Creating a New Sound Pandemic Response Plan

There is a lot of information circulating about emergency preparedness in the last few weeks; and it may be overwhelming. ACA International member Chris Meier provides a key tip: communicate, communicate, communicate.

3/15/2020 8:00 AM

News
Creating a New Sound Pandemic Response Plan

By Chris Meier

General Counsel & Chief Compliance Officer

The CMI Group

It is hard to imagine that it was only two months ago that the word “corona” still made you think of sunshine and limes. Now it brings to mind visions of hospital tents, heat maps, and pandemic response plans.  Or at least it should. 

With the World Health Organization officially labeling the spread of COVID-19 (or coronavirus) a pandemic, the virus is something all businesses have to contend with.  And if your agency is anything like mine, (a) it was immediately met with client requests for your Pandemic Response Plans (PRP) and (b) you immediately realized that it did not have one, or it simply was not sufficient. 

The good news (if there is any here) is that a PRP is relatively easy document to put together.  It is merely an addition to your existing Business Continuity Plan, and there are plethora of sources available to help you flesh it out. 

Communication

As is true of most business plans, communication is the backbone and key to a successful PRP.  Not only are your clients going to be concerned about how your business will carry on, your employees will want to know how you plan to keep them safe (and, likely, receiving a paycheck).  Additionally, you have vendors and other business partners whose livelihood may be tied to your business continuity and they will want to know how you plan to weather this impending storm. 

The first steps in developing your communication strategy are going to be (a) determining who will be impacted by the implementation of your PRP (i.e., client, employees, business partners) and (b) who will be responsible for contacting them.  When deciding who will handle communications, it is important to make sure you know how they can be reached in the event of displacement, and who their backup will be in the event they are unable to fulfill their responsibilities under the Plan.

The next step is to determine how you are going to reach out to each category of interested parties.  Clients may warrant a personal phone call from a client services representative or sales person, but that may not be practical for your staff.  Fortunately the majority reading this article specialize in contact solutions so you likely already have technology you can deploy.  Just remember to get your employees’ consent before you start sending mass texts or prerecorded messages. 

Finally—and most importantly—you need to decide on the content of each notification.  Client concerns are not all the same, nor are employees’.  For example, whereas some clients might want to know how you are going to keep their receivables managed, others will want to know what you are doing to avoid harassing heavily affected areas.  Likewise, some employees will be focused on how you can keep your offices safe while others are mostly concerned with keeping their paychecks coming in the event of an office closure or quarantine.  The ideal messages is the one that provides the most relevant insight without creating unnecessary panic. 

Planning and Execution

Although the media has at times made COVID-19 seem like a zombie apocalypse, it is extremely unlikely that your entire staff will turn into the walking dead.  Instead, the more likely disruption of business will be due to voluntary/self-imposed quarantines or school closings.

If your office is anything like the average agency, you have a large number of employees who depend on public and private schools for childcare. In the face of this pandemic, schools face different considerations than businesses do, however, and may be closed even while many businesses need to remain open. For that reason, you need to plan (a) how you will handle a large number of employees needing to stay home and (b) what the clearance process will look like once those employees (who have possible been exposed to others who have been exposed) want to return to work.

The same decisions will need to be made for employees who ask (or are asked) to stay home due to flu or COVID-19 like symptoms (e.g., fever, cough, and shortness of breath).  The CDC recommends a 14-day quarantine before they are allowed to return to work, but you may also require a doctor’s clearance.  The important thing is not to penalize those who stay home.  Although there is sure to be concern over employee abuse of a lax attendance policy, it is better that than losing your staff to a two week bug.

Whether you are without a handful of employees or a large chunk due to a school closing—or, worse yet, you have a mandatory facility closure on your hands—you need to plan for and be prepared to action your business continuity plan.  For some larger agencies, this may mean rolling accounts over to another, unaffected work site, but for most it will mean deploying some variation of a work-at-home strategy.  This is going to required careful planning from your IT and Operations departments, though.  They will need to take a survey of who has personal equipment at home and assess how much productivity may be lost so you can prepare your clients.  Additional training may be warranted to create redundancies in skillsets wherever possible, and your compliance team needs to make sure it is fully prepared for life on the road.  This includes making sure “work at home” policies are current, office-specific contractual requirements are waived, state licensing restrictions are accounted for, and there is a plan for continuing the daily risk audits.  After all, regulation and enforcement do not quit merely because your office fell victim to the pandemic. 

Finally, it would behoove you to make sure your vendors have a pandemic plan just like your clients expected of you.  Some functions—e.g., scoring and skiptracing—may be largely automated and will continue without disruption, but others may require more human intervention.  For example, your letter vendor still needs someone to load the paper and replenish the ink wells.  What happens if their office gets quarantined? 

Conclusion

With a pandemic like COVID-19 it is easy to let fear get in the way of our operations.  But by getting out in front of things and creating a sound pandemic response plan, you put yourself in a position to alleviate your clients’ and employees’ concerns and maximize the potential for business as usual.   Just remember this obstacle is not unique to your office and there are resources available.  And remember—eventually, this too shall pass.

The following article was contributed by a member of ACA International’s Member Attorney Program (MAP) committee. ACA Daily will publish future legal analyses and thought pieces written by members of this important committee.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

Creating a New Sound Pandemic Response Plan

By Chris Meier

General Counsel & Chief Compliance Officer

The CMI Group

It is hard to imagine that it was only two months ago that the word “corona” still made you think of sunshine and limes. Now it brings to mind visions of hospital tents, heat maps, and pandemic response plans.  Or at least it should. 

With the World Health Organization officially labeling the spread of COVID-19 (or coronavirus) a pandemic, the virus is something all businesses have to contend with.  And if your agency is anything like mine, (a) it was immediately met with client requests for your Pandemic Response Plans (PRP) and (b) you immediately realized that it did not have one, or it simply was not sufficient. 

The good news (if there is any here) is that a PRP is relatively easy document to put together.  It is merely an addition to your existing Business Continuity Plan, and there are plethora of sources available to help you flesh it out. 

Communication

As is true of most business plans, communication is the backbone and key to a successful PRP.  Not only are your clients going to be concerned about how your business will carry on, your employees will want to know how you plan to keep them safe (and, likely, receiving a paycheck).  Additionally, you have vendors and other business partners whose livelihood may be tied to your business continuity and they will want to know how you plan to weather this impending storm. 

The first steps in developing your communication strategy are going to be (a) determining who will be impacted by the implementation of your PRP (i.e., client, employees, business partners) and (b) who will be responsible for contacting them.  When deciding who will handle communications, it is important to make sure you know how they can be reached in the event of displacement, and who their backup will be in the event they are unable to fulfill their responsibilities under the Plan.

The next step is to determine how you are going to reach out to each category of interested parties.  Clients may warrant a personal phone call from a client services representative or sales person, but that may not be practical for your staff.  Fortunately the majority reading this article specialize in contact solutions so you likely already have technology you can deploy.  Just remember to get your employees’ consent before you start sending mass texts or prerecorded messages. 

Finally—and most importantly—you need to decide on the content of each notification.  Client concerns are not all the same, nor are employees’.  For example, whereas some clients might want to know how you are going to keep their receivables managed, others will want to know what you are doing to avoid harassing heavily affected areas.  Likewise, some employees will be focused on how you can keep your offices safe while others are mostly concerned with keeping their paychecks coming in the event of an office closure or quarantine.  The ideal messages is the one that provides the most relevant insight without creating unnecessary panic. 

Planning and Execution

Although the media has at times made COVID-19 seem like a zombie apocalypse, it is extremely unlikely that your entire staff will turn into the walking dead.  Instead, the more likely disruption of business will be due to voluntary/self-imposed quarantines or school closings.

If your office is anything like the average agency, you have a large number of employees who depend on public and private schools for childcare. In the face of this pandemic, schools face different considerations than businesses do, however, and may be closed even while many businesses need to remain open. For that reason, you need to plan (a) how you will handle a large number of employees needing to stay home and (b) what the clearance process will look like once those employees (who have possible been exposed to others who have been exposed) want to return to work.

The same decisions will need to be made for employees who ask (or are asked) to stay home due to flu or COVID-19 like symptoms (e.g., fever, cough, and shortness of breath).  The CDC recommends a 14-day quarantine before they are allowed to return to work, but you may also require a doctor’s clearance.  The important thing is not to penalize those who stay home.  Although there is sure to be concern over employee abuse of a lax attendance policy, it is better that than losing your staff to a two week bug.

Whether you are without a handful of employees or a large chunk due to a school closing—or, worse yet, you have a mandatory facility closure on your hands—you need to plan for and be prepared to action your business continuity plan.  For some larger agencies, this may mean rolling accounts over to another, unaffected work site, but for most it will mean deploying some variation of a work-at-home strategy.  This is going to required careful planning from your IT and Operations departments, though.  They will need to take a survey of who has personal equipment at home and assess how much productivity may be lost so you can prepare your clients.  Additional training may be warranted to create redundancies in skillsets wherever possible, and your compliance team needs to make sure it is fully prepared for life on the road.  This includes making sure “work at home” policies are current, office-specific contractual requirements are waived, state licensing restrictions are accounted for, and there is a plan for continuing the daily risk audits.  After all, regulation and enforcement do not quit merely because your office fell victim to the pandemic. 

Finally, it would behoove you to make sure your vendors have a pandemic plan just like your clients expected of you.  Some functions—e.g., scoring and skiptracing—may be largely automated and will continue without disruption, but others may require more human intervention.  For example, your letter vendor still needs someone to load the paper and replenish the ink wells.  What happens if their office gets quarantined? 

Conclusion

With a pandemic like COVID-19 it is easy to let fear get in the way of our operations.  But by getting out in front of things and creating a sound pandemic response plan, you put yourself in a position to alleviate your clients’ and employees’ concerns and maximize the potential for business as usual.   Just remember this obstacle is not unique to your office and there are resources available.  And remember—eventually, this too shall pass.

The following article was contributed by a member of ACA International’s Member Attorney Program (MAP) committee. ACA Daily will publish future legal analyses and thought pieces written by members of this important committee.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

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