Long-term disability programs in selected countries

In 1985, the Social Security Administration commissioned an 18-month research project to study disability in eight industrialized countries: Austria, Canada, Finland, the Federal Republic of Germany, Israel, the Netherlands, Sweden, and the United Kingdom. The study focused on three key areas: (1) the initial determination of disability, (2) the methods of monitoring disability, and (3) the incentives to return to work. Although the study revealed great variations among the countries in the definition of long-term disability, the approach followed in providing benefits, and the organization and features of the programs, some basic similarities were also found. Among the similarities are: (1) most countries have several income-maintenance programs to protect workers in the event that they are disabled, and (2) the disability test to determine whether a person is eligible for a disability benefit is ambiguous in that the various programs each have different eligibility criteria, different definitions of disability, different considerations given to labor-market conditions, and so forth. This article examines the diversity among the countries and attempts to highlight unique approaches to adjudicating disability, providing linkages to rehabilitation, and creating incentives for returning to work.