Coronavirus Disease 2019 (“COVID-19”) is a respiratory illness caused by a novel (new) virus, and we are learning more about it every day. There is currently no vaccine to protect against COVID-19. At this point, the best way to prevent infection is to avoid being exposed to the virus that causes it. Stopping transmission (spread) of the virus through everyday practices is the best way to keep people healthy.

The Centers for Disease and Control and Prevention (“CDC”) recently published “Interim Guidance for Administrators of US Childcare Programs and K-12 Schools to Plan, Prepare, and Respond to Coronavirus Disease 2019 (COVID-19)” on its website. 

School Administrators should review this guidance in its entirety (and continue to check for updates with the CDC and their local health department), but the highlights of this guidance are set forth below.

For School Districts that do not have COVID-19 identified in their communities, the CDC recommends:

• Review, update, and implement emergency operations plans (EOPs). This should be done in collaboration with local health departments and other relevant partners. Focus on the components, or annexes, of the plans that address infectious disease outbreaks.

• Monitor and plan for absenteeism.
  • Alert local health officials about large increases in student and staff absenteeism, particularly if absences appear due to respiratory illnesses (like the common cold or the “flu,” which have symptoms similar to symptoms of COVID-19).
  • Review attendance and sick leave policies. Encourage students and staff to stay home when sick. Use flexibility, when possible, to allow staff to stay home to care for sick family members.
  • Discourage the use of perfect attendance awards and incentives.

• Establish procedures for students and staff who are sick at school.
  • Establish procedures to ensure students and staff who become sick at school or arrive at school sick are sent home as soon as possible.
  • Keep sick students and staff separate from well students and staff until they can leave.
  • Remember that schools are not expected to screen students or staff to identify cases of COVID-19. The majority of respiratory illnesses are not COVID-19. If a community (or more specifically, a school) has cases of COVID-19, local health officials will help identify those individuals and will follow up on next steps.
  • Share resources with the school community to help families understand when to keep children home.  The CDC provides a link to guidance issued by American Academy of Pediatrics.

• Perform routine environmental cleaning.

• With respect to employees, review CDC’s guidance for businesses and employers.  Some highlights include:
  • Actively encourage sick employees to stay home
  • Emphasize staying home when sick, respiratory etiquette and hand hygiene
  • Employees who are well but who have a sick family member at home with COVID-19 should notify their supervisor and refer to CDC guidance for how to conduct a risk assessment of their potential exposure.
  • If an employee is confirmed to have COVID-19, employers should inform fellow employees of their possible exposure to COVID-19 in the workplace but maintain confidentiality as required by the Americans with Disabilities Act (ADA). 
  • Employees exposed to a co-worker with confirmed COVID-19 should refer to CDC guidance for how to conduct a risk assessment of their potential exposure.

• Coordinate with local health officials to determine what type of information might be best to share with the school community.

• For questions about students who traveled or planned to travel to areas with community spread of COVID-19, the CDC has published a FAQ page on its website.

For School Districts with identified cases of COVID-19 in their communities, schools may need to take additional steps in response to prevent spread in the District.  The CDC recommends:

• Talk with local health officials.  This is the first and most important step.  The CDC encourages Districts to work closely with local health officials to determine a course of action for their childcare programs or schools.

• Determine if, when, and for how long childcare programs or schools may need to be dismissed.  School administrators should work in close collaboration and coordination with local health officials to make dismissal and large event cancellation decisions. Districts are not expected to make decisions about dismissal or canceling events on their own.

• If an ill student or staff member attended school prior to being confirmed as a COVID-19 case:
  • Local health officials may recommend temporary school dismissals if a student or staff member attended school prior to being confirmed as a COVID-19 case. Local health officials’ recommendations for the scope (e.g., a single school, a full district) and duration of school dismissals will be made on a case-by-case basis based on the most up-to-date information about COVID-19 and the specific cases in the impacted community.
  • Schools should work with the local health department and other relevant leadership to communicate the possible COVID-19 exposure. This communication to the school community should align with the communication plan in the school’s emergency operations plan. In such a circumstance, it is critical to maintain confidentiality of the student or staff member as required by the Americans with Disabilities Act and the Family Education Rights and Privacy Act.
  • If a student or staff member has been identified with COVID-19, school and program administrators should seek guidance from local health officials to determine when students and staff should return to schools and what additional steps are needed for the school community. In addition, students and staff who are well but are taking care of or share a home with someone with a case of COVID-19 should follow instructions from local health officials to determine when to return to school.

• If schools are dismissed, Districts can consider the following steps:
  • Temporarily cancel extracurricular group activities and large events.
  • Discourage students and staff from gathering or socializing anywhere.
  • Ensure continuity of education.
    • Implement e-learning and online lesson plans, including digital and distance learning options as feasible and appropriate.
    • Determine, in consultation with school district officials or other relevant state or local partners if a waiver is needed for state requirements of a minimum number of in-person instructional hours or school days (seat time) as a condition for funding;
    • Determine how to encourage appropriate adult supervision while children are using distance learning approaches; and
    • Determine how to deal with the potential lack of students’ access to computers and the Internet at home.
  • Ensure continuity of meal programs.
  • Consider alternatives for providing essential medical and social services for students.

Schools, working together with local health departments, have an important role in slowing the spread of diseases to help ensure students have safe and healthy learning environments.  While there remain many unanswered question, the CDC’s guidance at least provides a good starting point for School District administrators to consider if and when difficult decisions need to be made.