On June 25, 2020, we issued a frequently asked questions document, “40 Answers to Your Phase 4 Questions: Practical FAQs on ISBE’s Phase 4 School Reopening Guidance,” clarifying ISBE and IDPH joint guidance for Phase 4 school reopening. Later that day, ISBE issued additional materials, including an FAQ of its own, with a number of changes and clarifications to its guidance. We have updated our FAQs to address the major changes. You can download the revised Franczek FAQ here.
One major change we address relates to “self-certification,” Question 26 of our FAQ. The ISBE guidance contains little direction as to how self-certification can or should be effectuated. The ISBE guidance also does not require that schools verify self-certification. Nor does it prohibit reliance on annual confirmation from parents, students, and staff that they will check for temperature and symptoms every day. If that is permitted, schools could rely on a student or employee’s presence as self-certification each day.
Now, however, ISBE has stated in its FAQ that “[a] self-certification may not be completed at the beginning of the year for the entire year.” Notably, although ISBE recommends use of an app or electronic form, schools will necessarily have to verify whether individuals present in the building have completed the self-certification. Neither ISBE nor IDPH has issued any guidance on how schools will achieve either screening or self-certification as a practical matter or monitor compliance.
Our Franczek team has expressed concerns to ISBE that significant manpower and resources will be required for schools to confirm with thousands of students and employees that they have self-certified each day. Even an app needs to be checked against attendance and compliance could take hours. Unlike CDC guidance to schools, which requires daily health checks (such as temperature screening and/or or symptom checking) only “if feasible,” the ISBE FAQ includes no feasibility consideration for screening of students and employees.
Our Franczek team is working to obtain clarification from ISBE and the IDPH as to what options are available with respect to verification of self-certification. We will update you when we reach resolution on this issue.
