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Table 2 Disability program parameters across Countries as of 2013

From: Disability benefit growth and disability reform in the US: lessons from other OECD nations

 

Australia

Great Britain

Netherlands

Sweden

United States

Summary of Benefits Program

Universal means-tested flat-rate benefit payable to people with disability aged 16 and over.

Insurance-based flat-rate benefit payable to people with disability with sufficient work history; same flat-rate benefit payable to people with disability with insufficient work history, but means-tested

Merged sickness and disability program which makes a strict distinction between fully and partially disabled. Those fully disabled receive guaranteed income until age 65 while partially disabled workers receive benefits conditional on work history and incapacity level determined by doctor.

Merged sickness and disability system with disability benefits granted only to those deemed to have permanent reductions in work capacity.

Social insurance program for workers who have paid social security taxes over their working lives with benefit levels tied to past earnings.

Full or Partial Benefits Program

Intended to cover only individuals incapable of at least 15 hours per week of gainful employment.

Intended to cover individuals with very limited capacity to work, so closer to a full disability program than a partial disability program. But not restricted to permanent disability.

Program differentiates between full (IVA) and partial disability (WGA) and awards benefits accordingly (see above).

Workers may receive sickness benefits in the event of a sickness (with approval of a doctor), however disability insurance is only granted to those with a serious and permanent impairment that reduces work ability.

Full disability program designed to be a last resort program for those with permanent and total disabilities.

Eligibility Criteria

Must have a physical, intellectual or psychiatric impairment which has a severe (or extreme) functional impact, and must be unable to work at least 15 hours per week in a minimum-wage job for at least (the next) two years.

Must be assessed as having “limited capacity to work”, i.e. scoring 15 or more points on a points-based assessment of physical and mental capabilities

Applicants must meet with designated doctor (either a company doctor or agency) who evaluate incapacity. Several evaluations are carried out by integration supervisors on a rolling timeline during the initial two year sickness period.

Sickness benefits are awarded for first 14 days with a doctors approval and reevaluated along a rolling timeline with worker “check-ins”. Disability benefits are only awarded after the SIA determines work capacity is permanently reduced.

Full disability program requiring applicants to be unable to perform any substantial gainful activity for at least one year.

Benefits Conditional on Contributions?

No. Benefits are universal.

No, but more heavily means-tested for those with insufficient contributions (insufficient work history)

Yes. Benefits levels are conditional on past earnings, number of weeks worked before, and the percentage of earnings the worker is deemed capable of earning currently with impairment.

There are two types of benefits awarded. A universally guaranteed pension provides assistance to all those residing in Sweden. The earnings related pension is contingent upon weeks of work and past earnings.

Yes, sufficient quarters of coverage necessary as defined described in Social Security Administration 2013b.

Other Income Programs for the Disabled

State workers’ compensation programs provide benefits for workers injured on the job for up to two years. Private disability insurance policies also exist, although commonly pay a single lump sum for specified events rather than an income stream.

Statutory Sick Pay for first 28 weeks for those in employment prior to onset; a range of additional costs benefits are potentially available in addition to ESA (e.g. housing benefit, Personal Independence Payment)

Means tested Social Assistance Program (SA) with benefit equal to minimum wage

Assistance Allowance, Car Allowance and other programs are designed to accommodate those who have severe, long-term disabilities meeting specific criteria

Workers Comp and SSI and private disability insurance