In 2024 almost 52 per cent of the more than 8 million employees in the Netherlands reported sick at least once, and average absence duration rose for the second year running. Long-term absence affects not only the employee themselves, but also puts heavy pressure on the organisation: in continued wage payment, replacement and lost productivity. In exactly that situation, a good action plan for reintegration is not a side issue but the foundation of the whole recovery process.
The action plan is a legally required document that employer and employee draw up together on the basis of the Gatekeeper Improvement Act (Wet verbetering poortwachter) (in Dutch). It records concrete agreements on the goal of reintegration, the steps to be taken and the responsibilities of everyone involved. An incomplete or late plan can give UWV (the Dutch employee insurance agency) grounds to impose a wage sanction, extending the obligation of continued wage payment by up to 52 weeks.
But what exactly does a good action plan look like? When does it have to be ready, what must it contain and which pitfalls do you most often see as an employer or HR professional? In this article you will read everything you need to draw up the reintegration action plan carefully and to monitor the process properly afterwards.
Legal basis: the Gatekeeper Improvement Act
The obligation to draw up an action plan follows from the Gatekeeper Improvement Act. That Act requires employer and employee to take joint responsibility for a responsible and timely return to work. Further rules are set out in the Regulation on the procedure in the first and second year of illness (Regeling procesgang eerste en tweede ziektejaar) and the Gatekeeper assessment framework policy rules (Beleidsregels beoordelingskader poortwachter). Together they form the legal framework within which the action plan has to be drawn up.
The plan is not optional. At a WIA application (the Dutch disability benefit), UWV checks whether employer and employee have met their obligations. If the reintegration effort turns out to have been insufficient, UWV can impose a wage sanction: an extension of the obligation of continued wage payment by up to 52 weeks, on top of the two years already required. For a full-time employee on an average salary, that quickly amounts to tens of thousands of euros in extra wage costs, quite apart from the administrative and legal burden that comes with it.
The timeline: when does the plan have to be ready?
The timeline within the Gatekeeper Improvement Act (in Dutch) is tight. By week six of the absence at the latest, the occupational physician draws up a problem analysis. It sets out what the employee can and can no longer do, without medical details being shared, because of privacy legislation. On the basis of that problem analysis and the occupational physician's advice, employer and employee draw up the action plan together. It must be discussed, completed and signed by both parties by the end of week eight at the latest.
Do not wait until week six or eight if it is already clear earlier that the absence will last longer. As an employer you can start exploring the possibilities sooner, which ultimately makes the action plan better and more concrete. The employee always receives a copy for their own records.
What do you put in the action plan?
A good action plan is not a collection of vague intentions, but a concrete, action-oriented document. It contains at least the following elements:
- The goal of reintegration: a return to the employee's own role, adjusted work or another role inside or outside the organisation.
- The concrete actions that employer and employee will take, including who does what and from when.
- A timeline with realistic terms, taking account of treatment time and recovery periods.
- The appointment of a case manager, often the direct manager, who monitors the plan and acts as the contact between all parties involved.
- Agreements on how and how often employer and employee keep in touch, also when resuming work is not yet possible.
- The evaluation moments: at least once every six weeks.
Do not include medical information in the action plan, even if the employee shares it voluntarily. The nature of the complaints or the type of practitioner do not belong in this document; that is required both legally and ethically.
Since 1 July 2023 there is also an obligation for employer and employee to record their own view of the reintegration process, both when drawing up and when adjusting the plan and at the first-year evaluation. That addition is meant to encourage the conversation about reintegration and to contribute to a successful process, as Arboportaal describes (in Dutch).
A common misconception: the plan is a snapshot
Many employers think the action plan is drawn up once and then disappears into a drawer. That is a stubborn misconception. The plan is a living document that is evaluated at least every six weeks and adjusted when the employee's situation changes or when the chosen approach does not have the desired effect. If reintegration does not go as expected, adjusting course is compulsory, not optional.
After 52 weeks of illness the compulsory first-year evaluation takes place. If at that point a return within the employee's own organisation is no longer realistic, track 2 has to be started: reintegration with another employer. That track 2 must have started within six weeks of the first-year evaluation at the latest. Starting track 2 too late is one of the most common reasons for UWV to impose a wage sanction.
Practical tips for a solid action plan
- Start as early as possible: as soon as it is clear the absence will last longer than six weeks, begin preparing.
- Use the official UWV form and complete it digitally; both parties sign the document.
- Formulate goals as concretely as possible: not 'the employee resumes work', but 'from [date] the employee works two mornings a week in an adjusted role'.
- Appoint a case manager who actively maintains contact and monitors progress.
- Schedule evaluation moments straight away and document every conversation in the reintegration file.
- Involve the occupational physician in good time if the situation changes or if you are in doubt about the employee's capacity.
Good record-keeping throughout the whole process is essential. Every conversation, every decision and every change to the plan must be recorded, so that at a WIA application you can show that as an employer you made sufficient effort.
The role of the occupational physician in the process
The occupational physician is not a party to the action plan itself, but does form its substantive basis. The occupational physician's problem analysis in week six gives direction on what is feasible in terms of resuming work, which adjustments to the content of the work, working conditions or working hours are needed, and whether additional guidance is required. Employer and employee then translate that advice into concrete agreements in the plan.
At Dokter Beter we work closely with employers and employees to make that translation as well as possible. Dokter Beter works with Arbo Concern, a certified occupational health service. That way a fixed occupational physician is involved throughout the whole absence process, who draws up the problem analysis, signals in good time when adjustment is needed and offers suitable guidance, both in track 1 and when track 2 comes into play. For second-track reintegration we work with Going Concern, specialists in that field.
An action plan is not a form you fill in and forget, but the compass for the whole road back to work.
A good action plan for reintegration is more than a legal obligation: it is the practical instrument with which employer and employee work together on lasting recovery and a return to work. Anyone who draws up the plan carefully, evaluates it regularly and adjusts course in time protects both the employee and the organisation.
Key takeaways
- The action plan is legally required under the Gatekeeper Improvement Act and must be signed by both employer and employee by week 8 of the absence at the latest.
- The basis is the occupational physician's problem analysis from week 6: without that advice you cannot draw up a concrete and tenable plan.
- The plan contains at least: the reintegration goal, concrete actions with a timeline, the name of the case manager and agreements on contact moments and evaluation.
- Evaluate the plan at least every six weeks and adjust it when the employee's situation or capacity changes; it is a living document, not a one-off form.
- If reintegration effort is insufficient, UWV can impose a wage sanction: an extension of the obligation of continued wage payment by up to 52 extra weeks.
- Start track 2 in good time if a return to the employee's own employer is no longer realistic; starting too late is a common cause of wage sanctions.
- Dokter Beter gets in touch within one working day and, as an occupational health practice, supports you with the problem analysis and suitable guidance throughout the absence process.
Are you unsure whether your action plan is complete, or do you want to be certain as an employer or HR professional that you are setting up the reintegration process properly, legally and in substance? Get in touch with Dokter Beter and we will help you further.