研究另發現，政府在立法過程中同時扮演議程推進者、制度設計者及政策掮客。政府不僅主動設定政策方向、整合保險給付與預防重建制度，也透過程序安排、協商及配套設計降低不同聯盟之衝突。然而，政府並非完全中立的仲裁者，而是在維持專法化核心方向之前提下進行折衝，呈現政策主導性與政策掮客性並存之特徵。整體而言，倡導聯盟架構對本個案具有相當解釋力，但仍應納入政策問題長期累積所形成的漸進式政策窗、聯盟內部異質性，以及臺灣強行政國家脈絡下「主導型政策掮客」之政府角色，方能更完整解釋我國職業災害保險政策的變遷過程。;Taiwan’s occupational accident insurance system was long incorporated into the broader labor insurance system， while insurance benefits， accident prevention， and post-accident rehabilitation services were dispersed across different legal frameworks and administrative agencies. To address problems such as insufficient insurance coverage， limited flexibility in benefit adjustments， and unstable funding for prevention and rehabilitation， the Legislative Yuan passed the Labor Occupational Accident Insurance and Protection Act in 2021. This legislation marked a gradual transition from a fragmented and supplementary occupational accident protection system toward a specialized statutory framework integrating insurance benefits， occupational accident prevention， and vocational rehabilitation. Focusing on the legislative process of the Act， this study applies the Advocacy Coalition Framework to examine the external events and policy windows that facilitated policy change， the relatively stable parameters within the policy domain， the actions and motivations of different advocacy coalitions， conflicts among coalitions and between coalitions and government agencies， and the role of the government throughout the legislative process.
This study adopts a qualitative research approach， using in-depth interviews as its primary research method. Through purposive sampling， key actors from the Department of Labor Insurance of the Ministry of Labor， the Bureau of Labor Insurance， the Occupational Safety and Health Administration， and a non-governmental occupational safety and health advocacy organization were interviewed. Documentary analysis was also employed to examine Legislative Yuan records， government documents， statements issued by advocacy organizations， news reports， and relevant academic studies. The interview data were cross-validated with secondary sources to reconstruct the policy change process leading to the enactment of the Labor Occupational Accident Insurance and Protection Act.
The findings indicate that the enactment of the Act in 2021 was not directly triggered by a single major occupational accident. Rather， it resulted from an incremental policy window created by the gradual convergence of long-standing institutional gaps， persistent occupational risks， repeated cases exposing deficiencies in worker protection， sustained advocacy by civil society organizations， changes in the governing coalition， political commitments， and growing administrative capacity for policy implementation. In addition， the complexity of occupational accidents and diseases， financial pressures on the labor insurance system and fund sustainability， Taiwan’s industrial structure characterized by a high proportion of small and micro enterprises， and constitutional and legal requirements concerning lawful administration， statutory authorization， and budget allocation constituted relatively stable parameters that constrained available policy options and the scope of coalition activities.
Within the policy subsystem， this study identifies three major types of advocacy coalitions: an administrative-agency-centered coalition promoting institutional integration and implementation feasibility; a civil-society-centered coalition advocating the enactment of a separate statute; and an opposing or defensive coalition composed of employer organizations， certain occupational unions， and conservative elements within the administrative system. Based on their policy beliefs， organizational interests， institutional positions， and available resources， these coalitions adopted different strategies， including drafting legislation， interagency coordination， consultation meetings， policy discourse construction， public advocacy， lobbying， and the defense of existing institutional arrangements. Conflicts among the coalitions cannot be understood merely as conventional labor–management confrontation. Instead， they constituted multidimensional conflicts concerning the expansion of protection， insurance premiums and business costs， employers’ compensation liabilities， insurance enrollment channels， financial equity， and administrative feasibility.
