Audit Opinion supporting analysis and findings

Transcription

Workplace Safety and
Insurance Board
Workwell Program
2011 Value for Money
Audit
March 2012
Table of contents
•
Workwell program current profile……………….……………..……………………………………………………………….3
•
Project Objectives and Scope …………...…..………………………………………………………………………………...6
•
Basis of Value for Money Audit Opinion .……..……………………………………………………………………………....7
•
Bill 160 Alignment Findings…………………………………………………………………………………………………......9
•
Summary Opinion ………..……………………………...……………………………………………………………………..11
•
Audit Opinion Findings ….…………………………………………………………………………………………………......13
•
Auditors Report………………………………………………………………………………………………………………….20
•
Recommendation for Improvement & Management Response… ……………..………….………….………..................21
•
Considerations for Program Redesign………………………………….…………………………………………………….23
•
Audit Opinion Supporting Analysis
2
–
Bill 160 Alignment Detailed Findings………………………………..……………………………………………….....30
–
Value for Money Opinion Detailed Findings ……………...………….…..………………...…………………….…..32
–
Interjurisdictional Research ……………………………………………..…………….…...………….……….............49
–
Internal Consultations/Documentation Review …………………………..………………………………...…….......51
–
Appendix………………………………………………………………………..…………………………………...….…55
WSIB - Workwell Program Value for Money Audit
© Deloitte & Touche LLP and affiliated entities.
Workwell program current profile
• Workwell was established as a pilot program in December 1987 as a
policy “designed to promote health and safety in Ontario workplaces by
providing additional assessments to be levied on employers who are
not maintaining safe and healthy working environments”.
• The Board’s current Operational Policy states that “the Workwell
program issues an additional premium charge to employers who have
not taken sufficient precautions to prevent accidents in the workplace.
Workwell operates independently of the Workplace Safety & Insurance
Board’s (WSIB) experience rating programs and its additional premium
charges are issued in addition to any premium or premium rate
adjustments that may be realized through experience rating”.
• Employers are considered for the Workwell program based on mature
WSIB data (e.g., injury costs, frequency information) input into the Firm
Selection Model and Workwell Selection criteria. Referrals also come
from Ministry of Labour orders, complaints from workers and other
sources.
• Firms are notified that they have been identified for an audit through a
WSIB letter and the phase 1 audit is scheduled by the Workwell
Evaluator.
• A score of 75% is required to pass the audit. Firms that do not pass
phase 1 have approximately six (6) months to improve their health and
safety system prior to the phase 2 audit.
• Firms that do not pass phase 2 are subject to a surcharge of up to
$500,000 based upon their audit score and annual premium amount.
• Employers may choose to use internal resources, external consultants
or the Health and Safety Associations to assist in their Workwell
preparation and implementation efforts.
3
Workwell program
overview
• Workwell Evaluators
closed 964 cases (i.e.,
Audits or Risk
Management Plans) for
the 12 month period
ended December 2011
• There are presently 22
Workwell Evaluators
covering the province
• Workwell Evaluators
perform Core Health and
Safety Audits, Small
Business Health and
Safety Audits and Risk
Management Plans (RMP)
• The 2011 (fully staffed)
program budget was
$4.028 million
• The 2011 surcharge
levied was approximately
$1.1 million
• Approximately 80% of
firms do not pass the
phase 1 audit
• Phase 2 audits are
successfully completed by
approximately 80% of
firms
The changing landscape of Ontario’s health and safety
system
• The health and safety system in the Province of Ontario is currently in a state of transition as a result of
the Tony Dean Report, introduction of Bill 160 and the forthcoming WSIB Funding Review and
recommendations.
• Bill 160 actioned recommendations from the Tony Dean Report and enabled the Ministry of Labour to
appoint the province’s first Chief Prevention Officer, effective October 2011.
• Based on Ministry of Labour communications (MoL Backgrounder Ontario’s First Chief Prevention
Officer To Spearhead Improvements To Worker Health And Safety, December 16, 2011) the Chief
Prevention Officer will be responsible for:
– “Establishing a provincial occupational health and safety strategy;
– Promoting the alignment of prevention activities across all workplace health and safety system
partners;
– Advising on proposed changes for the funding and delivery of prevention services; and
– Working with Ontario's Health and Safety Associations (HSAs) to establish effective delivery of
prevention programs and services”.
• Presently the Workplace Safety and Insurance Board (WSIB) provides funding to the Ministry of Labour
($95 million) to administer the Occupational Health and Safety Act and to the HSAs ($91 million
including mine rescue) to provide services and resources to the province’s employers.
• The WSIB Funding Review has been gathering information and input from stakeholders across the
province over the past year to assess specific issues related to WSIB’s financial situation. As part of the
review employer incentives were evaluated through the following analysis:
– Is the present design and operation of these programs appropriate?
– What alternatives exist to promote increased safety in the workplace, fairness in insurance costs to
employers, and incentives to employ injured workers?
• The Funding Review report and recommendations have not yet been made public.
4
Implications to Workwell from the changing landscape
• The essence of Bill 160 is that WSIB’s previous prevention mandate will be transferred to the Ministry
of Labour under the Chief Prevention Officer.
• WSIB is currently working with the Chief Prevention Officer to identify the existing prevention focused
responsibilities within WSIB that could be allocated to the newly created organization.
• At the same time, the Chief Prevention Officer is beginning to develop the elements of a provincial
occupational health and safety strategy that ultimately, amongst many other things, will define the
scope and delivery of existing and new prevention programs.
• Independent of the strategy developed by the Chief Prevention Officer, WSIB needs to look at Workwell
and assess whether the program in its current form has a role to play within the scope of WSIB’s future
operations, or whether there are modifications to the current program that would better align to
emerging strategic directions.
• The Value for Money Audit (VfMA) is an annual regulatory requirement to assess the efficiency and
effectiveness of a WSIB program delivered under the Act. In 2011 the Workwell program was selected
for the VfMA. Stakeholders were interested in considering where Workwell should be positioned in the
health and safety system given the shift of prevention activities.
• The findings from this project will help to inform future decisions on the scope, nature and service
delivery mechanism for Workwell.
5
Project objectives and scope
• To meet legislative requirements, the Workplace Safety and Insurance Board is required to
undertake an annual Value for Money Audit of at least one program delivered under the Act.
• Following a formal Request for Proposals and vendor selection process, Deloitte was engaged to
conduct the VfMA.
• The project objectives and scope as referenced in the Request for Proposal and confirmed with
management through input from the VfMA Steering Committee are outlined below.
Objectives
•
Provide an opinion as to whether there is value for
money in the outcomes generated by the Workwell
program and recommend improvements that could be
made.
•
Include the three key elements of effectiveness,
efficiency and cost of the Workwell program in the
value for money opinion.
•
6
Identify program improvements/opportunities that will
allow efficient and effective alignment of the Workwell
program with the new prevention mandate (Bill 160) as
it develops.
•
Identify opportunities for efficient and effective
alignment of the Workwell program within the WSIB’s
Insurance System.
•
Assist WSIB management in the formulation of a
response to the recommendations of the Audit which
are to be included in the final report.
Scope
•
The cost, efficiency and effectiveness of the
administration of the Workwell program will be
assessed including roles and responsibilities,
administrative controls, monitoring and reporting
processes, use of information technology and training
and development activities.
•
The audit will assess the Workwell program from the
Firm Selection Model process through to the completion
of a Workwell case.
•
Data will be provided by WSIB to assist in the
evaluation of the program’s effectiveness. Workwell
selected firms from the 2006 through to 2010 cohort
years will be assessed.
Basis of Value for Money Audit Opinion
The value for money audit opinion for the Workwell program is based on a pre-determined guiding
principle in combination with program specific criteria developed for each of the core value for money
components – systems, resources and outcomes.
Opinion
Guiding
Principle
• The scope of the audit will focus on the efficiency, effectiveness and cost of Workwell and the program’s
alignment in the WSIB’s Insurance System.
Audit Criteria
Statutory
Definition
• Roles, responsibilities, accountabilities, and performance expectations are
defined, understood, and consistently executed by management and staff.
Systems
• The adequacy of
management systems
(including performance
standards and
measurement), controls
and practices, including
those intended to control
and safeguard assets,
and to ensure due regard
to cost, efficiency and
effectiveness.
• The extent to which
resources have been
managed in conducting
relevant activities with
due regard to cost and
efficiency.
• Program resources are managed efficiently to meet program demands.
• The extent to which
programs, operations or
activities of an entity
have been effective.
• The program has clearly defined objectives that are aligned with organizational
strategies, and there are measures in place that demonstrate satisfactory
progress towards those objectives.
Resources
Outcomes
Workwell Program
Key Audit Criteria Attributes
• Appropriate administrative controls and safeguards are in place to mitigate
program risks.
• A tracking and reporting process is in place to monitor program performance;
and, performance metrics are monitored and acted upon.
• The information technology systems in place to support the program have the
desired functionality to deliver and monitor the program.
• Policies and processes supporting the program are documented, communicated,
and understood by management and staff.
• Policies and processes are executed in a timely manner.
• Identified challenges and issues are addressed in a timely fashion and in
accordance with the established escalation and resolution process.
• Adequate training and development programs are in place for management and
staff to ensure succession planning and knowledge retention.
• The program contributes to a sustainable (evidenced by WSIB reporting metrics
in the years subsequent to a Workwell interaction) reduction in injuries and
illnesses in the Province's workplaces.
• The program meets the needs of workplace parties in the Province of Ontario.
7
Rating categories
Using input from documentation review, focus groups, interviews and data analysis, we applied the
audit framework to determine the extent to which the Workwell program is achieving Value for Money
for the WSIB.
Bill 160
Rating
Categories
Audit
Criteria
Alignment
No
Improvements
Required
Systems
Some
Improvements
Required
Resources
Significant
Improvements
Required
Critical
Outcomes
Please note that for reporting purposes, the alignment of Workwell to the changes proposed under Bill 160 has been
considered as separate and distinct to the statutory Value for Money Audit criteria, the assessment of which forms the
basis of the audit opinion. However, the assessment of the alignment question is presented first in our report since the
answer shapes the context for the Value for Money Audit findings and the future opportunities for consideration in
developing and implementing health and safety prevention programs.
8
Bill 160 alignment findings
• WSIB’s new vision aspires the organization “to be the leading workplace compensation board”. To
accomplish this vision the Board’s mandate is:
– To promote health and safety in the workplace
– Facilitate return to work
– Provide compensation where required.
• Bill 160’s intent is to promote, educate and foster commitment to health and safety for employees and
employers within the Province’s workplaces (Section 4.1 (2)). Specifically the objectives of the
Prevention mandate are:
– To promote occupational health and safety and to promote the prevention of workplace injuries and
occupational diseases
– To promote public awareness of occupational health and safety
– To educate employers, workers and other persons about occupational health and safety
– To foster a commitment to occupational health and safety among employers, workers and others
• The implication of Bill 160 is that WSIB’s previous prevention mandate was transferred to the Ministry
of Labour under the Chief Prevention Officer effective April 1, 2012.
• While our review indicates that there are a number of facets to the Workwell program including
education, creating awareness, monitoring compliance and enforcement activities, all of which can be
construed as promoting health and safety in the workplace, we conclude that the program is
fundamentally an injury prevention program.
• Further, as we identify later in our report, there are a number of elements within Workwell that require
significant improvement to make the program, or its elements, a more effective contributor to the
Province’s Health and Safety system.
9
Bill 160 alignment findings (cont’d)
• Therefore, based on our review of the Workwell program and an assessment of the implications of Bill
160, we conclude that the Workwell program, in its current form, no longer aligns to the WSIB’s new
strategic direction.
• There is an opportunity to perform the education, implementation and monitoring activities for
employer’s health and safety systems on a more integrated basis across the system partners.
• WSIB needs to work with the Chief Prevention Officer (CPO) to support the CPO in determining the
elements of the current Workwell program that could be retained in a new Prevention system, defining
the nature and scope of the future offering, and identifying the system partner(s) best qualified to
deliver the activities within that offering.
10
Summary Opinion
The scope of the audit assessed the cost, efficiency and effectiveness of the Workwell program from the
Firm Selection Model process through to the completion of a Workwell case. We present the following
summary conclusions:
• Systems:
– Review of current program management systems reveals some controls and practices are in place to
safeguard assets with due regard to cost, efficiency and effectiveness. There are opportunities to:
– Clarify the roles and responsibilities of Workwell Evaluators, particularly with reference to the
program mandate (e.g., compliance vs. consultative, incentive vs. punitive).
– Improve the reporting on the Health & Safety System -Target & Performance Dashboard to include
outcome indicators.
– Improve the use of technology that support Workwell Evaluators.
• Resources:
– Program resources are being managed to conduct relevant activities with due regard to cost and
efficiency. There is some room for improvement to:
– Focus attention on the Firm Selection Model and the need to use leading indicators in the model.
– Perform the Workwell intervention in a more timely manner after the incident which led to the firm
being identified for audit.
– Train and deploy resources based on industry expertise.
(cont’d..)
11
Summary Opinion (cont’d)
• Outcomes:
– An analysis of LTI outcomes has not provided evidence that the program has a unique impact on
declines in LTI rates since evidence is mixed and there are many other environmental factors that
impact LTI.
– Although LTI rates do decline after Workwell interventions, there is limited quantitative evidence
that declines are due to the audit and the on-going trending of firms undergoing intervention is no
different than overall declines in LTI across the Province.
– There is evidence that some workplace interventions (i.e., within Workwell and considering other
programs such as Safety Groups and SCIP) may have more impact than others notwithstanding
opportunities to improve clarity around the mandate and execution of the program.
– Key improvement opportunities include:
– Clarify the mandate of the program and align the appropriate program elements and activities to
the WSIB and health and safety system partners according to the new strategic direction advanced
by the introduction of Bill 160.
– Track and report metrics to evidence Workwell’s ongoing success (i.e., fewer injuries and illnesses,
reduced risk of injury).
• Overall:
– While elements of the Workwell program do provide some value (e.g., notifications to employers and
Risk Management Plans) the Workwell program as a whole has not clearly delivered value for
money for the Workplace Safety & Insurance Board.
12
Audit Opinion findings - Systems
The following table shows our summary audit findings for the Systems component of the Value for
Money Audit Framework as it relates to the Workwell program.
Audit
Criteria
Systems
Key Audit Criteria
Attributes
Observations
Roles, responsibilities,
accountabilities, and
performance expectations
are defined, understood, and
consistently executed by
management and staff.
•
Appropriate administrative
controls and safeguards are
in place to mitigate program
risks.
•
•
•
Resources
•
•
Outcomes
A tracking and reporting
process is in place to monitor
program performance, and
performance metrics are
monitored and acted upon.
•
•
LEGEND
13
No Improvements Required
Rating
Workwell Evaluator Job description notes that they are to be
“providing collaborative risk-based consultative services to
customers”. There is confusion internally and externally
regarding their role.
The Workload Objective to ‘ensure a minimum of sixty (60)
evaluations are completed on a rolling twelve (12) month
basis is not being consistently met.
Efforts to align the Workwell Evaluator Evaluation Process
and ISO 19011:2002 standards are partially completed.
Further effort is required to ensure the standard is
accurately applied to the Workwell process.
The Workwell Findings Committee has not met regularly
during 2011.
Concerns were noted by stakeholders that the Workwell
Evaluators may not have sufficient and appropriate
background to understand the health and safety issues for
all of the types of businesses encountered by Workwell.
The Workwell program System Collaboration Branch Survey
of Employers Undergoing First Workwell Audit only looked
at Phase 1 of the process.
The Health & Safety System -Target & Performance
Dashboard report is point in time and does not include
metrics to demonstrate sustainability of improved
performance for employers involved in the Workwell
program.
Financial metrics for surcharges generated by Workwell
audits are not tracked and reported.
Some Improvements Required
Significant Improvements Required
Some
Improvement
Required
Some
Improvement
Required
Some
Improvement
Required
Critical
Audit Opinion findings – Systems (cont’d)
The following table shows our summary audit findings for the Systems component of the Value for
Audit
Criteria
Systems
Resources
Key Audit Criteria
Attributes
Observations
The information technology
systems in place to support
the program have the
desired functionality to
deliver and monitor the
program.
•
Policies and processes
supporting the interpretation
of the guiding legislation are
documented, communicated
to, and understood by
•
•
•
Rating
There is opportunity for efficiency improvement by enabling
the use of electronic forms/documents by Workwell
Evaluators to eliminate duplication of input efforts.
Instances of poor data quality and integrity issues were
noted during the analysis.
There is a lack of clarity amongst staff (and consequently
customers) regarding the Workwell mandate (i.e., is it
compliance or instructional and guidance driven?).
Workwell program policy indicates that “Employers that fail
the initial evaluation are required to work with a health and
safety program provider”. However, this is not the current
practice.
Some
Improvement
Required
Significant
Improvement
Required
Outcomes
LEGEND
14
Critical
Audit Opinion findings - Resources
The following table shows our summary audit findings for the Resources component of the Value for
Audit
Criteria
Key Audit Criteria
Attributes
Program resources are
managed efficiently to meet
program demands.
Observations
•
•
Systems
•
•
Resources
Policies and processes are
executed in a timely manner.
•
•
Outcomes
•
LEGEND
15
Rating
The program’s actual spend is presently operating at
approximately 71% of the year to date budget with only 65%
of the budgeted FTE.
There is opportunity for additional management support for
field operations.
The Firm Selection Model may result in numerous large,
multi-site operations being selected due to use of the WSIB
account number being the primary employer data driver.
Locations that caused the incidents may not be selected for
review and sites that demonstrate good performance may
be reviewed.
Subsequent to implementing the 2008 Risk Management
and Monitoring Plan Procedure the number of Risk
Management Plans has been reduced and represents only
8% of completed cases for the past two (2) years. Through
the data analysis, in some instances RMPs demonstrated
larger reductions in LTI rates than a full Workwell audit.
The use of lagging indicators in the selection models results
in a considerable period of elapsed time (potentially greater
than 2 years) prior to being identified for Workwell
intervention.
A selected firm may not be audited for an additional 12
months after being notified that they have met the Workwell
criteria.
The Firm Selection Model’s reliance on a one year negative
performance spike may limit the ability of Workwell to
interact with firms which experience many years of
consistently poor or below average performance.
Significant
Improvement
Required
Significant
Improvement
Required
Critical
Audit Opinion findings – Resources (cont’d)
The following table shows our summary audit findings for the Resources component of the Value for
Audit
Criteria
Systems
Key Audit Criteria
Attributes
Identified challenges and
issues are addressed in a
timely fashion and in
accordance with the
established escalation and
resolution process.
Observations
•
•
Resources
Adequate training and
development programs are
in place for management and
staff to ensure succession
planning and knowledge
retention.
•
•
Rating
There is lack of an integrated prevention approach and
mechanisms between Workwell and other programs in
Ontario’s health and safety system to foster sustainability
(e.g., transition for Workwell audited employer into a
‘sustaining’ type program such as SCIP or Safety Group;
Health and Safety Associations function to provide ongoing
support to Workwell audited firms).
Despite Workwell appeals not being frequently successful
(i.e., results are overturned) analysis of the reason(s) for the
appeal being launched is not performed.
A formal mechanism to identify the Workwell Evaluator
subject matter expert (SME) areas of expertise and to
continue to develop and retain the Evaluator’s experiences
and capabilities is not in place.
Formal succession planning processes are not in place.
Significant
Improvement
Required
Some
Improvement
Required
Outcomes
LEGEND
16
Critical
Audit Opinion findings - Outcomes
The following table shows our summary audit findings for the Outcomes component of the Value for
Audit
Criteria
Systems
Resources
Key Audit Criteria
Attributes
Observations
The program has clearly
defined objectives that are
aligned with organizational
strategies, and there are
measures in place that
demonstrate satisfactory
progress towards those
objectives.
•
The program contributes to a
sustainable reduction in
injuries and illnesses in the
Province’s workplaces.
•
•
•
•
•
Outcomes
LEGEND
17
Rating
Metrics to evidence the program’s ongoing success by
internal or external stakeholders (i.e., fewer injuries and
illnesses, reduced risk of injury) are not tracked and
reported at a level to enable conclusions to be made of the
program effectiveness.
The current Workwell prevention mandate does not
specifically align with the updated WSIB mandate, vision
statements and strategic direction.
Data analytics did not show consistent evidence that
Workwell alone has helped to reduce LTI on a sustained
basis. All LTI rates, based on WSIB supplied data, show
sustained declines independent of an intervention.
Notifications combined with a Risk Management Plan
(RMP) are generally the most successful Workwell
intervention to show evidence of decreasing a selected
firm’s LTI rate.
Consistent criteria to define the application of one Workwell
interaction (e.g., Risk Management Plan or Core Audit)
versus another depending on the characteristics of the client
are not in place.
Workwell does not analyze the effectiveness of its various
methods of intervention (e.g., Core Audit vs. RMP, vs.
Notification only).
Critical
Critical
Critical
Audit Opinion findings – Outcomes (cont’d)
The following table shows our summary audit findings for the Outcomes component of the Value for
Audit
Criteria
Systems
Key Audit Criteria
Attributes
The program meets the
needs of the workplace
parties in the Province of
Ontario.
Observations
•
•
•
Resources
Rating
There are opportunities for overall program improvements to
enhance Workwell’s operational effectiveness and
efficiency.
There is some confusion in the employer community with
respect to the role of Workwell Evaluators and Ministry of
Labour Inspectors and their application and interpretation of
regulatory and legislative requirements. Both are often
viewed as compliance and enforcement focused and the
‘prevention intent’ is lost during the intervention.
An integrated approach for prevention and health and safety
programs is not in place for the Province’s workplaces. Our
audit indicates that, notwithstanding confusion as to the
existing mandate of the Workwell program, Workwell in its
current form no longer aligns to WSIB’s mandate.
Significant
Improvement
Required
Outcomes
LEGEND
18
Critical
Summary Audit Findings
The table below shows our summary audit findings of each component as it relates to the Workwell
program.
Audit
Criteria
Observations
Rating
• There is confusion within the Workwell team and in the employer community about the nature
of the program i.e., is it compliance or consultation and collaboration?
• Program volumes are not being met.
Systems
Some
Improvement
Required
• Health and Safety dashboard reporting does not track and report trending to enable monitoring
of the sustainability of health and safety efforts once a Workwell audit has been performed.
• The Workwell Case Information System has opportunities for enhanced functionality through
the use of electronic forms which would improve the efficiency of Workwell Evaluators.
• Data analytics on an ongoing basis is a challenge due to WSIB’s use of multiple systems which
prevents integrated data reporting.
• The level of deployed program resources may not be commensurate with the program design
and objectives. There is opportunity to evaluate the structure of management support provided
to field operations.
Resources
Significant
Improvement
Required
• Employers noted concerns about the background of Workwell Evaluators and whether there is
sufficient experience to effectively assess the wide variety of businesses in the province.
• Resources engaged in large, multi-site audits may not target or visit the worst offender
locations within the organization.
• There is opportunity to use predictive analytics to select firms for Workwell audits.
• Metrics to evidence Workwell’s ongoing success (i.e., fewer injuries and illnesses, reduced risk
of injury) are not tracked and reported.
• Data analytics did not show consistent evidence that Workwell alone has helped to reduce LTI
on a sustained basis. All LTI rates, based on WSIB supplied data, show sustained declines
independent of an intervention.
Outcomes
Critical
• Consistent criteria to define the application of the type of Workwell intervention are not in
place.
• The Workwell Core Health and Safety Audit tool is very comprehensive. However, there are
opportunities for improvements to the design and execution of the tool.
• The province does not have an integrated approach between Workwell and other prevention
and health and safety programs.
19
Auditors’ Report
To the Directors, Workplace Safety & Insurance Board:
• We have conducted a Value for Money Audit of the Workwell program at the Workplace Safety and
Insurance Board (WSIB) of Ontario in accordance with WSIB’s request for proposals No. RFP # 201197-SVB.
• The objective of the audit, as stated in the request document, was to:
– Provide an opinion as to whether there is value for money in the outcomes generated by the
Workwell program and recommend improvements that could be made
– Identify improvements/opportunities that will allow efficient and effective alignment of the Workwell
program with the new prevention mandate (Bill 160) as it develops (please see page 5 of this report
for a full description of the project’s objectives and scope).
• We conducted our audit in accordance with the value for money audit standards recommended by the
Canadian Comprehensive Auditing Foundation and accordingly included such tests and other
procedures as we considered necessary in the circumstances.
• Specific criteria encompassed by this audit are identified on page 6 of this report.
20
Recommendation for Improvement &
Management Response
21
Recommendation for improvement
Based on our analysis of the Workwell program audit findings and conclusions and the
alignment of the program with the WSIB mandate we offer our recommendation and the
respective Management Response.
No.
Recommendation
1
Workwell program alignment with WSIB mandate – As a result of Bill 160, the Workwell
program no longer aligns with the WSIB's future mandate and operations. The WSIB should
support the Chief Prevention Officer in determining which elements of the current program could
be retained and/or refined in the new system, defining the nature and scope of the elements, and
identifying the system partner(s) best qualified to deliver the activities within those elements.
Management Response
WSIB agrees with the recommendation.
WSIB will support the Chief Prevention Officer (CPO) in identifying the elements of Workwell that should
be retained and/or refined in the new Prevention system. WSIB will assist the CPO in defining the nature,
scope and delivery of those elements by the end of Q4, 2012.
22
Considerations for Program Redesign
23
Considerations for program redesign
In the pages that follow, we present a series of considerations for the redesign of the Workwell program as
part of the broader development by the CPO of a new prevention system within the Province.
Theme
Program
Strategy and
Communications
24
Program development opportunity
Health and safety system partners - System partners should collaborate their efforts to increase
awareness and standardization related to the programs, procedures, processes, tools and
methodologies which are available to support an organization’s health and safety initiatives. Where
possible, the use of existing standards such as CSA Z-1000 and ISO 19011 should be considered
in developing and delivering the programs.
Roles and responsibilities should be developed to ensure that firms continue to experience
interaction with system partners once the intervention is complete. Ongoing involvement with other
programs offered by system partners upon exiting the intervention process may help to sustain
health and safety improvements in the organization and reduce the possibility of future incidents or
non-compliance.
Communications – To reduce the likelihood of confusion in the employer and worker community
the new program should clearly identify its nature and intent in the official communications and
publications. For example, mixing terminology such as ‘incentive’, ‘compliance’, ‘consultative’ and
‘audit’ creates differing perceptions for stakeholders related to outcomes and type of involvement
which may be experienced while interacting with the program.
Theme
Role clarity – Based on the new program’s direction there should be clearly defined roles and
responsibilities for the management and staff job descriptions. It is important to delineate more clearly
between education versus consultative versus audit versus enforcement roles. The roles and
responsibilities should be communicated appropriately to all stakeholders (e.g., workplace parties,
WSIB, Health and Safety Associations, and Ministry of Labour).
Role Clarity
and Expertise
25
Specialist roles and Subject Matter Experts (SME) - Specialist type roles based on industry and
sector specific organizations (e.g., to perform interventions at clients such as hospitals and
healthcare institutions) should be developed as a program resource. The staff in these roles should
be trained regarding the specific types of risks within these organizations and have an understanding
of the terminology and health and safety methodologies and practices which should be in place.
In addition, program staff that are considered to be subject matter experts (but not necessarily acting
in a specialist role) in their industry or area of expertise should be identified and recognized as a
resource within the team. Ongoing training needs for the SME should be identified and formalized
through the performance management process in order that their knowledge level remains current
and relevant. The listing of subject matter experts should be shared across the program team to
ensure they may be consulted as required during the interaction with the employer/firm. Active
participation and involvement between subject matter experts and the employer will build credibility,
enable knowledge transfer and retention of expertise within the program.
Theme
Program
Resources
26
Program resources - The level of resources, both financial and human, which are committed to the
program, should be commensurate with the program design and objectives. Program outputs and
outcomes should be monitored to ensure optimal program performance.
Program organization structure - The program organization structure should be designed to ensure
that appropriate levels of administrative control, oversight and field level support are in place. For
example, a Field Supervisor type role with responsibility to review and approve completed
interventions, communicate with employers for customer service issues and provide program
introduction seminars to the employer community would be beneficial as a link between field
operations and head office functions.
Staff performance objectives - The workload target quantity of interventions to be performed by
staff should consider the overall program goals and objectives in addition to throughput volumes. A
series of factors should be considered to plan the potential effort required to complete an intervention
such as:
-employer history and risk profile(s);
-number of employees;
-number of facilities/locations;
-square footage;
-number and type of shifts;
-nature of workplace hazards.
Based on the anticipated and actual efforts to complete a case a scalable metric should be developed
to record and track the types of interventions to be completed by program staff.
Theme
Targeting and
Intervention
Use of predictive analysis in Firm Selection Model – The system partners should collaboratively
identify and establish a methodology and criteria to enable more timely workplace interventions with
firms experiencing poor health and safety records. The use of current performance metrics and
predictive analysis should be considered in the Firm Selection Model to ensure that issues within
firms are quickly and proactively addressed to reduce risk and potential cost to the employee,
employer, WSIB and system partners.
The Firm Selection Model should be made available to the public through the partner’s websites. This
would increase program transparency and enhance employers’ understanding of why they have been
selected for intervention.
Intervention types and data analytics – A series of workplace interventions should be developed to
ensure the widest possible coverage of Ontario’s workplaces based on results output from the Firm
Selection Model and other targeting methods. Workplace interventions by type should be tracked and
analyzed. This analysis will also be of use to determine which type(s) are most effective in order to
inform future resource deployment. Consistent criteria should be created to identify the type of
workplace interaction which is appropriate for the employer’s circumstances, risk profile and health
and safety system which may be in use.
The use of current injury data (i.e., subsequent to the intervention) should also be considered to
determine which interactions are most effective at sustaining improved health and safety
performance. Factors to consider may include injury profile, firm size and injury results by full-time
equivalent (FTE).
Targeted interventions - A detailed analysis of multi-site operations identified during the selection
process should be completed to ensure that the location(s) and incidents responsible for poor
performance are targeted and reviewed during the intervention. This analysis will enable program
resources to be deployed to areas of highest risk within selected organizations.
27
Theme
Outcomes and
Reporting
Dashboard reporting – The program should develop and implement reports and dashboards to
enable tracking and ongoing performance for key metrics such as lost time injuries (LTI) and high
impact claims for firms which have been selected for intervention. Use of these types of analytics will
assist health and safety system partners in identifying those firms which are chronic repeaters in the
selection process in a more timely manner. In addition, positive outcomes for firms that have
embraced health and safety as a result of interaction with the program may be identified. Where
possible, this trending data should be shared with other partners in the health and safety system to
ensure that appropriate and targeted interventions are executed.
Continuous program improvement – The program should develop and implement a process to
obtain feedback from stakeholder groups (e.g., employers, workers, system partners) to assess the
program’s effectiveness and delivery compared to its goals and objectives. Feedback obtained
through the process (e.g., program experience surveys completed by firms which have participated in
an intervention) should be evaluated by program management and staff to identify solutions in order
to address noted concerns.
28
Theme
Data collecting and sharing - As part of the program design consideration should be given to
ensure that data, results and other program information can be shared and reported across the
system partners as required. The program should consider an inventory of the relevant data,
classification of data, ranking (i.e., who has access to the data) and how the planned use of data
aligns with management’s decision making.
Information
Technology
Systems
29
Bill 160 Alignment
Detailed Findings
Supporting Analysis
30
Bill 160 alignment supporting analysis and findings
Workwell alignment in the new health and safety system in Ontario
To foster a commitment to
occupational health and
safety among employers,
workers and others
To educate employers,
workers and other persons
about occupational health
and safety
Bill 160 Prevention Mandate
To promote occupational
health and safety and to
promote the prevention of
workplace injuries and
occupational diseases
Provide compensation and
other benefits where RTW
cannot be achieved
Facilitate RTW, recovery
and LMR of workers who
sustain a work related
injury or occupational
disease
Promote health and safety
in the workplace
New WSIB Mandate
To promote public
awareness of occupational
health and safety
Characteristics of Workwell* in
in its current form
Targets worst performers
Attempts to interpret/provide
guidance on regulatory compliance
Punitive (fines) versus incentive
(achievement)
Prescriptive (one way) versus flexible
(many ways to meet intent)
Short term (one time) versus long
term (developmental) focus
*Source: Workwell Evaluator Evaluation Process & ISO 19011:2002
31
Lack of alignment
Partial alignment
Strong alignment
Value for Money
Opinion Detailed
Findings
Supporting Analysis
32
Rating:
Audit
Criteria
Attribute: Roles, responsibilities, accountabilities, and performance expectations are
defined, understood, and consistently executed by management and staff
Defined
Understood
Consistently
Executed


Some
confusion
around
execution
Accountabilities



Performance
Expectations


Variations
noted
Roles and
Responsibilities
Systems
Resources
Selected Workwell Performance Objectives
Organizational
Excellence
Outcomes
33
Some Improvement Required
Service
Excellence
•
Minimum of sixty (60) evaluations
are completed on a rolling twelve
(12) month basis
•
Complete assigned evaluations
within 6 - 8 months of the first audit
•
Deliver presentations and workshops
as assigned
•
Surcharges and credits to be posted
to PeopleSoft A/R within 2 weeks of
evaluation completion
•
Introductory phone call to customer
within 15 days of notification letter
mailing
•
Send evaluation letter, audit or RMP
report to customer within 10 days of
completing the audit or RMP
• Job descriptions noting the Job Summary,
Major Duties and Responsibilities and Job
Requirements are in place for the Workwell
Evaluator and Manager roles.
• Input from the stakeholder sessions noted that
there is some confusion internally and
externally regarding the extent of Workwell
Evaluator’s ‘consultative services’ and
‘compliance’ type activities (Role Clarity and
Expertise).
• The Workwell objective is to complete 60 cases
per evaluator over a 12 month cycle.
Workwell Evaluator Closure Statistics for the
period December 1, 2009 to December 1, 2011
indicate that the 23 Workwell Evaluators
completed 1,748 cases (Program Resources):
• 38 completed cases per 12 months is the
average per Workwell Evaluator;
• 3 (13%) Workwell Evaluators completed
more than 60 cases;
between 30 and 59 cases; and
less than 30 cases.
• The Workwell team meets monthly, records
meeting minutes and assigns action items for
follow-up.
Rating:
Audit
Criteria
Systems
Attribute: Appropriate administrative controls and safeguards are in place to mitigate
Program risks
• A Workwell Evaluator Evaluation Process and ISO 19011:2002 flow chart has been developed by
the team during 2011. The flow chart overlays the ISO methodology of ‘Plan, Do, Check, Act’ on
to the Workwell Evaluation Process. However, the application of the methodology does not align
with actual Workwell practices (Program Resources).
• A Workwell Evaluators Findings Committee is in place. The purpose of the Committee is to
establish a consistent response to issues which have been identified during execution of Workwell
audits. However, the former Chair is no longer with the Workwell program and consequently the
Committee has not met regularly during 2011 (Program Resources).
• The Workwell Evaluators Findings Committee is not specifically identified on the Workwell
Evaluator Evaluation Process and ISO 19011:2002 document as a control for monitoring,
reviewing or improving the audit program.
Resources
Outcomes
34
• Workwell assigns cases based on postal codes noted in the FSA List – 2011. Employer and
worker/labour stakeholders noted concerns that the Workwell Evaluators may not have sufficient
and appropriate background to understand the nature of all the business types which they are to
review (e.g., healthcare institutions, large construction sites). Workwell Evaluators have the
opportunity to request the assistance of colleagues to provide background and context (e.g., due
to their expertise within an industry/sector) during an audit. There is opportunity to increase the
level of auditor calibration and use of industry/sector experienced resources in order to address
employer concerns that Evaluators may not have appropriate background to understand their
business (Role Clarity and Expertise).
• A System Collaboration Branch Survey of Employers Undergoing First Workwell Audit was
completed January 4, 2011 but did not obtain feedback on the entire Workwell customer
experience. There may be further opportunity to address customer concerns within the program
execution (e.g., implementation timelines for phase 2; pass/fail requirements for audit elements)
by conducting a survey of the entire Workwell timeframe (Outcomes and Reporting).
• Operating budgets are prepared and monitored monthly. Workwell surcharge/revenue tracking
and reporting is not consistently performed.
Rating:
Audit
Criteria
Attribute: A tracking and reporting process is in place to monitor Program performance,
and performance metrics are monitored and acted upon
Tracking & reporting systems with select
performance metrics tracked
Systems
Workwell Case
Information
System (WCIS)
 Number of open cases per Workwell
Evaluator
 Aging of open cases
 Upcoming case load counts ,
scheduling and timing
 Case approval listing for Managers
(Request Assistant for an evaluation;
surcharge > $100,000)
Resources
Health & Safety
System –
Target and
Performance
Dashboard
(quarterly)
 Performance reporting
 Injury Profile – LTI Count
 High Impact Claims – LTI Count
 System Partner Cohort Injury Rates
Performance
 System Partner Cohort Engagement
 Health and Safety Association Injury
Rates Performance
• Workwell Managers run periodic reports from the
Workwell Case Information System (WCIS) to
monitor Evaluator case loads and upcoming
schedules.
• Depending on circumstances within the team,
cases may be re-assigned to other Evaluators.
• Management review and approval for case
specific requests are also routed through WCIS.
• WSIB prepares quarterly dashboards which
include LTI rates for Workwell audited firms. The
dashboard report is a point in time value and
does not include metrics to demonstrate
sustainability of improved performance over time
for firms which have been through Workwell.
• The LTI rate reported in the dashboard is based
on those firms which interacted with Workwell
during that quarter. This approach does not
provide an assessment of the potential impact of
having been through the Workwell evaluation
(Outcomes and Reporting).
• Trend type data analysis is not regularly
performed by program management for internal
review or to be shared at an operational level
with the Workwell Evaluators.
Outcomes
35
Rating:
Audit
Criteria
Attribute: The information technology systems in place to support the Program have the
desired functionality to deliver and monitor the Program
Workwell Case Information System – Selected
current system functionality
Systems
Resources
 Web based solution is
available 24/7
 Schedule manager
 Use of pre-determined
alerts
 Case management
options by role
 Core Health and Safety
Audit, Small Business Audit,
Agriculture Audit and Risk
Management Plan templates
 Editable templates for
Audit Cover Letter, Audit
Results
 Secure access with User
ID and Password
 Automated calculation of
audit results
Workwell Case Information System – Opportunities
to enhance functionality
 Use of electronic forms
which can be uploaded into
WCIS
 Improved formatting
capabilities for Audit reports
 Built in spell checking
within the system
 Surcharge tracking to
enable management
monitoring and reporting
Outcomes
36
• Evaluators consider the Workwell Case
Information System (WCIS) to be a positive
application for performing their duties.
• There is opportunity for efficiency improvement
by enabling the use of electronic
forms/documents to eliminate duplication of
Workwell Evaluator efforts in manually reentering audit results into WCIS. Presently,
Workwell Evaluators manually complete the
audit using paper based forms which they then
input into WCIS (Information Technology
Systems).
• The Workwell Evaluators noted that they have
identified additional improvements to the WCIS
functionality which have not been implemented
due to resource constraints.
• During the information request and data
selection process numerous instances of poor
data quality and integrity issues were noted by
Workwell management.
• Systems controls and reconciliations for data
between Workwell and injury history do not
appear to be in place. This is further evidenced
by the lack of ongoing reporting of injury
history related to Workwell firms due to
challenges in combining and consolidating
results from multiple systems (Information
Technology Systems).
Rating:
Audit
Criteria
Attribute: Policies and processes supporting the Program are documented, communicated
and understood by management and staff
Workwell Program Policy and Guidelines
Policy
Systems
“The Workwell program issues an
additional premium charge to employers
who have not taken sufficient
precautions to prevent accidents in the
workplace.
Workwell operates independently of the
WSIB’s experience rating programs and
its additional premium charges are
issued in addition to any premium or
premium rate adjustments that may be
realized through experience rating.”
Guidelines
Resources
Workwell identifies employers with
particularly poor accident records and/or
high accident costs compared to their
rate group and/or rate groups, or who
have a history of non-compliance with
the Occupational Health and Safety Act
and encourages them to improve their
prevention programs.
Workwell requires these employers to
participate in a workplace health and
safety evaluation. Employers that fail
the evaluation are given a specified time
frame to make improvements. If
improvement does not occur within the
given time the WSIB issues an
additional premium charge.
Outcomes
37
Significant Improvement Required
Governing Law and Policy
s.82 (1) (4)
Workplace Safety and Insurance Act
13-01-02
Workwell Program
• During the stakeholder sessions comments
were noted that there is lack of clarity amongst
staff (and consequently customers) regarding
the Workwell mandate (i.e., is it compliance or
instructional and guidance driven) (Program
Strategy and Communications).
• Workwell is included on the WSIB website as an
Incentive program.
• The Workwell Program Policy indicates that
“Employers that fail the initial evaluation are
required to work with a health and safety
program provider (e.g., a Health and Safety
Association) to improve their compliance with
the evaluation criteria. Failure to do so results
in the immediate levying of the additional
premium charge, based on the initial evaluation
score”. This policy provision has never been
put in place. The inclusion of reference to a
secondary additional premium charge within
the Workwell Program Policy further increases
the perception that the program is punitive in
its intent (Program Strategy and
Communications).
• Through the stakeholder discussions it was
noted that the program’s operational policies
and procedures are understood by Workwell
Rating:
Audit
Criteria
Attribute: Program resources are managed efficiently to meet Program demands
Number of Workwell Cases Closed
• Average annual value for Workwell surcharges
assessed over the past three (3) years is
$978,000 and average program cost is
$2.7million.
• The program’s actual spend ($2.9 million) is
presently operating at approximately 71% of the
year to date budget with only 65% (22) of the 35
budgeted FTE. Management indicated that some
staff have left the program due to uncertainty
and have not been replaced. Field Supervisor
positions are not in place (Program Resources).
Systems
• Stakeholder sessions noted that there is
perception in the worker/labour and Health and
Safety Association groups that there are
insufficient Workwell resources to address the
number of firms requiring improvements to their
safety practices.
Resources
Average Cost of Closed Cases
• Large, multi-site audits impact the ability for
Evaluators to meet the 60 completed cases
expectation. There is opportunity for more
targeted interventions in these instances
(Targeting and Intervention).
• Risk Management Plans represent approximately
8% of completed cases for the past two (2)
years. Performing additional Risk Management
Plans may be a more effective use Workwell
Evaluator resources and increase the coverage of
selected employers. (Targeting and Intervention)
Outcomes
Source: Evaluator’s Activity Summary
38
Rating:
Audit
Criteria
Attribute: Policies and processes are executed in a timely manner
Systems
Resources
Outcomes
39
• The use of lagging indicators in the Firm Selection
Model and Workwell Selection criteria results in a
considerable period of elapsed time (potentially
greater than 2 years) prior to being identified for
Workwell. (Targeting and Intervention)
• Through discussion with WSIB management it
was noted that there are ongoing initiatives to
identify and possibly use predictive analysis as a
tool to assist in the selection processes for other
WSIB compliance type audits. There is
opportunity to consider use of predictive metrics
in the Firm Selection Model and more targeted
interventions within the Workwell program.
• The Firm Selection Model and Workwell Selection
criteria are not published on the WSIB website.
Through discussion with employers concern was
expressed that firms are being held accountable
to standards of which they do not have
awareness (and which may also change annually)
until such time as they are identified for a
Workwell audit.
• The Workwell process may result in a selected
firm not being audited for more than 12 months
after being notified that they have met the
Workwell criteria. This could be up to three (3)
years of elapsed time after the event(s) which
resulted in Workwell selection.
Rating:
Audit
Criteria
Attribute: Identified challenges and issues are addressed in a timely fashion and in
accordance with the established escalation and resolution process
Systems
Resources
Outcomes
40
• There is lack of an integrated prevention
approach and mechanisms between Workwell and
other programs in Ontario’s health and safety
system to foster sustainability (e.g., transition for
Workwell audited employer into a sustaining
program such as SCIP or Safety Group). Workwell
related ‘fee for service’ options are presented to
employers on the Health and Safety Associations
websites which also receive funding directly from
the WSIB (Program Strategy and
Communications).
• There are ongoing efforts to increase the touchpoints in the system through sharing Firm
Selection Model results with the Ministry of
Labour and Health and Safety Associations.
• There is a lack of consistency within standards,
methodologies and competencies across the
system which results in frustration and reduced
engagement of all available resources in the
employer community.
• A Workwell appeals process is in place through
the WSIB for employers who are not in
agreement with the audit result. Appeals are not
frequently successful and the results overturned.
Analysis of the reason(s) for the appeal being
launched is not performed. (Outcomes and
Reporting)
Rating:
Audit
Criteria
Attribute: Adequate training and development programs are in place for management
and staff to ensure succession planning and knowledge retention
Overview of Workwell Evaluator Orientation/Training
Program – Selected Weekly Objectives
Week 1
 Obtain an initial understanding of the role
and purpose of the Workwell Program with
OH&S system
Week 2
 Understand the structure and content of the
Workwell Core Audit
Systems
 Through case study apply the audit content
to the OH&S program of a suitable firm
Week 3
Assigned to two different senior Evaluator’s
for audit shadowing opportunities
Week 4
 Conduct research into assigned firms using
CICS/RESET and other databases
Week 5
 Attend Collision Free and Skid school driver
safety training
Weeks
6-8
 Shadow a minimum of 2 audits per week with
experienced Evaluator
Weeks
12-14
 Conduct audit of at least 8 of their own files
while being shadowed by experienced Evaluator
or Manager
Resources
Outcomes
Team Training Activities for 2010 and 2011
 Working at Heights
 Machine Guarding
• An Orientation/Training Program is used to
onboard new hires to the team.
• Workwell Evaluators completed CSA Z1000
Essentials Course and OHSAS 18001 training in
2009. The Workwell team has approximately
two (2) professional development days annually
• Through discussion with employers and Health
and Safety Associations concerns were
expressed about a lack of experience and
background by Workwell Evaluators in some
industry/sectors. The stakeholders indicated
that the lack of background in some instances
resulted in misinterpretation or
misunderstanding of certain systems or
processes in the firm by the Workwell
Evaluator.
• There are members of the Workwell team who
are considered to be subject matter experts in
some industries/sectors due to their previous
experience. A formal mechanism to identify the
areas of expertise and to continue to develop
and retain the Evaluator’s experiences and
capabilities is not in place. (Role Clarity and
Expertise)
• Formal succession planning processes are not
in place for Workwell management positions.
(Role Clarity and Expertise)
 Insights into Influencing Workshop
 Note Taking and Interviewing Techniques Facilitation
 WHMIS: Our Right to Know
41
Rating:
Audit
Criteria
Critical
Attribute: The Program has clearly defined objectives that are aligned with
organizational strategies, and there are measures in place that demonstrate
satisfactory progress towards those objectives
• The Workwell Policy and information published on the WSIB website indicate that Workwell’s
mandate is prevention and the “evaluations help workplaces identify weaknesses in workplace
health and safety programs and practices”.
Systems
• Metrics to demonstrate evidence of the program’s ongoing success (i.e., fewer injuries and
illnesses, reduced risk of injury) to internal or external stakeholders are not tracked and reported
at a level to enable conclusions to be made of the program effectiveness. As noted earlier, LTI is
the key Workwell metric reported on the WSIB dashboards (see below for example of dashboard
reporting). (Outcomes and Reporting)
• Some employers noted that Workwell will temporarily raise awareness of health and safety within
an organization but in many cases is not sustained over the long term.
Resources
• Based on review of the WSIB Strategic Plan, Corporate Measures reports, Workwell Policy
documents and discussions with stakeholders the current Workwell prevention mandate does not
demonstrate alignment with the updated WSIB mandate, vision statements and strategic
direction.
2011 YTD System Partner Cohort Engagement
2011 System Parter Cohort Injury Rates Performance
System Partner
Outcomes
42
WORKWELL
SCIP
SAFETY GROUP
VU
OHCOW
MOL
IHSA
PSHSA
WSN
WSPS
# of Firms
%
in Cohort Engaged
1,260
985
3,400
2
4
5,000
1,575
1,002
402
2,245
89%
87%
97%
100%
100%
22%
96%
56%
100%
39%
% High
Engaged
32%
11%
0%
100%
100%
100%
63%
74%
26%
43%
System Partner
WORKWELL
SCIP
SAFETY GROUP
VU
OHCOW
MOL
IHSA
PSHSA
WSN
WSPS
LTI Rate
2011
LTI Rate
2010
1.92
1.59
1.35
2.50
0.00
1.28
1.69
1.35
0.76
1.45
2.39
1.87
1.50
3.12
2.32
1.50
1.95
1.67
0.82
1.81
LTI Rate
Outcome
Total Rate
2011
Total Rate
2010
6.38
5.36
5.49
12.52
9.81
5.28
6.36
4.01
4.85
5.62
7.16
5.80
5.80
20.05
4.63
5.40
7.06
4.34
5.10
6.36
Total Rate
Outcome
Rating:
Audit
Criteria
Critical
Attribute: The Program contributes to a sustainable reduction in injuries and illnesses in
the Province’s workplaces
• Workwell’s effect on reducing injuries and illnesses is not conclusive after analysis of Workwell data.
• Overall societal trends, economic conditions, and the impact of other Health and Safety
organizations/programs such as Experience Rating influence LTI rate decreased presented in
addition to Workwell.
Systems
• Analysis suggests that factors external to Workwell have a greater influence than Workwell on LTI
rate decreases.
• The table below exhibits that companies improve LTI rate with or without Workwell intervention.
Average LTI Rate / Cohort
LEGEND
Incident
Year
Resources
Year of WW
Interaction
Outcomes
Year
2003 2004 2005 2006 2007 2008 2009 2010
Average LTI Rate 2006 Cohort
5.46
5.41
10.58
5.20
3.84
3.42
2.26
2.24
4.45
3.56
3.40
12.16
2.75
4.97
2.92
2.23
3.8
3.9
3.9
14.0
3.1
3.6
2.7
1.9
Average LTI rate 2009 Cohort
4.1
3.8
4.1
4.2
7.1
3.7
2.7
2.7
4.6
4.2
5.4
5.3
4.2
6.3
3.6
2.7
• LTI rates spike in incident years, however, firms revert
to their pre-incident year downward trend with or
without Workwell interaction (see appendix for trend
summaries for each cohort).
• The spike in LTI rates implies that poor performance
years are discrete events as opposed to consistent
trends. Firms appear to action these events
themselves.
43
• LTI rate was decreased even though
Workwell interaction did not occur.
•
The amount of decrease is similar to
years were Workwell interaction
occurred in the year directly
following poor performance.
Rating:
Audit
Criteria
Critical
Firms experience decreased LTI rates due to a combination of factors such as:
Societal Trends - Schedule 1 acts as a proxy for the influence of overall societal trends on LTI rate
decreases.
Systems
Own Motivation / Other Influencers - The “No Interaction – Met Criteria” cohort serves as a
proxy for how firms with poor performance behave after the year of poor performance due to
influences outside of Workwell.
Workwell Influence
It is the incremental decrease in LTI rate that firms experience over and above the LTI rate
decrease experienced by “Schedule 1” and “ No Interaction,- Met criteria” that approximate
Workwell’s influence. Therefore, even though in 2010 the cohort “Had Workwell interaction”
experienced a 58% total decrease in LTI rate, it is reasonable to estimate that:
• 29% of that total 58% decrease was due to the firm’s own motivation / external factors.
• 24% of that total decrease was due to overall societal trends.
Resources
26%
37%
44
42%
33%
Outcomes
2006 Cohort
5%
29%
2007 Cohort
Invalid
Data
2008 Cohort
Total LTI rate
decrease
20%
16%
58%
LTI RATE
LTI Rate Decrease
Of total LTI rate decrease
potentially attributable to WW
potentially attributable to firm’s
own motivation
potentially attributable to overall
societal trend
5%
29%
26%
24%
2009 Cohort
2010 Cohort
Rating:
Audit
Criteria
Critical
Year-Year Comparison
Systems
• Due to a change in Workwell selection criteria in 2009, more firms with performance that was not as
poor as 2006/07 cohorts were selected for Workwell. As this cohort’s performance was not as bad
there was less room for improvement, and therefore the total decrease in LTI rate was smaller.
• Additionally, the incremental influence of Workwell decreased while the influence of firms’
own motivation/other influencers decreased.
Workwell Impact – Short Term
Resources
Outcomes
45
WW Interaction
Schedule 1
% Decrease in
LTI Rate:
No WW interaction – Met Criteria
Incident Year –
2010
Had WW interaction
Incremental LTI rate Improvement over
Incremental % Schedule 1
decrease in LTI
Incremental LTI rate Improvement with
rate
WW Interaction
2006 2007 2008 2009
Cohort Cohort Cohort Cohort
37%
29%
26%
42%
63%
62%
79%
82%
26%
33%
16%
20%
2007
cohort
used –
data
invalid
68%
5%
63%
42%
5%
Rating:
Critical
• Workwell firms have similar LTI rate
decreases from 2003-2010 as schedule 1
firms, indicating that they follow the same
trend in LTI rate as schedule 1.
• Workwell does not seem to have a sustainable
effect on LTI rate decreases because firms
appear to return to their prior LTI level after
their year of poor performance and do not
consistently perform better than their
Schedule 1 peers in the long term.
• Firms that are “Notified Only” receive no
further interaction in their cohort year beyond
a notification letter. However, all firms that
have any other interaction with Workwell,
(RMP / Audit) receive a notification letter first,
in addition to their RMP/ Audit.
• The percentage decrease that firms experience
from an RMP or an Audit may be influenced by
the fact that they first receive a letter of
notification in addition to their Workwell
intervention.
• RMP was the most effective Workwell
interaction overall in terms of decreasing LTI
rate.
• “Notification Only” was the second most
effective Workwell interaction in terms of
decreasing LTI rate.
46
Workwell Impact – Long Term
WW Interaction
%
Decrease
in LTI
Rate
20032010
Schedule 1
2006 2007 2008 2009 2010
Cohort Cohort Cohort Cohort Cohort
42%
42%
No WW interaction –
52%
Met Criteria
59%
Had WW Interaction
50%
59%
Invalid
data
42%
42%
38%
43%
35%
42%
Most Successful type of Workwell Interaction
Cohort
Year
Most effective at
decreasing LTI
Rate
Incident year - 2010
Second most effective at
decreased LTI Rate:
Incident year – 2010
2006
RMP
Notified Only
2007
RMP
Notified Only
2008
RMP (same %
decrease as Notified
only )
Notified Only (same % decrease
as RMP)
2009
First Audit Pass
RMP/ Notified Only (both equal
decrease )
2010
Notified only
First Audit Pass
Rating:
Audit
Criteria
Attribute: The Program meets the needs or the workplace parties in the Province of
Ontario
• There is a split of opinion between worker/labour groups (favour Workwell) and employer groups
(generally disfavour Workwell).
• Workwell’s program mandate and objectives are not clear in the employer community (e.g., role
differentiation with Ministry of Labour Inspectors).
Systems
• The program is perceived as punitive due to the surcharge resulting from failing an audit.
• Workwell is the only health and safety system compliance evaluation in the province outside of
those conducted for fee by independent firms or consultants.
• Employers indicated support and value for Safety Groups. Safety Groups LTI rates have
outperformed Workwell over the past 3 years based on the metrics reported in the WSIB
dashboard.
• The Workwell Core Health and Safety Audit tool provides a very comprehensive evaluation of a
firm’s health and safety system. However, there are opportunities for improvement in the design
and execution of the tool (Targeting and Intervention):
Resources
• Workwell is a ‘bolt-on’ approach to health and safety versus a ‘built’ system. The approach
is prescriptive and does not recognize systems in place which may be suitable for the
business but do not meet Workwell’s definitions.
• The scoring methodology is based on receiving all of the points or none of the points for
each element. There is no opportunity for the recognition of efforts that are underway in
the organization.
• A firm can fail a key section of the audit (e.g., health and safety hazards) yet still receive
an overall audit pass. An audit pass is only 75% of the Workwell standard.
Outcomes
47
• The document is heavily influenced by references to industrial type descriptions and
examples which reduces the program credibility in non-industrial applications.
(cont’d…)
Rating:
Audit
Criteria
Attribute: The Program meets the needs or the workplace parties in the Province of
Ontario
(…cont’d)
• The timeline to implement and train employees for the changes required after Phase 1 is
generally insufficient. Many organizations do not have resources to dedicate to developing
and implementing the health and safety program in the six (6) month timeframe.
Systems
Resources
• There is heavy emphasis on documentation versus observing operations/practices and
looking at compliance in action. If a firm does not score points for Documentation then
Observation and Interview are not evaluated.
• The province is presently experiencing a dynamic environment related to workplace health and
safety due to the introduction of Bill 160, the WSIB Funding Review and the changing WSIB
mandate. Ontario workplaces do not have access to an integrated approach for prevention and
health and safety programs. Our audit indicates that, notwithstanding confusion as to the existing
mandate of the Workwell program, Workwell in its current form no longer aligns to WSIB’s
mandate. The current system is a series of initiatives, including Workwell, and organizations
which have limited involvement with each other and do not have standardized expectations for the
types of health and safety systems which should be in place to reduce risks, safeguard employees
and protect the interests of WSIB premium paying employers.
Outcomes
48
Interjurisdictional
Research
Other workplace health and safety
prevention and compliance programs
49
Interjurisdictional research
A review of the practices that other workers compensation boards have around compliance, prevention and
incentives has identified several interesting differences amongst programs. Other programs are voluntary and
offer rebates as a reward for completing a series of requirements that award successful firms with a Certificate
of Recognition (COR). These programs use industry partners for firm audits, required to gain a COR. There is
a high degree of collaboration amongst industry partners, other stakeholders, and COR programs. In line with
Workwell’s approach British Columbia and Alberta have modified programs for small companies.
Alberta
50
 A Certificate of Recognition (COR) is a document issued
jointly by a Certifying Partner (e.g., ENFORM, Construction
Safety Association, Manufacturers Health and Safety
Association, and Human Resources and Employment,
Workplace Partnerships.) The COR recognizes that an
employer’s health and safety management system has
been evaluated by a certified auditor and has been found to
meet the Partnerships' standard.
 The Partners in Injury Reduction (PIR) is completed in order
to attain COR. The program encourages the development
of effective workplace health, safety and disability
management programs.
 Achieving & maintaining a valid COR is required for earning
refunds from WCB if registered in the WCB PIR Program.
 Through this voluntary program, the Alberta Workers’
Compensation Board (WCB) works with Alberta
Employment and Immigration, industry partners, safety
associations, employers and labour groups to offer WCB
premium incentives. Employers who reduce their claim
costs below predicted targets and achieve a COR can earn
up to 20 per cent off their industry rate.
 In order to qualify for COR an audit must be carried out by a
certified auditor. An audit covers the basic elements of a
health and safety system, personal interviews,
documentation review, and work place observation. To
acquire COR, you must receive 80% overall mark without
less than 50% in any one element.
 SECOR : The Small Employer Certificate of Recognition
(SECOR) program provides an option for employers with 10
or less employees to develop a health and safety
management system and achieve a Certificate of
Recognition (COR) referred to as SECOR (Small Employer
Certificate of Recognition). This program is specifically
designed to meet the training needs of smaller employers.
British
Columbia
 “Partners in Injury and Disability Prevention Program” offers
incentives to employers who work with a Certifying Partner
to go beyond the legal requirements of the Workers
Compensation Act and the Occupational Health and Safety
Regulation and take a best practices approach to
implementing health, safety, RTW management systems.
After passing an audit, employers receive a Certification of
Recognition (COR) and become eligible to receive an
incentive payment.
 Annual incentive payments are awarded to eligible
employers who have earned a certificate of recognition
(COR) in one or more of the following areas:
 Health and Safety Management = 10% incentive
 Injury management/ RTW system = an additional
5% incentive
 Extremely detailed and sophisticated statistics reporting.
Manitoba
 To obtain COR accreditation, an employer must undergo a
safety training program, develop a company safety manual,
develop and implement a health and safety program, and
pass an independent safety audit.
 COR certification is administered by the Manitoba Heavy
Construction Association Work Safely Program and the
Construction Safety Association of Manitoba.
 The initiative is self-funded by all construction employers in
Manitoba. There is no additional cost to employers in other
industries.
 The Manitoba Government and the WCB have joined with
partners in labour and the business community in a
comprehensive injury prevention program under the banner
of SAFE Manitoba. The joint prevention initiative grew out
of recommendations from the Minister of Labour's Review
Committee on Workplace Safety and Health.
Internal Consultations/
Documentation Review
Summary of Internal Consultations Conducted and
depiction of the Types of Documents Reviewed as part of
the Audit
51
Stakeholder consultations
The following tables summarizes the type of stakeholder consultations that have been conducted in order to
augment the audit opinion findings and conclusions. The themes noted during discussions are a high level
summary of views expressed by the stakeholders during the sessions while responding to a series of
questions related to the Workwell program and Bill 160.
Group
Format
Internal
Executives
Individual Interviews
(x1)
Shift responsibility for performing the Workwell audits to
the Health and Safety Associations. This would enable the
Associations to expand their footprint in the employer
community and integrate, where possible, with their
existing programs. Employers would be audited by their
respective association which may reduce complaints that
Workwell Evaluators do not have background or
understanding of the relevant business/industry sector.
Steering Committee
Meetings (x7)
N/A
Program
Management
(numerous discussions
throughout the
engagement)
Retain Workwell within the WSIB as a risk and compliance
type program. The program delivery, communications and
execution would be enhanced to improve the overall
customer experience.
Program Staff
Focus Group (x1)
Numerous meetings and
follow-up throughout the
engagement
N/A
(Workwell Evaluator
Team Meeting
December 5, 2011,
Hamilton, ON)
Data Analytics Staff
52
Themes noted during consultations
Stakeholder consultations (cont’d)
Group
Employer and/or
Umbrella Groups
Format
Focus Group(x1)
Themes noted during consultations
Leverage the previous WSIB efforts and implement an
incentivized accreditation type program including
employer self-assessments and sample based testing by
certified examiners to provide governance and oversight.
Eliminate Workwell and continue with Ministry of Labour
inspections to provide enforcement of health and safety
requirements within Ontario’s workplaces.
External
53
Worker/labour
Groups
Focus Group (x1)
customer experience. Increase the annual number of
employers which undergo Workwell.
Health and Safety
Associations
Focus Group (x1)
Government
(x1)
Implement the leading practices from the Workwell
program into the new ‘continuum of compliance’
prevention strategy. The leading practices would form the
Chief Prevention Officer’s basis for various levels and
types of employer interventions between prevention
activities and enforcement measures.
Documentation review
The following tables shows the types of documents that have been reviewed as part of the Audit in order to
augment the audit opinion findings and conclusions.
Workwell Role,
Responsibilities, Policies
and Process Details
• Workwell Evaluator Job
Description
• Workwell Manager Job
Description
• 2011 Organization Chart
at November 11, 2011
• Workwell Evaluation
Process ISO19011
October 25, 2011
• Policy 13-01-02 Workwell
Program
• Workwell Health and
Safety Core Audit Tool
• Workwell Case
Information System User
Guide
• 2010 and 2011 Workwell
Team Meeting agendas
• Workwell Large Firm
Audit Procedure
• Workwell Findings
Committee Procedure
• Workwell Evaluation and
Risk Management Plan
files
• Workwell Evaluator
Orientation/Training
Program
54
External and Internal
Focus Groups, Research
and Analysis
• Survey of Employers
Undergoing First Workwell
Audit Final Report for Pre
and Post Audit Surveys
January 4, 2011
• Firm Selection Model
Presentations for 20082011
• Table Differentiating the
Roles of the Workwell
Evaluator and MOL
Inspector
• Understanding Workwell
Core Fall 2011
(presentation to selected
employers)
• Health and Safety
Associations Consulting
Services
• Jurisdictional Scan for
Workwell Equivalents
• Workwell Budgets and
Actuals Analysis for 20062011
• Listing of Workwell Appeals
for 2007-2011
• Employer Audit Services
2012 Audit Plan Fact Sheet
Other
Relevant Statistical Data
and Information
• Workwell Evaluator’s
Activity Summary for
2006-2011
• Bill 160
• Data analytics: Firms
Meeting WW Criteria,
Firms Notified Only ,
Firms 1st Audit Pass ,
Firms 2nd Audit Pass ,
Firms 2nd Audit Fail,
Firms RMP for 20062011 (as available)
• Workwell Presentation to Chief
Prevention Officer
• Chief Prevention Officer roles
and responsibilities
• Tony Dean Report
• WSIB Funding Review
Background material
• 2010 IHSA , PSHSA,
WSN, WSPS High
Engaged Cohort
• 2010 MOL Engaged
Cohort
• Derived FTE, LTI count,
NLTI count, LTI Rate,
NLTI Rate, Traumatic
Fatality Count, Lower
Back Claim Count,
Shoulder Claim Count,
Fracture Claim Count, %
of Claims off Benefits at
3 months, % of Claims
off Benefits at 6 months,
% of Claims off Benefits
at 12 months for injury
years 2003 -2010
Appendix
55
2006 Cohort
56
2006 Cohort – Results Summary By Cohort
% change:
Interaction incident yr
- 2010
1st Audit
Pass
73%
2nd Audit
Fail
73%
2nd Audit
Pass
79%
2006 Cohort Performance: LTI Rate
14.00
12.00
10.00
8.00
6.00
4.00
2.00
0.00
2003
2004
2005
2006
2007
2008
2006 RMP
Audit
2006 No Interaction (Met Criteria)
2006 Notified only
2009
2010
RMP
Notified
only
Average WW
interaction
No
Interaction
84%
Schedule 1
37%
82%
79%
63%
Schedule 1 - All Firms
Firms per WW Cohort
2nd Audit
Fail
2%
RMP
13%
2nd Audit
Pass
11%
1st Audit
Pass
3%
57
Notified
only
18%
Met Criteria
- No
Interaction
53%
•
Firms undergoing RMP showed the highest percentage
of decrease in LTI Rate, however it cannot be
determined what proportion of the decrease is due to
the notification versus the actual RMP itself
•
Compared to Schedule 1 firms, which reflect the overall
societal trend to be more safety conscious, WW
appears to have an impact on decreasing LTI rates in
the year directly proceeding poor performance.
However, due to the fact that firms with poor
performance improve back to the overall societal trend
in the same fashion that WW firms do, it cannot be
determined that WW improves performance more than
firms would on their own. This is particularly so when
considering that WW firms have larger room for
improvement as their performance is worse than those
with no interaction.
2007 Cohort
58
2007 Cohort – Results Summary
% change:
- 2010
1st Audit
Pass
80%
2nd Audit
Fail
47%
2nd Audit
Pass
58%
35.00
30.00
25.00
20.00
15.00
10.00
5.00
0.00
RMP
2003
2004
2005
2006
2007
2008
2007 RMP
Audit
2007 Notified only
Notified
only
52%
Met Criteria
- No
Interaction
35%
2010
Schedule 1
Firms per WW Cohort
59
2009
Notified
only
Average WW
interaction
No
Interaction
1st Audit
Pass
1%
2nd Audit
Pass
4%
2nd Audit
RMP Fail
7% 1%
94%
88%
82%
62%
29%
•
RMP firms showed the highest percentage
decrease in LTI Rate, followed by Notified Only
firms.
•
RMP firms show the most sustainable results of
those with WW interaction
•
52% of firms were notified only, marking an
increase in the use of this method compared to
2006
•
Overall, 2007 Cohort results are less sustained
than 2006, with LTI rates increasing again in
2008.
2008 Cohort
60
% change:
- 2010
1st Audit
76%
Pass
2nd Audit
76%
Fail
2nd Audit
54%
Pass
2008 Cohort Performance : LTI Rate
45.00
40.00
35.00
30.00
25.00
20.00
15.00
10.00
5.00
0.00
RMP
2003
2004
Audit
2005
2008 Notified only
Firms per WW Cohort
2nd Audit
Fail
11%
2nd Audit
Pass
2%
1st Audit
Pass
3%
61
2006
2007
2008
2008 RMP
2010
Schedule 1
93%
86%
29%
•
WW targeted 2007 cohort firms in the 2008
cohort year due to the legal issues regarding the
selection criteria. As such, a greater number of
small firms were included and no firms that met
the criteria were left without WW interaction.
•
RMP and Notified Only were the Cohorts with
the greatest percentage decrease in LTI Rates.
However, as with the 2007 cohort, results for
the notified only cohort were not as sustainable
as RMP and Audit, rising again in 2009.
RMP
10%
Notified
only
74%
2009
Notified
only
Average WW
interaction
No
Interaction
93%
2009 Cohort
62
% change:
- 2010
1st Audit
71%
Pass
2nd Audit
51%
Fail
2nd Audit
63%
Pass
10.00
8.00
6.00
4.00
RMP
2.00
0.00
2003
2004
2005
2006
2007
2008
Audit
2009 Notified only
2009 RMP
2nd Audit
Pass
23%
2nd Audit
Fail
3%
RMP
2%
Notified
only
49%
63
2010
Schedule 1
Firms per WW Cohort
1st Audit
Pass
11%
2009
Notified
only
Average WW
interaction
No
Interaction
Met Criteria
- No
Interaction
12%
68%
68%
63%
68%
26%
•
The 2009 Cohort experienced the greatest
decrease in LTI Rate from firms which passed the
first WW audit. The 2009 Cohort also had 92% of
firms with over 20 FTE.
•
49% of firms were notified only, however, there
is no increase in LTI rates following the
notification year as with other cohorts. This more
sustainable result could be due to the fact that
only 14% of small firms were notified only in
2009 compared 30-50% in the 2006 – 2008
cohorts. This may indicate that notifications have
the most sustainable effect for larger companies.
2010 Cohort
64
% change:
- 2010
1st Audit
63%
Pass
2nd Audit
54%
Fail
2nd Audit
51%
Pass
8.00
6.00
4.00
RMP
2.00
0.00
2003
2004
2005
2006
2007
2008
2009
2010 Audit
2010 RMP
2010 Notified only
Firms per WW Cohort
No
Interaction
(Met
Criteria)
65%
1st Audit
Pass
7%
2nd Audit
Fail
1%
2010
Notified
only
Average WW
interaction
No
Interaction
Schedule 1
62%
67%
58%
53%
24%
•
Similar to the 2009 cohort, the 2010 cohort is
composed mostly of firms with over 20 FTE,
however, there is a great deal of variability in LTI
rates.
•
Compared to previous cohorts, a greater degree
of variability in LTI rates, particularly for firms
that underwent RMP and Audit occurred in 2010
2nd Audit
Pass
12%
RMP
3%
Notified
only
12%
65
66

Audit Opinion supporting analysis and findings

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