Once considered an “ignored step-child”, the Americans with Disabilities Act (ADA) has risen to star status as integrated absence management (IAM) has evolved.
Whether your organization has a vision of employee inclusion, or holds a tighter focus on compliance, the ADA has acquired importance since Congress passed the ADA Amendments Act in 2008. Employers are motivated to increase integration among their IAM-based programs to identify accommodation needs and meet them successfully. And in most organizations, it does not matter if inclusion or compliance is the primary focus; both are developed on parallel tracks to meet corporate needs.
Employer Example: EY
The experience of EY (formerly Ernst and Young) is a case in point. As a professional services organization providing skilled personnel to clients, “our product is our people,” notes Susan Morrison, Associate Director, Total Rewards/Benefits. EY’s global workforce of 231,000 includes 45,000 U.S. employees with an average age of approximately 27 years, she said.
EY U.S. is driven by a vision of employee inclusion and success, which affects its benefit policies in numerous ways. Unlike many employers, EY provides salary continuation before a short-term disability (STD) claim is approved, and EY manages the use of salary continuation in-house. Historically, this model was the norm. But during the development of integrated disability management, some employers rejected that model to contain costs, and to give employees a financial motivation to return to work (RTW) as early as possible.
EY’s predominantly young employees don’t need any help with motivation, said Selvi Springer, CRC, Assistant Director of Medical Accommodations. “This population is used to putting out 150% at all times. If they’re not able to go in to the office, they insist on working from their beds,” she said. Salary continuation until an STD claim is approved is an employee-centric approach that reduces financial hardships for employees, helping motivated employees stay motivated. And rather than uniformly treating STD as an expense to reduce by denying claims, EY often uses STD as part of the solution process for employees having difficulties.
EY’s Integration Evolution
In recent years, employee accommodation has played a growing role in the way EY integrates benefits. The most dramatic example was the creation of the new position held by Springer in August 2016, with the accommodation and ergonomic request functions joining the leave management team, both under Morrison’s direction.
About 14 years ago, EY began to centralize its leave of absence management function in a small call center. Over the years, other functions were added to this team, including dependent certification. During this period, accommodations and ergonomics were located in the employee assistance program called EY Assist. This program already interacted with partners or staff and their healthcare providers concerning behavioral health conditions, so it was a logical choice to handle all types of accommodation.
“As demand grew, and we noticed a continuum from disability to accommodation, we began to think that leave management was a more appropriate area for accommodations; that this would simplify the process,” Morrison explained. FMLA or other leave could be a precursor for disability, and the leave management team could work more closely with disability vendors for earlier intervention. “The addition of a staff member with specialized experience in accommodations could add even greater quality and efficiency,” Morrison said.
This program cluster was fairly similar to the way other employers integrate around the leave management function. But EY had a larger number of programs in the integration cluster, and unlike some employers, EY was driven by employee inclusion and success. “We do ask for medical information so we can provide services to ensure employees can still do their job; that’s how it evolved with the leave team,” said Morrison.
The unit became the new location for accommodations and ergonomic requests in August 2016, when it was re-located from its former position in EY Assist. It includes three leave specialists, an accommodations manager, and an ergonomic analyst who coordinate both accommodations and ergonomic requests. Locating both functions in the same unit helps in securing integrated medical information from physicians, since physicians provide medical information for FMLA and other leaves.
EY has an ADA compliance effort operating on a parallel track to accommodations. EY’s U.S. legal department provides in-house consulting on accommodation processes in general, and on cases that rise to the level of a formal ADA claim. EY offers employees the ability to obtain some common accommodations simply by requesting them. For example, any EY employee can download voice-activated software from the internal App store or request an ergonomic laptop stand. “Flexible work arrangements and the ability to work from home for many positions allows us to have a more diverse work force and has the added benefit of preventing some more serious claims,” says Springer.
That is one of the reasons that EY encourages employee participation in benefits or services, such as EY Assist or the behavioral health services available through the health plan. These services can help reduce the incidence of more serious claims. Behavioral health care is about 5% of EY’s total medical expense, said Dr. Sandra Turner, Director of EY Assist. “We would like to see that increase,” she said. “If we have more people getting help early, we’re going to retain more people, and retain our brand through them.”
For the same reason, Turner also wants to see increased use of EY Assist, which already has a high utilization of 5% to 7% in recent years. A new initiative called “r u ok?” has increased EAP utilization about 30%, bringing it up to 8% in 2017; all of the increase came in the area of mental health or related EAP services.
“R u ok?” was developed by a broad group of EY stakeholders, driven by strong interest and support from corporate leaders. “We want everyone to bring all of who they are to work,” said Turner. “Mental health and addictions are part of life. We have the resources to address these conditions. So we encourage colleagues to volunteer for training about the signs and symptoms of these conditions, how to ask ‘r u ok?’ and become familiar with the appropriate resources at the firm and/or in the community.”
To explain “r u ok?” Turner put it in the larger context of EY’s many behavioral health initiatives and corporate culture. “We believe that ‘r u ok?’ can only work in a culture of caring,” she said. “Without such an organizational culture, employees are not likely to acknowledge their personal or family struggles, or accept the offer of help.”
EY launched “r u ok?” with a one-year communications and online training initiative starting with Mental Illness Awareness Week in October 2016, including local events in five major EY offices. A second round of 18 local events was planned for 2017 and is nearly complete now. Local office managing partners presented their experience with mental illness, either personally or through a family member or colleague. This was just one aspect of a comprehensive communications campaign.
With a campaign of this scope and depth, not only did utilization of EY Assist increase, so did accommodation activity. Accommodations were trending up in 2016 prior to the launch of “r u ok?” but the activity has continued, and has increased roughly 20% compared to years earlier, said Turner.
Another synergistic program that facilitates increased utilization of accommodations is EY’s AccessAbilities professional network group. This group is not a formal party during the interactive process, but employees often contact AccessAbilities for peer support during the process. Given the voluntary and informal nature of this link, it is not possible to measure the impact of AccessAbilities, but anecdotally the program has been a significant contributor.
ADA Points of Contact
The ADA and accommodations are deeply embedded in EY’s highly integrated “culture of caring.” Other organizations may have less history with accommodation, yet still may feel substantial impact from the ADA in different ways.
Intermountain Health, a Utah hospital organization, saved an estimated $1 million in the first year of an initiative that reduced the average duration of mental health claims from 72 days to 60. Early intervention initiatives like this thrive on integration that builds new links to identify higher-risk claims. Supervisors and line managers played an important role in this process at Intermountain Health. Securing the cooperation of these busy people was a make-or-break component for the initiative.
“These line managers were aware of the need to comply with the ADA, and this provided leverage to win their support and involvement,” said Kimberly Mashburn, National Accounts Practice Lead at The Hartford. “Because they were more aware of the ADA, they had already begun to have earlier conversations with employees when problem signs cropped up.” This reversed the historic learning curve, where line managers first gained skills in other programs that equipped them to play a role in ADA compliance.
And some organizations with less ADA experience still follow that progression, learning about the ADA in the process of managing short-term disability (STD) claims. Often new resources are injected into an organization through an external vendor, whether a third-party administrator or a disability insurance carrier. Standard Insurance Co. (The Standard) has a program for developing accommodations and RTW or stay-at-work plans for its clients’ employees with STD and long-term disability (LTD) claims. “Employers often begin by seeking accommodations for complex disability claims, and then request resources and coaching to develop their own internal accommodations program,” said Brian Kost, Senior Director, Workplace Possibilities at The Standard. In this development process, integration with STD, LTD, and other programs is baked in.
“Accommodation” is becoming part of the corporate language around integrated absence management. In an IAM initiative, employers integrate benefits to give employees a more efficient return to work following a leave or disability event. Some initiatives have early intervention programs to reduce disability duration.
Sophisticated integration initiatives like the one at EY use accommodations as a tool at every stage of a potential claim, helping employees stay at work through early intervention or RTW from disability. These extensive employee services require the integration of multiple specialties such as accommodation, leave management, and ergonomics. Even if an EAP is not formally integrated, EAP initiatives like “r u ok?” may have a significant impact on accommodation requests and utilization. Increasing awareness of the ADA may foster greater attention and adherence among line managers, another crucial need for successful program integration.
In short, regardless of the focus of a particular employer IAM initiative, competent program efforts link the ADA, accommodations, and inte