Do You Have a Policy on Returning to the Workplace in the Covid Environment? With most Americans now receiving at least one vaccine shot, many organizations are updating the employee handbook to ensure policies around remote work, paid leave, and others to handle returning to work during a pandemic. New government regulations like requiring employees to be vaccinated or tested weekly need to be incorporated into policies. 

When your employee is symptomatic or exposed to COVID

Under Occupational Safety and Health Administration (OSHA) has several regulations employers must adhere to following a suspected COVID infection, including: 

  • Cleaning and disinfecting: When disinfecting a facility, appropriate protective equipment must be provided and used.
  • Report COVID work-related cases: Employers must record confirmed work-related cases on OSHA’s Form 300 logs.
  • Supplying Personal Protection Equipment (PPE) if applicable

In addition, the Centers for Disease Control (CDC) has the following guidelines after suspected or confirmed infection:

  • Testing: Employees with a suspected case of COVID should receive a test immediately. If the test is negative, the individual should retest within 5-7 days.
  • Quarantine: Employees who have been in close contact with someone who has COVID should quarantine for 14 days if not vaccinated. If the employee is fully vaccinated, they do not need to quarantine unless they become symptomatic or have a positive test after 3-5 days from the exposure.
  • Isolation: Employees with COVID symptoms or a positive test should remain isolated for ten days and not return to work until they have been fever-free for 24 hours without the use of fever-reducing medications.
  • Identifying close contacts: Employees that have been within 6 feet from an infected individual for a total of 15 minutes or more over 24 hours are considered close contacts. 
  • Cleaning and disinfecting: All areas of the facility an infected employee occupied should be cleaned and disinfected if it has been less than 24 hours. If it has been more than 3 days, no additional cleaning is required.

What requirements do I need in place to minimize COVID exposure?

State laws may require COVID-19 control plans to reopen. In addition, OHSA and CDC have several recommendations for keeping employees safe during the pandemic.

Checking Symptoms

The CDC recommends virtual or in-person health checks where an employee conducts a self-screen questionnaire and temperature reading. Screening questions should incorporate the following areas:

  • COVID symptoms
  • Diagnosed with COVID in the past ten days
  • Close contact with someone with COVID during the past 14 days

Document screening protocols to educate employees on the processes in place for positive screening results. These procedures should include communication, quarantine protocols, and telework options.

Social Distancing

Vaccinated or unvaccinated employees should stay at least 6 feet away from others. Alter workspaces to promote social distancing and educate employees on the recommended distance. Evaluate policies in place around common areas, meetings, conferences, and traveling. For example, you might decide to use video conferencing even for employees in the office to minimize the number of people in a confined space.


A lot of companies have adopted work at home policies. Telework policies should incorporate who and under what circumstances working from home is acceptable (e.g.,  management discretion, on exposure to COVID, during stay-at-home orders…). In addition, the policy should incorporate employee performance expectations during telework. 

Cleaning & Disinfecting

All organizations need to establish and maintain regular cleanings to reduce the risk of exposure. Policies should include:

  • Areas cleaned and disinfected.
  • The frequency of cleaning, including the common areas
  • Cleaning and disinfecting after an employee with suspected COVID has been in the facility.


Educate employees on hand hygiene, respiratory hygiene, and cough etiquette. Facilities should provide access to the following:

  • Hand-washing supplies 
  • Hand sanitizer
  • Tissues 
  • No-touch trash cans

Vaccination and Testing

The Department of Labor’s OHSA requires employers with over 100 employees to ensure employees are vaccinated or provide weekly negative test results. In addition, employers must provide time off to get the vaccine or recover post-vaccination. Organizations should incorporate CDC guidelines into the vaccination policy to ensure all eligible employees receive the vaccine and booster if applicable. Below are some items to consider within the vaccination policy:

  • What types of COVID tests will the organization accept? Will employees need to go to specific testing locations, and will at-home kits be acceptable?
  • What information needs to be submitted, and how will employees submit the required documents? 
  • Will you allow exemptions for vaccine requirements like disabilities or sincerely held religious beliefs?
  • What is the policy for employees that do not comply with vaccine or testing requirements?

Many companies have also implemented regular, periodic, or targeted testing of workers for screening purposes to minimize exposure. Policies should cover testing frequency, is testing mandatory or voluntary for employees, and the process for administering tests.

Masks Requirements

Employers must follow CDC, OSHA, and state guidelines around masks. In addition, guidelines may require some employees to wear additional protection like a respirator or facemask. Policies should reflect when and what type of protection to wear within the facility. In addition, educate workers on properly wearing protective equipment, including masks. Protocols for inspecting, cleaning, storing, and disposing of PPE must be documented and available to all employees.

Should I update my paid time off policy?

Recovering from COVID-19

Organizations should evaluate existing policies for sick leave, considering extending time off for quarantine and offering telecommuting options for employees in isolation. For greater flexibility, many companies allow employees to donate unused vacation time. Lastly, payroll should consider establishing a separate bank for COVID time off if the government offers additional tax benefits.

Caring for family members

The tax credits for Families First Coronavirus Response Act expired on September 30, 2021; however, many states have enacted regulations for paid leave, including Massachusetts and New York. In addition, incorporate Family and Medical Leave Act (FMLA) requirements into the sick leave policy. Under FMLA, a covered employee may receive time off to care for a family member with severe health conditions, including long COVID, but does not protect employees that want to avoid exposing family members, including those with disabilities, to COVID. FMLA also does not cover school or child care closures. Policies around time-off should include:

  • Supported circumstances 
  • Covered employees
  • Duration
  • Compensation

Vaccination and Testing

For organizations requiring testing or vaccination, policies should update the time off to adhere to these requirements.

  • Will employees be required to get tested or vaccinated outside of work hours? 
  • How much time-off to allocate to workers recovering from the vaccine?
  • Will employees use PTO for recovering from the vaccine, or should they utilize a different bank of leave?

How we can help

The PolicyCo platform is the ideal tool for updating your employee handbook to include COVID updates. Updating your policies and procedures will level-set expectations, reduce risk, provide clarity, and ensure compliance with federal, state, and local guidelines. Our platform lets you map these guidelines directly back to your policy statement and procedures. Employees have access to a customized procedure manual allowing you to hold employees accountable for following COVID protocols. If you need assistance with crafting policies and procedures, please get in touch with our vCISO services.