Last week, Illinois moved in to “Phase 4” of the state’s five-stage Restore Illinois Plan (the “Plan”). As part of this transition, the Illinois Department of Commerce and Economic Opportunity issued updated, industry-specific Phase 4 Guidelines (the “Guidelines”).

From an employer compliance standpoint, the transition from Phase 3 to 4 is not a radical change. Rather, the transition primarily involves loosened restrictions for already open businesses, and the reopening of additional industries (such as indoor recreation facilities like bowling alleys and skating rinks). Social distancing and other guidelines introduced in Phase 3 remain in effect. For an in-depth review of these guidelines, please see our advisory on Illinois and Chicago’s Phase 3 Reopening Guidance.

One notable change in the updated Guidelines is that to the extent that there was ambiguity in Phase 3 about whether health screenings were required to be “in person,” the updated guidance makes clear that “virtual screenings” are permitted. Employers should also note, from an enforcement perspective, that in its Workplace Health Safety Guidance, the Illinois Department of Public Health is now encouraging employees who have COVID-19 related-concerns about the safety of their work environment to contact the Workplace Rights Bureau of the Illinois Attorney General’s Office.

Chicago, meanwhile, also issued its own Phase IV Guidelines, which are part of the city’s Be Safe reopening framework. Similar to the Illinois Guidelines, Chicago’s guidelines loosen restrictions for various industries, reopen additional industries (such as, gyms and indoor dining), and recommend that employers continue to ensure employees stay home when sick and follow other applicable health safeguarding measures (e.g., wearing face coverings and maintaining social distance).

Illinois employers should continue to carefully review the guidance relating to their specific industry and determine what steps they need to take in Phase 4 to be compliant with Illinois and, if applicable, Chicago guidelines.  As the circumstances surrounding the current pandemic evolve, so, too, will the applicable guidance. For additional recommendations, see our Act Now Advisory on Phase 3.

For more information about this post, please contact:

Peter A. Steinmeyer

Kellie Y. Chen


Back to Workforce Bulletin Blog

Search This Blog

Blog Editors


Related Services



Jump to Page


Sign up to receive an email notification when new Workforce Bulletin posts are published:

Privacy Preference Center

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.