We all know that we need to modify the way we work to adapt in the wake of COVID-19. One of the main changes businesses are exploring is daily employee health screenings.
Health screenings help employers protect their teams and ongoing work by keeping coronavirus out of their offices. However, many employers aren’t sure how to roll out a program or approach communicating with their team about the transition toward workplace COVID screenings.
In this post we’ll:
Describe what an effective COVID-19 employee screening program looks like
Explain what employees need to know about your new health screening procedures
Provide a memo template you can use to communicate with your employees in a way that explains your program and builds buy-in
Connect you with more resources to simplify and strengthen your return-to-work plan
What Strong COVID-19 Screening at Work Looks Like
A Clear Team & Point of Contact
COVID-19 screening should be conducted by a designated professional or team with strong knowledge of CDC guidance on COVID-19 symptomology and prevention. Those professionals must be protected with proper personal protective equipment (PPE) including masks, gloves, and potentially face shields, to protect their own health and minimize their potential as vectors for the employees they’re screening.
Temperature Checks
Employees should be checked for temperatures upon arrival at work and sent home if they exhibit fevers of 100.4 °F or higher.
How do we capture temperatures in a safe, compliant way?
Temperature checks should be carried out with a touchless temporal thermometer and avoid direct skin contact to minimize potential spread of the COVID-19 virus and other germs.
Respiratory Health Screening Questions
In addition to checking temperatures, your screening team should have each employee complete a short questionnaire describing their current respiratory health with an eye towards identifying red flags.
This guide from the Department of Health provides guidelines for which symptoms should be included in a COVID-19 employee health screening, including providing a model questionnaire.
What Employees Need to Know About Workplace COVID-19 Screening
Of course, the final piece of a great implementation plan is a strong employee communication strategy. When you’re communicating with you team effectively, it fosters engagement and helps your employees see that you’re focused on safety and taking steps to reopen with everybody’s health in mind.
Before you reopen with your new workplace health screening system in place, you need to contact your team through whatever official channels you’ve been using during your temporary shutdown or remote work to alert them that screenings will be taking place upon your reopen and providing them with the information they need to comply with and feel comfortable with this new procedure.
Below, we’ll provide a memo template we’ve built to help businesses simplify this process. First, though, let’s talk about what information your employees absolutely need to know to reduce return-to-work anxiety and ensure your workplace reopen is a success.
Why You’re Screening Employees at Work
To some people, lining up for a health inspection as you head into work sounds like something from a dystopian science fiction novel. You need to set a positive tone and help your employees understand that these new procedures are for their health and wellness, not simply the wellbeing and liability of the company.
The better you can explain your rationale for new health screening protocols in a humanistic, talent-centric way, the better you’ll be able to win buy-in.
When/Where Screening Will Occur
Before your reopen occurs, employees need to know how to comply with the new COVID-19 screening protocols. That means you they need to know when and how often screenings occur, where to go, and who to make contact with.
Remember, you can only expect compliance and enthusiasm about your new procedures when you’ve made the effort to communicate. If people show up to work and see a line they’re not expecting, it’s a recipe for disharmony and frustration.
What the Screening Entails
Nobody likes to go into any kind of “test” without knowing the expectations. Your health screening procedure needs to be clear and transparent for employees ahead of time to reduce anxiety.
What kind of questions will they need to answer?
Your employees should know the respiratory screening questions they’ll be asked ahead of time to ensure they understand what they’re being asked and have the opportunity to ask questions about interpretation of either your HR team or their own personal healthcare professional.
How will temperature checks work?
No one likes the idea of being poked or prodded, especially with a potentially virus-covered tool. By ensuring your employees you’ll be monitoring their temperature using no-touch tools and will have screeners use PPE in a way that aligns with best practices, you can minimize anxiety about the physical aspects of the health screening.
Launchways’ Employee Health Screening Memo Template
How to Use This Tool
The following template provides a basic form letter you can modify to inform employees of your new COVID-19 screening protocols. Keep in mind you’ll need to make some modifications to this memo, including:
Adding your company’s name
Clarifying the effective date for screenings
Specifying the location for screenings
Communicating who will carry out the screenings
Establishing a point of contact for questions/concerns about this process
The Template
Memo: COVID-19 Employee-Screening Procedures
Effective [date], all employees reporting to work will be screened for respiratory symptoms and have their body temperature taken as a precautionary measure to reduce the spread of COVID-19.
Every employee will be screened, including having his or her temperature taken, when reporting to work. Employees should report to [location] upon arrival at work and prior to entering any other areas of [company name] property.
Each employee will be screened privately by [insert name or position] using a touchless forehead/ temporal artery thermometer. The employee’s temperature and answers to respiratory symptom questions will be documented, and the record will be maintained as a private medical record.
Time spent waiting for the health screening should be recorded as time worked for nonexempt employees.
An employee who has a fever at or above 100.4 degrees Fahrenheit or who is experiencing coughing or shortness of breath will be sent home. The employee should monitor his or her symptoms and call a doctor or use telemedicine if concerned about the symptoms.
An employee sent home can return to work when:
He or she has had no fever for at least three (3) days without taking medication to reduce fever during that time; AND
Any respiratory symptoms (cough and shortness of breath) have improved for at least three (3) days; AND
At least seven (7) days have passed since the symptoms began.
An employee may return to work earlier if a doctor confirms the cause of an employee’s fever or other symptoms is not COVID-19 and releases the employee to return to work in writing.
An employee who experiences fever and/or respiratory symptoms while home should not report to work. Instead, the employee should contact his or her immediate supervisor for further direction.
How to Learn More
If you’re an HR professional or business leader looking to guide a successful reopening as COVID-19 continues, be sure to download Launchways’ Complete Return to Work Toolkit. The toolkit provides a variety of checklists and other resources that help you consider reopening from every conceivable angle, including:
Recalling furloughed or laid off employees
Modifying your physical workspace
Best practices for employee safety
Personal protective equipment (PPE)
New policies for meeting, communication, shared space, etc.
When extending work-from-home is the better option
For the last two months, businesses and professionals around the nation have held their breath waiting for the go-ahead to reopen and get back to work. Now that those orders are in place and the dates to resume business are nearing, it’s essential that physical workspaces across America are ready to support employees and keep everybody safe and healthy under the rules of the new reality.
In light of these emerging needs, Launchways is proud to announce our partnership with ATrend Safety, a local Chicago-area company that has been reborn with the purpose of enabling employers and employees to get back to work in the safest possible environment.
In this post we’ll:
Introduce Atrend Safety and their approach to workplace safety
Describe the services available to Launchways clients through Atrend Safety
Explain how you can learn more
Meet Atrend
Before COVID-19, Atrend was one of the industry’s most respected international manufacturers of electronics and audio equipment, especially for vehicles. However, with the coronavirus crisis, Atrend decided to retool their production facilities to create personal protective equipment (PPE) and other workplace safety equipment to support social distancing.
If you’re interested in learning more about Atrend’s electronics and audio empire and their community-focused reemergence as Atrend Safety, click here!
What Can Atrend Safety Do for Launchways Clients?
Atrend Safety provides end-to-end workplace COVID-19 safety services, including assessment of your current environment, recommendations for PPE and safety strategy based on CDC and WHO recommendations, and assistance creating your new employee safety policy.
Once that assessment and plan articulation are completed, Atrend Safety can connect you directly with the PPE you need, including:
Disposable face masks
Reusable/washable facemasks (with your company logo or preferred pattern)
Face shields
Gloves
Vinyl floor graphics to communicate foot traffic patterns
Thermometers and body temperature checking stations
Hand sanitization stations
Safety screens for cabs and ride shares
Launchways and Atrend Safety
Atrend’s pivot toward PPE is a perfect example of how Chicago-area businesses are coming together and problem-solving in new ways in the wake of COVID-19. Their dedication to enabling the work of their colleagues in the Midwest business community stands as an example for all of us.
At Launchways, we were eager to partner with Atrend, both because of their community-focused response and because of their ability to provide clients with a streamlined consultative experience that demystifies the workplace safety questions that have so many business leaders looking for answers right now.
The fact that Atrend can deliver the PPE businesses require in addition to assessing their environment and making recommendations streamlines the reopen process significantly, limiting the number of vendors and consultants businesses leaders have to turn to.
How to Learn More
If you’re a business owner, finance leader, or HR professional trying to figure out how to adapt your physical workspace for social distancing and incorporate PPE best practices into your approach, Atrend Safety can help you today.
To learn more about a consultation or PPE purchases from Atrend, enter your information here and a member of the Launchways team will be in touch to discuss all your business’ COVID-19 workforce needs.
Takeaways
During these unprecedented times, it’s important to keep our eyes and ears open for stories about businesses who are finding new ways to thrive, serve their customers, and adapt to the new normal in the world of COVID-19.
Atrend Safety is a great example of an organization that adapted to meet the needs of the community and serve Chicago-area businesses in ways that will simplify and power the economic revitalization of our metro area in the coming months.
Remember:
Atrend, an audio and electronics leader here in the Midwest, has retooled as Atrend Safety, a workplace safety consultant and PPE manufacturing company
Atrend Safety provides end-to-end services, helping you scope your environment, devise a new workplace safety plan, and providing you with the PPE you need
Atrend Safety’s services are currently available to all that are part of the Launchways community!
As the majority of states transition toward some level of economic reopening, many professionals are scared that the economy is claiming priority above their health and wellbeing. If not addressed directly, this perception could easily lead to a disconnect between leadership and the ground-level team, significantly hampering our collective ability to make a strong economic recovery.
Addressing and reducing reasonable employee anxieties in the wake of COVID-19 is absolutely essential to our new way of business. Moving forward, we’ll explore:
The increased importance of clear and humanistic communication
How health screenings can provide employees with reassurance
Why it’s crucial to articulate a vision for the “new normal” of each role
How you can connect with impactful resources to aid your reopen
Explain Your COVID-19 Response Strategy Ahead of Time
In an information vacuum, panic is the default setting. The less your employees know ahead of your reopen, the lower their morale/enthusiasm/buy-in level will be. That means communication is the first cornerstone to a successful transition back to business.
Before you order employees back to their workstations, you need to clarify how you’re adapting or modifying the way you do work to protect everybody’s health. You also need to explain why you’re returning to work – why it’s the right choice for the business as a whole as well as your team in general.
If you fail to address either of those two concerns, your employees will probably have trouble believing you have their best interests at heart. If you aren’t making modifications, it seems like you’re taking them for granted. If you can’t explain why this is the right time to reopen, how can they be sure leadership is being strategic and not just reactionary?
Use Screening Questions & Temperature Checks
Your employees’ main concern about reopening is that they will be exposed to COVID-19 or bring it home to their families. In order to earn their trust, you need to show them that transmission isn’t going to happen in your workplace.
By creating a screening protocol to use before and during your reopen, you communicate that you’re dedicated to keeping COVID-19 out of the office and maintaining a safe, healthy environment.
Screening Before Reopen
While it’s true COVID-19 is frequently spread by people who are not yet feeling symptoms of the virus, you can still take major steps to protect your team collectively and as individuals by preventing as many symptom-positive individuals and recent exposures from entering your office or workspace.
Before your official reopen date, you should contact your employees to determine:
Who is currently ill with COVID-19 or similar symptoms
Who has been exposed to or cared for someone with COVID-19 in the last 14 days
Who has been advised by a doctor to stay home due indefinitely due to increased risk (i.e. who requires ADA accommodations?)
Who is currently the only source of childcare for a minor
Those questions will help you determine the scale of your re-open and identify areas of HR need in terms of transitioning employees to expanded sick or FMLA leave under the FFCRA. If responses indicate that staffing is not currently feasible, you may need to consider delaying your reopen or considering alternative staffing solutions.
Temperature Checks as Your Reopen
Temperature checks at the door prove to employees that nobody in the building currently has a fever (one of the most common COVID-19 symptoms). That reassurance goes a long way to helping people feel like they’re in a COVID-free environment.
However, if you’re going to administer temperature checks, you need to think about things like:
What is the exact temperature threshold for denying an employee entry?
How will you transition employees with fever to paid leave or work-from-home?
Who will administer the temperature screenings?
How will send-homes be documented?
How will you address employees who come to work with other symptoms but no fever?
What about Customers? What about Visitors? What about the Public?
To this point, we’ve been discussing screening your employees to keep the environment safe. With that said, the members of your team probably trust each other fairly well; it may be potential outsiders they’re nervous about.
If you run a hospitality, retail, healthcare, or other business where there’s frequent interaction with customers/the public, you need screening procedures in place to prevent your employees from becoming sick. Similarly, if you maintain an office where business travelers are often hosted, you need to reassure your core team members that you don’t have an open-door policy for the virus.
Whether it’s temperature checks, sneeze guards/partitions, or some other solution that makes sense for the work you do, it’s absolutely crucial you let your employees know you’re thinking about protecting their health from others.
Provide a Clear Vision for Every Role
In order for each employee to feel safe and empowered continuing their career in general and role in your organization specifically after COVID-19, they must feel like there is a specific plan in place for them.
Right now, professionals are hungry to know what their day-to-day work will look like moving forward for the next year or two. The more information and transparency you can provide, the better you can win your team’s trust and buy-in.
That means getting together with departmental and team leaders to make sure you’ve addressed what work will look like when you re-open for each individual employee. If that sounds like a challenging task, that’s because it is – but it’s absolutely a best practice for getting return-to-work right on a level that allows you to leverage the full productivity and enthusiasm of the team you’ve built.
For each role within the company, you need to address:
How their physical workspace needs to/will be modified to keep them safe
How their interactions with colleagues, customers, and the public need to/will be modified
What kind of personal protective equipment (PPE) they’ll need on a daily basis and what you will supply
What new cleaning/disinfection responsibilities they’ll have, both for individual workstations and common/shared spaces they use
A chain of command for reporting concerns/issues about reopening, adherence to new policies, etc.
Takeaways
Returning to the office in the aftermath of the unexpected coronavirus pandemic is truly the great challenge of our time. If we just flip the switch back to “on” and act like nothing’s changed, we’re sure to lose the employee buy-in that makes productivity and innovation happen.
If you’re hoping to reopen in a way that rallies your team and sets the tone for safe, positive work moving forward, it’s important to remember:
Your employees need advance notice of new policies and procedures to feel safe
You need to be able to explain how you’re protecting employees from potential COVID-19 exposure
Your approach to reopening needs to address every role and business process that’s directly or indirectly affected by COVID-19
How to Learn More
If you’re an HR or business leader looking to guide a successful reopening as COVID-19 continues, be sure to download Launchways’ Complete Return to Work Toolkit. The toolkit provides a variety of checklists and other resources that help you consider every aspect of reopening, including:
Recalling furloughed or laid off employees
Modifying your physical workspace
Best practices for employee safety
Personal protective equipment (PPE)
New policies for meeting, communication, shared space, etc.
With some states cautiously reopening non-essential businesses before the COVID-19 national emergency has been officially declared over, it’s crucial for the owners and managers of those businesses to get reopening right from a wellness and employee/public protection standpoint.
If we as a business community can execute this properly, then we’ll be bringing what normal looks like after COVID-19 to employees and the public at large, stimulating the reemergence of our strong American economy. However, we desperately need to talk about what reopening “right” actually looks like.
This is why Launchways created our Complete Return to Work Toolkit, a resource any business can use to plan for a successful return built on best practices and up-to-date information.
Moving forward, we’ll explore some of the concepts from the toolkit including:
Key policy & procedural concerns related to screening employees & visitors for COVID-19
Crucial questions about expectations for personal protective equipment that must be addressed before employees return to the office
Modifications you need to make to your physical workspace and way of fostering collegial collaboration in order to reopen safely
Health Screenings
The most important aspect of a proper reopen is getting your team members back in their traditional workplace in a way that ensures talent is returning to the building without introducing the spread of COVID-19 within your workforce.
Here are a few examples of questions you need to be able to answer regarding health screenings before you can plan to reopen:
What screening questions will you ask employees before they return to the office?
What screening questions will you ask customers/clients/office guests before anticipated visits to your facility?
What communication system will you use to transmit and manage screening questions?
Who will be in charge of reading/assessing eligibility to return based on screening responses?
What screening questions will you ask customers/clients/office guests before anticipated visits to your facility?
Will you carry out temperature checks as people arrive to work?
Where will you carry out temperature checks?
Who will carry out temperature checks?
What will be the temperature threshold for denying admittance to the workplace?
What are next steps for employees for are denied entry because of failing a screening?
How will you transition them toward leave?
How can you enable work-from-home for those who insist they can work?
What are next steps for customers/clients/office guests who fail a screening?
What parameters must a COVID-19 positive employee meet before returning to the workplace (for example 14 days from diagnosis, or 72 hours without experiencing a fever)
Personal Protective Equipment (PPE)
Given that COVID-19 is often spread by asymptomatic carriers, PPE is essential to minimizing the spread of coronavirus, even between people who do not feel or appear to be sick. The use of PPE among the public is currently inconsistent, so you need to set clear expectations for usage in your workplace.
Here are just a few different questions you need clear answers to before you recall your workforce and reopen your facility:
What PPE will public-facing employees use?
What PPE will back-office employees use?
Will you be issuing PPE or expecting employees to bring their own? (if employees must provide their own, will they be reimbursed?)
How often will you expect employees to change/sanitize PPE?
What cleaners or approaches will you approve for sanitizing PPE?
How/where will employees dispose of soiled PPE?
Will you require PPE for clients/customers/office guests?
Will you make PPE available to clients/customers/office guests?
How will you address refusal to comply with your PPE policy?
For employees?
For clients/customers/guests?
Social Distancing
Maintaining six feet or two meters of distance between all people remains a best practice until the official end of the outbreak period.
Here are some examples of baseline social distancing concerns you absolutely must have plans and policies in place for as you reopen:
How will you modify the physical space of public-facing areas to enable distancing for employees and customers/clients/guests?
How will you modify your back-office space to enable distancing for employees and guests?
How will you create sensible traffic patterns that allow people to get around the office in ways that support distancing and prevent anybody from “squeezing past” each other in the halls? (for example, some offices are transitioning their layout to use only ‘one-way’ hallways)
What kind of signage will you create to provide distancing reminders and where will you put it?
How will you enable meetings, brainstorming sessions, and other collaborative group work in ways that support distancing?
How will you address distancing with regard to the use of common spaces (kitchens, bathrooms, etc.)?
How will you address refusal to comply with your social distancing policy?
For employees?
For clients/customers/guests?
How to Learn More
If you’re a business leader hoping to reopen your business or transition remote workers back to the traditional office in the coming days and weeks, be sure to download Launchways’ Complete Return to Work Toolkit!
The toolkit covers:
How to Determine Who Should Return to Work & When
Preparing & Modifying Your Physical Workspace
Protocols for Employee Re-Entry & Health Screenings
Building and Enforcing Social Distancing & COVID-Specific Employee Protocols
How to Address Workforce Anxiety About Returning to Work
Sample Return to Work Survey for Employees
How to Identify & Correctly Update Effected Company Policies
Roadmap for a Return-to-Work Communications Strategy
The COVID-19 outbreak is changing nearly everything about how we work and do business. And if changing work conditions weren’t enough for employees to deal with, they also have to navigate a host of new federal policies including temporarily expanded sick leave and FMLA family leave. But, they don’t have to do it alone. Employers can help their team members work more effectively while achieving a healthy work-life balance by setting clear leave policies.
The Families First Coronavirus Response Act established Emergency Paid Sick Leave and drastically, albeit temporarily, expanded the scope of the Family Medical Leave Act. But it also left it up to employers to set the terms of how employees can use that leave. That means that employers must educate themselves on how their team members can take advantage of the leave to protect themselves and their families while staying productive, and then provide clear guidelines for their teams.
This can be particularly useful for employees who don’t want to take time off of work but have to take care of children who are now home from school or childcare. These employees are entitled to paid leave if they decide not to work. But they may not know how to take paid leave for time spent caring for their children while working part-time. That’s where employers can help employees navigate the situation so that they can work as much as possible while simultaneously taking care of their other obligations.
In this article, we’ll provide an overview of how employers can set flexible leave policies and help their team members navigate the new leave policies including:
Employees’ leave coverage under the Families First Coronavirus Response Act
How to expand the leave policies to help your team members work more effectively during the outbreak and as businesses begin returning to work
Employees’ Rights Under the Act
The Families First Coronavirus Response Act implemented several employee leave expansions that went into effect at the beginning of April. We wrote a full overview that you can read here, but here is a quick overview of what your employees are entitled to from the FFCRA if you have fewer than 500 employees:
2 weeks full paid sick leave if they are unable to work due to COVID-19 illness, quarantined due to exposure, or are experiencing symptoms and waiting for a diagnosis
Paid sick leave is available to employees who are quarantined but not sick only if they cannot work remotely
2 weeks of paid family leave at 2/3 pay if they need to care for an individual subjected to quarantine or need to take care of minors whose schools or childcare facilities are closed due to the virus
10 weeks of extended family leave at 2/3 pay if employees need to take care of minors and have been with the company for at least 30 days
Notably, if your company has 49 or fewer employees, you can apply for a small business exemption. But unless you receive a small business exemption, you cannot prevent qualified employees from taking leave. Nor, given the current health crisis, should you aim to prevent employees from taking the leave they need. Your leave costs will likely be covered by tax credits under the new CARES Act. It’s often in your best interest to help your employees maximize their ability to leverage the leave policies, especially to discourage the spread of the virus amongst your workforce.
Expanding Leave Policies for More Effective Work
Under the FFCRA, employees may not be eligible for leave if they are healthy, do not have to care for minors, and can work remotely. While on the other end of the scale, employees who have to take care of minors may be eligible for a full 12 weeks of leave, paid at 2/3 their normal rate. However, many employees who do qualify for leave to take care of minors, but can work remotely, will not want to take three months away from their work. And many employees may be concerned about keeping some of that time in reserve, since no one knows how long the outbreak will last. That’s where employers can help their employees make the most of their paid leave while simultaneously minimizing the disruption to their business.
You have the right to force employees to either work full time or go on leave. But it is often in both of your best interests to work out an arrangement where employees with family obligations work as much as they can while taking leave when they cannot. And the FFCRA gives employers a lot of leeway in allowing employees to take sporadic or intermittent paid leave.
Employers can allow employees to take paid leave in increments anywhere from week-to-week, day-to-day, or even hour-to-hour. That means you could allow your team members to take paid leave to homeschool their children every other day while working full time on the other days. Or they can take a few hours of paid leave every day to take care of their family obligations and work for the rest of the work day. And this does not just apply to remote employees: you can allow employees who have to come into the workplace to work a partial schedule while taking paid leave on their days off.
It’s important to remember that employers are not obligated to provide this kind of flexibility. But it can often be in your best interest to work with employees to find the best arrangement for both parties. Not only will it allow you to retain key employees, on a partial basis, who would otherwise go on full-time leave, thus reducing the disruption to your business from COVID-19, but it can also have a lasting impact on employee relations. Employees will remember it if you work to help them juggle their work and non-work obligations, increasing loyalty and productivity in the long-term. On the other hand, they will also remember if you took an all-or-nothing approach that adhered to the bare minimum requirements of the FFCRA. It’s crucial to consider the optics of your approach to leave during COVID and as employees begin transitioning back to work.
To recap, you are allowed but not required under the FFCRA to let your team members take emergency paid sick leave or family medical leave:
On a day-by-day basis while working a partial schedule either remotely or in-person
On an hourly basis to allow for reduced hours per day, either around a shorter shift or to allow for breaks to care for family
On a weekly or monthly basis
At your discretion, within the limitations of the FFCRA (you can prevent employees from working until they come back from leave but you cannot prevent them from taking continuous leave while they qualify for it)
You should decide which of these arrangements, if any, will work for your business and then set a clear leave policy. Then, inform your entire staff of that policy and work with each employee to help them set up the arrangement that works best for them, within the limits set in your policy. Clarity and flexibility will help your business run smoothly and help your employees balance their work with their other obligations.
Key Takeaways
With the COVID-19 outbreak continuing to disrupt every part of life and business as we know it, we can all benefit from working together to find solutions. The FFCRA requires that employers offer 2-12 weeks of paid leave for qualifying employees at either full or 2/3 pay and you should take responsibility for that obligation. If you create flexible leave policies that enable employees to work as much as they can while taking only as much leave as they need, you can minimize disruptions to your business. Setting clear and flexible leave policies and helping employees take advantage of those policies is truly a win-win strategy. Just remember that:
Healthy employees who do not need to care for minors or sick family members may not be eligible for any expanded leave and can be required to work full time if they can work remotely
Employers are allowed to decide whether and how their employees can take intermittent sick or family medical leave
If they chose to, employers can let their employees take their expanded leave on an hourly, daily, or weekly basis
For more on the Families First Coronavirus Relief Act and running a business during the COVID-19 outbreak, check out Launchways’ comprehensive resources on our COVID-19 Emergency Resource Center.
Filling out form I-9 is a standard onboarding procedure for any new hire. The new employee fills out Section 1 and provides supporting documentation of their identification and work-eligible status; then an HR professional makes copies of that documentation, completes Sections 2 and 3 (as applicable), and retains the form.
Generally speaking, it’s expected that the I-9 is completed in person, with the new hire and a HR professional exchanging physical documentation and verifying information face-to-face.
However, given the CDC’s social distancing guidance for COVID-19, that procedure obviously isn’t appropriate for this moment. In order to enable strong businesses to continue hiring and providing meaningful work for new employees, the Department of Homeland Security (DHS) has temporarily deferred in-person I-9 verification.
Moving forward, we’ll explore:
Hiring/operating procedures during the current COVID-19 I-9 deferral period
The term of the deferral
Compliance expectations at the end of the deferral
The value of this deferral period for businesses
Modified Procedures for COVID-19
The DHS has temporarily suspended the need for in-person I-9 verification. That means businesses can continue to hire and onboarding new employees remotely during this time without fear of non-compliance.
For now, documents pertaining to identity verification and employment eligibility can be submitted and reviewed remotely (i.e. by scanning and attaching documents to an email or submitting through an HR portal). Copies of those files should be retained in your internal HR records.
DHS’ verification deferral has also loosened up the time window for I-9 completion. Temporarily, employers have three working days to complete the paperwork and confirm documentation instead of just one day.
How Long Will This Deferral Last?
The I-9 verification deferral period will end either sixty (60) days from March 20, 2020 or three (3) days after the end of the COVID-19 national emergency has been announced, whichever comes first.
What Do We Need to Do to Comply When This is Over?
Once the deferral period ends (as described above), employers have three business days to complete standard in-person I-9 verifications for any employees they have hired and onboarded during the deferral.
Under “Additional Information” on Section 2 of form I-9, the employer must note that COVID-19 temporarily prevented them from a detailed physical review of the original documentation and provide the date they physically examined the documents. From there, the forms can be filed and retained as usual.
Why is This Deferral Good for Business?
In-person I-9 verification would prevent many businesses from filling the holes in their depth chart created by COVID-19, as employees must take leave for their own health, to care for a family member, or to supervise children. By enabling streamlined remote hiring, the DHS is providing support to businesses who are doing their best to continue the work and provide paychecks to their teams during this time.
Furthermore, remote hiring has the potential to connect great talent with jobs where they can be impactful faster than ever, fighting back record unemployment to help jumpstart the economy once again.
Takeaways
The Department of Homeland Security is deferring in-person I-9 verification during COVID-19-related social distancing. This is a great opportunity for businesses to fill out their teams and keep the work going without slipping into noncompliance, but it’s important to remember:
The deferral window will end on May 19 or 3 days after the national emergency is declared to be over
Employers still need to review digital versions of identification/eligibility documents within three days of hire
When the deferral period ends, employers will have 3 days to complete traditional in-person I-9 verification
