While requirements from regulatory and government organizations remain fluid, we’ve compiled this return to work checklist for employers to review as the U.S. considers reopening the economy.
General considerations for reopening
- Review and comply with CDC and OSHA guidance.
- Check your local and state guidelines.
- Review FMLA for guidance related to parental leave related to schools that remain closed.
- Review industry and third-party guidance (e.g., National Association of Homebuilders, National Restaurant Association).
- Verify that your workplace is in a community that no longer requires significant mitigation.
- Inform and seek authorization for your plan from your organization’s leadership.
Protect vulnerable or ill employees
- Stay compliant with the ADA: review EEOC guidance on reasonable accommodations for disabled employees during COVID-19. Read the EEOC’s Q&A.
- Have a plan to protect high-risk employees (e.g., older adults, those with underlying conditions resulting in immunocompromise, and pregnant women).
- Explore and mitigate privacy issues related to health screenings, ADA/EEOC compliance, and other COVID-19 issues.
- Encourage workers to stay at home if they are feeling ill.
- Employees who’ve experienced symptoms or have been exposed to others who have tested positive should stay home for 7 to 10 days beginning when symptoms first appeared.
Implement exposure-reducing measures
- Encourage employees to work from home when feasible to help improve social distancing.
- Continue investing in remote work infrastructure to allow employees to work without risking exposure.
- Consider a staggered reopening, beginning with employees who are low risk.
- Consider staggered work shifts, downsizing operations, and delivering services remotely.
- Evaluate and restructure workplace layouts to improve social distancing.
- Modify access to common areas such as elevators, cafeterias, break rooms, and conference rooms.
- Increase cleaning protocols and frequency.
- Use internal communications such as email, as well as physical signage that promotes hygiene practices, including regular hand washing and wearing a face covering.
- Discourage workers from using other workers’ phones, desks, offices, or other work tools and equipment, when possible.
- Provide protection for those who interact with the general public (e.g., install temporary barriers to prevent respiratory transmission, install barriers to physically require social distancing, provide masks and gloves).
- Replace high-touch surfaces such as doorknobs with electronic equivalents.
- If renting office space, work with building management to learn what protocols are being implemented and what employers themselves will be responsible for.
- Train staff on safety measures.
- Require employees experiencing COVID-19 symptoms (CDC guidance) to leave work, promptly seek testing, and report results (paid leave requirements for FFCRA-covered employers).
- Plan for testing before employees return to work and daily temperature readings.
- Ensure testing compliance with the ADA: Any information gathered, including screening results, must remain protected under ADA confidentiality requirements. This information may not be stored with employee personnel files.
- Train those who will be testing on all steps of the process, including how to sanitize the tools used. Create appropriate forms to record information
- Be thoughtful about where testing will occur. Employers might consider a space with multiple stations where people can come in and out with a certain degree of privacy and to minimize the area of exposure for persons who do not pass screening.
- Put procedures in place if an employee fails a health screening, such as a temperature reading, and if they refuse a health screening for any reason (privacy, religious exemption, etc.).
Monitoring risk, staff absences
- Have plans in place for managing staff absences, including flexible leave policies.
- Ensure affected workers have sufficient paid leave to observe a quarantine period or are able to stay home as indicated.
- Continue to monitor sickness absence but expand sick leave provisions to allow employees to stay at home if ill and to care for sick family members.
- Plan for surge in demand for elective procedures deferred due to pandemic.
- Review changes to leave durations based on new leave laws.
- Consider capacity issues due to demand changes.
For more information, please visit our COVID-19 resource center at guardianlife.com/coronavirus.
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