What to know about holiday travel policies during COVID-19

By Cheryl Meyer

It’s the holiday season, traditionally a time of joy, celebration, travel, and gatherings with friends, family, and colleagues. But this December, coronavirus numbers are spiking worldwide, requiring employers to follow state and national guidelines and protect their individual workforces by determining how to handle pre- and post-travel intermingling.

Plante Moran, with 3,300 employees across 21 domestic and four international offices, is requiring every staff member to complete a daily health-check screening form and to quarantine at home for seven days if they take any form of mass transit. If workers gather with people outside of their home, even if they drive, the firm is asking them to stay at home for seven days, said Auburn, Mich.-based Teresa Pollock, group managing partner for regional offices.

Other firms have put similar policies in place. If employees at DiCicco, Gulman & Company LLP in Boston and Woburn, Mass., travel outside low-risk areas, they must work from home for 14 days or have a negative COVID-19 test result within 72 hours of their return in order to come into the office. “We’re not telling employees that they can’t travel, but if they choose to travel, they need to follow state guidelines,” said Dawn Hagman, a partner for human resources at the firm.

With COVID-19 numbers on the rise as people in cold-weather states shift indoors, accounting firms are grappling with how to handle holiday travel, particularly because there is no one-size-fits-all road map. Each state issues its own rules, some strict, and some simply mirroring the Centers for Disease Control and Prevention (CDC) guidelines, all of which are updated regularly.

Travel is also not the only issue at hand — firms must consider gatherings as well. “You can have somebody who never leaves Baltimore but is having Thanksgiving dinner with 50 people at one long table” and thus could potentially risk being exposed to the virus, said Lindsey White, J.D., an employment litigator and partner at Baltimore-based law firm Shawe Rosenthal LLP.

Employers can’t restrict travel or get-togethers this holiday season, but without proper protocols in place, firms could open themselves up to liability if an outbreak occurs in-house or if clients contract the virus. “Employers have an obligation under OSHA [Occupational Safety and Health Administration] to provide a safe workplace,” White said. “They can and should screen their employees both for symptoms, exposure, and any sort of enhanced risk factors, which could include travel.”

White and HR experts offer the following advice for firms putting guidelines into place over the holiday season:

Stay up-to-date on state and CDC travel guidelines. While it’s a lot to take in, know your state and CDC regulations for dealing with COVID-19, and then implement policies accordingly. “Each state is treating this pandemic differently, and several states have explicit travel requirements, so you might have mandatory quarantine if you travel to certain states,” White said. “Employers should be aware of state- specific laws.” Maryland, for instance, has a travel advisory, as opposed to a mandate; Maryland residents who have traveled out of state to a location with a COVID-19 positivity rate above 10% or a case rate of over 20 people per 100,000 in the past seven days “should get tested and self-quarantine until the test results are received,” she said.

Know your rights as an employer. Firms have more rights than they may realize. “Employers can require employees to report on personal travel and comply with CDC travel restrictions and comply with relevant state quarantine orders,” White said. However, she added, some states have “off-duty conduct laws that prohibit employers from taking an adverse employment action based on such conduct, which would likely include travel,” so it’s critical to read up on these off-duty regulations.

Grassi & Co., a New York-based accounting firm that has stayed open all year without incident, is monitoring employees’ travel to stay safe. “People have to tell us when they are traveling,” said Jeff Agranoff, chief human resources officer and human resources consulting principal at the firm. Per state rules, Grassi’s employees must also quarantine for 14 days or get tested three days prior and three days after their trips to anywhere but neighboring states. The firm is also following CDC guidelines, including mandatory mask wearing in common areas and high-grade cleaning procedures, in order to remain open. “I don’t anticipate a lot of people will travel” over the holiday season, he said.

Employers can also demand their workers take a COVID-19 test after travel and can specify a PCR, or polymerase chain reaction, test versus a less accurate rapid test, White said. Of course, not all firms will do this. “We do not mandate COVID testing, but what we do is prohibit meeting with clients if employees have traveled,” Plante Moran's Pollock said.

Communicate clearly with staff. Keep an open channel of exchange with employees, who may ask questions regarding travel and holiday assemblies. “Make sure that you clearly communicate to your employees what the expectations of the quarantine process are prior to travel, so they understand it,” Agranoff said.

And with COVID-19 numbers rising, be clear why your protocols are important. “Educate employees so they understand the concerns of what could happen if they travel, not only for the company, but themselves,” he said. “We are encouraging our people not to travel out of state.”

Be consistent but flexible with employees. The degrees of risk vary nationwide, and in some cases, travel or gatherings may be important or necessary. Some employees may have a dying or elderly relative they need to see or several children coming home from college. Or your state may be a COVID-19 hotbed, meaning any human interaction is a risk.

“Give people a little bit of grace,” said Lauren Sanders, human resources director at accounting firm Brown Smith Wallace LLP in St. Louis. Missouri saw more than 24,000 cases of COVID-19 during the first week of December per the CDC’s data tracker. “Because Missouri is a hot spot, it’s hard for us to say, ‘You cannot go anywhere,’” Sanders said. Her firm, which remained open this year but gave employees flexible work-from-home options, also conducts daily health questionnaires and requires in-office workers to quarantine after traveling internationally or taking a cruise.

No matter what your policies of compliance and flexibility, however, ensure you treat everyone the same. “Employers need to apply their rules consistently throughout their workforce,” White said.

Consider the safest options of all. To ease the worry of holiday travel and get-togethers, contemplate shutting your doors temporarily. Grassi plans to close offices around Christmas until about Jan. 5, to give employees a chance to self-quarantine after the holidays and “to stop the spread if somebody was exposed,” Agranoff said.

One of the easiest ways to avoid any safety concerns, though, is to simply insist employees work from home versus the office, especially while coronavirus numbers remain high. “If you are requiring employees to stay home and work from home, there’s really no issue here,” White said.

For more news and reporting on the coronavirus and how CPAs can handle challenges related to the outbreak, visit the JofA’s coronavirus resources page.

Cheryl Meyer is a freelance writer based in California. To comment on this article, contact Courtney Vien, a JofA senior editor, at Courtney.Vien@aicpa-cima.com.

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