“Long Covid” and Head Start Agencies’ Legal Obligations under the Americans with Disabilities Act (ADA) and Other Disability Rights Law

September 8, 2022

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Some people who have been infected with the virus that causes COVID-19 can experience long-term effects from their infection, known as post-COVID conditions (PCC) or, known more commonly as, “Long COVID.” According to Centers for Disease Control (CDC) guidance issued in July of 2022, the proportion of people who had COVID-19 who go on to experience post-COVID conditions are estimated as:

The CDC further noted that of more than 40% of adults in the United States who reported having COVID-19 in the past, nearly one in five of those (19%) are currently still having symptoms of “long COVID.”

Meanwhile, in July of 2021, the Office of Civil Rights of the U.S. Department of Department of Health and Human Services (HHS) issued a guidance document entitled “ ‘Long COVID’ as a Disability Under the ADA, Section 504, and Section 1557.” This guidance confirmed that long COVID can qualify as a defined “disability” under the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973 (Section 504), and Section 1557 of the Patient Protection and Affordable Care Act (Section 1557). Each of these federal laws protects people with disabilities from discrimination. As such, health center employees with “Long COVID” may be entitled to protections under these laws.

Head Start agencies must balance workforce staffing challenges with their legal obligations under these disability rights laws to not discriminate against employees who have “Long COVID.” Notably, on September 27, 2021, the Administration for Children and Families (ACF) issued Information Memorandum (IM) No. ACF-IM-HS-21-05 entitled “Supporting the Wellness of All Staff in the Head Start Workforce” describing the importance of and recommendations for building a culture of wellness across all Head Start programs. In this IM ACF stated, “A critical part of promoting staff wellness is ensuring staff are aware of their rights as employees. Programs must establish written personnel policies and procedures...“ This IM further encourages Head Start programs to regularly inform staff of these policies and procedures, including their rights under applicable federal and state laws while specifically referencing the ADA in particular.

This webinar will cover a Head Start grantee’s legal obligations when faced with an employee who has Long COVID. What accommodations, if any, may be or must be offered and under what circumstances? What documentation requirements are triggered? Do Head Start agencies need to revise their personnel policies and procedures? Attendees will receive practical suggestions for addressing this still-evolving area of legal obligations and potential liability.

The On-Demand version of this webinar will be available for purchase one week after the conclusion of the live webinar. 

Target Audience

  • Head Start management and governing bodies
  • Human Resources professionals
  • Compliance professionals
  • Counsel and paralegals

Learning Objectives

After this webinar, you will be able to:

  • Identify when “Long COVID” triggers legal obligations under the ADA, Rehabilitation Act, and Section 1557 of the Patient Protection and Affordable Care Act
  • Identify the key features of the Americans with Disabilities Act, the Rehabilitation Act, and  Section 1557 of the Affordable Care Act that come into play when an employee presents with “Long COVID”
  • Determine whether your agency’s policy and procedures require revision and what the nature of those revisions should be
Course summary
Available credit: 
  • 1.00 Certificate of Attendance
Course opens: 
Course expires: 
Event starts: 
09/08/2022 - 1:00pm EDT
Event ends: 
09/08/2022 - 2:00pm EDT

Kathy Ghiladi 

Kathy Ghiladi, a Partner in FTLF’s federal grants practice, serves as counsel to Federal and State contractors and grant recipients across the country, including community action agencies receiving CSBG Act and Head Start funding. She has assisted Head Start agencies in reviewing and responding to monitoring reviews and has represented Head Start agencies in appeals before the Departmental Appeals Board. She has provided Head Start trainings across the country including trainings provided to U.S. Department of Health and Human Services, Administration for Children and Families personnel. In addition, she represents federal grant recipients in Government investigations and audits, and has helped Head Start agencies navigate governance and related obligations during difficult times involving CEO transitions, Policy Council disputes/mediation, investigations, and audits. [Full Bio]

Participants can earn up to 1.20 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.


If you purchase CPE credit for this webinar you must satisfy the following conditions in order to receive your certificate:

  1. Answer at least 3 of the 5 polling questions during the webinar
  2. Complete the evaluation survey after the conclusion of the webinar or in the follow-up email

Upon completion of these requirements, FTLF will email you your CPE Certificate within seven (7) business days.


  • Prerequisites: None 
  • Target Audience: Head Start management and governing bodies, Human Resources professionals, Compliance professionals, Counsel and paralegals
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based
  • Attendance Requirements: In order to be awarded the full credits, you must respond to three (3) out of five (5) polling questions.

Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).

Available Credit

  • 1.00 Certificate of Attendance


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Access to the recorded version of this webinar is included in your purchase.


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