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Return to Work Plans and COVID-19

As COVID-19 unfolds, the importance of a properly deployed Return to Work is reviewed and in place with contingencies.

Echoing the sentiments of public health officials, a return to normalcy won’t be like flipping a switch, but rather a gradual effort. In preparation for reopening your business and asking employees to come back to work, it’s imperative that your company thoughtfully constructs a return to work plan for its employees to keep everyone healthy and safe following the COVID-19 pandemic.

 Things To Consider Before You Open

1. Make sure your workspace is thoroughly cleaned with CDC recommended cleaners
2. Check with state and local health codes for your type of work in light of COVID-19
3. Create health and safety protocols for your work environment 
4. Train your staff on new work and health protocols as it relates to COVID-19
5. Implement paid sick leave if you don’t have it already for sick employees

Returning to Work and Benefits Eligibility Considerations


Employers should first determine whether the plan document addresses furloughs, rehires, or unpaid leaves of absence.  It may be time to check and update existing Employee Handbooks

Premium Payments

The employer may recoup the cost of any missed contributions during the period the employee was furloughed without pay.  Employers should check state wage and hour laws, as some states have limits on what can be deducted from an employee’s pay.  

Restoring Previous Election

When more than 30 days have elapsed between an employee’s termination and rehire, the cafeteria plan may (by design) allow a new election or require the old election to be reinstated.

ACA and FMLA Considerations

For special unpaid leaves of absence (such as leave under the FMLA and USERRA), the employer has two options for crediting hours. One option is to exclude the period of special unpaid leave from the applicable measurement period. The other option allows employers to credit the employee with hours equal to the average hours worked during weeks not part of the unpaid leave.

Employers who furlough employees without terminating employment will need to make careful determinations as to whether employees need to be credited with hours of service under the applicable look-back period. The failure to correctly credit hours could cause the employer to misclassify employees as not full-time and cause penalties under the ACA employer shared responsibility rules. Careful records should be kept so that the employer knows each employee’s status as full-time or not full-time during each month of 2020 in order to be prepared for ACA reporting that is done in early 2021. Employers may wish to go ahead and credit employees with hours service during the furlough period. While this would be one way to avoid penalty under employer mandate rules, the employer should get the carrier’s

What Happens If Your Employees Get Sick?

  • Send them home immediately if they aren’t already working from home.
  • Advise them to contact their doctor immediately.
  • Advise them to keep their direct report updated on their status.
  • Deep clean the office if the employee has been there during the last 14 days.
  • Notify Human Resources to send information on how to self-monitor and self-quarantine at home.
  • They should not return to the office until symptoms are gone for 72 hours, without the use of symptom-reducing medication.

What do I do if an employee tests positive for coronavirus?

  • If they learn of this while in office, send them home immediately.
  • Notify all office employees of the exposure and send them home.
  • Deep clean the office.
  • Close the office for 14 days.
  • Identify and notify any employees from other offices who may have visited the office in the last 14 days.
  • Advise all employees to self-monitor for 14 days, and to reach out to a doctor if they start to exhibit symptoms.
  • Notify Human Resources to send information on how to self-monitor and self-quarantine at home.
  • Advise employees to keep in contact with their direct report.
  • Require a doctor’s note that verifies the employee is no longer sick, contagious or COVID-19 positive before they can return to work.

Continued Safety

Once back at work employees with symptoms should understand the importance to stay home and get tested and have a plan if an outbreak occurs again. Remember, reopening your business after the COVID-19 pandemic isn’t as simple as opening your doors. You’ll need to carefully evaluate each step of your reopening and gradually ask employees to return to work.

The next phase of responding to the COVID-19 pandemic involves reopening your business. While this task may seem daunting, we’re here to help. Understanding your health benefits well is the key to helping your employees get the right health care when they need it. If you’d like to find out more about how you can get better benefits so your employees use them when they need to, we’d like to show you how. Please contact us using form below or [email protected] or 855-667-4621.


The information provided on this website is intended for informational purposes only.  Millennium Medical Solutions Corp. does not offer legal or medical guidance.  Those with legal or medical questions should seek appropriate assistance from a licensed professional.  Stay up to date by signing up for Newsletter and Coronavirus Dashboard below.

To Test or Not to Test: That is just one of many critical questions

TIME:  Friday, May 15, 1:00 P.M. EST


COVID-19 has dramatically affected the world and created new hurdles for businesses in virtually every industry. To meet this challenge, Optum has built a practical Return to Workplace approach for employers.

DISCUSSION  presenters discuss the issues defining (and redefining) the workplace in the age of COVID-19, including:

  • Testing, re-testing, and quarantine management – all top of mind with employers as they consider how to open for business
  • What employers should think about as employees return to the workplace
  • A framework for building an effective return to work approach


Learn how our PEO Partnership can help your group please contact us at [email protected] or (855)667-4621.

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For more information on PEOs or a customized quote please submit your contact. We will be in touch ASAP.

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