Godfrey & Kahn Updates
Coronavirus internal communication plan do’s and don’tsMarch 13, 2020
Once your business has its novel coronavirus 2019 (COVID-19) response plan in place, you need to roll out a communication plan. This plan needs to be mindful of key employment law constraints.
When developing your communication, key messages should include that a plan is in place, a team is assembled and ready to act, and that the response was developed thoughtfully. The communication can take multiple forms. Some employers may opt for an email blast, a frequently asked questions (FAQ) document or a combination of both.
COVID-19 internal communication plan do’s
When creating your internal communications, we recommend that you do the following:
- Do highlight the work completed on the plan to date, what steps are being taken to keep the workplace free of the virus and the expertise assembled on the team.
- Do remind employees that everyone has a duty to help keep the workplace safe.
- Do help dispel fears by educating employees on the virus and how COVID-19 spreads using the U.S. Centers for Disease Control and Prevention’s (CDC’s) detailed summary.
- Do detail temporary changes in any benefits, policies or practices, and highlight those that will not change.
Common modified policies and practices often include:
- International travel and work re-entry requirements
- Domestic travel to red zones and work re-entry requirements
- Extended paid leave and sick time policies
- Telework policy and procedures
Common benefits, policies and practices that are not modified, but highlighted, include:
- Family and Medical Leave Act (FMLA) and Wisconsin Family and Medical Leave Act (WFMLA)
- Short-term disability benefits
- Protection of medical information
- Time and attendance
- Do stay up to date on interim changes to federal laws that may impact your workforce, like the Families First Coronavirus Response Act.
- Do describe how employees can help with efforts to keep the workplace clean and safe. Efforts range from from washing hands and social distancing to encouraging self-reporting. The CDC’s guidance is a great base, but consider tailoring it to your specific workplace.
- Do conclude with a statement that outlines continuing efforts and that this is a fluid situation. Mention that your response team is monitoring international, federal, state and municipal government agency guidance and will provide updates to employees as they arise.
COVID-19 internal communication plan don’ts
From an employment law perspective, some issues can land employers in hot water if they are not careful. Many of these issues are better addressed on a case-by-case basis. For this reason, we recommend that you don’t do the following:
- Don’t address topics such as Occupational Safety and Health Administration (OSHA) direct threat issues.
- Don’t address Americans with Disabilities Act (ADA) reasonable accommodations.
- Don’t address potential physical screening of employees.
- Don’t address workers’ compensation.
- Don’t address wage and hour scenarios other than related to a change in policy or practice as noted in the “do’s” section.
Future posts on COVID-19 will address common questions and application of these laws to various scenarios.