What to do if an employee tests positive for COVID-19?

An employee reports to her supervisor that she has tested positive for COVID-19. There are several steps you can take to address the situation. The following items are an overview and are offered as a guide to start the process. This is not exhaustive or applicable to all situations. It’s best to monitor all the government websites that regulate your industry and consult with your counsel to make sure no laws are violated when handling this situation. The CDC, OSHA, WHO and others are updating their sites with the most current information.

What to do:

Assess level of exposure. Talk with the employee and ask where she has been, who has she come in contact with, how long was that contact, did she attend meetings. Look for close contact within 6 feet for a prolonged time period (greater than an hour).

Confirm close contact people and notify them. It’s advisable to notify them in person, individually, that they have been in close contact with a person who has tested positively. Do not disclose the name of the person who tested positive. The conservative approach would be to send the close contact people home for 14 days. Review the CDC guidelines for exposure.

Notify all employees. A company communication sent to all employees that there has been a confirmed case of COVID-19 is advisable. Provide the CDC guidelines. It may help to identify the steps that have been taken to address the situation: employee is at home for 14 days, close contact people have been identified and notified, and other measures. Again, do not disclose the employee’s name. You may identify general work location – 2^nd floor.

Notify the landlord. If your company occupies shared space, notify the building manager, so they can commence their safety and notification procedures.

Clean. Engage in a deep cleaning of common shared spaces and employee’s space. Communicate to the employees about the cleaning.

Communicate. Inform the employees of what to do if they have symptoms. Display the posters from the government agencies.

Additional considerations.

• You may ask your employees if they are experiencing symptoms if they are coming onto business property and all employees are being asked. Do not ask only certain people or certain categories of employees.
• You may be required to report the positive test to OSHA or your workers’ compensation insurance provider.
• If an employee with underlying medical conditions who has been in the workplace where there was exposure, clearly identify if they are seeking accommodations under ADA.