As branch and office reopenings continue, human resources (HR) professionals will play a critical and multifaceted role in shaping what the return to work will look like for credit union employees during the coronavirus (COVID-19) pandemic.
"It’s never been more important for HR to have a seat at the table to figure out how we’re going to progress into the 'new normal' at credit unions," says Diane Reed, owner and founder of CU Doctor LLC.
Reed addressed the CUNA HR Compliance Rule Changes Virtual Conference during the session "Office Considerations: OSHA, ADA, and Reasonable Accommodations."
One of HR’s biggest tasks will be ensuring compliance with local, state, and national health and safety guidance—and sometimes making the best decisions possible in an uncertain environment.
"We’re getting guidance from everywhere," Reed says, "and sometimes the guidance is in conflict with itself."
Reed suggests taking a four-step approach to planning for employees to reenter the office safely.
Gather an up-to-date list of all employees, including their job duties and primary work locations, and whether they work from home and how often. With a complete list in hand, focus on employees you’ll need on the first day of returning to work.
This first wave should comprise managers and essential staff who perform required functions as defined by HR.
Also identify staff who are potentially vulnerable due to increased risk factors, such as age, preexisting health conditions, and family or living situations.
"Look holistically at each employee to figure out who’s at risk and who’s vulnerable," says Reed.
Determine which processes work well in a remote environment. "Have enough of your members moved online now that you don’t think they’re going to move back?" Reed asks.
This might prompt a look at structure and delivery channels to see whether you’ll need the same in-person staffing as before.
Embrace change and use data to determine how members are accomplishing their banking tasks. Review all aspects of the "remote toolkit," such as phone centers, ATM networks, online and mobile banking, remote deposit capture, and eSign or eNotary.
Follow local and state stay-at-home orders, as well as industry guidance, when planning a back-to-work timeline. Potential approaches include a phased return in stages, shifts or half-day increments in the office, or pod concepts that isolate employees to smaller groups.
State laws matter, Reed says. "Almost every state has a stay-at-home or reopening plan. Stick with it. Know that it is different from a shelter-in-place order and that we are a critical service. People need to be able to get to us."
Some states or localities are enforcing required protections like capacity limitations, mandatory masks, and six-foot distancing rules. But everything is subject to change down to the local level, such as some reopening orders being rescinded.
"Stay in touch with what’s happening in your locality," Reed says.
The Americans with Disabilities Act (ADA) permits employees to seek reasonable accommodations from their employers due to COVID-19. Reed advises HR professionals to plan for this possibility as early as possible if they know employees will need reasonable accommodation.
The ADA does not interfere with HR’s ability to require employees with symptoms to stay home. HR departments can require a medical note certifying that an employee is fit for duty before returning to work.
HR can require COVID-19 tests if needed—but not antibody tests.
Reed also says credit unions can screen employees, vendors, visitors, and members who enter branches or offices. These screens could incorporate temperature checks or self-acknowledgement of risk factors.
Get every individual’s contact information so they can be alerted in case of potential exposure, and store information related to an employee’s medical information separately from their personnel file.
Under the Occupational Safety and Health Administration (OSHA) General Duties Clause, if an employer fails to control for high to very high occupational exposure risk for COVID-19 and guidance is available, that employer may be found in violation of the clause.
To mitigate that risk, OSHA makes several preventative recommendations:
Reed advises HR professionals to prioritize policy first. "If you don’t have one now, get on it immediately. Our policies and procedures at each of our credit unions should be specific to the conditions in our area."
Contact tracing is another HR responsibility. "Keep track of who is near whom so you know who to notify of potential exposure," Reed says.
Use the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) for this purpose.
The difficulties created by COVID-19 can feel overwhelming, but Reed says detailed planning and organization can make returning to work safer for employees.