Return to Work Policy

Policy Number: CS-1302-2013

Policy Title: Return to Work Policy

Policy Owner: Chief Human Resources Officer

Effective Date: March 3, 2013

Last Revised: September 11, 2026

1. Purpose

Mohawk College is committed to providing a safe, healthy and supportive work environment. The College will proactively and fairly support employees who are unable to fully perform their duties due to occupational or non-occupational injury, illness or disability ensuring each case is assessed on its own merit with consistency and respect.

This Policy promotes a fair, transparent, and respectful process that balances employees’ individual health needs and rights with the operational requirements of the College. Its purpose is to ensure effective, consistent management of Return to Work (RTW) cases, including short- and long-term disability and medically related accommodation requests.

The objectives of this Policy are to:

Ensure all individuals involved in the RTW process are treated with dignity and respect;
Provide appropriate support to employees throughout recovery and facilitate a safe return to work;
Establish a clear framework for managing RTW cases;
Outline processes for accommodating employees with medical restrictions and limitations;
Promote fair and supportive administration of RTW processes; and

Ensure compliance with applicable legislation, collective agreements, and policies.

2. Application and Scope

This Policy applies to all College employees absent due to work-related or non-work-related illness or injury, or who require workplace accommodations as a result. Early intervention, full participation and collaboration of the workplace parties is essential to ensure the success of RTW efforts and the overall Policy.

3. Definitions

“Accommodation” means any change or adjustment to job duties or the workplace that enables an employee to safely perform essential job functions. In this document, “accommodation” and “reasonable accommodation” are used interchangeably.

“Disability” is any mental or physical condition that limits an employee’s ability to perform activities or fully participate at work, as defined by the Ontario Human Rights Code.

“Elimination period” is the time between the onset of a disability and eligibility for Long-Term Disability benefits; it is also known as a “waiting period” or “reference period.”

“Functional Abilities Evaluation (FAE)” is an objective, third party evaluation of an employee’s ability to perform work related physical tasks, such as lifting, carrying, pushing, pulling, bending, and reaching.

“Independent Medical Evaluation (IME)” is an objective, third-party assessment of an employee’s current medical condition, including diagnosis, functional limitations, and ability to work.

“Long-Term Disability (LTD)” is a benefit that provides partial income replacement when an employee is unable to work due to a serious injury, illness, or disease.

“Medical Information” refers to documented health data—such as observed physical findings, self-reported symptoms, clinical notes, and test results—substantiated by appropriate medical records and, where applicable, confirmed by a qualified physician. It must include both positive and negative findings, and diagnoses cannot rely solely on self-reported symptoms.

“Medical Restrictions and Limitations” are physical or cognitive activity constraints that prevent an employee from fully performing their duties. These restrictions identify tasks to avoid because of the employee’s health condition, treatment, or to prevent further injury or worsening of symptoms.

“Modified or Transitional Duties” are temporary accommodations involving adjusted or alternative tasks that an employee can safely perform based on their abilities.

“Non-Occupational Injury/Illness” is a condition, injury, or disability that occurs outside of work and is not caused or contributed to by workplace duties, activities, or exposures.

"Occupational or Workplace Injury/Illness" is a condition or injury that arises from or is directly related to workplace duties, activities, exposures, or other job-related factors.

“Productive Work” is work that is required as part of the College’s normal operations.

“Reasonable Accommodation” is a personalized process of modifying duties or the work environment to remove barriers and enable employees to participate in the workplace despite injury or disability, in accordance with the Ontario Human Rights Code. Accommodations must be effective and not create undue hardship for the College, such as excessive cost or health and safety risks.

“Return to Work (RTW)” is the process of returning an employee to work after a disability due to injury or illness, whether work-related or not. Its goal is to place the employee in suitable and available duties that are safe, productive, and consistent with their medical restrictions and limitations.

“Return to Work (RTW)/Accommodation Plan” is a written document developed by the Employee Abilities Coordinator outlining a temporary or permanent plan for an employee’s return to work, including start and end dates, medical restrictions and limitations, duties, hours, and any workplace modifications.

“Safe” refers to work that does not cause a health or safety risk to the employee (e.g., should not cause re-injury or a new injury), to co-workers, or to third parties.

“Short-Term Disability (STD)” is a benefit that provides eligible employees with temporary income replacement during a medically approved absence from work. Eligibility, coverage, and terms are outlined in the applicable employee group Benefits Booklet.

“Suitable Work” refers to job duties that are meaningful and consistent with employees' functional capabilities. It refers to ensuring the employee is working in a location that is safe.

“Total Disability” is a medically supported impairment from a non-occupational illness or injury that prevents an employee from performing the essential duties of their own job or any available alternative work. Please refer to the applicable Benefits Booklet for each employee group.

“Workplace Parties” include the employee, manager/supervisor, Employee Abilities Coordinator, Human Resources Strategic Partner, Union or Employee Representative.

4. Principles

The College is committed to providing accommodations in accordance with the Ontario Human Rights Code, the Workplace Safety and Insurance Act, the Occupational Health and Safety Act, and the Accessibility for Ontarians with Disabilities Act (AODA). It values diversity, respects individual needs, and promotes fairness and inclusion. The College and employees are expected to act in good faith and cooperate to achieve successful accommodation outcomes.

5. Accountability and Compliance

5.1 Accountability Framework

This policy affects many College employees and was developed through consultation with key stakeholders, including OPSEU support staff and faculty representatives, before approval by the Senior Leadership Team.

5.2 Compliance

The College is committed to maintaining an inclusive workplace, and to providing support for its members as required under the applicable policies and procedures, benefit plans, collective agreements and all relevant legislation such as: The Ontario Human Rights Code, The Workplace Safety and Insurance Act, the Occupational Health & Safety Act, the Accessibility for Ontarians with Disabilities Act (AODA).

6. Roles and Responsibilities

6.1 Employees

Employees are expected to:

Notify their manager when absent for medical reasons, (not diagnosis) and provide an expected return-to-work date. If the return date is unknown, the employee must check in daily to confirm continued absence. If the employee cannot contact their manager for medical reasons, an emergency contact should do so on their behalf. Diagnosis details are not required in any communication.
Contact Cowan Benefits Limited to initiate a claim when/if an absence reaches or is expected to exceed five (5) consecutive days.
Cooperate with Cowan Benefits Limited by providing all required medical documentation to support their STD leave.
Attend an IME when necessary to clarify their abilities, restrictions, and limitations for the RTW plan.
For STD claims, if the medical documentation initially submitted is complete but insufficient to assess the claim, and additional information is required, the College will cover the cost of the physician or specialist report in line with the Ontario physician fee guide. The College and employee will cooperate in good faith to arrange the assessment as promptly as possible.
Communicate with the Employee Abilities Coordinator when required to support the accommodation or return-to-work process
Actively participate in rehabilitation and make reasonable efforts to schedule treatment appointments outside of work hours.
Work with the Employee Abilities Coordinator, manager, and Union representative to identify suitable duties and follow modified work plans within their functional abilities.
Inform their treating physician that the College has a RTW policy and can provide accommodations based on functional abilities, restrictions, and limitations.
Report any concerns with the RTW plan to their manager and, when appropriate, the Employee Abilities Coordinator.
Co-workers are expected to show understanding, support, and empathy during an employee’s return to work and to cooperate with accommodation needs where applicable.

6.2 Managers

Managers are expected to:

Provide a safe work environment.
Consult regularly with the Employee Abilities Coordinator to ensure clear, consistent communication and appropriate support throughout the RTW process.
Contribute to the development of written RTW plans.
Apply policies and procedures consistently.
Collaborate with the employee and relevant parties to identify suitable, productive work.
Implement workplace modifications outlined in the RTW/Accommodation Plan.
Monitor employee progress on modified duties and if needed, meet with employees to address any concerns; for permanent accommodations, continue monitoring on an appropriate schedule.
Maintain confidentiality of employee information.
Support team cohesion during the employee’s absence and return.
Endeavour to ensure equitable workload distribution within the department.

6.3 Union or Employee Representatives

Work collaboratively with other workplace parties to facilitate return to work initiatives and/or accommodation planning.

6.4 Health Professional Responsibilities

Provide timely and clear documentation on functional abilities, assistive devices, and other relevant health resources throughout the RTW process.

6.5 Employee Abilities Coordinator

Acts as the central contact for coordinating the RTW process and administering the RTW Policy.
Collaborates with third-party vendors, workplace parties, medical consultants, and insurers to ensure a fair, consistent approach to early and safe return to work following occupational and non-occupational illness or injury, as well as for temporary and permanent accommodations.
Develops individualized RTW plans based on objective medical restrictions and input from relevant parties.
Provides guidance and education to managers on RTW processes, accommodations, collective agreements, benefit entitlements, and legislative requirements.
Monitors case progress, including changes to duties, duration, and compensation, and communicates updates to all parties.
Maintains complete documentation of all RTW activities and decisions.

6.6 Human Resources Strategic Partners (HRSP)

Provide advice and guidance to managers and employees on HR matters, including attendance management, compensation and benefits, legislative compliance, College policies and procedures, and collective agreements.
Consult with the Employee Abilities Coordinator and manager as needed to identify suitable work placement options.

6.7 Insurance Carriers/Consultants (i.e. Sun Life, Third Party Vendor)

Request medical documentation to support an absence due to medical reasons.
Determine eligibility and approval of STD, LTD or WSIB benefits.
Advise the College when employees have received clearance to return to work, in addition to providing details of abilities, restrictions and limitations, while ensuring compliance with the appropriate legislation, collective agreements and benefits plans.
Work collaboratively with Mohawk’s Employee Abilities Coordinator, managers, employees and their Union representatives to facilitate a successful return to work.

7. Return to Work Process

When medically cleared to return to work with documented restrictions or limitations, the Employee Abilities Coordinator will arrange a RTW meeting with workplace parties as needed. For short absences (less than 5 days) with no restrictions, a formal RTW plan or meeting may not be required. The RTW/accommodation process is most effective when all parties are actively involved.

The RTW Process will include:

Early Intervention, Communication,
Assessment,
Evaluation of options,
Planning/Coordination,
Implementation,
Monitoring and evaluation of the outcome.

7.1 Early Intervention, Communication

Early intervention and clear communication are essential to support returning employees, maintain their connection with the College, and address concerns following illness or injury. They also help reduce the risk of prolonged absences and support a smoother, well-supported return to work.

Further, early intervention enables the employee to:

maintain income (where possible, with no loss of pay);
retain productive employment and job security;
maintain self-esteem, family stability and social ties;
maintain job skills;
retain eligibility for government benefits;
retain pension and benefit packages; and
resume “routine” life activities sooner, with less uncertainty about the future.

7.2 Assessment

Once medical clearance to return to work is received, the Employee Abilities Coordinator will notify workplace parties and proceed with RTW planning. Functional abilities, restrictions, and limitations will be assessed against essential job duties, and strategies will be developed to address any RTW barriers.

If clarification is needed, the third-party vendor may contact the treating physician or specialist with employee consent. Employees are expected to fully cooperate with the RTW Program in providing required information.

7.3 Evaluation of Options

Workplace parties will review available options to determine the appropriate course of action, considering operational needs, available sick time, essential job duties, and whether restrictions are temporary or permanent, including possible modifications to duties, hours, and progression.

All accommodations begin with an assessment of the essential duties of the pre-disability position and are evaluated individually. If the employee cannot perform these essential duties or full hours, the College will explore alternative placement options.

7.4 Planning/Coordination

All parties are expected to cooperate in a transparent and collaborative RTW process that supports both the employee and the College.

The Employee Abilities Coordinator develops RTW plans in writing, in consultation with the employee and Union representative, in accordance with the collective agreement. Input may also be sought from healthcare providers, third-party providers, and the employee’s manager.

7.5 Implementation

Once a RTW or Accommodation Plan is approved, the College will cover reasonable implementation costs, such as equipment, hardware, or software. The business area will cover reasonable costs related to the employee’s workstation, equipment, hardware, software, etc. and the College will cover larger reasonable implementation costs, such as lighting.

Employees must promptly report any concerns with the RTW plan or schedule to the Employee Abilities Coordinator and their manager. Minor adjustments may be made as needed; significant changes or extended recovery periods may require updated medical information.

Employees are expected to schedule treatment or rehabilitation appointments outside of working hours whenever possible.

7.6 Monitor and Evaluate Success

Managers must monitor progress and address concerns directly with the employee. If adjustments are needed, the Employee Abilities Coordinator must be notified so the RTW plan can be updated, and workplace parties must meet to discuss changes if required.

Follow-up meetings will be scheduled as needed to monitor ongoing progress.

8. Training and Policy Communication

8.1 New Employee Orientation

All new employees will be made aware of the RTW Policy and have access through MyMohawk.

8.2 Employee Communication

Human Resources will ensure general communication regarding updates to the Policy, when necessary, and will continue to promote the benefits of the Policy and work collaboratively to ensure a successful implementation.

The Employee Abilities Coordinator will meet with managers who require support with managing individual cases.

9. Compliance

Employees and workplace parties are expected to actively participate in developing and following a suitable RTW or accommodation plan. Employees must provide requested medical documentation, cooperate in the process, and accept reasonable accommodations that align with their functional abilities. While participation in treatment or rehabilitation is encouraged, employees should schedule appointments outside work hours when possible or discuss them with a manager if not.

If the College requires further clarification of medical status or work capacity, it may arrange an IME or FAE. Employees are generally given 10 days to submit required medical documentation, with extensions granted where reasonable. Failure to provide sufficient documentation or to cooperate in the process may result in suspension or termination of benefits, and could lead to disciplinary action, up to and including termination of employment.

10. Dispute Resolution

Where there is a dispute regarding the RTW process, the Employee may follow the complaint/grievance process outlined in the relevant collective agreement or in accordance with applicable Mohawk College policy. Administrative employees who have a dispute regarding the RTW process, may submit a written request for review to the Director of Health, Safety and Wellness within ten (10) business days of receiving the decision.

11. Confidentiality Statement

The College is committed to protecting the confidentiality of employee medical and personal information collected during the RTW process. Records of personal medical information and/or claim files are kept confidential in accordance with the Personal Health Information Protection Act. Employee health information is gathered through informed, written consent from the employee.

All individuals participating in the RTW process (i.e. workplace parties) shall protect the confidentiality of personal medical documentation.

12. Policy Revision Date

12.1 Revision Date

March 2029

12.2 Responsibility

The Chief Human Resources Officer is responsible for reviewing this policy every five years or earlier when required.

13. Attachments

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