Reminder: Providers Must Submit OSHA Injury & Illness Reports

Source: NAHC, Jan. 31, 2024

Health care providers must submit injury and illness reports to the Occupational Safety & Health Administration (OSHA), according to a final rule that became effective on Jan. 1, 2024. The rule amended its occupational injury and illness recordkeeping regulation to require certain employers to electronically submit injury and illness information to OSHA that employers are already required to keep under the recordkeeping regulation.

OSHA finalized the requirement for establishments with 100 or more employees in certain designated industries to electronically submit information from their OSHA Forms 300, 301, and 300A to OSHA once a year. Establishments with 20 or more employees in certain industries would continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year.

OSHA proposed to remove the requirement for establishments with 250 or more employees, not in a designated industry, to electronically submit information from their Form 300A to OSHA on an annual basis. However, based on public comments expressing concern over the proposal, OSHA is retaining the requirement for establishments with 250 or more employees to also submit the Form 300A -Summary of Work-Related Injuries and Illnesses, electronically to OSHA once a year.

OSHA finalized its intent to post the data from the annual electronic submission requirement on a public website after identifying and removing information that reasonably identifies individuals directly.

OSHA has developed a list (Appendix A) of Industries that will be required to continue to electronically submit Form 300A annually if they have 20 or more employees. The second new list (Appendix B) includes the industries that OSHA requires submission of Forms 300, 301, and 300A annually if they have 100 or more employees.

Neither home health nor hospice agencies are on the lists and therefore are not included in the OSHA form submission requirements for establishments with less than 250 employees. Because OSHA finalized that all establishments with 250 or more employees must electronically submit Form 300A, large home health and hospice organizations will be required to comply with this requirement.