After months of federal agency closures, and a wide expansion of teleworking and other remote work policies crafted in response to the novel coronavirus, the federal government is planning for a phased re-opening.[1] This post was most recently updated on June 26, 2020, and it includes updates to the following agency plans: Department of Defense, IRS/Treasury, U.S. Census Bureau, NASA, Department of Energy, State Department, Department of Homeland Security, Office of Personnel Management, Department of Transportation, Department of Agriculture and the EPA. In June, a number of agencies entered Phase One of their reopening plans. We will continue to update as agencies continue to release and modify their reopening guidance.

On April 20, 2020, the Executive Office of the President, Office of Management and Budget (OMB) published Memorandum M-20-23 on “Aligning Federal Agency Operations with the National Guidelines for Opening Up America Again.”

In this Memorandum, OMB provides a framework to be used by federal agencies to develop policies and procedures for re-opening and a return to the federal workplace. Each federal agency must develop its own policies and procedures consistent with the Guidelines for Employers included in the Memorandum, as well as accounting for the agency’s own operational needs and the geographic area in which each agency operates. Like most states that have issued re-opening guidelines, the Memorandum contemplates a gating period in which the agency must see a downward trend in COVID-19 cases before proceeding to a phased re-opening. Agency policies and procedures for a phased re-opening must take into account the following criteria:

(a) Geography. Includes state and regional phasing status and guidance. It also may include, school and day-care closures, mass transit availability, parking availability, facility requirements, and the agency’s mission needs.

(b) Telework. Agencies are given flexibility to develop their own telework policies, and are encouraged to maximize telework flexibilities for high-risk populations, and special populations identified by the Centers for Disease Control and Prevention (CDC). It may also include new working arrangements, such as alternating schedules for in-office and telework.

(c) Personnel. Agencies must develop procedures to follow if an employee or contractor is symptomatic or tests positive for COVID-19. Re-opening policies should consider the needs of vulnerable populations. Policies should also address the employee’s ability to wear face coverings, and whether agencies will provide masks.

(d) Facilities, Service & Operations. Re-opening policies should prioritize public-facing properties and facilities. Facilities that handle classified information should also be prioritized. Policies for facilities must set forth the screening procedure that will be implemented, such as questions to be asked, temperature checks, or other visual inspections. Such policies must also ensure that the agency has adequate hygiene supplies, is following CDC guidelines for cleaning buildings, and implements social distancing procedures to the extent practicable.

(e) Travel Guidelines. Agency policies may reconsider travel limitations currently in place, and adapt them as necessary based on mission needs.

These are merely guidelines; therefore, federal contractors will need to familiarize themselves and their employees with the policies and procedures for each of the federal agencies with whom they do business. Agencies are continuing to develop policies and procedures in accordance with the Memorandum. In an effort to make this information more easily accessible for our clients, we are tracking these agency policies and procedures as they are released. We will update this tracker regularly to ensure that the latest policies and procedures are available.

Re-Opening Guidance Summary (by Agency)

Department of the Interior

  • Offices are encouraged to begin to move toward normal operations as conditions warranted and consistent with plans by using telework options.
  • Supervisors are permitted to encourage telework for high risk populations, regardless of location. When office/duty locations return to normal (Phase 3) vulnerable populations should continue physical distancing.
  • Teleworking employees with childcare or dependent care responsibilities affected by COVID-19 have access to up to 20 hours per pay period of excused absence administrative leave.

Department of Veterans Affairs

  • Contemplates a three-phase approach after localities meet the gating criteria. Dates for each phase are not yet set.
  • Phase 1 will allow the following agencies to resume certain essential and emergency services: Veterans Health Administration, Veterans Benefits Administration, National Cemetery Administration, Board of Veterans’ Appeals VA Staff offices. Telework will continue where possible.
  • Phase 2 will expand to allow non-emergent procedures and services. Reopen additional facilities including Fisher Houses, Hoptel Program, and VBA regional offices. Telework will continue where appropriate. Up to 50% of Veteran’s Benefit Administration and Board of Veteran’s Appeals will return on a rotational basis, using staggered shift/steams and expanded core hours.
  • Phase 3 will allow visitor access to all Veteran’s Healthcare Administration facilities. Additional non-emergent procedures and services will be expanded as resources permit. Resume in-person Board of Veteran’s Appeals hearings but also allow virtual hearings.
  • VA will, but has not yet, identified polices for screening, testing, and tracing at VA facilities.
  • VA has enhanced cleaning services and closed common areas. It will disseminate additional policies regarding availability of hygiene supplies and face masks. If required, VA will make those face masks available for employees and contractors on site.

VA Press Release:

VA Framework: CHARTING THE COURSE: Maintaining Continuous Services to Veterans and Resuming Normal, Pre-COVID-19 Operations, dated May 7, 2020:

Department of Energy

  • In June, DOE entered Phase 1 of reopening.
  • Phase 0 included preparation activities for reopening, such as facility-specific plans for returning in phases. This phase included sanitizing facilities, adding enhanced screening criteria to determine whether individuals may enter each facility. It included establishing social distancing protocols, as well as procuring and installing additional hygiene stations. Employees and contractors received communication providing the criteria and protocol for the process, which was posted outside each facility.
  • Phase 1: Personnel must be approved by the Head of the Departmental Element to return to the workplace, and will include employees in mission-critical positions whose jobs can be better performed onsite than through telework. It will not include self-identified vulnerable populations, or employees who have caregiving responsibilities due to facility closures. Employees may, but are not required to wear masks. Cafeterias, gyms, and childcare will remained closed.
  • Phase 2: Personnel must be approved by the Head of the Departmental Element to return to the workplace, and will include employees whose jobs are best performed on site; namely senior leadership, staff supporting PMEFs and MEFs, or other high-priority senior-level program staff. It will not include self-identified vulnerable populations, or employees who have caregiving responsibilities due to facility closures.
  • Phase 3: All personnel will resume their pre-COVID-19 work schedules and telework agreements as deemed appropriate by their supervisor. Requests for special accommodations will be reviewed on a case-by-case basis.
  • Guidance for face coverings will be detailed in individual site plans.

State Department

  • In June, numerous passport agencies throughout the United States entered Phase 1.
  • Phase 1 contemplates alternating teams with up to 40% of the workforce at one time. Mandatory telework will be lifted, but strongly encouraged. Social distancing will be enforced and groups of larger than 10 will be prohibited. Cloth face coverings should be worn, but are not mandated. Employees will be encouraged to take their temperature daily. This can occur at home when state and local stay-at-home orders are lifted or modified and essential businesses are open. Other indicators are that transportation is available, the facility meets CDC disinfection guidelines, offices allow for social distancing, and there is an availability of food, medicine, and sanitation supplies.
  • Phase 2 contemplates an option for alternating teams with up to 80% of the workforce at one time. Bureaus are encouraged to continue telework where possible. Distancing will continue, with an option to wear face masks, and daily temperature monitoring. This can occur when non-essential business can open, and when schools, day care and elder care are available.
  • Phase 3 contemplates a return to work greater than 80% of workforce. Cautious resumption of normal flow and seating, and socializing may resume in larger groups. Cautious resumption of normal travel patterns may happen when public places opened, large events permitted, and restrictions on domestic travel lifted.
  • Additional conditions apply to overseas facilities.

Internal Revenue Service/Department of the Treasury

  • The IRS has now called back employees in a number of states, and will fully reopen the remaining states by July 13.
  • Personnel required to wear own face covering in all public places, including walkways, elevators, staircases, bathrooms, cafeteria, entering and leaving facility.
  • Personnel are instructed to self-screen for symptoms.
  • For the majority of employees than can perform duties at home, the IRS is maximizing telework.

The Department of Treasury’s Acting Senior Procurement Executive issued guidance to Contractors on May 20, 2020:

Department of Defense

  • In June, the DoD moved the Pentagon Reservation into Phase 1.
  • Pentagon Reservation Plan for Resilience and Aligning with National Guidelines for Opening Up America Again
    • Phase 0: Stay at home orders in place, schools, daycare and camp closed.
    • Phase 1 (Restricted): Stay at home orders lifted and schools and daycare reopened.
    • Phase 2 (Moderate): Stay at home orders lifted and schools and daycare reopened.
    • Phase 3 (Normal): No stay at home orders.
    • Phase 4 (Resilience): TBD.
    • Movement between phases to align with gating criteria in national guidelines.
    • Individuals are instructed as follows throughout the phased reopening:
      • Take temperature before coming to the office, and stay home if greater than 100 degrees Fahrenheit
      • Stay home and self-quarantine if you have been exposed, or live with someone that has been exposed
      • Maintain social distancing, and practice good hand hygiene
      • Mandatory face coverings on the Pentagon Reservations until Phase 3, if you cannot maintain social distancing. Optional face coverings through all phases.
      • Maximum telework for high risk and vulnerable population during the gating period, Phase 1 and Phase 2.

  • In June, DoD lifted travel restrictions in 46 U.S. locations and 8 host nations.
  • The lifting was based on DoD’s previously announced Transition to Conditions-based Phase Approach to Coronavirus Disease 2019 Personnel Movement and Travel Restrictions
    • No travel unless following conditions are met.
    • Unrestricted travel will be permitted to geographic regions that (a) remove shelter-in-place orders, (b) 14-day downward trajectory of flu-like and COVID-19 like symptoms, and (c) 14- day downward trajectory of new COVID-19 cases or positive tests.
    • DoD installations, facilities, and locations will be continually assessed for whether it is restricted for travel, including removal of local travel restrictions, availability of essential services such as schools and childcare and moving services, quality control/assurance capability for household goods packing and moving, and favorable heath protection conditions. Once a facility or location meets these criteria, it may permit movement to or from these areas.

  • Guidance for Deployment and Redeployment of Individuals (including contractors) (Supplement 9)
    • Contractor personnel are recommended to follow DoD force health protection deployment and re-deployment guidance as service members and DoD civilian employees.
    • If DoD contract personnel do not complete the same pre-deployment screening and restriction of movement (ROM as Service Members and DoD civilian employees, they will not be allowed to travel with military and civilian risk mitigated forces.
    • DoD component heads will require that individuals are appropriately screened at the assigned place of duty or point of embarkation, which will consist of – at a minimum – temperate check, check for COVID-10 signs and symptoms, and review of past COVID-19 testing results. Symptomatic individuals should be isolated per guidance.
    • Individuals (including contractors) deploying outside the US will undergo a 14-day ROM prior to deployment. If re-deploying, a screening will occur to determine if a 14-day ROM is indicated.

U.S. Department of Agriculture

  • In June, USDA entered Phase 1 in 12 facilities in the National Capital Region.
  • Phase 1: USDA facilities are allowed to reopen, but telework should be widely practiced. Returning employees include NCR political appointees, employees with customer-facing roles, and employees that cannot perform their normal duties while teleworking. Facilities should consider the number and on-site positioning of employees and contractors, including availability of hygiene and PPE products. Common areas will remain closed. Agency may stagger schedules. The agency will not perform temperature checks.
  • Phase 2: Agency will lift maximum telework policy. Additional employees and contractors may be on site if they have a practical and operational need. This includes administrators, COOs, senior program managers, and other individuals required to carry out critical programs. Common areas remain closed. Food service may reopen.
  • Phase 3: Facilities can reopen with up to 100% of employees and contractors returning. Telework may be permitted for certain employees and contractors that can perform mission needs from home. Common areas will reopen if social distancing can be ensured.
  • In order to move between phases, the facility must pass 14 consecutive days with no new COVID-19 cases onsite.
  • Facilities may also consider capacity of local public transportation, status of public schools, and day care where applicable before moving between phases.
  • Face masks are expected to be worn in all three phases, and the agency plans to provide masks to employees.

U.S. Department of Commerce, U.S. Census Bureau

  • U.S. Census Bureau sought statutory relief from Congress to obtain 120 additional calendar days to complete the 2020 Census;
  • Resumed dropping off census invitation packages and completing hiring operations in certain local areas, consistent with state and local reopening plans.
  • All staff will be provided with needed PPE –including face masks and hand sanitizer – and trained on safety protocols.
  • In June, the U.S. Census Bureau began to reopen several area offices in California, Maryland, New Jersey, New York, Texas, and Virginia.
  • Additionally, the U.S. Census Bureau has started to resume field activities throughout the states and in Puerto Rico.


  • NASA facilities are currently in Stage 4 or Stage 3, depending on the region.
  • Stage 4: Mandatory telework, facilities are closed except to mission-essential personnel. All on-site facilities are closed.  Virtual meetings only. All travel is suspended.
  • Stage 3: Mandatory telework. On-site work is limited to mission-essential personnel land approved mission-critical work. On-site food service is open for take-out only. Daycare and fitness on site remains closed. Virtual meetings only. Clinics are open to support on-site personnel. Mission-critical travel only.
  • Stage 2: Employees who can accomplish work remotely are encouraged to telework.  Mission-critical visitors only with approval. On-site daycare opened. On-site fitness closed. Clinics to defer physicals. Practice social distancing and hand hygiene.  Virtual meetings only. Mission-critical travel only.
  • Stage 4: Full access, be telework ready. All facilities open. Practice social distancing and hand hygiene. Virtual meetings when possible, reduce in-person meetings and large gatherings. Reduce non mission-critical travel
  • NASA will provide PPE to individuals who cannot work 6-feet spaced apart.
  • After mandatory telework ends, individuals may request continued teleworking from supervisors on an individual basis.
  • Employees are eligible for up to 20 hours per pay period of excused leave (XLV) for caregiving responsibilities due to school and/or care facility closures. Employees should continue to communicate with their supervisors if they need this type of leave.

Environmental Protection Agency

  • The EPA is currently in Phase 1. In late June, the EPA will reopen its D.C. headquarters. Employees, however, will retain flexibility to telework.
  • Rolling re-opening to begin with Region 4 (Atlanta, GA), Region 7 (Lenexa, KS), and Region 10 (Seattle, WA).
  • Facilities will close for seven (7) days to render the coronavirus inactive. Then facilities will enter into Phase 1.
  • Maximum telework flexibility through Phase 1. Vulnerable population should telework through Phase 2.

Department of Homeland Security

  • In June, the United States Citizenship and Immigration Services began to reopen field offices and asylum offices to permit in-person services.
  • Restrictions in place include:
    • No entrance if one exhibits COVID-19 symptoms, or has been in close contact with a person known or suspected to have COVID-19, or is under orders to quarantine.
    • Hand sanitizer is provided at entry points.
    • Facial coverings required for members of the public.
    • Health screening questions at entry points.
  • In June, Customs and Border Patrol resumed operations at training academies.

Federal News Network reported that a FEMA department spokesperson advised that FEMA has sent phased reopening guidance memorandum to all FEMA employees and noted that “Monday [June 8] is the earliest date in which FEMA employees may return to their facilities, the agency said, although most will continue to telework through at least July 15, the earliest possible date that “phase two” could begin.” See

Office of Personnel Management

  • In June, OPM released its own return to facilities plan that discussed a different plan for each of its facilities, depending on need.
  • Phase 1: Encourages telework, however may require individuals to return to work if necessary to perform essential duties. Common areas are closed. Non-essential travel is minimized, and requires adherence to CDC guidelines on isolation after travel. Food service can offer “to-go” options. Face coverings are recommended but not required. Social distancing is required, or alternatively employees are permitted to work in shifts. PPE will be provided for staff that engages with the public, security staff, staff that provides services to building occupants, and anyone else as needed.
  • Phase 2: Continue to encourage telework. Agency may require individuals to return to work if necessary to perform essential duties, or if work is better performed in OPM workspaces. Common areas to remain closed. Food service can offer “to-go” options. Face coverings are recommended but not required. Social distancing is required, or alternatively, employees are permitted to work in shifts. PPE will be provided for staff that engages with the public, security staff, staff that provides services to building occupants, and anyone else as needed.
  • Phase 3: Resume unrestricted staffing of worksites, except for employees that request special accommodations.

Department of Transportation

  • Current posture is maximum telework. To transition to Phase 1, the DOT requires a downward trend in COVID-19 illness and positive tests for 15 days in each geographic areas.
  • Contractors are expected to follow the same protocol as DOT employees.
  • Phase 1: Designated leadership and managers will be instructed to return on a gradual basis. Employees who can perform their duties effectively via telework, or who are not comfortable returning to normal duty stations, will be allowed to continue teleworking. Social distancing is expected. No external visitors are permitted without a specific business need. Access to common areas will be restricted, and meetings may not have more than 10 people. Face coverings are expected when employees are in close interaction with others in the workplace. Limited travel to mission critical and will require special approval. Vulnerable individuals may remain on max telework.
  • Phase 2: Additional categories of individuals may be instructed to return to normal duty stations. Some restrictions on common areas may be eased. No other changes from Phase 1.
  • Phase 3: DOT personnel will be expected to return to work, subject to flexible approval of leave and authorized telework. Vulnerable individuals may make liberal use of telework. Business travel will resume without special approval. External visitors will be permitted, but their entry will be monitored and screened.

Department of Education

[1] “Re-opening” in this article refers to the re-opening of federal facilities allowing a return to the federal workplace.