Section 1: Reopening Indiana
A. About Reopening Indiana
On May 1, Governor Holcomb unveiled the state’s five stage plan to reopening as Indiana’s stay-at-home order expired. While much of the state will begin phase two, Marion and Lake counties will be extending stay-at-home orders until May 15 and Cass County until May 18. It is important to note that these stages could be delayed if a spike in COVID-19 infections occurs. Below, IAA has broken down the most relevant details to our industry based on each stage’s date.
B. Stage 2: Beginning May 4
C. Stage 3: Beginning May 24
D. Stage 4: Beginning June 13-14
E. Stage 5: Beginning July 4
F. Pool Guidance
G. Gyms & Fitness Centers
Section 2: Returning to Work
A. OSHA Guidance: Returning to Work
See below for guidance and considerations when returning to work.
B.CDC Guidance for Reopening
Guidance for Congregate Housing
Cleaning & Disinfecting Guidance
Public Health Recommendations
C. Returning to Work Considerations
NEW! D. Indiana Safety Plan Sample
NEW! E. Sample Infectious Disease Plan
F. PPE Marketplace
G. Teleworking Resources
H. Best Practices: Transitioning Employees Back into the Workplace
Section 3: Federal Updates
A. CARES Act Analysis
B. Federal Laws Prompted By COVID-19
C. Guidance on Essential Workers During COVID-19
On March 28, the Cybersecurity and Infrastructure Security Agency (CISA), a division of the U.S. Department of Homeland Security, issued an “Advisory Memorandum on Identification of Essential Critical Infrastructure Workers During COVID-19 Response.” The memorandum contains an updated “Essential Critical Infrastructure Workforce” advisory list that identifies workers who perform operations and services essential to protecting state and local communities and ensuring continuity in critical functions. On page 15, the guidance calls out “Residential/Shelter Facilities and Services,” specifically identifying as essential:
On March 22, the National Apartment Association (NAA) and the National Multifamily Housing Council urged CISA to update their guidance to specifically identify the critical roles played by residential property management staff and residential construction teams.
The updated CISA memorandum notes that the list is purely advisory and not a federal directive or standard. It also emphasizes that the list is not exclusive and that individual jurisdictions should add or subtract essential workforce categories based on their own requirements. To that end, NAA continues to urge its affiliates to reach out to their state and local governments to ensure that the apartment industry is declared essential during any shelter-in-place declarations. To date, many affiliates have been successful in this advocacy and our hope is that this updated guidance from CISA will aid in those efforts.
D. FHFA Offers Mortgage Relief for Multifamily Property Owners
On March 23, The Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac, the Enterprises will offer mortgage forbearance for multifamily property owners, under the condition that they suspend all evictions for renters who are unable to pay rent because of COVID-19, also known as “coronavirus.”
To be eligible, property owners must suspend evictions for as long as the owner remains in forbearance. Forbearance is available only for multifamily housing properties with an “Enterprise-backed performing multifamily mortgage” that is financially impacted by coronavirus.
We will continue to update you as FHFA, Fannie Mae and Freddie Mac release information about implementation of this decision. For owners who believe they qualify, contact your loan servicer to learn more about the process to seek relief.
E. Business Interruption Insurance
F. HUD Notice on Foreclosures and Evictions
On March 18, the White House announced a moratorium on foreclosures and evictions. This announcement only applies to single family mortgages. Click here to view the HUD Notice.
G. HUD Responses on Disruptions Due to COVID-19 Pandemic
The following clarifications and confirmations were made: