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The reintegration of sick employees follows two tracks: track 1 (return to original or adapted work within the organization) and track 2 (suitable work with another employer). Track 1 is assessed before week 52; track 2 from the first-year evaluation onwards if track 1 offers insufficient prospects. Failure to comply with the Gatekeeper Improvement Act can lead to a wage sanction (up to 52 weeks of additional continued wage payment) — often amounting to thousands of euros. Below are the rules and tips for employers.
The short answer: two tracks
- Track 1: return to own or other work within the own organization. First attempt.
- Track 2: suitable work with another employer. When Track 1 is not feasible within a reasonable timeframe.
- Company doctor: advises both tracks, determines work capacity.
- Action Plan: draw up in week 8, together with the employee.
The Gatekeeper timeline
- Week 1: notification of illness, first contact employer–employee.
- Week 6: problem analysis by company doctor.
- Week 8: Draw up the Action Plan.
- Monthly: interim evaluation of the plan.
- Week 42: notification of illness to UWV (employer).
- Week 52: first-year evaluation — outcome determines track 2.
- Week 87: WIA application by employee.
- Week 104: end of obligation to continue paying wages.
Schedule these dates in your absence protocol — see absence protocol.
Track 1: own work or adapted work
Employer and employee seek a return to their original position or an adapted role within the company. Investigate:
- Adjusted working hours: fewer hours, different days.
- Adapted workplace: ergonomics, working from home, other location.
- Modified tasks: part of work, lighter work.
- Change of function within the organization: appropriate to limitations.
The company doctor advises on what the employee is reasonably capable of doing. The employer must offer what can reasonably be offered.
Track 2: other work with another employer
Actively implement this from the first-year evaluation (week 52) if Track 1 proves insufficient. Practical:
- The employer engages a reintegration agency.
- Job application training, job coach.
- Employee is actively applying for jobs.
- Documentation of all efforts.
The employer pays the costs of the Track 2 process — typically €2,500 – €7,500 per process.
Wage sanction: what if you don't do it right?
When processing a WIA application (week 87), the UWV assesses whether the employer and employee have taken sufficient steps. Insufficient? The UWV imposes a wage sanction: an extension of continued wage payment for a maximum of 52 additional weeks. Common causes of a wage sanction:
- Starting track 2 too late.
- Insufficient reintegration efforts documented.
- Action Plan not drawn up or drawn up late.
- No interim evaluations conducted.
- Do not engage a reintegration agency for track 2.
For an employee with a €4,000 monthly salary: 52 weeks of additional continued salary payment = ~€36,000 net salary plus employer contributions. Very expensive.
UWV Expert Opinion
In the event of a disagreement between employer and employee regarding reintegration, an expert opinion can be requested from the UWV. It costs approximately €100 and provides independent advice. Particularly useful for:
- Dispute regarding the suitability of the offered work.
- Employee refuses to cooperate with reintegration.
- Employer doubts sick leave notification.
Honest recommendation
Reintegration is not an administrative fill-in-the-blanks exercise but an active process. Appoint a good occupational health and safety service, collaborate according to the Gatekeeper framework, document all steps, and escalate to Track 2 on time. A wage penalty of €30,000+ is avoidable with proper process guidance.
For related topics: continued payment of wages during illness and incapacity for work.
Frequently Asked Questions
The process in which employer and sick employee work together on a return to work — first their own or adapted work within their own company (track 1), and possibly other work with a different employer (track 2). Based on the Gatekeeper Improvement Act.
Track 1 = return to own or adapted work within the own organization. Track 2 = suitable work with another employer, starting from the first-year evaluation if Track 1 proves insufficient. The employer must investigate and document both tracks.
From the first-year evaluation (week 52) if Track 1 does not appear feasible within a reasonable timeframe. Often involves the engagement of a reintegration agency, job application training, and job coaching. Starting too late results in a wage penalty.
An extension of continued wage payment by the UWV (maximum 52 extra weeks) if the employer has done insufficient regarding reintegration. This often costs SME employers tens of thousands of euros. Avoidable with proper process guidance and documentation.
The employer. Including company doctor, Track 2 reintegration agency (€2,500 – €7,500), training, coaching, expert opinions. Part of the obligations during continued payment of wages.
Continued payment of wages may be suspended, provided it is carefully documented. An official warning, a wage freeze in case of persistence, and ultimately dismissal due to culpable conduct are possible. Confirmation by the company doctor and an expert opinion from the UWV strengthen the evidentiary position.
Independent advice from UWV in case of disagreement between employer and employee regarding reintegration or illness. Costs approximately €100 and can help with conflicts concerning suitable work, reporting sick, or cooperation with reintegration.