directed that they participate and ensure that the policies and processes associated with long-term sick leave are adhered to. Personally, I have raised the contents of the report with the Divisional Administrative and Personnel Officers from across the country. They are well aware of the report and will participate in the creation of our action plan.

We have taken the contents of this report seriously and, in that spirit, I commit to drafting a detailed action plan by December 20th, 2013. This action plan will contain specific time lines and milestones to which the RCMP will adhere.

Implementation will not be without its challenges, particularly in light of the financial pressures we presently face as an organization. However, we accept the results of the Audit of Long-Term Sick Leave.

D.G.J. (Daniel) Dubeau, D/Commr.

Chief Human Resources Officer

1 Background

When members are unable to work, operational requirements to maintain service delivery levels are impacted and significant additional costs can be incurred. Sick leave is an essential benefit in the member's compensation package. It allows a member who cannot work due to sickness or accidental injury to continue receiving his or her salary uninterrupted. The current compensation package provides Royal Canadian Mounted Police (RCMP) members access to unlimited sick leave with full salary and benefits.

The RCMP manages and administers, in-house, its own disability and sick leave program (short- and long-term) for both occupational and non-occupational illness and injury. The program is managed nationally with the objective of helping members to return to work in a safe and timely manner. Long-term sick leave is defined as sick leave over 30 consecutive days. Members who do not return directly to active duties may participate in a graduated return to work (GRW).

The Chief Human Resources Officer (CHRO) is responsible for all matters related to compensation and the well-being of RCMP employees, and oversees Health Services and Workplace Relations Services (Attendance Management and Return to Work Programs). The key position responsible for managing individual cases of long-term sick leave and return to work is the Commander. Footnote 1 Other positions involved in the process include Health Services Officers and Psychologists, Disability Case Managers, Return to Work Facilitators, and Employee Management Relations Officers.

RCMP policy describes the responsibilities of key positions in the administration of sick leave as well as the responsibilities of its members. In addition to policy, several divisional 'Supervisor's Guides' are available. Commanders are fully responsible for managing the first 30 days of sick leave. Thereafter, the Commander and member are supported by the Divisional Health Services personnel for disability case management, which includes health assessments, implementation of treatment plans and facilitation of return to work.

The Human Resource Management Information System (HRMIS) is the official system for recording and reporting all leave within the RCMP. The departmental financial system, TEAM, reflects costs associated with long-term sick leave through the use of medical cost centres.

In June 2012, the Commissioner approved an audit of Workforce Management (return to work) as part of the 2012-2015 Risk-Based Audit Plan (RBAP). Specifically, the RBAP identified this area as the RCMP employs over 22, 000 regular and civilian members under the RCMP Act and there are inherent risks in the work they perform.

During the planning phase of the audit, ongoing initiatives for RCMP Health Services modernization were identified. It was determined that the audit would focus on those aspects of the management of long-term sick leave that will not significantly change in the short term: the role of the Commander, and monitoring and oversight at the various levels within the Force. These aspects have a direct impact on the successful management of long-term sick leave.

2 Objective, scope and methodology

2.1 Objective

The objective of the audit was to assess the management of long-term sick leave.

2.2 Scope

The audit was national in scope and focussed on the management of Regular and Civilian members on long-term sick leave during the 2012-2013 fiscal year.

Specifically, the audit focused on:

  • Assessment of the knowledge and awareness of long-term sick leave requirements;
  • Monitoring and oversight of long-term sick leave; and
  • Key control activities to ensure accurate and timely reporting of sick leave.

2.3 Methodology

The planning phase for the audit was completed in February 2013. In this phase the audit team conducted preliminary interviews with CHRO Policy Centre Managers and Divisional Unit Commanders, reviewed relevant policies and procedures, and examined ongoing HR initiatives.

Sources used as a reference to develop audit criteria included RCMP policies as well as Treasury Board policies and guidelines. Audit objective and criteria are available in Appendix A.

The examination phase, which concluded in July 2013, employed various auditing techniques including interviews, documentation reviews, file reviews, and analysis of information. Four sites were assessed, representing 65% of the total reported sick leave population as at March 1, 2013, and enabling testing of both contract and federal divisions. A sample of 61 files were randomly selected and tested for compliance with RCMP policies.

2.4 Statement of conformance

The audit engagement was planned, conducted and reported in accordance with the Internal Auditing Standards for the Government of Canada.

3 Audit findings

3.1 Commanders - Knowledge and awareness

Commanders' current knowledge and awareness of their roles and responsibilities is not sufficient to ensure accurate and timely recording of long-term sick leave.

Commanders are the key to ensuring that members on long-term sick leave are appropriately managed. Their responsibilities include:

  • reporting a change in operational status;
  • ensuring leave hours are entered in HRMIS;
  • obtaining a medical certificate every 30 days;
  • maintaining regular contact; and
  • retrieving intervention equipment (pistols, loaded magazines, etc.)

Changing operational status

It is critical to account for a member's operational status to ensure resources are supplemented as required and members are properly accounted for. Policy requires that on the 31st day of sick leave, following notification from the Commander, members are removed from the unit's cost centre and added to a medical cost centre. Therefore, when this occurs, the unit ceases to fund the member's salary. It was observed in contract divisions, Commanders were more diligent in ensuring that a member's absence was reported in a timely manner to expedite the process of replacing the member to meet contract requirements. However, these Commanders were less timely towards re-establishing the member back onto the unit's cost centre when the member returned on a part-time or full-time basis. Additionally, several occurrences were observed where Commanders notified Health Services of a member on long-term sick leave, however never reported a change in the member's operational status in HRMIS. A lack of timeliness to accurately report a member's status decreases the integrity of data available for decision-making, and prevents senior management from knowing the true 'state of affairs' of the organization with respect to sick leave and affiliated budgetary implications. While the process for reporting changes to member's operational status was automated in April 2013, the process still relies entirely on commitment by the Commander to take the appropriate action to ensure the reporting takes place.

Recording sick leave hours

Few commanders were ensuring that members' sick leave hours were recorded in HRMIS. For a sample of 57 members who were on long-term sick leave during the examination phase of the audit, 75% of those members had no leave hours entered into the system, and for the other 25%, the hours were not fully reported. Some Commanders were not aware that they should have leave entered on a member's behalf, but the majority opted to have the members enter their own leave upon return to work. This practice results in retroactive entries which may not provide a full accounting if the leave period goes further back than the current fiscal year, or more importantly, leave hours not being entered at all as indicated in audit testing. The monitoring of members' leave absences is prevented when leave hours are not entered in HRMIS.

Requesting medical certificates

Medical certificates are required from a medical practitioner to validate every 30-day period of a member's absence and support Commanders' approval of sick leave. Sample testing determined compliance to the 30-day requirement was rarely being achieved given that most medical certificates on file covered several months as opposed to 30 days, and some were for an 'indefinite' period. Commanders made efforts to ensure their approvals of sick leave were supported by a medical practitioner rather than adhering to the 30-day timeline. Nonetheless, there were gaps in coverage where many periods were not supported by a medical certificate. In one division, Commanders relied on the RCMP Health Services Officer (HSO) medical profiles in lieu of medical certificates from the treating physician although this is not provided for in policy. Some further reported they were not in a position to challenge or approve medical certificates as they were not privy to member's health information and this role would be more suitable for Health Services. They further reported receiving limited support from HSOs when voicing concerns regarding the legitimacy of sick leave. Commanders were of the opinion that HSOs relied heavily on the medical notes and were not always open to considering information they had regarding the member's situation. Several acknowledged applying less rigour to the approval process and would benefit from added support from Health Services.

Contacting the member

Commanders indicated that they were fulfilling the requirement to maintain regular contact with members on long-term sick leave. Where members were not cooperative, Commanders delegated or chose not to maintain regular contact, or at times, took administrative action. Commanders could benefit from direction specifying what frequency or nature of contact is expected, including any requirements to document the contact. Commanders do not always document contact with members, and this could affect the RCMP's ability to defend its actions if challenged at a medical board or faced with a complaint of inattention.

Retrieval of intervention equipment

No major concerns were found with respect to the retrieval of intervention equipment (pistols, loaded magazines, etc.) when a member is on long-term sick leave. Commanders were aware of their responsibilities although some did not maintain documentation in the format prescribed in policy, and sometimes they stored equipment in their own facilities instead of forwarding it to armouries.

Clear roles and responsibilities

Success in managing sick leave depends on the support and joint contributions made by Human Resources, senior management and health specialists. Roles between these key players need to be clearly defined and understood to deal effectively with long-term sick leave. Although policy outlined Commanders' responsibilities, and Guides for Managers were available in a few divisions, there remains ambiguity which may contribute to the non-compliance in completing certain activities. There is no detailed guidance provided on management of long-term sick leave and the practice of early intervention had not been promoted for Commanders to perform. A further impact is that Commanders do not have information that would enable them to monitor members' hours and identify trends in leave or early signs of potential abuse. Complete and accurate leave records would support early intervention practices that could have a positive impact on member's attendance.

3.2 Monitoring and oversight activities

Current monitoring and oversight activities are not sufficient to ensure that long-term sick leave is managed appropriately.

The RCMP has an obligation to closely monitor and address sick leave usage to ensure that leave is being used appropriately, and that productivity does not suffer as a result of excessive or inappropriate absences from the workplace. A complete and accurate record of leave taken is critical to the success of any monitoring program.

There were limited monitoring activities implemented to support the achievement of accurate, complete and timely data entry, and there was no evidence of quality control and reconciliation between various databases and lists used to record long-term sick leave. Significant errors and omissions were observed in HRMIS. Four divisions reported in HRMIS a total of 494 members on long-term sick leave as at March 1, 2013. Within these divisions the statuses of at least 181 members were incorrect. HRMIS incorrectly reported 80 members on long-term sick leave which had returned to work on a part-time basis or full-time basis, and 101 members who were on long-term sick leave were not reported as such in the system. While it was observed that timing differences accounted for a portion of the discrepancy, the member's operational status not being updated by the Commander was a major cause.

In addition, there was limited monitoring and significant under reporting of members on graduated return to work. For instance, in one division, Health Services reported that 98 members were on GRW but only 39 were recorded as such in HRMIS. Further review of HRMIS information identified another division that was not making any use of the GRW status in HRMIS. Health Services was aware that HRMIS information on member's operational status was not accurate but did not have any accountability for ensuring its accuracy, as this is primarily a Commander function.

Inaccurate reporting of member's operational status, whether on long-term sick leave or GRW, also affects the accuracy of cost allocations within TEAM. Furthermore, unit budget savings are realized when a member is on long-term sick leave or GRW. The member's salary is not allocated to the unit, while the unit benefits from the member's contribution and productivity. The removal of a member from graduated return to work status often did not occur on a timely basis. There were no monitoring functions in place to identify and address these issues.

Oversight activities

Although there was no decision-making body in place to oversee the disability case management process, a National Integrated Service Committee (NISC) was established under the authority of the CHRO to provide guidance and recommendations on workplace accommodation issues. The NISC was expected to meet bi-monthly according to the Terms of Reference but had not been active since February 2012. As a result, divisional Integrated Service Committees (ISCs) were left to review and oversee their own long-term sick leave cases.

In the divisions, ISC meetings occurred but were sporadic. Employee Management Relations Officers selected complex cases to address at ISC meetings at their discretion. Operational outcomes were not well-defined and there was limited documentation on decisions. As limited historical information was kept, an assessment of the ISC's contribution in achieving return to work objectives could not be performed. Committee focus was geared toward medical discharges for cases where members were unlikely to return to work more than resolving problems to facilitate return to work.

Monitoring and oversight processes in place were not sufficient to ensure accurate and complete identification of members on long-term sick leave. While some reports were generated from HRMIS for statistical purposes, limited actions were taken to oversee and assess the effectiveness of the disability case management process. New initiatives developed to improve monitoring focus on the progression of a member along the disability case management process in accordance with a recently developed process map. Initiatives do not consider the accuracy of information contained in the systems (HRMIS and TEAM), thus impacting Senior Management's ability to provide sound oversight.

3.3 Management practices - Long-term sick leave and return to work

There are no standards against which to measure performance and enable sound management of long-term sick leave and return to work.

Sound long-term sick leave management practices are centered on early intervention and action plans to assist individuals to return to work in a safe and timely manner. Best management practices recognize that an organizational culture is needed where individuals feel their attendance is important and that appropriate support measures are in place to address cases of ill health or injury.

Overall, key Health Services personnel were aware of their responsibilities and were executing them in accordance with policy requirements, but the absence of standards and performance measures impeded the ability to evaluate the effectiveness of their case management practices and improve health services outcomes. Health Services acknowledged that they were experiencing challenges to provide timely services to members with respect to initiating and maintaining contact and scheduling appointments. Industry practice suggests that delayed intervention reduces the potential for a timely return to work. While cases with 30 days or more of reported sick leave are referred to Health Services, their active involvement will often occur much later. The organization strives to promote a healthy workplace via a prevention strategy that includes fitness programs and work-life balance initiatives. However, there are no measures in place to assist managers to monitor short-term sick leave. Therefore, opportunities to provide early support to members or to identify areas of potential abuse are limited.

It was also determined that information to monitor GRW was lacking. The standard Footnote 2 for return to work from illness or injury is 1.5 to 3 months. It was determined that GRW periods were much longer than the standard. Cases were individually assessed and timelines for return to work relied primarily on treating physician's recommendations. Cases were not closely monitored by Health Services to ensure they were not prolonged unnecessarily by the Commander.

As shown in Table 1 below, notwithstanding the lack of complete and accurate information in HRMIS, for the divisions tested GRW timelines were significantly higher than standard:

Table 1 - Average period for members reported GRW as at March 1, 2013
Division #GRW on HRMIS Average # Months
1 7 7.1
2 187 9.4
3 39 7.1
4 28 7.5
Total 261 7.78

Members on long-term sick leave are to maintain communication and actively participate in the process. However, sick leave policy does not contain consequences to deter undesired behaviour. The level of cooperation by members and their treating physicians heavily impacted the ability of Commanders and Health Services personnel to advance long-term sick leave cases. HSOs did not have the authority to initiate disciplinary actions, and the limited administrative actions available for Commanders to address non-compliance have proven ineffective. In addition, challenging a treating physician's assessment and treatment plan, and encouraging members toward graduated return to work or return to work can also be a delicate issue. Enhanced mechanisms to address differences of medical opinion or inaction by members are needed to better support the effective delivery of disability case management.

Complex long-term sick leave cases that are not progressing may be selected for review at the ISC. Common practice was to consider cases of continual absences over 2 years. Therefore members who remain on sick leave for several months, return to the workplace for a short period of time and then subsequently return on long-term sick leave tend to not be identified for review. Due to the fact that insufficient information was maintained by Commanders and Health Services on members with multiple long-term sick leave absences, a true assessment of the magnitude of the issue could not be determined.

Finally, there was a lack of integration and coordination with other functions that contributed additional delays in the return to work process. For instance, a member who has been away from the workplace for more than a year and is ready to return to work, will likely experience further delays due to the requirement to undergo a security clearance.

The current long-term sick leave practices do not enable timely return to work. Commanders and Health Services personnel could benefit from clearer expectations and support to manage members on sick leave and resolve long-term sick leave cases.

4 Recommendations

  1. The CHRO should implement measures that will ensure the accurate and timely recording and reporting of long-term sick leave in corporate systems (HRMIS, TEAM).
  2. The CHRO should develop service standards for disability case management and graduated return to work processes in order to assess the effectiveness and efficiency of return to work from long-term sick leave.
  3. The CHRO should develop a process to enable the organization to provide ongoing monitoring and oversight of the management of long-term sick leave, including the accuracy and timeliness of leave-related information.

5 Conclusion

The management of long-term sick leave requires improvement to better account for the operational statuses of members, and to develop standards to assess the effectiveness of the processes. The current RCMP long-term sick leave and return to work policies and processes are not sufficiently comprehensive and integrated to enable timely return to work and resolution of complex cases. Better communication of organizational expectations and sound information management to support decision-making will contribute to more cohesive, well-managed processes.

Appendix A - Audit Objective and Criteria Footnote 3

Objective: The objective of this audit was to assess the management of long-term sick leave.

Criterion 1:
Management practices and key control activities are adequate to ensure that long-term sick leave is reported in an accurate and timely manner.
Criterion 2:
Management and key personnel are aware of their responsibilities for the administration of sick leave.
Criterion 3:
Monitoring and oversight activities are in place to support the management of long-term sick leave and decision-making.
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