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
  • All gyms and fitness centers and community centers remain closed
  • Recommended that Hoosiers wear face covering in public settings
  • People also should continue to practice social distancing and good hygiene
  • Office Settings:

  • Remote office work strongly encouraged
  • Screen employees working in offices daily
  • Make provisions for social distancing
  • Face coverings recommended if sufficient barriers do not exist
  • Commercial Business:

  • Open at 50% Capacity
  • Screen Employees Daily
  • Highly recommend employees and customers wear face coverings
  • Social distancing for employees and customers
  • C. Stage 3: Beginning May 24
  • All gyms and fitness centers can open with restrictions – equipment must be cleaned after each use, and employees are required to wear face coverings
  • Pools may open according to CDC guidance
  • Continue to practice social distancing
  • Social gatherings of up to 100 people are permitted
  • Office Settings:

  • Remote office work encouraged whenever possible/li>
  • Bring employees back to work in stages
  • Screen employees working in offices daily
  • Make provisions for social distancing
  • Face coverings recommended if sufficient barriers do not exist
  • Commercial Business:

  • Open at 75% Capacity and remain socially distanced
  • Screen Employees Daily
  • Highly recommend employees and customers wear face coverings
  • provisions for employees to maintain social distancing
  • D. Stage 4: Beginning June 13-14
  • Continue to practice social distancing
  • Social gatherings of up to 250 people are permitted
  • Office Settings:

  • Face coverings optional
  • Employees may resume work at full capacity
  • Screen employees daily
  • Make provisions for social distancing
  • Commercial Business:

  • Open at full capacity
  • Screen Employees Daily
  • Recommend employees and customers wear face coverings
  • E. Stage 5: Beginning July 4
  • Open for normal operations
  • Remote work optional
  • Face coverings optional
  • Social gatherings of more than 250 people may take place
  • F. Pool Guidance

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    G. Gyms & Fitness Centers

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    Section 2: Returning to Work

    A. OSHA Guidance: Returning to Work

    See below for guidance and considerations when returning to work.

  • OSHA: Enforcement Guidance for Returning to Work
  • OSHA: Discretion in Enforcement for Returning to Work
  • NEW! Ten Steps All Workplaces Can Take to Reduce Risk of Exposure to Coronavirus / Click here for Spanish
  • OSHA: Control and Prevention Measures
  • B.CDC Guidance for Reopening

    Guidance for Congregate Housing

  • COVID-19 Guidance for Shared or Congregate Housing
  • Resources for Shared or Congregate Housing Facilities
  • Living in Shared Housing
  • Reopening Guidance

  • Reopen Guidance Click here for CDC resources.
  • Guidance for Small Businesses Click here for CDC resources.
  • General Business Frequently Asked Questions Click here for the FAQ
  • Cleaning & Disinfecting Guidance

  • Creating a plan for Cleaning and Disinfecting Decision in the Workplace
  • Critical Workers: Implementing Safety Practices
  • Reopening Guidance for Cleaning and Disinfecting Public Spaces, Workplaces, Businesses, Schools, and Homes
  • Guidance for Cleaning and Disinfecting Decision Tool
  • Public Health Recommendations

  • Guidance for Community-Related Exposures
  • C. Returning to Work Considerations

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    NEW! D. Indiana Safety Plan Sample

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    NEW! E. Sample Infectious Disease Plan

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    F. PPE Marketplace

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    G. Teleworking Resources

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    H. Best Practices: Transitioning Employees Back into the Workplace

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    Section 3: Federal Updates

    A. CARES Act Analysis

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    B. Federal Laws Prompted By COVID-19

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    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:

  • Workers responsible for the leasing of residential properties to provide individuals and families with ready access to available housing.
  • Workers responsible for handling property management, maintenance, and related service calls who can coordinate the response to emergency “at-home” situations requiring immediate attention, as well as facilitate the reception of deliveries, mail, and other necessary services.
  • Workers performing housing construction related activities to ensure additional units can be made available to combat the nation’s existing housing supply shortage.
  • Workers supporting the construction of housing, including those supporting government functions related to the building and development process, such as inspections, permitting and plan review services that can be modified to protect the public health, but fundamentally should continue and serve the construction of housing (e.g., allow qualified private third-party inspections in case of government shutdown).
  • 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

    Click here to login and view the guidance.

    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

    HUD released a formal statement on March 13, 2020, clarifying an official response statement regarding COVID-19. An updated Q&A document was also updated and posted to HUD’s website.

    The following clarifications and confirmations were made:

  • REAC inspections have been postponed until further notice,
    [except] where there is an exigent circumstance or reason to believe that there is a threat to life or property at a specific location, inspections will be conducted by HUD quality assurance inspectors in compliance with CDC guidelines.
  • For households who have a member who needs to be quarantined, and the remaining members need to be separated/relocated, resident requests to occupy vacant units or temporarily relocate should be verified before being granted. Verification could include written communication from a medical health professional or through communication with the local health department. Managers may use electronic and telephonic communication to perform verification.
  • If there are any questions that owners and agents may have during this period, HUD has created an e-mail address where such questions can be sent. For PIH program questions that are not answered by the FAQs, please e-mail For Multifamily Housing program questions that are not answered by the FAQs, please email
  • Section 4: State Updates

    A. Indiana Public Health Emergency Update

    On May 1, Governor Holcomb extended the public health emergency 30 more days or until June 4, 2020. Meaning, the statewide eviction moratorium continues until at least June 4, 2020. IAA has sent countless messages to the governor’s office pleading for an exception to that moratorium for emergency possessory orders. Clearly, the governor does not wish to make that exception.

    On March 19, Governor Holcomb announced new measures to protect and support Hoosiers during the COVID-19 outbreak by signing executive orders that extend the closure of schools, provide economic relief and protections for individuals and businesses, and expand unemployment insurance benefits for those impacted by job loss.

    The Governor also extended the state’s public health emergency 30 days from the April 5 expiration to May 5.Click here to view his list of new measures. The following items were important to our industry:

  • This announcement includes that no residential eviction proceedings or foreclosure actions may be initiated during the public health emergency.
  • The state of Indiana will align with the federal government to delay state income tax payments from April 15 to July 15. The U.S. Treasury extended the deadline to pay federal income tax by 90 days.
  • Penalties will be waived for 60 days for property tax paid after May 11.
  • B. IHCDA Memos on Inspection and Monitoring Policies

    In response to concerns related to COVID-19,IHCDA is implementing the following policies:

  • RED 20-20: Suspension of Rehab Work under CDBG OOR, Ramp Up, LCAP and LHRD Programs
  • RED 20-19: Compliance Guidance for IHCDA Funded Rental Properties re: COVID-19
  • RED 20-18: Inspection and Monitoring Policy re: COVID-19
  • Executive Order 20-06: Evictions & Foreclosures
  • Executive Order 20-08: Stay At Home Order
  • IHCDA continues to monitor the situation with COVID-19 in Indiana as circumstances change and additional information becomes available. To provide transparency and customer service, IHCDA will update these RED Notices with any updates to policies or procedures

    C. Critical Industries Hotline

    Governor Holcomb announced that he will open a call center to field industry questions about Executive Order 20-08, which provides for essential and non-essential business operations, infrastructure and government functions while the state observes a stay-at-home order from March 25-May 1. This center, reachable by calling 877-820-0890 or by emailing, is for business and industry questions only.

    Section 5: COVID-19 Resource Links

    A. Indiana State Department of Health

    Please consult the ISDH for updated news and guidance on the COVID-19 virus as it related to Indiana. Click here to be directed to the ISDH website.

    B. Centers for Disease Control & Prevention

    The CDC has various guidelines and resources for your use.

  • COVID-19 Guidance for Shared or Congregate Housing
  • Resources for Shared or Congregate Housing Facilities
  • Printable COVID-19 Posters & Handouts (Available in Different Languages)
  • Interim Guidance for Businesses and Employers
  • Environmental Cleaning and Disinfection Recommendations
  • Resources for Businesses & Employers
  • Cleaning & Disinfection for Households Recommendations
  • Use of Cloth Face Coverings to Help Slow the Spread of COVID-19
  • C. Occupational Safety & Health Administration

    OSHA has issued guidelines and standards in regard to COVID-19

  • Infectious Diseases Guideline
  • COVID-19 Standards
  • Guidance on Preparing Workplaces for COVID-19 / Click here for Spanish
  • D. National Multifamily Housing Council

    As the home to millions of Americans, apartment communities across the country must take the responsibility of emergency preparedness seriously. Click here to be directed to the NMHC’s resource guide for emergency preparedness.

    E. U.S Department of Labor

    The Wage and Hour Division provides information on common issues employers and employees face when responding to COVID-19, and its effects on wages and hours worked under the Fair Labor Standards Act (FLSA), job-protected leave under the Family and Medical Leave Act (FMLA), and paid sick leave and expanded family and medical leave under the Families First Coronavirus Response Act (FFCRA). Click here for Fact Sheets, FAQ’s and more.

    G. Fannie Mae Loan Look Up + Forbearance Eligibility

    Fannie Mae’s Loan Lookup tool helps you quickly determine if Fannie Mae owns your loan, which may be helpful to know your options by checking here first. Click here to visit the website. In addition, click here to view a letter issued by Merchants Capital stating forbearance eligibility and requirements for Fannie Mae borrowers.

    H. Freddie Mac Loan Look Up

    To understand the options available for getting help with your mortgage it’s important for you to know who owns your loan. Click here to use the secured look-up tool so you can quickly find out if Freddie Mac owns your loan.

    I. State-By-State Reopening Guide

    The US Chamber of Commerce recently launched an interactive guide to help track states reopening guidelines for businesses. Click here to view the interactive guide.

    Section 6: Communication Templates

    A. Model Policy – COVID-19 Exceptions

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    B. Coronavirus Renter Resources FAQ

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    C. Click & Lease COVID-19 Forms

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    D. Sample Lease Addendum for Payment of Rent

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    E. Sample Late Rent Notice

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    F. Subsequent Lease – Delinquent Payment Plan Addendum

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    G. Resident FAQ for On-site Staff

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    Other Archived Templates

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    *The IAA website does not contain medical advice. Please consult your physician for personalized or general medical advice. Always seek the advice of a physician or other qualified healthcare provider with any questions regarding a medical condition.

    ** The information provided on this website does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available on this site are for general informational purposes only. Information on this website may not constitute the most up-to-date legal or other information. This website contains links to other third-party websites. Such links are only for the convenience of the reader, user or browser; the IAA and its members do not recommend or endorse the contents of the third-party sites. Readers of this website should contact their attorney to obtain advice with respect to any legal matter.