As with any individual on leave due to an ADA disability, to minimize complaints and ensure compliance, we recommend that the employer engage in the interactive process to ensure that each individual has the accommodation(s) they need (if any) to safely return to work and perform the essential functions of their job. In addressing your concerns about the level of risk for returning employees, OSHA has provided guidelines that may assist you in making reasonable determinations regarding the specific work environment and risk to those with underlying disabilities. These risks can be mitigated by the safety measures outlined by the Centers for Disease Control and Prevention. Employers can also request updated medical certifications, fitness-for-duty documents, and take other measures outlined in Equal Employment Opportunity Commission guidance to ensure it is safe for these individuals to return to the workplace.