Occupational Health incentives consultations

The Government has launched two consultations looking at Occupational Health (OH), with a view to tackle economic inactivity and increase labour force participation.

One of the consultations, led by the Treasury (HMT), looks at the role of tax incentives in boosting OH provision by employers, while the second one, led by the Department for Work and Pensions (DWP) explores proposals to increase the use of OH Services.

Please find below a short summary of each consultation paper, followed by key questions the BRC is seeking members’ views on.

We will submit a response on behalf of members, and as part of our exercise to inform this response, we are:

• Requesting written feedback on the questions below (and wider consultation questions) by 08 September 2023 (please submit your responses to gomes@brc.org.uk)
• Inviting members to join the next HR Technical call (Wednesday, 20 September, 1-2pm, MS Teams) to discuss our response – follow this link to register.

If you have any questions or comments regarding this consultation, please contact Luiza at luiza.gomes@brc.org.uk

 

Click here to read the full consultation papers and questions.

On this consultation, the government is considering a range of options to increase the levels of OH services provided by employers, which includes tax incentives, subsidies, and regulation. 

Currently, there are incentives to the provision of OH services through a Benefit in Kind (BiK) exemption that is available in respect of certain medical benefits, and the proposal is to explore the potential impact of changing the existing tax treatment for employers when they provide health related services to employees through the BiK rules, particularly how expanding the BiK exemption for medical benefits could increase the range of OH offered. 

For response: Views are welcomed on:

• What types of OH services are provided by employers across different sized businesses, and what factors influence the provision of OH
• Whether and how tax incentives for OH could encourage employer behaviour
• The existing BiK rules for employers in relation to their OH spend, and whether their scope and design is appropriate or whether they should be tailored to provide further support
• Whether there are alternative tax incentives that stakeholders consider would be more effective at incentivising employer investment in OH
• The impacts of the proposal contained in this consultation, and whether changes would be effective in increasing employer investment in OH

Existing support through the tax system: the following costs are covered under the existing BiK exemption:

• Recommended medical treatment funded by an employer to help employees return to work
• Cost of annual health screening and medical check-ups
• Welfare counselling
• Eye tests and glasses or contact lenses

For response: Employers are invited to provide feedback on: why do certain treatments are offered, what are the most common ones? What’s the impact of those in bringing people back to work?  And if the tax treatment impact business decision to offer certain treatment?

Potential additional tax relieve: government is considering offering additional tax relief for the following types of costs, relating to OH:

• Health screenings for employees, within a specific pre- defined limit
• Medical check-ups for employees, within a specific pre- defined limit
• Treatments that aim to reduce workplace absence or enable employees to perform better, including preventative treatments
• Flu vaccinations, where paid for by the employee and later reimbursed by the employer

For response: Government welcome views on how the inclusion of these treatments could have a positive impact in workplace participation, and also other costs that could be in scope.

According to the proposals, the tax treatment of these costs would remain unchanged:

• Private medical insurance for employees
• Non-clinical treatments, such as wellness retreats, fitness classes, or gym memberships
• Wages for OH staff employed by the business
• Consulting costs, for example relating to the development of a business’ OH strategy
• Costs relating to family members of employees
• Costs relating to persons that are not employees

For response: Views as to why these should be kept out of scope are welcomed, as well as reasons why it would be positive to be included in scope are welcomed.

Alternative tax incentives: Government welcomes views on alternative tax incentives, beyond changes to the existing BiK exemption, that could be more effective in increasing employer provision of OH.

For response: are there other alternative tax incentives that could be more effective in incentivising the provision of OH?

Impacts: Lastly, the consultation looks at possible impacts of potential changes to the BiK exemption as proposed, and business are invited to consider questions such as:

For response:

• To what extend would business increase investment into OH if the BiK exceptions were extended as proposed?
• Comments on the possible positive impact of the provision of OH in the health of employees, wellbeing and stronger culture
• What would be the economic benefits of a greater provision of OH?
• What are your current processes and budget on the provision of OH?
• Any potential disproportionate impact in different groups, included protected characteristics, or regional impact

2. DWP Occupational Health: Working Better consultation

Click here to read the full consultation papers and questions.

This consultation focuses on the role of the Government, OH providers, and employers, in increasing OH offers in the UK, to enable better workplace support, improving productivity, and preventing health related absences and job losses.

Chapter One of the consultation sets out voluntary proposals, including a national health at work standard for employers, and best practice sharing, to help provide a simple and clear baseline for quality OH provision to all employers.

For response: Government is seeking views on:

• best practice models to promote better health support in the workplace, including views on how these are informed, examples, benefits and costs.
• consolidating guidance on workplace health provision, including defining a simple and clear baseline for quality OH provision for all employers, looking at what would be the ideal level, and how it should be monitored.
• a new voluntary national health at work standard for employers, embedding a baseline for quality OH provision;
• Government-funded support to enable businesses to work towards that standard, seeking input into what would be most valuable for employers and possible requirements to access funding.

Chapter Two looks at international comparations and what other countries have done to increase the provision of OH, successes from UK-based employer in increasing OH and, what could be applied to the UK. It also looks at the role of legislation in accelerating the provision of OH with a view of looking at a potential framework to do so. Lastly, this session also looks at drivers such as automatic enrolment and other policy initiatives utilised to deliver in this field.

For response: Government is seeking views on:

• How international comparations might be applied in a UK context, also looking at the impacts of a combination of systems and legal change to increase provisions, considering also costs and benefits.
• The impacts of self-reporting and automatic enrolment models in driving up OH provisions

Chapter Three sets out proposals to develop the existing OH workforce capacity and develop a longer-term sustainable multidisciplinary OH workforce in partnership with the private sector. It looks at the role of a multidisciplinary model of work and health provision. The proposals focus on boosting recruitment in this sector, through promotion and pipeline development.

For response: Government is seeking views on (England only):

Views are sought on identifying new models of care, the range and balance of clinical and non-clinical professionals needed, and appropriate pathways for them to play a role in this profession in future. Views are also sought on optimising additional workforce capacity on work and health conversations through fit notes and a greater role for private providers of OH services in building the workforce.