By Mwaka Mukweli, Disability Inclusion Officer, UNDP Namibia
Understanding Medical Boarding on the Grounds of Disability: A Guide for Employers, Employees, and the Community
May 20, 2025
Accessible entrance to UN Namibia, ensuring inclusion for persons with disabilities.
Disability inclusion in employment is a fundamental human rights issue and a critical component of sustainable development. According to the International Labour Organization (ILO), persons with disabilities (PWDs) are significantly less likely to be employed than those without disabilities. Global estimates indicate an employment rate of approximately 36% for persons with disabilities compared to 60% for non-disabled persons (ILO, 2023). In Namibia, data from the 2011 Population and Housing Census revealed that only 33% of PWDs were economically active, highlighting a persistent employment gap (Namibia Statistics Agency [NSA], 2011). Factors contributing to this gap include inaccessible workplaces, stigma, and limited access to education and skills training (ILO, 2023).
Currently, Namibia lacks national data on employees with disabilities who were misclassified during medical boarding, particularly those who acquired a disability while employed but were boarded under ill health instead of being classified appropriately under disability provisions. This absence of data creates a policy vacuum and hinders the efforts of employers, policymakers, and advocates striving to ensure full and fair inclusion in the workplace. However, the NSA has made notable progress in improving disability data by incorporating the Washington Group Short Set of Questions into national surveys, bringing Namibia in line with global best practices and improving the quality and relevance of disability-related data.
A study by Shumba and Moodley (2018) found that many stakeholders, including employers, human resources practitioners, medical professionals, and medical boards, demonstrate a limited awareness of disability-related policies. This often leads to incorrect application of policies and insufficient support for employees with disabilities, particularly when determining eligibility for medical boarding. As a result, many individuals who should be recognized under disability provisions are instead boarded under general ill health, resulting in long-term consequences for their dignity, rights, and financial security.
Globally, the World Health Organization (2022) reports that there are over 1.3 billion people, roughly 16% of the population, with a disability. In Namibia, the 2023 Population and Housing Census reports that 4.4% of the population has a disability, with higher prevalence in rural areas (5.8%) than in urban areas (3.2%). Despite the progress in data collection, many people with disabilities continue to face employment barriers, including discrimination and inaccessible work environments (ILO, 2021).
Disabilities can take many forms, including physical, sensory, intellectual, neurological, and psychosocial impairments. Accurate classification of these impairments is essential when considering medical boarding. Physical disabilities may involve mobility challenges such as spinal cord injuries or limb loss; sensory impairments include hearing or vision loss. Intellectual and developmental disabilities affect cognitive function, while neurological and psychosocial conditions include epilepsy, depression, and schizophrenia. These distinctions are critical to understanding the types of support and accommodation individuals may require.
Within the Namibian public service, medical boarding is a formal procedure used to determine whether an employee should be retired due to continued ill health, as stipulated in the Public Service Commission Act (Republic of Namibia, 1995, sec. 5[2][j], p. 18). The Government Institutions Pension Fund rules (GIPF) distinguishes between two categories: ill-health retirement and disability benefits. Ill-health retirement applies to employees deemed permanently unfit to work due to chronic or terminal illnesses; they receive a lump sum and a monthly pension and become fund pensioners. Disability benefits, by contrast, are designated for employees who acquire a disability during employment and cannot continue in their roles. These individuals cease active employment but continue contributing to the pension fund until reaching retirement age, which ensures better long-term security.
The correct classification of employees who acquire a disability while employed is critical for inclusive human resource practices in both public and private sectors. Misclassifying such individuals under ill-health retirement instead of disability not only violates their rights but also denies them access to necessary accommodations, rehabilitation, and sustained financial support. Rehabilitation includes services and support such as physical therapy, vocational training, and psychosocial assistance that aim to improve functioning and enable individuals to reintegrate into the workforce (World Health Organization, 2011). Unlike medical treatment, rehabilitation empowers individuals with long-term impairments to return to productive life and employment.
Before initiating medical boarding, employers are legally and ethically required to explore reasonable accommodations for affected employees. According to the United Nations (2006), reasonable accommodation involves necessary and appropriate modifications, without imposing undue hardship, to ensure that persons with disabilities can enjoy equal rights and freedoms. Examples of such accommodations include flexible work schedules, physical modifications to the workplace, provision of assistive technologies, and reassignment of non-essential duties.
However, the failure to consider these accommodations is a widespread issue. Often, medical boards and employers neglect to thoroughly assess whether an employee with a newly acquired disability could continue working with support. This results in many employees being prematurely boarded under ill health, effectively excluding them from the more favorable conditions of disability benefits. The Public Service Commission Act permits retirement for continued ill health (Republic of Namibia, 1995), but this process is frequently applied without comprehensive evaluation for disability status. While the GIPF does provide a pathway for second opinions when medical board reports are inconclusive, classification typically relies heavily on medical assessments that focus on illness rather than functionality and inclusion potential. This undermines Namibia’s obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).
The Public Service Commission Act also mandates, in Section 8(e), that the Commission must ensure the continued health of public servants. This duty implies an obligation to prioritize rehabilitation, workplace accommodations, and other interventions that support employee retention and reintegration. Retiring employees prematurely, without a thorough disability assessment, contradicts this mandate and exacerbates marginalization of persons with disabilities.
Another challenge lies in the limited awareness among supervisors, human resources officers, and medical board professionals about the differences between ill health and disability. Disability, as defined in the Namibian National Disability Council Act and the UNCRPD, results from the interaction between long-term impairments and societal barriers, whereas ill health can be temporary or progressive. Employees who acquire a long-term impairment, such as vision loss from untreated glaucoma, should be provided with assistive tools like screen readers or magnifiers, as well as mobility and orientation training, to support continued employment rather than being retired prematurely.
This need for proper classification and support extends to individuals with physical impairments, such as those who rely on wheelchairs due to work-related trauma. Employers must ensure accessible infrastructure, including ramps, wide corridors, accessible restrooms, adjustable desks, elevators, and emergency exits, to facilitate full inclusion. The International Labour Organization emphasizes the importance of embedding return-to-work programs, reasonable accommodation, and ongoing support within public human resources policies. While Namibia has made progress through legislative and policy frameworks such as the Affirmative Action Act, the Labor Act, the Constitution, and various disability-specific instruments, significant implementation gaps remain.
The economic and social consequences of these gaps are profound. High unemployment and limited disability grants mean that prematurely boarding employees not only leads to individual loss of income but also increases dependence on public assistance and contributes to reduced productivity. These outcomes are both economically inefficient and socially unjust.
One root cause of this problem is the absence of standardized workplace disability assessment protocols. Many medical boards do not include rehabilitation or disability experts, leading to decisions based purely on medical diagnosis rather than the employee’s remaining functional abilities or accommodation possibilities. This reflects a biomedical model of disability, which focuses on impairment, rather than a rights-based approach that emphasizes inclusion.
Addressing these challenges requires the development of disability-sensitive assessment tools that evaluate the individual’s ability to function in the workplace and the accommodations required. This approach should include integrating the perspectives of social workers, rehabilitation professionals, and disability rights experts into medical board assessments. Additionally, human resources officers, health personnel, and supervisors must be trained in disability inclusion, policy application, and best practices for workplace accommodations.
Namibia’s inclusive development vision, articulated through Vision 2030 and the Harambee Prosperity Plans, demands that no one be left behind, particularly not employees who acquire disabilities. As a leading employer, the public service must ensure the rights and livelihoods of such employees are protected. Current practices surrounding medical boarding and ill-health retirement reflect systemic weaknesses that prematurely remove individuals who could remain productive contributors with appropriate support.
UNDP Namibia, as part of its broader commitment to inclusive governance and disability rights, highlights the urgent need to reform disability assessment and medical boarding practices. This commitment is in line with the “Leaving No One Behind” principle of the Sustainable Development Goals and the requirements of the UNCRPD. Achieving disability inclusion requires not only policy declarations but also concrete implementation strategies that ensure accessible infrastructure, inclusive employment practices, and meaningful participation of persons with disabilities across all sectors of development.
By recognizing the importance of accurate classification, timely rehabilitation, and reasonable accommodation, Namibia can build a truly inclusive public service where employees with disabilities are not just protected but empowered to thrive.
Read more:
International Labour Organization. (2021). Disability inclusion in employment. https://www.ilo.org/global/topics/disability-and-work/lang--en/index.htm
International Labour Organization. (2023). World Employment and Social Outlook: Trends 2023. https://www.ilo.org/global/research/global-reports/weso/trends2023/lang--en/index.htm
Namibia Statistics Agency. (2011). Namibia 2011 Population and Housing Census: Main report. https://nsa.org.na/page/publications
Republic of Namibia. (1995). Public Service Commission Act, 1995 (Act No. 2 of 1995). Government Gazette of the Republic of Namibia.
Shumba, T. W., & Moodley, I. (2018). Disability and the workplace: Experiences of employees with disabilities in a public sector organization in Namibia. African Journal of Disability, 7(0), a380. https://doi.org/10.4102/ajod.v7i0.380
United Nations. (2006). Convention on the Rights of Persons with Disabilities (CRPD). https://www.un.org/disabilities/documents/convention/convoptprot-e.pdf
World Health Organization. (2011). World report on disability. https://www.who.int/publications/i/item/9789241564182
World Health Organization. (2022). Global report on health equity for persons with disabilities. https://www.who.int/publications/i/item/9789240063600