Preparing for Post-COVID-19 Return-to-Work Policies



Reopening the economy: it’s a simple phrase that belies the difficulties that lie ahead. Yet, for many employers, the phrase oversimplifies the complexities they face as they figure out how to safely bring their employees back to the workplace.

Although it may not yet be clear when you’ll be able to reopen your workplace, now is the time for your organization to put together a strategy for reopening rather than scrambling when your state or city lifts your stay-at-home order.

Here are the critical elements to include in your post-pandemic return-to-work plan.

  1. Form a Return-to-Work Planning Team

If you’re a larger company, you’ll want to assemble a cross-functional team with the responsibility of creating and implementing your return-to-work plan. The team should consist of leaders from various departments, including human resources, legal, compliance, IT, and operations, among others. In smaller organizations, you might have a group of executives working with your human resources lead. If you need to configure your facility differently to accommodate social distancing needs, it may be prudent to obtain the guidance of a third-party health expert.


  1. Review Federal, State, and Local Guidance and Recommendations on Returning to Work

Your team should continually monitor the guidelines issued by federal, state, and local government agencies. At the federal level, check the latest recommendations from the U.S. Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA), which has tailored its guidance to specific industries. Employers should also review the technical assistance published by the Equal Employment Opportunity Commission (EEOC), which permits employers to perform health screenings, including temperature checks, before employees may enter the workplace.


Your state or municipality may also have issued orders requiring compliance; for example, some states are requiring, or at least encouraging, employers to screen employees’ temperatures before they enter the workplace, while others are mandating that companies take preventive measures to limit the spread of the virus, such as requiring employees to wear face masks and to attend health and safety training.


  1. Assess Your Workplace for Potential Threats

Carefully review your workplace to determine where and how employees might be exposed to COVID-19. Determine whether you need to add policies, implement physical changes, or require employees to wear personal protective equipment (PPE) to protect against exposure. If PPE is necessary to limit risks, then OSHA regulations require you to provide that PPE and train employees in how to use it. If no PPE is required, consider asking your employees to wear face masks to protect themselves and each other (if they aren”™t required by law).


  1. Develop a Written Return-to-Work Plan

Each organization—and potentially each of its workplaces, if they are in different locations or house different functions—should have a written return-to-work plan. The plan should include the following:

  • Identification measures: Teach employees how to self-monitor for the symptoms of COVID-19, and make sure your policies explain how employees should report if they are sick or are experiencing coronavirus symptoms. Consider conducting health screenings of employees, and create a policy for how to retain this protected health information securely in compliance with the Americans With Disabilities Act (ADA) and Health Information Portability and Accountability Act (HIPAA).
  • Prevention measures: Make sure employees have a convenient place to wash their hands, offer hand sanitizer at strategic places throughout the workplace, and clean and disinfect surfaces regularly.
  • Training: Remind employees of the importance of following good hygiene practices by displaying a COVID-19 safety poster in common areas and holding meetings to review your policies and procedures.
  • Basic prevention measures: Limit the number of people in the workplace, and reconfigure the workplace to allow for social distancing; erect barriers between workspaces if possible.
  • Recurrence: Create a plan of action steps that the company will need to take if the virus recurs, including closures and remote work protocols.

The team should also consider whether changes to any other company policies or procedures are necessary, including those governing attendance, safety, telework, accommodations, travel, and privacy.


Preparing for the Future

If only we had a crystal ball that allowed us to plan better for what the future holds. However, following the steps outlined in this article will help employers safely reopen their workplace and be ready to adapt as governmental guidance and regulatory requirements evolve.