Ever since the federal government issued its three-phased guidance for returning to work in March 2020, employers have been bombarded with questions like: who to recall first; what to do about PPE; how to treat vulnerable employees; how to address current/future requests for accommodation; and what COVID-19-related leave/benefits (if any) do returning employees have left.

Last week, the Equal Employment Opportunity Commission and the Department of Labor both updated their respective employer guidance to more specifically address two issues that will be continually challenging as an organization ramps up staffing: What can employer prepare for in terms of making reasonable accommodations? What continued FFCRA leave (if any) are employees entitled to once they return to work?