Across large health systems, a structural crisis is hiding in plain sight. The symptoms look like staffing debates and productivity gaps. The actual diagnosis is far more serious.
Something is breaking inside the occupational health programs of large health systems — and it is breaking quietly. There are no alarms, no single catastrophic failure. Instead, there is a slow accumulation of structural contradictions: compliance obligations that were never properly resourced, revenue models that were never properly separated, and productivity metrics applied to work that was never designed to produce them.
Program directors across the country are navigating this in near-silence — fielding increasingly unrealistic demands from leadership while lacking the frameworks, benchmarks, or administrative backing to push back effectively. What gets called a staffing problem is usually something deeper. What gets called a productivity problem is almost always a structural one.
Ask most CFOs how their occupational health program performs financially, and they will tell you it underperforms. What they are actually describing, almost without exception, is a blended model in which compliance-driven employee health work — surveillance visits, regulatory screenings, fit testing, immunizations — is absorbed into the occupational health cost center with no corresponding revenue attribution.
The result is predictable and punishing. A program operating with occupational health staffing levels absorbs the full salary and non-salary expense load of both functions. Only a fraction of visits generate any revenue at all. And when leadership examines the financials, they see an underperforming department rather than two distinct programs operating under one roof without proper accounting for each.
"Leadership remains focused on productivity metrics without fully accounting for the differing goals and staffing models between compliance work and revenue-generating work."
The fix is not complicated in concept: separate the models. Allocate full costs to employee health and isolate the revenue-generating occupational health services. In most systems where this analysis has been done honestly, the occupational health program is actually profitable. The problem is not performance. The problem is presentation — and the institutional will to restructure the accounting.
The Staffing Benchmark That Does Not Exist
When program directors try to make the case for adequate staffing, they run into a wall that most administrators do not realize is there: there are no industry benchmarks for compliance-based occupational health work. MGMA publishes productivity standards for clinical encounters. It does not publish models for respiratory protection programs serving tens of thousands of employees. It does not benchmark fit testing campaigns, exposure surveillance workflows, or multi-site employee health operations.
This creates an impossible conversation. Leadership asks for benchmark data. The program director cannot produce it — not because the staffing need is not real, but because the benchmarking infrastructure for this work simply does not exist. What fills the vacuum is a productivity metric designed for something else entirely, applied to a program it was never meant to measure.
Consider the math of a respiratory protection program spanning thousands of employees, multiple hospitals, and a handful of clinical staff. Annual fit testing alone represents a staggering volume of compliance work — work that is time-intensive, protocol-driven, and cannot be meaningfully accelerated without additional hands. When leadership denies a request for per diem staff and the only alternative is vendor quotes that cost more than full-time hires, the program is caught in a resource trap with no clean exit.
The Expansion Paradox
There is a particular cruelty to the moment when a health system receives outside interest in expanding occupational health services to a new location — and the program director must weigh genuine growth opportunity against an infrastructure already stretched past its limits. New sites require new FTEs. New FTEs require justification. Justification requires benchmarks. And the benchmarks do not exist.
Each individual decision looks defensible in isolation. Deny the per diem staff — budget pressure is real. Delay the FTE request for the new campus — headcount approvals take time. Hold the line on the current staffing model — productivity numbers are what they are.
But view these decisions together, across eighteen or twenty-four months, and a pattern emerges: a program being asked to grow its obligations without growing its capacity, while being evaluated on metrics designed for a different kind of work entirely.
The issue here isn't about having enough staff; it's really about how things are being managed. Simply having another chat about benchmarks won't fix it.
IS YOUR PROGRAM STRUCTURALLY SOUND — OR JUST SURVIVING?
The Executive Diagnostic was developed specifically for health system leadership navigating the intersection of employee health compliance obligations and occupational health revenue strategy. It surfaces the structural gaps that standard reporting never captures — and gives program directors the language, frameworks, and financial models to make the case to administration.
Applied recently to a health system program serving more than 80,000 employees, the diagnostic identifies where cost allocation is obscuring true performance, what a properly separated model would show, and how to quantify staffing need in the absence of traditional benchmarks.
Confidential consultation — no obligation — structured for program directors and system executives.