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Table of Contents


NMHC: Multifamily Preparedness Begins with an Incident Response Plan

Hurricanes, construction fires, cyber-attacks, catastrophic flooding, wildfires—just some of the many threats our industry faces on a daily basis. Given this unpredictable and volatile risk landscape, multifamily firms must be proactive in readying their communities to handle and navigate any and all crises that might come their way.

To manage risk effectively is to embed risk mitigation strategies across the enterprise and that begins with the C-Suite. Whether it’s a cyber breach, impending wildfire or even a rare infectious disease outbreak, clear minded and orchestrated decision making is key. To ensure effective incident management, firms should start by creating a "Crisis Team" comprised of senior executives charged with developing the plan and carrying it out. This type of plan should be flexible and actionable regardless of whether the apartment firm is facing a potential outbreak like COVID-19 or staring down a catastrophic hurricane. Team members should include personnel from the corporate suite, risk management, human resources, legal, information technology, and operations. And team members should have decision-making and spending authority.

Write a Plan

Having a written plan in place will help organize and streamline the incident response process. The incident response players must have clarity on roles, responsibilities and authority during an incident. Without clear instructions and authorizations in place, personnel will respond inconsistently, which can be especially damaging to an organization’s brand and can also create legal or regulatory risks. Similarly, without clearly identified procedures, organizations run the risk of departments duplicating efforts, wasting both time and resources. A written plan will help to provide structure, clarity and organization around the incident response process. The time to develop an incident response plan is not after your community is impacted directly.

Roles and Responsibilities

It is also imperative that the plan identify roles and responsibilities during the incident response process. The plan should clearly designate an Incident Commander, who is ultimately in charge of the response process and who has real-time decision-making authority. In particular, the plan should be clear about the scope of the Incident Commander’s authority and whether any approvals are needed before certain actions can take place, especially with respect to actions affecting company systems. Similarly, the plan should identify key incident response team members (including designated back-ups) and clearly define their roles and responsibilities for the incident response process.

Communications

Perhaps one of the most important aspects of the incident response process—and one which frequently causes problems for organizations—is the communications process. It is critical that the incident response plan establish clear communications protocols, including triggers for cross-functional coordination and escalation. Key personnel are unable to carry out their responsibilities if they are unaware of incidents that require their attention. A common communications error is neglecting to engage the appropriate parties early enough in the incident process, so clearly defined triggers for when certain departments and players need to be informed of and engaged in the response process must be established. In addition, clear protocols for when to escalate issues to senior management are also necessary. The plan should be clear as to who is responsible for re-porting to senior management and when such reporting should occur. The issue of late engagement frequently surfaces with respect to communications with the legal department. For example, if legal is not engaged early enough in the process, the risk for non-compliance with state or federal laws (e.g., breach notification requirements) increases, which can result in or detrimentally affect government investigations or litigation. Legal is also needed for ensuring attorney-client privilege protection, which can be important in related litigation or investigations.

The plan should also include clear procedures for external communications, including who is authorized to speak on behalf of the company and what approvals are required. Because public health incidents can both be complex and have legal implications, early involvement by the legal department is also important for reviewing and approving external communications, especially public statements to the media and press. Facts develop quickly, and many pieces of information are often unknown during the early stages of the incident response process. Apartment companies must develop a clear strategy for handling media inquiries at this early stage, such as cold calls from reporters. One way to manage this is by creating pre-developed templates or canned holding statements. Relatedly, companies will frequently experience an influx of questions from customers as well as employees outside of the incident response process during early stages of an incident. Therefore, this process should be memorialized in the incident response plan, including: who is responsible for drafting communications for this audience; how the information will be communicated; and any associated approvals required for doing so. Finally, the plan should establish clear protocols for communications with third parties, such as: (i) law enforcement and first responders; (ii) public health officials; (iii); affected individuals and; (iv) insurance or other business contacts. Requirements or expected communications with public officials and affected individuals is often dictated by state law and can vary substantially across jurisdictions. Thus, legal counsel needs to maintain control and oversight of determining what, if anything, should be communicated and when such communication should occur to these parties.

Test Yourself & Your Incident Response Plan

A company can have a seemingly perfect plan on paper, but it can be rendered meaningless if the policies are not effective and internalized by key players in the process. Companies who test their incident response policies have a significant advantage—from both a practical as well as a liability standpoint—over those who first execute these procedures in response to a real-life crisis. Testing the incident response plan in a controlled environment allows the organization to identify and remediate gaps or deficiencies and to use the experience to prevent making similar mistakes in the future.

Implementing a clear process for documenting “lessons learned” after any type of crisis-type event—as well as ensuring this process is adequately communicated across the organization and accessible for review and consultation during events—will help reduce the veracity of any allegations that the company failed to learn from its past mistakes. Lessons learned meetings should be held regularly after live incidents as well as incident response exercises to review the effectiveness of the incident handling process and to identify necessary improvements to existing security controls and practices. The information accumulated from lessons learned meetings should be used to identify and correct any noted weaknesses and deficiencies in policies and procedures. Follow-up reports generated for each resolved incident can be helpful not only for evidentiary purposes but also for reference in handling future incidents and in training new team members. Multifamily firms should communicate these procedures and make these materials available to appropriate parties across the organization.


NMHC: Coronavirus Preparedness for Apartment Firms

The Center for Disease Control (CDC) is currently monitoring a new outbreak of coronavirus, (COVID-19), which originated in Wuhan, China and is causing respiratory illness. 

As apartment owners and operators prepare to mitigate and educate residents on potential exposure, NMHC has compiled an overview of suggested apartment owner preparations in anticipation of the potential spread of COVID-19.

Of course, NMHC recognizes the broad array of company types, sizes and geographic locations that discourage one-size-fits-all approach to planning. This overview is not to be construed as legal guidance but merely a starting point for your company-specific plan. Therefore, we encourage you to seek expert consultation in the development of your plan to ensure comprehensive coverage. 

 

Getting Management “Buy-In”

Firms should start by creating a "Crisis Team" comprised of senior executives charged with developing the plan. Since the impacts of the spread of COVID-19 can vary significantly, team members should include personnel from the corporate suite, risk management, human resources, legal, information technology, and operations. And team members should have decision-making and spending authority.

 

Communication is Key

Accurate, timely and regular communications with employees, residents, suppliers and even the media are critical. Make sure you have all available contact information for your staff, residents and suppliers (cell, e-mail, fax), and develop alternative ways to disseminate information (corporate web sites, hotlines) in case telecommunications are disrupted.  Also be sure to appoint spokespersons

The most common communications will concern prevention practices, changes in office policies (telecommuting policy or sick time) and resident communications. Certain resident policies will need to be adjusted, such as transitioning to an emergency-only maintenance policy. 

 

Managing Infection Control

Clearly the most important and ongoing component of any plan. Everyone is now familiar with the “common sense” approach to infection control-practicing proper cough etiquette, washing your hands frequently and staying home if you are sick.  

Once beyond the early stage, enhanced measures may be required, such as sanitizing work areas, public places and commonly touched elements (door handles, elevator buttons, etc.) and placing hand sanitizers in common areas and fitness centers. 

 

Establishing Protocol for Employee Leave

A severe outbreak could cause absenteeism, due to infection, fear of infection and caring for family members. Develop a leave policy that includes telecommuting, staggered schedules and liberal leave. Establish protocol for employee/supervisor communication, cross-train your staff in case of long-term absences and test telecommuting plans to ensure they work.   

 

Crafting a Plan for Potential Lapse in Services and Supplies

With the loss of staff and on-site personnel, most companies will have to curtail their services. It may be necessary to implement online-only leasing and online rent payment or drop boxes. Service calls, trash collection, security, maintenance and move-in/move-out will require another look in a severe outbreak. Fitness centers, pools and community rooms may need to be closed. 

Anticipate high absenteeism at your suppliers and service providers that might create disruptions in trash removal, utilities, transportation and Internet access. Seek alternative service providers and outsource options for IT. Secure generators for power outages. Consider allowing employees to stay in model units.

 

Understanding Legal Liability

The spread of COVID-19 could raise a host of legal issues that must be analyzed in advance to reduce company liability. Consider liability sources such as resident illness, employee exposure to sick residents, evictions and employee leave scenarios. Also consider how much risk you want to assume. Do you direct residents to third-party sources for information on the virus rather than being the source of information; do you advise residents on how to secure protective supplies instead of distributing them yourself?

 

Dealing with the Aftermath

Disaster planning also means considering what happens after the event. The human and financial impact on a company and its property operations can be devastating if the recovery process is not included in your overall plan.  

In the days following a disaster, experts recommend companies evaluate their insurance coverage, revisit human resources policies regarding back-to-work issues, identify any need for Employee Assistance Programs or counseling, and evaluate re-opening common areas and services.  Pay special attention to the availability of government aid.  

Finally, evaluate the effectiveness of the plan and modify as needed and practice regularly.

It is unknown whether one or more “waves” of COVID-19 outbreak will emerge. However, to proceed without a plan is a risk your company should not take. Firms must remain vigilant and fine-tune their plans, practice them and adjust to unanticipated events.


NAA: Statement and Position on Coronavirus Disease

The Centers for Disease Control and Prevention (CDC) is closely monitoring the outbreak of Coronavirus Disease 2019 (COVID-19) [formerly novel coronavirus 2019- nCoV], which was first detected in Wuhan City, China, and has since spread to 28 additional countries. With 14 cases of coronavirus confirmed in the United States (through February 26, 2020), the National Apartment Association (NAA) believes it prudent for its members and affiliates to be prepared for incidents involving COVID-19 should they occur.

NAA understands that affiliates, members and residents may have concerns about how apartment communities should address the virus and, in an effort to offer preliminary guidance and information to assist with preparations, we have compiled the following material from official sources.

It is important to recognize that NAA, its affiliates and individual members are not health care professionals. The CDC and other qualified health officials should continue to be the primary source of current information and guidance. NAA is offering general, precautionary guidance from officials, and adding some common-sense guidelines for our industry in the interest of promoting a proper amount of caution at this time. Because this is a rapidly evolving situation, NAA will monitor developments and will continue efforts to secure guidance specific to the operation of rental housing from health officials. Additionally, NAA will update its website with new information as it becomes available.

 

Current Point of View:

  1. Refer most media and key stakeholder inquiries to Centers for Disease Control (CDC) resources at this time. NAA, its affiliates and individual members are not health care providers. Providing specific guidance (health tips) beyond general precautionary measures, is not advised. The CDC and other qualified officials should provide this information.
  2. Continue to monitor the situation, stay tuned to your local authorities and their ongoing communications and keep track of how it affects “higher risk” sectors such as travel/tourism, convention centers, sporting events and the like to see whether efforts here lead to more definitive guidance from health officials.
  3. If a resident is confirmed to have COVID-19, do not direct facilities management or maintenance staff to the apartment. Immediately contact the local health department and CDC for guidance regarding appropriate measures to take.

 

Media Guidance:

NAA recommends that incoming media requests be directed to CDC and/or local health officials, who are better qualified to answer their questions at this time. You don’t want to be at risk with liability concerns. 

Ensure your office has the proper contact information of the local health authority and/or the best CDC resources on hand for handling queries from local stakeholders. NAA recommends a holding statement be developed. An example: “We appreciate your call. It is wise for everyone to remain current and follow the most recent guidance provided by health officials. That is why we request that you direct your question to [Local Health Official] or the CDC, who are on top of this situation.”

 

Other Key Messages to Consider:

NAA recommends that guidance from CDC and other officials be treated seriously. At present, CDC prevention information includes:

  • Wash hands often with soap and water for a minimum of 20 seconds. If soap and water are unavailable, use an alcohol-based hand sanitizer.
  • Avoid touching your eyes, nose and mouth with unwashed hands.
  • Avoid close contact with people who are sick.
  • Stay home when you are sick.
  • Cover your cough or sneeze with a tissue, then throw the tissue away.
  • Frequently clean and disinfect touched objects and surfaces.
  • NAA encourages all members and affiliates to monitor the situation and stay current with advice from CDC and public health officials.