PCS briefings have reported the introduction of a new attendance management approach for DWP, following consultation with PCS, from 3 April 2018.
The Health and Attendance Improvement Meeting (H&AIM) has been introduced to emphasise that the focus of the meeting should be about the employee’s wellbeing and improvement, not about warnings. There is a reduced emphasis on warnings so that it will always be a final consideration for the manager to decide whether there are reasonable grounds to issue a warning. PCS briefing DWP/BB/047/18 has been issued to provide guidance for disability related absences.
Adjustments that are reasonable must be implemented
Adjustments that are reasonable must be implemented if the employee is disabled but, in accordance with DWP’s work focused approach, managers should consider reasonable adjustments to overcome all health barriers to good attendance and performance whether the employee is disabled or not. In the case of disabled colleagues, it may be appropriate to increase the employee’s trigger point. This is known as the Disabled Employee’s Trigger Point (DETP). All adjustments implemented must be periodically reviewed but not so frequent that it becomes onerous and bureaucratic. (Procedure 9)
DETP for discussion at the H&AIM
The H&AIM must be welfare focused. Its main purpose is for the manager to understand more about the employee’s absence(s), including more about their illness, the treatment they are having or had and what might be done to achieve a satisfactory level of attendance. Most of the time should be spent discussing support, help and health / wellbeing improvement, focusing as much as possible on practical things that might be done. Reasonable adjustments and other corrective/supportive measures should be considered and discussed. In relevant cases, it may be appropriate to award or increase a DETP. (Procedure 24 d)
Deciding a warning
At the end of the H&AIM the manager must decide whether there are reasonable grounds to issue a formal warning. Warnings are not automatic or a default outcome but require a positive, case-specific decision by the line manager. For disabled colleagues an isolated or short/moderate increase in disability related absence wouldn’t justify a warning. The process for ‘Deciding a warning’ starts from Procedure 26. Managers must give careful consideration to the decision making standards and criteria under Procedure 28, such as taking advice from CSHR Casework, and Procedure 29
Procedure 30 confirms that A warning is not required when there is a reasonable expectation of improvement and a manager should also not give a warning in eleven other specified circumstances, including where:
- Reasonable adjustments have been identified but not yet made (Procedure 30 b)
- The employee is disabled, the absence is directly related to the disability, and it is reasonable to increase the trigger point (Procedure 30 c)
DWP advice for disability-related absence
Attendance Management Advice, available on the DWP Intranet, includes guidance for reasonable adjustments:
Q6. In what circumstances can I award a Disabled Employee’s Trigger Point?
Q7. How do I decide what a Disabled Employee’s Trigger Point should be?
Q8. When should the manager consider taking attendance management action for someone with a Disabled Employee’s Trigger Point?
PCS advice for Branches
The HR Decision Maker’s Guide provides additional guidance. Decision Makers, under Procedure 67 (e), and Appeal Managers, under Procedure 78, are expected to comply with this guidance. This means line managers also need to adhere to these decision making standards so that their decisions stand up to scrutiny. Members have the right to be accompanied by a PCS representative at an H&AIM (Procedure 23) Members should always contact their local PCS Representative for advice, support and representation when invited to attend a Health & Attendance Improvement Meeting.