Guidelines To Keep Your Workplace Compliant


Wellness screenings are an important part of your return-to-work plan.

Taking the time to conduct simple health checks or ask employees to complete a short questionnaire before they enter your workplace can help you minimize the spread of COVID-19 after you’ve reopened.

However, it’s important to use the right approach to avoid concerns about privacy or discrimination. Here’s a closer look at how to conduct wellness screenings in an effective and compliant manner.

Conducting EEOC- and ADA-compliant wellness screenings

In light of the COVID-19 pandemic, the Equal Employment Opportunity Commission (EEOC) has released revised guidelines that outline how employers can implement wellness screenings that are still compliant with EEO laws and the Americans with Disabilities Act (ADA).

Here are some of the main takeaways:

  • When conducting a wellness screening, employers can ask employees whether they are experiencing the symptoms identified by the CDC and other public health authorities as being associated with COVID-19. They can also ask if the employee has been tested for and/or diagnosed with COVID-19.
  • Under the Genetic Information Nondiscrimination Act (GINA), employers cannot ask an employee if any of their family members have been diagnosed with COVID-19 or are experiencing COVID-19 symptoms. However, they can ask if an employee has been in close contact (within six feet for at least 10 minutes) with anyone diagnosed with COVID-19 in the last two weeks.
  • If an employee travels for either personal or professional reasons during the pandemic, an employer is allowed to ask if their trip was to a location that would require them to stay home for several days upon return, per recommendations from the CDC or state/local public health officials.
  • While, in general, taking an employee’s body temperature is considered a medical examination, the EEOC guidelines permit employers to conduct temperature checks. However, as with all medical information, if an employee registers a fever or exhibits other symptoms, this information would be subject to ADA confidentiality requirements.
  • If during a wellness assessment an employee is exhibiting COVID-19 symptoms, an employer is allowed to send the employee home.
  • An employer is permitted to administer a COVID-19 test as part of a health screening as long as the test is considered accurate and reliable by the CDC and other public health authorities.
  • If an employee refuses to have their temperature taken or refuses to answer questions about whether they have COVID-19, have symptoms associated with COVID-19, or have been tested for COVID-19, the ADA allows an employer to prohibit the employee from entering the workplace.

To avoid the appearance of discrimination, you should follow the same procedure for every employee and, when necessary, make modifications for employees who are unable to comply due to medical reasons. You should also provide verbal and written instructions in multiple languages to ensure non-English-speaking employees can properly understand what is expected of them.

COVID-19 symptoms to consider in wellness screenings

Whether you implement on-site wellness screenings or pre-arrival self-screens, you need to decide which symptoms will be included as part of the assessment.

While there are many different symptoms that have been associated with COVID-19 infection, the CDC recommends focusing on the following:

  • Fever or feeling feverish (e.g., chills, sweating)
  • Cough
  • Difficulty breathing
  • Sore throat
  • Muscle aches or body aches
  • Vomiting or diarrhea
  • Loss of taste or smell

The CDC also recommends using questions that concentrate on “new” or “unexpected” symptoms. An employee with a chronic gastrointestinal or respiratory condition may be experiencing symptoms on the list, but that isn’t necessarily an indicator of infection. In other words, the symptoms should be out of the ordinary for the employee.

Safety measures for on-site wellness screenings

If you choose to initiate on-site wellness screenings, protecting the employees conducting the health assessments must be a top priority.

Upon arrival at the check-in station, the screener should wash their hands with soap and water for at least 20 seconds or use hand sanitizer with at least 60% alcohol. They should wear personal protective equipment (PPE), including gloves as well as a face mask and eye protection or a disposable face shield that covers the front and sides of the screener’s face.

Depending on the screener’s level of contact with employees, they should either discard their PPE and wash their hands/use hand sanitizer after every check or periodically do so throughout the day.

The most effective methods for eliminating or minimizing the screener’s exposure are those that incorporate physical distancing. If the screener cannot maintain six feet of distance from the employees being screened (for example, in wellness screens that include an on-site temperature check), a physical barrier (such as a plastic partition) should be installed.

As long as the screener’s face stays behind the barrier at all times during the assessment, they should be protected from the respiratory droplets that can be produced when an employee being screened talks, sneezes, or coughs.

If your wellness screenings include a temperature check, the screener should remain behind the barrier and reach around the partition to take the employee’s temperature. Disposable and non-contact thermometers are the preferred method for taking an employee’s temperature as they do not require the screener to change their gloves after every temperature check.

If you use non-contact thermometers, be sure to clean and disinfect them according to the manufacturer’s recommendations. In locations with more extreme temperatures, non-contact thermometers should be regularly calibrated to ensure accurate readings.

Using technology to conduct pre-arrival self-screenings

While conducting on-site wellness screenings are an acceptable way to reduce your workforce’s risk of exposure to COVID-19, they are time-consuming and cumbersome. A faster, more efficient option is to have employees complete a self-assessment before coming into the workplace.

With iOFFICE’s visitor management system, you can have employees complete a self-screening questionnaire or review a health checklist as part of the pre-registration or check-in process. If an employee’s temperature is in a safe range, they aren’t experiencing symptoms, and haven’t been exposed to someone who is infected with COVID-19, they can come to the office. If they can’t check those three boxes, the employee should be advised to stay home.

Regardless of whether you implement on-site screenings or pre-arrival self-screens, part of your strategy for wellness screenings must be to deter employees who are actively exhibiting symptoms of COVID-19 and/or who have a fever ≥100.4°F from entering the workplace.

You should also discourage employees from coming to the office if they are under evaluation for COVID-19 (e.g., waiting on test results to confirm infection status) or have been diagnosed with COVID-19 and are not yet cleared to leave isolation.

Wellness screenings are an essential element of an effective return-to-work strategy, along with contact tracing, and maintaining appropriate physical distances at work.

In addition to simplifying wellness assessments, iOFFICE’s visitor management solutions can also support streamlined contact tracing that allows you to respond quickly to notification of exposure while maintaining confidentiality throughout the process.

To learn more, request a free demo today.



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