Key takeaways:
Most employers take pride in a clean injury record. A low claim count feels like proof that safety is working – and in many cases, it is. But there’s another explanation worth considering: Your employees may be getting hurt and saying nothing.
Delayed injury reporting is one of the most costly blind spots in workers compensation. When employees stay silent, small injuries grow into serious ones, claims become more complex, and you’re left managing a problem you didn’t know existed.
Brad Minor, Senior Safety and Risk Consultant, has been with MEM since 2017, serving policyholders across northeast and central Missouri and Iowa. He evaluates workplace hazards and business risks to help employers create safer workplaces and a better work comp experience.
Claim-free isn’t always good news
A low claim count is worth celebrating – but only if it reflects reality. In a workplace that’s actively operating, zero reported injuries and zero near misses are uncommon. The more likely explanation, Minor said, is distrust: Employees who fear for their jobs, or simply don’t believe reporting an injury will lead to a good outcome.
The distinction matters. An employer who assumes their clean record reflects a working safety program may never look deeper. But culture – how employees relate to management, whether people communicate openly, whether the workplace feels safe enough to speak up – tells a different story than the numbers alone.
When incentive programs backfire
One of the most common contributors to underreporting is incentive programs tied to injury-free performance. Team lunches, bonuses, and recognition tied to zero claims or zero OSHA recordables can pressure employees to remain silent if an injury occurs. “Employees don’t want to be the one who got hurt and kept everybody from getting their Christmas bonus or their all-employee lunch,” Minor said.
Minor steers employers away from outcome-based incentives and toward recognizing the behaviors that truly improve safety: Near-miss reports, safety observations, and employee suggestions. Near-miss reporting rate is one of the most actionable leading indicators in a safety program. Every near miss reported is an opportunity to address hazards before they cause an injury.

The cost of delayed reporting
Consider a common scenario: An employee tweaks their back on a Monday, says nothing, and keeps working. Two weeks later, it’s worse. By the time the injury surfaces, a manageable situation has become much bigger.
Minor walks through how quickly the ripple effect moves:
- The injury worsens without early intervention, potentially requiring surgery or extended recovery
- The employee continues working in positions that may aggravate the injury or create risk for others
- The manager, unaware that anything is wrong, keeps assigning work as normal
- Colleagues work overtime to cover for the team member’s eventual absence
- The claim that could have been minor is now costly and complex
Early intervention is one of the most effective tools available – but only when there’s a timely report to respond to.
📍 Read next: Claim Length: How Employers Can Improve Post-Incident Process >
Discouraging injury reporting goes against OSHA requirements
There’s also a legal dimension for employers to consider. OSHA specifically prohibits employers from discouraging injury reporting and has levied fines for incentive programs that effectively deter claims. “Rewarding low claim counts can be interpreted by an OSHA professional as deterring reporting and therefore can leave the company open to a potential fine,” Minor said.
Underreporting can happen in any industry
It might be tempting to assume underreporting is a construction or manufacturing problem. Minor pushes back on that. Construction, manufacturing, transportation, agriculture, healthcare – no industry is immune. The real variable isn’t the type of work. It’s the culture.
And culture, Minor said, is something you can feel before you can measure it.
“Safety is communication to me. If employees are actively communicating with management or the employer, the safety culture is typically going to be very good. Do people smile at each other? Do they talk? Are they actively communicating – or do people walk in with their nose down, clock in, clock out, and nobody really speaks about anything beyond the tasks they’re doing at the time? That doesn’t necessarily breed a safety culture.”
Brad Minor, Senior Safety and Risk Consultant, MEM
Where to start (or stop)
Before building anything new, look at what might already be working against you. Programs that reward the absence of claims are the most common culprits. Get rid of these and replace them with incentives tied to:
- Near-miss and hazard reports
- Safety observations
- Employee suggestions for safety improvements
- Participation in safety training or committees
➡️ The bottom line: The goal is to make reporting feel like a contribution to the team, not a threat to it.
How to build a culture where employees speak up
Shifting a culture of non-reporting isn’t a quick fix. It takes time, consistency, and genuine investment. But the approach is practical, and it starts with communication.
The suggestion box principle
Give employees a channel to report and consistently respond to what comes in. Minor’s framework is simple:
- Use a physical box, a digital form, or a QR code – whatever fits your workplace
- Allow anonymous or identified submissions
- Respond to every submission, even the ones you can’t act on
- When a suggestion isn’t feasible, say so – and say why
“It’s important for leaders to heed every suggestion made and recognize that each submission – regardless of whether it’s feasible or not – needs to be addressed and considered,” Minor said. Employees who feel heard keep contributing.
The same principle applies after an injury. When reviewing what happened, Minor recommends removing the injured worker from the corrective action conversation entirely – the goal is to fix the hazard, not assign blame.
Start with leaders
For employers whose culture already has a reporting problem, Minor recommends targeting lead employees first. Set expectations with them, and they’ll translate those expectations down to the team. It won’t happen overnight, but consistent follow-through is what builds trust over time.

Your safety program vs. your safety culture
A low claim count is only a meaningful metric if your employees feel safe enough to report. The next time you look at your injury numbers, Minor’s challenge to employers is simple: Ask yourself whether that number reflects your safety program – or your culture.
If the answer is unclear, that’s where the work starts. Address reporting expectations directly with internal leaders, eliminate incentives tied to outcomes you can’t fully control, and build communication channels to make speaking up feel safe. None of it is fast, but all of them compound over time.
If low claim counts don’t tell the whole story, what does? We break down the leading indicators that actually tell you whether your safety program is working: Safety Metrics: How to Measure Your Program’s Success >
Frequently asked questions: Underreporting
What is workers compensation underreporting?
Workers compensation underreporting occurs when employees don’t report work-related injuries or illnesses to their employer. This can be intentional, due to fear of job loss or workplace pressure, or unintentional, such as when an employee doesn’t recognize a gradual injury as work-related. Unreported injuries often worsen over time, resulting in more costly and complex claims than if they had been addressed early.
How can I tell if employees are underreporting injuries?
Zero reported near misses in an active operation is one of the clearest warning signs. Other indicators include a disengaged workplace culture without open communication and incentive programs tied to low claim counts.
What does delayed injury reporting actually cost employers?
Delayed reporting drives up both the medical and operational costs of a claim. An injury that could have been treated early may require surgery or extended recovery if left unaddressed. Meanwhile, the injured worker continues working – potentially aggravating the injury or creating risk for coworkers – until the claim can no longer be avoided. Coworkers absorb overtime, and what started as a minor claim becomes a major one.
Are incentive programs that reward zero injuries against OSHA rules?
Not automatically, but they can be. OSHA prohibits employers from discouraging injury reporting, and has levied fines for programs that effectively deter claims – including some bonus and recognition programs tied to zero injuries or zero lost time. Programs that reward safety behaviors (near-miss reporting, hazard identification, participation in safety training) are less likely to create compliance exposure than those tied to outcomes.
What should I replace injury-free incentive programs with?
Replace outcome-based incentives with recognition tied to safety behaviors: Near-miss reports, hazard observations, employee safety suggestions, and participation in training or safety committees. This shifts the cultural message from “don’t get hurt” to “help us identify problems,” which better aligns with a strong safety culture.
How do I build a reporting culture if employees are already reluctant to speak up?
Start with lead employees. Setting clear expectations at that level allows reporting norms to filter down to the broader team. Give employees an accessible, low-friction way to report (a physical suggestion box, a digital form, or a QR code) and commit to responding to every submission, even ones you can’t act on. Acknowledge what came in, explain your reasoning, and take corrective action publicly when possible. Consistency over time is what builds the trust needed for employees to report freely.
What should I do when an injury does occur?
Report it promptly, access early intervention resources, and focus the corrective action conversation on the hazard – not the employee who was hurt. Remove the injured worker from that conversation entirely. The goal is to identify and fix what went wrong so it doesn’t happen again, not to assign blame. This approach also signals to the rest of the team that reporting leads to improvement, not consequences.