Vladislav Kaminsky
The question comes from the National Confederation of Employers of Moldova (CNPM). Members of the organization support the reform and its goals—strengthening workers’ health protection, preventing occupational diseases, and aligning national legislation with European standards.
But today, less than three months before the new rules take effect, the main question is whether the healthcare system is ready for their practical implementation.
The new rules concern medical examinations for workers exposed to occupational risks, the prevention of communicable diseases, and increased monitoring of working conditions and staff health in sectors such as agriculture, construction, and HoReCa. Employers will face legal liability for noncompliance.
As Logos Press previously reported, this topic was discussed on August 12 as part of Working Group No. 4 of the Economic Council under the Prime Minister, with the participation of representatives from the Ministry of Health, the National Public Health Agency, the State Labor Inspectorate, social partners, and more than 70 business representatives from various industries.
More Than Forty Problem Areas
Following consultations with CNPM member companies, the organization identified more than forty problematic issues that are currently of concern to employers. One of the key issues is the system’s staffing capacity.
The new model provides for employers’ access to occupational health services. However, it remains unclear whether the healthcare system has the necessary number of specialists to provide services to approximately 700,000 workers nationwide. As Logos Press has discovered, although training programs have been organized to retrain doctors, the staffing shortage has not yet been resolved.
“This is a fundamental issue for businesses,” says Vladislav Caminschi, head of the working group and executive director of the Confederation of Employers’ Associations. “It is impossible to fulfill this obligation if the necessary service is physically unavailable. This issue may be particularly sensitive for companies located outside of Chisinau.”
In addition, employers need to understand where to turn for guidance on complying with the new obligations. Before the new rules take effect, businesses need access to transparent and regularly updated lists of occupational health services, as well as accredited laboratories and institutions that conduct the specialized tests required by the new regulations.
Occupational Risks of Digitalization
Questions also remain regarding the interpretation of certain occupational risks. These were raised by representatives of ATIC (Association of Information and Communication Technology Companies). Concepts such as electromagnetic fields, vibration, noise, optical radiation, the concept of “repetitive work,” and the use of computer mice and other office equipment require clarification.
There are also questions regarding psychosocial and organizational factors, the definition of “general clinical examination,” and the frequency of specific examinations.
Without a unified methodology, there is a risk that the same provisions will be interpreted differently by employers, medical institutions, and regulatory authorities, emphasizes Vladislav Caminschi.
The Cost of the New System
“A major issue in itself is the cost of the new system for monitoring workers’ health,” he continues. “Employers need to understand in advance who will finance the procedures required by the regulations and from which sources.”
In particular, clarification is needed regarding the payment for medical examinations and laboratory tests, occupational health services, specialist visits to workplaces, consulting services, vaccinations, and employee health promotion activities. Clarity is also needed regarding how these expenses relate to the mandatory health insurance system and the current catalog of medical rates.
It is also important that the information system be operational before reporting becomes mandatory. The new rules require employers to submit certain data and reports. Therefore, businesses need assurance that the information system will be fully functional by the time these obligations take effect.
A clear mechanism for appealing medical determinations is also necessary. Provision is made for challenging a medical opinion regarding an employee’s fitness for work. “In this regard, everyone must understand where to file a complaint, in what form, who reviews it, and within what timeframe,” explains the working group leader. “What is the legal significance of the decision, and what is the employee’s status while the dispute is being reviewed? This is a sensitive practical issue for labor relations.”
Small and medium-sized businesses may be the most vulnerable to the new obligations. “A large company has greater administrative and financial capacity to adapt,” he notes. “But for a small business, the new system could mean a significant burden, especially if the necessary medical services or laboratories are located far away or have limited capacity.”
One-Year Transition Period
Employers believe that the reform should take into account not only the requirements of the law but also companies’ actual ability to comply with them. Therefore, they propose a transition period of at least 12 months following November 7, 2026, during which oversight would be primarily advisory and corrective in nature.
In other words, clarification, training, and assistance for businesses to adapt are needed first, and only after all mechanisms are fully operational should sanctions be applied.
To resolve all emerging issues, the CNPM proposes establishing a permanent mechanism for dialogue. Work could continue in the format of a permanent joint working group involving the Ministry of Health, the ANSP, the State Labor Inspectorate, the CNAM, the Ministry of Labor and Social Protection, the CNPM, and social partners.
The goal is not to delay the reform, but to promptly resolve emerging issues and ensure that the new rules are actually effective. Employers have submitted these proposals, along with a list of problems, to the authorities. The Ministry of Labor and Social Protection agrees with many of the business community’s observations.
There has been no official response yet. As clarified by the Ministry of Health, under the law, amendments to legislative provisions can only be made six months after they take effect—that is, next spring.
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