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COVID-19: Workplace Re-Entry Checklist

May 11, 2020
Being a Broker, Managing Your Office, Safety, Legal, Coronavirus

Please note: Most of the information featured on this page is for historical purposes only. The guidances, orders, and regulations mentioned below were issued during the COVID-19 pandemic.

Businesses should devise a multi-faceted and phased approach to the workforce’s re-entry to the workplace, which takes into account guidance, regulations, and orders issued by federal, state and local governments and agencies, including the World Health Organization (WHO), the Centers for Disease Control and Prevention (CDC), the Equal Employment Opportunity Commission (EEOC), the Occupational Safety and Health Administration (OSHA), and The White House. 

Consider establishing a cross-functional COVID-19 Task Force, with representatives from across the organization, including human resources, legal, and facility operations, to prepare and monitor the re-entry of the workforce, as well as the evolving circumstances surrounding COVID-19. This checklist provides an overview of some of the key considerations the COVID-19 Task Force should consider when developing the organization’s plan for the workforce’s re-entry to the workplace.

This is general guidance only. Be sure to consult legal counsel, public health information, and all applicable executive orders, as required policies and practices may vary based on state and local laws.

Prepare the Physical Workspace

  • Establish cleaning protocols that adhere to CDC guidance.
  • Post building cleaning protocols throughout the workplace.
  • Post CDC recommended personal hygiene protocols reminders.
  • Identify and consider hands-free alternatives to high-touch areas, such as revolving doors, knobs, light switches and plumbing fixtures.
  • Conduct maintenance and updates to HVAC and building facilities by, for example, increasing ventilation and installing high-efficiency air filters.
  • Modify workspaces to promote social distancing by, for example, creating smaller offices to allow for additional offices or installing higher walls between cubicles or other physical barriers between workspaces, such as clear plastic sneeze guards.
  • Close or limit access to common areas, such as gyms, kitchens and cafeterias, or reconfigure to promote social distancing.
  • Provide and maintain supply of personal protective equipment (PPE), sanitizers, and disinfectant wipes for employees and building guests.
  • Restrict the total number of permitted building occupants in order to allow for social distancing.
  • Place decals and space demarcations in common areas, such as the lobby, to note social distancing requirements and traffic flow patterns.
  • Reconfigure meeting rooms to promote social distancing.
  • Control all points of entry for staff, guests, and vendors.
  • Remove and discourage the use of shared tools, such as remote controls and conference room phones.
  • Establish and communicate building rules with employees and building guests.

Topic: Coronavirus

Adult washing hands in white sink

Visit NAR's Coronavirus topic page for the latest information on NAR's response to the COVID-19 outbreak.

Coronavirus Resources and Guidance for Employers

Please note: Most of the information featured on this page is for historical purposes only. This guidance was issued during the COVID-19 pandemic, and the federal assistance programs listed at the bottom of the page have expired.

Businesses with employees are required to provide a hazard-free workplace under the Occupational Safety and Health Act of 1970. At the same time, employers with 15 or more employees must comply with the federal anti-discrimination law, the Americans with Disabilities Act (ADA).

Resources are now available to assist REALTOR® associations and brokerages who have employees meet their obligations under both federal laws. 

Workplace Vaccination Policies

NAR has provided Guidance for Workplace Vaccination Policies that provides some key takeaways from the Equal Employment Opportunity Commission’s vaccination guidance, to help brokerages and associations formulate a plan to address COVID-19 vaccinations in the workplace. The guidance also addresses independent contractors and in-person events.

OSHA Resources

To remain compliant with OSHA, the U.S. Department of Labor, Occupational Safety and Health Administration has compiled its advice for employers in Guidance on Preparing Workplaces for COVID-19. 

The guidance provides employers with detailed steps they can take to protect employees, including:

  • Develop an Infectious Disease Preparedness and Response Plan;
  • Prepare to implement basic infection prevention measures;
  • Develop policies and procedures for prompt identification and isolation sick people, if appropriate;
  • Develop, implement, and communicate about workplace flexibilities and protections; and
  • Implement workplace controls.

Sample Policy

NAR has provided a Sample Preparedness Plan for Circumstances Relating to COVID-19 that any real estate brokerage or REALTOR® Association may adapt and implement in their workplaces.

ADA Resources

The Equal Employment Opportunity Commission, the agency that enforces the ADA, has released a "What You Should Know" statement to assist employers who are grappling with employment-related issues due to the coronavirus pandemic. 

To be clear, the ADA rules still apply to employers with more than 15 employees, but they do not interfere with or prevent employers from following the CDC’s guidelines and suggestions for businesses and employers. The CDC is updating this page as more information and guidance become available, so be sure to check it regularly.

Additionally, the EEOC statement directs employers to review their guidance, Pandemic Preparedness in the Workplace and The Americans with Disabilities Act. Although the guidance was written for an influenza pandemic, now updated for COVID-19. Although the guidance was written for an influence pandemic, it is applicable to the current coronavirus pandemic. The guide is available online and answers questions frequently asked about the workplace during coronavirus-like events, like:

  • May an employer administer a COVID-19 test (a test to detect the presence of the COVID-19 virus) before permitting employees to enter the workplace?
  • How much information may an employer request from an employee who calls in sick, in order to protect the rest of its workforce?
  • When may an ADA-covered employer take the body temperature of employees during a pandemic?
  • Does the ADA allow employers to require employees to stay home if they have symptoms of the pandemic coronavirus?

The EEOC states that during a pandemic, employers should rely on the latest CDC and state or local public health assessments. (A list of state public health departments is available on the CDC website.)  While the EEOC recognizes that public health recommendations may change during a crisis and differ between states, employers are expected to make their best efforts to obtain public health advice that is contemporaneous and appropriate for their location, and to make reasonable assessments of conditions in their workplace based on this information.

Disaster Preparedness Resources

NAR has several guides and tools to assist brokerages and REALTOR® associations create and execute disaster plans:

The coronavirus situation is rapidly changing and evolving. Please be sure to stay up to date by regularly checking nar.realtor/coronavirus, and the Center for Disease Control's website. 

Coronavirus: A Guide for REALTORS®

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Maskot / Maskot / Getty Images

Learn to navigate important issues regarding COVID-19, such as shelter-in-place, fair housing guidance, transaction guidance and more. 

Topic: Coronavirus

Adult washing hands in white sink

Visit NAR's Coronavirus topic page for the latest information on NAR's response to the COVID-19 outbreak.

Employer Preparedness and Policies

  • Explore feasibility of workplace policies and practices that promote social distancing, such as encouraging continued telecommuting and staggered shifts.
  • Consider whether school and daycare facilities are open.
  • Consider availability of reliable and safe public transportation.
  • Consider beginning reentry with employees whose positions are best performed in the workplace.
  • Create a staff travel policy, and consider restricting all non-essential travel.
  • Require employees to stay home if they are sick, and ask any employee who stays home sick if they are experiencing symptoms of COVID-19.
  • Ensure the privacy of each employee who makes a COVID-19 report within the workplace.
  • Consider whether to conduct daily contactless temperature checks on employees and building guests before permitting entry to the building, and whether to hire a trained medical professional to conduct the checks.
  • Establish and communicate protocol for employees to report if they have been diagnosed with COVID19, are experiencing COVID-19 symptoms, or have been exposed to COVID-19.
  • Establish employer responsiveness plan to address reports of COVID-19 within the workplace, while keeping the identity of the individual confidential, to include sending the employee home immediately, cleaning and disinfecting the workplace, and informing others who have been in contact with the employee of potential exposure
  • Update and communicate changes to personnel policies based on COVID-19 related laws, such as Families First Coronavirus Responsiveness Act, and post all required employee notices in conspicuous places and on the employee intranet.
  • Consider whether to require employees and guests to complete a health certification prior to re-entry to the workplace affirming that they have not been experiencing COVID-19 symptoms within the past 14 days, and if previously tested positive, that their symptoms have resolved and have tested negative in accordance medical guidelines.
  • Limit in-person meetings, including the permitted size of in-person meetings.
  • Limit building guest access, and restrict outside meetings and events in the building.
  • Establish a policy regarding employee participation in meetings and events outside the building.
  • Continuously monitor for local outbreaks, and develop a plan in the event of an outbreak.
  • Prepare to manage leaves of absences under federal, state and local laws.
  • Review lease agreement, and coordinate with property manager regarding their plan for maintenance and upgrades to building infrastructure and protocols in response to COVID-19.

Staff Preparedness and Training

  • Train employees on proper sanitation and prevention techniques, including proper use of PPE and when and where PPE is required.
  • Clearly set employee expectations in advance of their return to the office, with a strong emphasis on employee value, safety, and security.
  • Train employees on how to safely get to and from the office.
  • Encourage contactless interactions through the increased use of technology in order to reduce staff contact and exposure, and provide additional training on such resources.
  • Articulate employer’s commitment to employee privacy.
  • Consider staggering employee shifts and breaks

Special Employee Considerations

  • Provide reasonable accommodations to employees with ADA-qualifying disabilities.
  • Employees with pre-existing mental conditions that have been exacerbated by COVID-19 may be entitled to reasonable accommodations; be sure to engage in an interactive process with the employee for any accommodation requests.
  • Do not ask employees whether they have an underlying medical condition that makes them more vulnerable to COVID-19.
  • Employees who contract COVID-19 in the workplace may file a workers’ compensation claim.
  • Provide accommodations and greater flexibility for those individuals who may be at a higher risk of severe illness from COVID-19; but do not compel, such persons to stay home.
  • Provide flexibility to employees with child or elder care obligations.

Foster a Communicative Culture

  • Communicate all details, and solicit staff input, throughout each phase of the re-entry strategy.
  • Engage and ensure leadership alignment with all phases of the reentry to the workplace strategy.
  • Schedule virtual meetings for staff to communicate guidance, policies, and to solicit questions and
  • feedback.
  • Establish mechanisms for ongoing two-way communication with staff.
  • Communicate new protocols and standards though all available channels, including signage, virtual
  • meetings, recorded messages, and employee intranet.
  • Promptly share all relevant updates from federal, state and local governments and agencies to
  • demonstrate fluidity, and to establish employer as a trusted source of information.

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