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JOBSEEKERS

How sick leave in France compares to the UK, the US and the EU

Sick leave can vary dramatically country by country. Here we compare what rights workers have in France compared to those in the UK, US and across the EU.

How sick leave in France compares to the UK, the US and the EU
Photo: sick leave/Depositphotos
Knowing your rights when it comes to sick leave is crucial as an employee and there are big differences between what countries offer their workers. 
 
We've compared the legal requirements for sick leave in France, the UK, US and elsewhere in the EU — although it's important to remember that sick pay can vary greatly from person to person as certain companies will have their own sick pay schemes. 
 
 
Sick leave in France 
 
In France, statutory sick pay can vary depending on how long you've been ill. And it's important to note that the amount you are paid if you are off sick will often depend on company policy or the most likely the collective bargaining agreement (convention collective) that applies to your position.
 
First six months
 
During the first six months sick pay is equal to 50 percent of your “basic daily wage” – that doesn't mean how much you earn each day. 
 
If you are paid monthly, you can use the following calculation to work out your basic daily wage: take the total (gross) of your last three salaries and divide by 91.25.
 
For example, if you earned €2,000 per month for the three months before getting ill, you will get a fixed sick pay of €32.87 per day (2,000 x 3 / 91.25 = 65.75).
 
You then take that amount and divide by two to arrive at the amount you'll be paid each day that you're off work sick, which in this case would be €32.86. 
 
In order to qualify for this sick pay you must have worked at least 150 hours in the three months before you became ill. Also, your gross salary which is taken into account to calculate your basic daily earnings is capped at 1.8 times the Smic (minimum wage) amount. In 2019, this works out at €2,738.19 per month.
 
After six months
 
If you are ill for longer than six months, then you have to meet the following criteria to continue receiving sick pay.  
 
To be certain you will receive sick pay in the case of long-term illness you must have worked at least 600 hours in the 12 months before stopping work due to the illness.
 
For example, if you stopped work on July 1st 2018, you would be entitled to sick pay if you had worked at least 600 hours between June 30th 2017 and June 30th 2018. 
 
Or else you must have contributed on a salary equal to at least 2,030 times the amount of the hourly Smic in the 12 months preceding getting ill.
 
For example, for a work stoppage that began on July 1st 2018, you are entitled to sick pay if between June 30th 2017 and June 30th 2018, you were paid at least €20,056.40. 
 
In either case, you must also have had health insurance for at least 12 months. 
 
How long does it last?
 
Social security will pay sick pay for a maximum of 360 days for a period of three consecutive years (regardless of the number of illnesses), without taking into account the compensation paid for a long-term illness or health condition. 
 

When you take sick leave in France, you will receive compensation in lieu of salary which will be paid either by social security, or in some cases by your employer if your company has its own sick leave policy.
 
If you are too sick to work, you are expected to give your employer and social security organisation a doctor's note within two days and if you don't, you probably won't receive any sick pay at all. 
 
On top of that, workers are not automatically entitled to sick pay for the first three days of absence, although their company or convention collective may cover it.
 
According to a 2016 survey, France is among the most generous countries in the EU when it comes to sick pay. By comparison, the same study revealed the UK to be one of the worst. 
 
Sick leave in the UK
 
In the UK, statutory sick pay (SSP) amounts to a flat rate of £92.05 per week, which is paid by your employer for up to 28 weeks.
 
You are entitled to at least this amount but you may be entitled to more sick pay if your company has an occupational sick pay (OSP) scheme, which would be detailed on your employment contract.
 
To qualify for SSP at all you must earn at least £116 per week and tell your employer you’re sick before their deadline – or within seven days if they do not have one.
 
In the UK, employees only need to provide a sick note after seven days of sick leave (including non-working days) and can sign themselves off sick up until this point. 
 
However like in France, you do not qualify for statutory sick pay (SSP) until you have been ill for at least four days — although this includes non-working days — meaning you will not be paid for the first three days that you are ill unless your employment contract says otherwise. 
 
When you return to work after a period of illness, your employer might ask you to sign a ‘self-certification’ form as proof that you were unwell or send details of their sick leave by email.
 
While OSP schemes tend to be a lot more generous than SSP, according to some sources, just 55.9 percent of companies in the UK have one. This means that for many workers in the UK there is no choice but to soldier on and make it into the office even if they are under the weather. 
 
And if that seems unfair, take a look at what employees in the US are offered.
 
Photo: Depositphotos
 
Sick leave in the US
 
In the US, there is no statutory sick pay. 
 
However, companies subject to the Family and Medical Leave Act (FMLA) do have to provide unpaid sick leave.
 
The FMLA provides for up to 12 weeks of unpaid leave for certain medical situations for either the employee or a member of the employee's immediate family. In many instances, companies will offer to pay for the employee's leave in this situation although they are not obliged to.
 
However to qualify for this as an employee you have to meet certain criteria. 
 
Employees are only eligible to take FMLA leave if they have worked for their employer for at least 12 months, and have worked at least 1,250 hours during that time. They also have to work somewhere with 50 employees or more with a 75 mile radius.
 
Sick leave elsewhere in the EU
 
Sick leave and pay in the EU are most generous in the Netherlands, where employees can miss up to 104 weeks (2 years) of work due to illness whilst still receiving 70 percent of their salary. 
 
In Germany employees can be absent for up to 78 weeks. They receive 100 percent of their earnings for the first 6 weeks they are off sick and 70 percent thereafter. 
 
As for Norway and Denmark, sick leave entitlement is for 100 percent of earnings for up to 52 weeks, a full year. 
 
Other countries where sick leave conditons are better than in France are Sweden, Spain, Belgium and Austria, where employees can be off from work for up to 52 weeks, with pay ranging from 50 percent to 100 percent of earnings. 
 
In Ireland sick leave pay is dependent on the specifics of a worker’s employment contract and in Switzerland labour law states that employers have to carry on paying sick employees for at least three weeks.

To qualify for SSP at all you must earn at least £116 per week and tell your employer you’re sick before their deadline – or within seven days if they do not have one.

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For members

HEALTH

Mutuelles: Why is French health insurance getting more expensive?

France’s top-up health insurance 'mutuelles' have been getting steadily more expensive in 2020. Here’s a look at what’s changing, why and who is the worst affected.

Mutuelles: Why is French health insurance getting more expensive?
A dentist is checking the teeth of an elderly lady in a nursing home in Paris. Photo: AFP

“The prices have never been so high in France,” said Fabien Soccio, spokesperson for the company Meilleure Assurance (Best Insurance).

His company this week revealed the results of a new study of France's private health insurance fees, mutuelles, to French media.

After comparing 55 different mutuelles health insurances, Meilleur Assurance concluded that there had been a general spike in the average cost.

What is a mutuelle?

France has generous state health care that covers a lot of medical expenses, but not all costs are reimbursed.

In France you pay upfront for your doctor's appointment, prescription or procedure and then the government reimburses the costs to you. Depending on the procedure and your situation, usually about 80-90 percent of the cost is reimbursed.

If that cost is a €25 appointment with your GP that's not such a big deal, but with more expensive treatments the costs can mount up, which is where a mutuelle comes in.

The mutuelle is a 'top-up' insurance – not obligatory, but recommended – which covers extra costs that are not covered by the state. How much a mutuelle covers will depend on the kind of insurance, where you live and the expenses in question.

If you are an employee, your employer must pay for at least half the cost of your mutuelle

Who was affected by the price increase?

The 2020 price hike touched the country as a whole, however some regions and population groups were harder hit than others, Soccio told Le Parisien.

To compare the costs for different socio-demographic groups, Meilleur Assurance created three different types of profiles; a 25-year-old employee with a “classic” mutuelle; a couple with two children, also on a “classic” mutuelle and a 60-year-old couple with “strengthened” guarantees in their mutuelle.

Seniors hardest hit

Retirees tend to go for fuller versions of mutuelles because these cover additional costs (such as dental and optical treatments). 

Seniors on extensive types of mutuelles were those suffering the steepest price increases this year, Soccio said. 

“In 2020, fifteen départements exceeded a threshold of €3,000 in annual fees for a senior couple with extra guarantees,” Soccio said.

“That’s an average increase of more than €176 in one year,” he said.

For the couple with a child, the increase was slighter ( an extra 4 percent), whereas the young employee saw health insurance bills largely unchanged.

READ ALSO Brexit: Do I need a mutuelle to get residency in France?

 

.. along with Parisians

The study also revealed large price differences between different regions, with inhabitants in the Paris region Ile-de-France paying the highest bills for their mutuelles.

A retired couple would pay on average €528 more if they lived in Paris compared to if they lived in a more rural, cheaper département like Mayenne.

Similarly, employees would pay 30 percent more on average in Paris than in Pays-de-la-Loire.

Parisians also saw the steepest price increases since last year, by 14.6 percent on average for the retired couple with a mutuelle covering extra costs.

On a national level, the average price increase for the same couple was 12.1 percent. 

.. but everyone was a little worse off

However the country as a whole saw a price increase last year, with even those opting for the cheapest kinds of health insurance affected by the general price hike.

In one year, from 2019 to 2020, the cheapest type of health insurance had increased by 13.7 percent, according to the study. 

Why the increase?

Prices generally increase a little every year, but this year was unusual, Soccio said.

“Today, we are in an uncertain and troubled situation,” he told Europe 1, listing several factors that had contributed to the price increase: the Covid-19 pandemic, the government's new health reform known as “100 percent Santé”, and a new health tax known as the “Covid surtax”.

When the French government presented their new budget for 2021, centred on their dazzling €100 billion relaunch plan, they promised not to increase taxes for the French. Instead, to top up their savings a little, the government introduced a new tax, the “Covid surtax”, which will be paid through the mutuelles and other health insurance companies.

This tax will provide €1 billion in total to the state in 2021, and €500 million in 2022, according to French media.

What about the future?

Soccio said he worried the trend of prices increasing would continue in the next couple of years, leading to steep prices for even those opting for the cheaper mutuelles.

“It's safe to bet that the national average costs will pass €3,000 in the next two years,” he told Le Parisien.

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