The Devil Is in the Details: Determining Why Employers Fail to Report Some Workers' Compensation Claims to the BLS Survey of Occupational Injuries and Illnesses

BACKGROUND:  Previous research has found that not all day away from work (DAFW) injuries eligible for the Bureau of Labor Statistics (BLS) Survey of Occupational Injuries and Illnesses (SOII) are reported by surveyed establishments. Little has been done to characterize the reasons at the record level behind this failure to report. By asking respondents about specific cases that were not reported in the 2012 SOII, we hoped to identify reasons for incomplete reports of occupational injuries and illnesses to the BLS. 

METHODS:  To identify cases of unreported SOII-eligible injuries, we linked Washington State Workers’ Compensation (WC) claim data to OSHA recordable DAFW cases reported by Washington establishments in the 2012 SOII case and demographic data. We used WC administrative data to determine SOII eligibility among unlinked claims. We conducted semi-structured telephone interviews with SOII respondents from establishments with unlinked claims soon after the establishment’s submission of SOII data. Only respondents with access to WC claims data were eligible to participate. We provided respondents with identifying information about the unlinked claims, and asked them if and how the claims were recorded in company records and why the claims had not been reported to the BLS. Unlinked claims were coded into categories describing the establishment or claim characteristics that led to the injury going unreported.

RESULTS:  Most frequently, we found that claims had been inaccurately recorded on company OSHA 300 logs such that they did not appear to the respondent to meet the SOII DAFW reporting criteria. Reasons for inaccurate records included confusion over how to record physician recommended modified duty, and failure to update existing records. Often, failure to report a claim was based on the establishment’s reliance on WC eligibility criteria instead of OSHA recordkeeping criteria in determining SOII eligibility. Conversely, many establishments had correctly determined that the case in question did not meet SOII reporting criteria, despite information in the WC data suggesting the opposite.  Examples included over-estimating injury severity based on WC wage replacement eligibility, and incorrectly assessing the timing of disability. 

CONCLUSIONS:  By discussing specific cases of unreported injuries with SOII respondents, we identified dozens of distinct reasons for the observed discrepancy between BLS SOII data and WC claims data.  Some identify difficulties employers have understanding and complying with recordkeeping and reporting regulations, while others highlight the complexity of comparing the SOII data and its particular case definitions to other data sources with different case criteria.