INSIGHTS COVID-19: Preparing Your Workforce

While Fairfield County has not yet become a COVID-19 ‘hot spot,’ it’s important for employers to begin preparing now, in the event that the virus takes a foothold in our area. Employers should begin by regularly monitoring recommendations from the CDC, public health agencies, and state officials. Below are additional steps employers can take to help prepare their workforce.

Create a Business Continuity Plan

Employers should begin preparing for an increase in absenteeism due to illness of employees and/or illness of their family members. Employers should:

• Identify essential business functions and create a plan to continue these functions in the event that key employees are absent, or the company faces higher absenteeism in general
• Cross-train employees to perform the identified essential business functions
• When possible, identify business functions that employees can perform from home. If your company’s continuity plan involves employees working remotely, it’s important to ensure that any remote internet connections (such as VPN or Terminal Server) can handle the increased traffic
• Communicate accordingly with others that rely on your business’s services or products if there will be any interruption or change that may impact them
• Involve key decision makers and/or departments in the creation of the business continuity plan ahead of time to avoid gaps or disruptions
• Create a written document with the finalized continuity plan. Identify which triggers will activate and terminate the continuity plan. Appoint the person responsible for communicating business changes should they take place

Communicate to Employees

It’s natural for employees to be nervous about the virus and inquisitive about how their company will handle an outbreak. It’s important for employers to limit the amount of panic and keep their workforce calm by communicating expectations and sharing continuity plans. According to the CDC, employers should also

• Communicate sick leave policies and actively encourage sick employees to stay home. Employers should make sure that their sick leave policies are flexible and consistent with public health guidance
• Communicate that employees who appear to have acute respiratory illness symptoms (i.e. cough, shortness of breath) upon arrival to work or become sick during the day will be sent home immediately
• Emphasize respiratory etiquette and hand hygiene. Employers should provide soap and water, alcohol-based hand rubs, and disinfecting products in the workplace and ensure that adequate supplies are maintained to the best of their ability. Employees should be encouraged to wipe down high-touch areas in their workspace with disinfectant regularly
• Encourage employees to work remotely when possible and limit non-essential travel to affected regions

Handling Sick Employees

Employers should instruct employees to inform their manager or HR if they have been exposed to the virus or if they and/or members of their household show symptoms of the virus.

Employees who have been officially diagnosed with the COVID-19 should follow the quarantine recommendations of their doctors.

In the event that an employee is diagnosed with COVID-19 , employers who are covered under the Americans with Disabilities Act (ADA) can and should provide notice to employees regarding potential exposure but should be careful not to identify diagnosed employees by name. Additionally, the U.S. Equal Employment Opportunity Commission (EEOC) released guidance on commonly asked questions in the event of something like the COVID-19 occurring in the workplace:

• Can an employer send employees home if they display COVID-19 symptoms?

Yes. The CDC states that employees who become ill with symptoms of influenza-like illness at work during a pandemic should leave the workplace.

• If an employee returns from travel, does an employer have to wait until the employee develops symptoms to ask questions about potential exposure?

No. If the CDC or state or local public health officials recommend that people who visit specified locations remain at home for several days until it is clear they do not have pandemic influenza symptoms, an employer may ask whether employees are returning from these locations, even if the travel was personal.

• Can an employer ask employees who do not show symptoms to disclose whether they have a medical condition that would make them vulnerable to the COVID-19?

No. If an employee voluntarily discloses that he has a specific medical condition or disability that puts him or her at increased risk of influenza complications, the employer must keep this information confidential. The employer may ask him to describe the type of assistance he thinks will be needed (e.g. telework or leave for a medical appointment). Employers should not assume that all disabilities increase the risk of influenza complications.

• How much information can employers request from employees who report feeling ill at work or call in sick?

Employers may ask such employees if they are experiencing influenza-like symptoms, such as fever or chills and a cough or sore throat. Employers must maintain all information about employee illness as a confidential medical record in compliance with the ADA.

• Can an employer require employees who have been away from the workplace during an outbreak to provide a doctor’s note certifying fitness to return to work?

Yes. As a practical matter, however, doctors and other health care professionals may be too busy during and immediately after a pandemic outbreak to provide fitness-for-duty documentation. Therefore, new approaches may be necessary, such as reliance on local clinics to provide a form, a stamp, or an e-mail to certify that an individual does not have the pandemic virus.

Local paid sick leave laws and Family and Medical Leave Act (FMLA) should also be taken into consideration during this time. Employees who have COVID-19 symptoms and are required to stay home from work by doctor’s order or who need to care for a sick family member, may be covered under FMLA. However, if an employer requires employees to self-quarantine due to travel or exposure, it is not suggested that the employer designate the time away from work as leave under a specific leave law.

Employers should also be consistent with Return to Work protocols outlined in company handbooks or other policies to ensure that employees do not pose a health risk to themselves or others upon their return.

As more information becomes available, Reynolds + Rowella will provide later updates on how employers should handle the COVID-19 .

REYNOLDS & ROWELLA | ACCOUNTING AND CONSULTING FAIRFIELD COUNTY CT

Reynolds + Rowella is a regional accounting firm known for a team approach to financial problem solving. As Certified Public Accountants, our partners foster a personal touch with our clients. As members of DFK International/USA, an association of accountants and advisors, our professional network is international, yet many of our clients have known us for years through the local communities we serve.

Our mission is to operate as a financial services firm of outstanding quality. Our efforts are directed at serving our clients in the most efficient and responsive manner possible, delivering services that exceed the expectations of those we serve.

The firm has offices at 90 Grove St., Ridgefield, Conn., and 51 Locust Ave., New Canaan, Conn. For more information, give us a call at 203.438.0161 or email us.