Coronavirus COVID-19 Spring Break Edition

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Spring break invites faculty travel to conferences abroad, student study trips abroad and student dispersal generally to their home location. What should a higher education institution do to prepare for this period of increased travel:

  1. COMMUNICATE, COMMUNICATE, COMMUNICATE. Members of your institution’s community will want up-to-date information about COVID-19 to stay informed about ways to stay healthy and safe. Misinformation and rumors can fill in for the absence of sound information.
  2. Stay up to date. The information related to COVID-19 as a health risk in many areas is changing rapidly. There are a number of resources available to keep higher education institutions apprised. Notably, see CDC Interim Guidance for Administrators of U.S. Institutions of Higher Education to Plan, Prepare and Respond to Coronavirus Disease 2019 (COVID-19) here

    Many colleges and universities have webpages dedicated to COVID-19 and include FAQs and other information that can help inform policies and response plans.

  3. Prohibit institution-sponsored travel to CDC Level 3 countries. (CDC recommends avoiding all non-essential travel.) Currently, this includes China, Iran, South Korea and Italy. The link to the CDC risk assessment by country can be found here.
  4. If possible, offer student housing for those who would otherwise travel to high risk areas over the break.
  5. Consider whether and how you should monitor personal travel by students and employees.
  6. If a student or employee travels to a high risk area, what do you do when they want to come back?  
  7. For individuals choosing to travel outside the U.S. during spring break, entry into the U.S. might involve additional scrutiny. It may be helpful for travelers to document details of their travel (e.g., trip itinerary, hotel or other travel receipts, or other evidence showing where you were during your time abroad), especially if there are questions relating to whether there was a visit to an area that has a COVID-19 outbreak.  
  8. Who students should call if they are unable to return to the U.S.
  9. Make sure you have thought about as many emerging issues as can be anticipated such as:
    a. possible COVID-19 diagnosis of a member of your institution’s community;
    b. tuition, financial aid, graduation and other issues if classes must be cancelled; and
    c. contract and other legal issues for program or conference cancellations.
  10. COMMUNICATE, COMMUNICATE, COMMUNICATE. This bears repeating. And in that communication, do not forget about responding to fears, rumors and concerns.

Finally, while not spring break focus, we wanted to alert you to the Department of Education’s issuance of a guidance on compliance with Title IV, Higher Education Act policies for students whose activities are impacted by COVID-19 that was released on March 5, 2020. A copy of the guidance can be found here.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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