Hospitality Industry Faces Multifront Crisis Amid COVID-19 Outbreak: Key Considerations for Stakeholders

Written by: James R. Embrey, Esq., and John G. Winkenwerder, Esq.

The coronavirus (COVID-19) outbreak has spread to at least 95 countries and has sickened more than 100,000 people, leading to increased anxiety and confusion across the globe. As governments continue to ramp up safety related restrictions and the populace forgoes travel for isolation in response to the COVID-19 outbreak, hospitality stakeholders face rapidly mounting challenges from both a liability and economic standpoint.

America’s largest hotel groups have released statements in response to COVID-19 for both customers and operators. These statements highlight industry leaders’ continuous response efforts and reference guidance from the Centers for Disease Control and Prevention and World Health Organization. For example, many hotel brands are extending or eliminating cancelation deadlines, adjusting food and beverage services, providing additional hand sanitizer to premises, and preparing response teams for potential outbreaks.

As the effect of this crisis continue to ripple throughout the industry, stakeholders must continue their response efforts and ensure that operators are implementing the following preparations:

    • Increase cleaning frequencies of commonly touched surfaces and objects, including but not limited to front desk areas, elevator banks, coffee stations, etc.
    • Review and potentially enhance your employee policies and procedures to ensure that all staff (1) are doing their part to maintain a safe environment, and (2) will be prepared for an emergency situation related to COVID-19
    • Provide clear recommendations to all guests instructing those who may feel sick to limit face-to-face contact with others and to seek immediate medical help
    • Prepare to educate customers in various languages about proper hand hygiene and cough etiquette
    • Reduce large, public events held on hotel property and consider ways to enhance safety protocols if cancellation is not feasible
    • Review Occupational Safety and Health Act (OSHA) requirements, which impose various duties on the employer to ensure a safe and healthy work environment, to ensure continued compliance during this unstable time
    • Review leave policies and confirm compliance with legal requirements around mandatory quarantines
    • Create and implement protocols regarding screening staff for COVID-10 risk factors while complying with HIPAA privacy requirements
    • Develop plan of action for potential a situation in which an employee might be infected with the virus
    • Consider instituting an employee travel ban
    • Prepare and develop alternative strategies for dealing with potential business interruption of vendors and other key service providers
    • Develop strategy for ongoing marketing communications with customer base to inform them of the steps you are taking to protect guests
    • Consult with counsel on policies of insurance, which may include coverage for business interruption
    • Consult with counsel as the coronavirus impacts the hotel, contractual obligations and business operations including the treatment of force majeure events and cancellation policies


Given the difficulties presented by the COVID-19 outbreak, hospitality stakeholders must be vigilant in their response efforts to both work through the current challenges as well as mitigate potential COVID-19 related risks that may arise in the future. For more information, be sure to follow the ongoing guidance from the Centers for Disease Control and Prevention.

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