Blog  |  May 29, 2020

How to Develop Your Financial Institution’s COVID-19 Return-to-Work Policy

While many stay-at-home orders have been extended, some states are allowing at least some businesses to reopen. It is important for organizations to realize the need for advanced planning of their return-to-work strategy to ensure a smooth transition.

The following best practices will provide guidance to consider while creating your institution’s return-to-work policy. While this guidance is not legal advice, it is a helpful source for getting started and can help you create a measured approach to your policy.

Review Federal, State and Local Plans

First, it is important to review any applicable federal, state and local recovery plans, including each state’s local stay-at-home orders. Some states may even have a posted recovery plan that your institution may leverage. If you are a larger multi-state institution, you may want to include the proposed recovery plan from the CDC and the White House in your decision-making process. Or, if you are a smaller institution located in a single state or in a handful of states, you may want to consider looking at a specific state’s recovery plan, such as the state of Missouri’s plan. Both plans incorporate and rely on guidance from medical professionals, which is important as you may not want to rush employees back too soon.

Consider a Phased-In Approach

After reviewing federal, state and local stay-at-home orders and recovery plans, decide if your institution will limit the number of employees that can return to work in stages with a phased-in approach. Both the federal government and some states have proposed plans that include a phased-in approach. Before implementing a phased-in approach for your institution, consider the following:

  • Size of Returning Workforce: What percent or number of employees will you allow back? Will you allow 25 or 50 percent? If so, at what time do you bring back the remaining staff?
  • Alternating Schedules: Managers may want to consider establishing alternating shifts for returning employees. Additionally, managers could find creative ways to encourage social distancing in the office by providing appropriate spacing between workstations.
  • Employee Preference and Performance: How are you going to address employees that want to return to the office sooner? How are you going to address employees who are performing at a level less than what is expected because they are working from home and not in an office? Those employees that continue optimal performance while operating at home may be included among the last employees to return to work.
  • Limiting Group Gatherings: Limit the use of common areas where large numbers of employees may gather, such as lunch or break rooms. Furthermore, with today’s available technology, managers may want to limit in-person meetings and continue encouraging videoconferencing when possible.

Utilize Resources from OSHA

As you develop your institution’s return-to-work policy, another great resource is the guidance on preparing workplaces for COVID-19 from the Occupational Safety and Health Administration (OSHA). It should be noted that the guidance states there is no specific OSHA standard, but some OSHA requirements may apply to preventing occupational exposure.

To help determine if you should require employees to utilize personal protective equipment (PPE), OSHA has divided job tasks into four risk exposure levels: very high, high, medium and low risk. The very high and high categories concentrate on healthcare and mortuary workers and are not usually associated with the financial industry. However, it is important to familiarize yourself with the medium and low risk levels. If you have employees that are classified as medium or even low risk, you may want to strongly consider requiring those employees to utilize applicable PPE.

Develop Protective Screening Procedures

Related to OSHA requirements, another topic to consider is the decision to screen employees, customers and/or visitors entering your institution’s locations. Screening can include taking temperatures or asking about any symptoms an individual may be experiencing. If you choose to screen individuals, keep the following guidelines in mind:

  • Apply any screening practice equally across all groups.
  • Keep any screening information separate from employees’ personnel files.
  • Ensure the confidentiality of any screening information for visitors.

Continue Practicing Good Hygiene

Your institution should encourage all employees returning to office settings to continue practicing good hygiene. Consider improving your institution’s hygiene requirements within your facilities by supporting the following hygiene etiquette for employees, customers and visitors:

  • Provide tissues and no-touch disposal receptacles
  • Provide individuals soap and water to wash hands
  • Place hand sanitizers in multiple locations to encourage hand hygiene
  • Place posters that encourage hand hygiene to help stop the spread
  • Discourage handshaking, but encourage the use of other noncontact methods of greeting
  • Avoid touching your face
  • Sneeze or cough into a tissue, or the inside of your elbow
  • Disinfect frequently used items and surfaces as much as possible

Implementing Your Policy

Though some institutions are beginning the process of returning to places of employment, there is still the possibility of a resurgence, or second wave, of COVID-19 cases. To further combat the likelihood of this happening, please be mindful of your current work-from-home strategies. As you navigate this difficult situation and implement the return-to-work policy that is best for your organization, continue sending employees home if they feel ill and maintain safety measures when necessary.

Watch this video from CSI for more information on creating and implementing return-to-work policies.

Keith Monson serves as CSI’s chief risk officer. In this role, Monson maintains an enterprise-wide compliance framework for risk assessment and reporting, as well as other key components of CSI’s corporate compliance program. With over 30 years of experience, he has a wide range of expertise in the compliance arena, having served as chief compliance officer for both large and small financial institutions.

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