General // Policy Management

10 Essentials for Your COVID-19 Return to Work Plan

Though many return to work plans will look different, here are 10 key issues your business needs to address to ensure a successful transition back to work.

December 29, 2020

Businesses across the country are starting to reopen. State by state, millions of remote and furloughed employees will return to work, but we won’t return to the same workplace we left. At least not for a while.

The coronavirus has changed the world and the workplace. For the first time, businesses need to plan for the safe and strategic return of nearly all their employees.

Unfortunately, bringing employees back to work won’t be as simple as announcing a return-to-work date and proceeding with business as usual. “Business as usual” no longer exists.

Many workplaces will need to be restructured to accommodate social distancing and workplace hygiene. Policies impacted by COVID-19 will need to be reviewed, updated, and communicated to employees. Some changes may even need to be long-term, persisting beyond a widely available vaccine or treatment.

Developing a return to work plan can instill confidence in your employees and build brand loyalty with your customers. Consider updating and including the following policies as part of your return to work plan (the remainder of this article will explain these and more in further detail):

  • Return to work policy
  • Sick leave policy
  • Remote work policy
  • Workspace hygiene checklist
  • Compensation policy
  • Business continuity plan

Every company’s plan will look different. But regardless of industry, here are 10 key issues your company may need to address to ensure a safe and successful transition back to work.

With these 10 tips, you will be better equipped to define the new normal for your business.

1. Workplace Safety

Each of your employees and customers will feel differently about returning to “business as usual.” Some will be itching to return. Others may feel anxious. Some employees may not want to return to work at all, due to personal health concerns or loved ones with underlying conditions. With employees all across the spectrum, understanding and empathy will go a long way.

We recommend creating a workplace safety plan. The goal is to reinstill confidence in your workplace and keep your staff healthy. Accomplishing this in the middle of a pandemic is not an easy task, but it is possible.

It starts by communicating that safety is a top priority, then following through with best practices. By implementing safety measures in the workplace, you will mitigate fears and increase brand loyalty for employees and customers alike.

Consider including the following workplace safety measures into your company’s return to work plan:

Workplace Safety Procedures

Exposure Response Plan

  • Develop isolation, containment, and contact tracking procedures
  • Set stay-at-home requirements
  • Send exposure communications to affected staff

Physical Distancing Measures

It’s important to establish social distancing measures at your office:

  • Staggered shifts and lunch breaks
  • Rotating weeks/days in the office and working remotely
  • Moving workstations to increase separation distance
  • Creating one-way traffic patterns in the office

Business Travel

  • Start with allowing essential travel only and define what that is
  • Follow government guidance to ease restrictions over time

Customer and Visitor Contact Protocols

  • Direct customer traffic through the workplace
  • Limit the number of customers in any area at one time
  • Refrain from handshake greetings, remain 3-6 feet apart
  • Use video or telephone conferencing instead of in-person client meetings
  • Provide contactless pickup and delivery of products

OSHA Regulations

Understand and comply with Occupational Safety and Health Administration (OSHA) record-keeping and reporting obligations:

  • Identify positions with potential for occupational exposure to the coronavirus
  • Review OSHA regulation 29 CFR § 1904 to determine if illnesses are work-related

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2. Return to Work Policy

How and when will employees return to work at your company? By planning now, you can implement an organized and controlled approach that helps your staff feel safe.

All employees returning on the same day could be overwhelming and possibly unsafe. So consider transitioning employees back to the office in phases.

Phased Return

  • Use seniority or other nondiscriminatory factors for selection
  • Consider adopting a work share program or SUB plan
  • Determine schedule changes to provide optimal protection to workers

High-risk Employees

Some of your employees may fall into high-risk categories for infection. Create a return to work plan specific to their needs.

  • Allow high-risk employees to work from home or remain on leave until they feel comfortable returning
  • Determine increased measures to protect them when working onsite, including isolated workstations, additional PPE, fewer days in the office, etc.

Employee Recall Requirements

If you had to lay off staff, then notify the state unemployment agency that you’re recalling employees to work. This is a state requirement, and it will help you save money on unemployment taxes for employees who choose not to return to work.

Unfortunately, some team members may be unwilling or unable to return to work. Their reasons may vary, but here are some things to consider as you determine a plan:

  • Employees who are fearful of returning to work
  • Employees with family obligations that interfere with returning to work
  • Employees who remain under quarantine due to exposure to COVID-19

3. Employee Benefits

Whether employees remained on your benefit plans or not, certain notices or actions may be required to stay compliant. Communicating these changes to staff should be done as soon as possible. Consider reviewing the following benefits issues:

Group Health Insurance

  • Eligibility: redetermine waiting-period issues due to leave or reinstatement; review any revised eligibility requirements during the layoff or furlough and determine if those changes will be revoked and when
  • Ensure that coverage changes (i.e. adding telehealth benefits) and services not subject to deductibles have been incorporated into the plan
  • If employee premiums were paid during leave, determine how or if you will recover those costs from employees

Flexible Spending Accounts

  • Review Dependent Care Assistance Program election changes with employees to ensure their new or revised elections are correct
  • Over-the-counter medical products are now allowed under flexible medical accounts on a permanent basis and should be included in plan documents and communications
  • Address new flexible spending account elections and allowable changes with employees

401(k) & Other Pension Plans

  • Review eligibility issues due to layoff or furlough
  • Consider any break in service issues or counting years of service concerns
  • Review any in-service loans employees may have, including eligibility and pay back procedures

Paid Leave

  • Review required leave under the Families First Coronavirus Response Act (FFCRA), ensure employees understand the eligibility requirements, and give them a policy
  • Create a way to track time used and collect supporting documentation for tax credit purposes
  • Determine if there will be company PTO policy changes, including increasing or decreasing paid leave benefits, or additional restrictions in using paid leave
  • Understand the coordination of leave benefits and communicate these to employees as needed

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4. Compensation Policy

Many businesses have had to adjust employee compensation to stay open during the pandemic. Others will need to implement a compensation policy in order to reopen. Where does your organization stand?

As you think through your return to work plan, it’s important to review your compensation policy. If pay cuts or lay offs aren’t necessary, maybe you could benefit from a salary or hire freeze. Whatever your business decides, remember to communicate clearly with all affected staff.

Consider addressing the following issues in your compensation policy:

  • How to handle missed annual pay increases, will they be applied retroactively?
  • Will any pay cuts be made or revoked?
  • How to reduce salaries for exempt employees if necessary
  • Determine if employee status changes (i.e. exempt to nonexempt, or full-time to part-time) are needed to reopen, or if completed status changes will stay in effect
  • How will bonuses be affected?
  • Will hazard pay be offered or revoked?
  • Consider a pay equity audit, as pay may have been reduced or frozen and may have impacted women differently

5. Work From Home Policy

Depending on your business model and industry, working from home may or may not have been effective for you. How productive was your remote workforce during the pandemic? Do you have a way of measuring work from home productivity?

Based on your answer, a work from home policy could be a great short-term emergency tool, helping your company survive the next year. It could even serve as a permanent work/life balance or cost-saving measure.

The following actions are worth considering when creating your work from home policy:

  • Continue to allow remote work where possible to keep employees safe
  • Stagger weeks in office and at home among team members, or implement part-time remote work on alternate weekdays
  • Respond to employee requests to continue to work from home, including long-term arrangements
  • Update technology to support remote workers
  • Consider the long-term cost savings or impact of permanent remote work

6. Communications

Communication is a critical piece of your return to work plan. Establishing a plan for clear communication builds trust with your employees and customers. It helps them understand the safety measures you’re taking before reopening.

Here are some topics worth covering in your return to work communication plan:

  • How sick leave, work from home, and physical distancing policies are being used to protect workers and customers
  • Detail the training you’ve implemented for new workplace safety and disinfection protocols
  • Prepare exposure-response communications ahead of time in case any of employees or customers are exposed to COVID-19
  • Prepare media communications on topics such as return to work timetables, safety measures, and however else your company is supporting workers and customers
  • Develop media-response messages in case of workplace exposures

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7. New-hire Paperwork

Generally speaking, new-hire paperwork won’t be necessary for employees who remained on the payroll. But for those who were laid off or furloughed, it may be best to follow normal hiring procedures.

If you have furloughed or laid-off employees returning to work, here are some steps worth taking:

  • Determine employment application and benefits enrollment requirements for rehired workers
  • Decide whether full or adjusted orientation procedures will be necessary
  • Submit new-hire reports for new and rehired workers
  • Notify state unemployment agencies of recalled workers, whether rehired or not

Address I-9 issues

If you completed I-9 forms remotely, then complete them in person after returning to the workplace.

Remember to update any expired work authorization documents, or make note of any that need to be updated as soon as new documents are received by the employee.

Last but not least, determine if you will have employees complete Section 3 of their original I-9 or complete a new I-9 form.

8. Policy Changes

Returning to work in the middle of a pandemic is anything but business as usual. To prepare for a safe and successful transition, you will need to update or create policies to reflect the new normal.

Here are some steps you can take to create and update your return to work policies:

  • Adjust paid-leave policies to reflect regulatory requirements and actual business needs
  • Relax attendance policies to encourage sick employees to stay home
  • Clarify time-off procedures to indicate when leadership can require time off in case sick employees need to be sent home
  • Implement flexible scheduling options allowing for compressed workweeks and flexible start and stop times
  • Adjust meal and rest break policies to stagger times and encourage physical distancing
  • Update travel policies to reflect essential versus nonessential travel and the impact of domestic or global travel restrictions
  • Detail work from home policies to reflect the type of work that is able to be done remotely and the procedures for requesting remote work
  • Revise information technology policies to reflect remote work hardware, software, and support

9. Business Continuity Plans

The COVID-19 pandemic has been a first for many businesses. What business continuity plans did you have in place before the pandemic, and how effective were they?

For many, it’s been a series of hard lessons in crisis preparedness, but now we can learn from them. If you already have a business continuity plan, now is the perfect time to review and revise it. By doing the hard work now, we can all be better prepared for future crises.

  • Implement a business continuity plan, including infectious disease control, if a plan did not exist prior to the COVID-19 crisis
  • Amend existing plans to include the latest emergency information, such as updates on epidemics, workplace considerations, or changes in global disaster protocols
  • Update plan resources and contact information to ensure accuracy
  • Establish a pandemic task force to continuously monitor external and internal data and implement appropriate protocols
  • Recognize the possibility of additional closings during this current pandemic as COVID-19 infections may rise and fall again, triggering more stay-at-home orders and supply chain disruptions
  • Practice the new or revised emergency plans company wide to make sure employees know what to do, and search for any gaps in the current plan

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10. Unions

If your business has a unionized workforce, there may be some additional considerations. Think through the following steps as part of your comprehensive return to work plan:

  • Determine obligations to bargain when implementing changes to mandatory bargaining subjects such as wages and benefits
  • Identify the need to add a force majeure clause into a collective bargaining agreement to protect the employer from contractual obligations during an event that is beyond the employer’s control
  • Review existing no-strike clauses to ensure continued work during future infectious disease outbreaks
  • Determine obligations for hazard pay under Section 502 of the National Labor Relations Act (NLRA) during “abnormally dangerous conditions”

Return to Work Policy Management

A safe and successful return to work plan boils down to three things: workspace safety measures, new and updated policies, and clear communication.

How are you managing policies related to remote work, compensation, business continuity, sick leave, travel, and employee benefits? How are you communicating and tracking policy updates to your workforce?

Without a tool for creating, updating, distributing, and tracking your documents digitally, it can be a headache making sure all your employees received, understood, and signed off on pandemic-related policies.

Are you interested in a modern, hassle-free way to manage your policies? PowerDMS is your single, unified platform for managing policies, training, and accreditation. One piece of software that does it all, that connects everything, so you can save time and money.

Create and manage your return to work plan in PowerDMS. To learn how our software can help you prepare for the unknown, be it a pandemic or common organizational risks, schedule a free demo today.

In the meantime, fill out the form below to get free, downloadable resources straight to your inbox.

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